OSHA’s PSM and EPA’s RMP standards are a great start for a SMS – but need more than cut & paste

One of the things that EPA learned from OSHA’s roll-out of their PSM standard was that not everyone recognized the standard as a 14-element management system.  So when it came time for EPA to roll out its RMP, they made a “management system” part of its requirements.  However, EPA quickly disappointed when they said all that was needed was an organizational chart showing who was responsible for each element.  And sadly, many facilities have yet even to do this.  But we see more often than not a “written PSM program,” and 9 out of 10 times, this “program” is simply a cut and paste of the PSM standard, which causes many issues for facilities that fall under both PSM and RMP.  In this article, I want to explain how we can use the framework of these standards to create a functioning SMS which goes a long way in defining key roles for management personnel.

For an SMS to be a well-functioning management system, each element needs a “champion” or what most of us call a Subject Matter Expert (SME).  This person is ultimately responsible for the execution of the element and is the resident expert on HOW, WHEN, WHO, and all the details that come with it.  I like to use the SOP elements of both PSM/RMP to demonstrate how these details look.

As I said before, most SOP written programs will be a direct cut and paste from these standards; however, these programs do not function as an element of a SMS because there are no details as to WHO and HOW SOPs will be developed, implemented, and managed.  The PSM/RMP standards do a nice job of framing up what content the SOPs must contain and the phases of the process we need SOPs for, but when it comes to 1910.119(f)(3), the written program does not state WHO or HOW…

If the written program simply stated WHO and HOW these two tasks are carried out, we would be much closer to a functioning element of a PSMS.  Simply stating that the “Unit Manager is responsible for annually certifying SOPs” is a start but it falls short of doing all we need.  We need to define HOW the Unit Manager is expected to certify the SOPs annually.  Does your facility use a “signature cover sheet” in the front of the SOP manual, and the Unit Manager simply signs this sheet annually or does your facility take a more detailed approach and the Unit Manager will sign-off on each individual SOP as if it is in a “document control” system?

What is the process used to “assure [SOPs] reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities”?  Who is involved in this process?  Who is responsible for the execution of this process and ensures it is done on time and meets all QA/QC needs?  Typically the Unit Super is assigned the role of managing this process.  He/She will divide up the SOPs to ensure that each week an SOP is reviewed by operators and submitted to the Unit Manager for Certification.  In my time, we even used this process as a “leading indicator” in our PSM/RMP management system.  To make this simple, assume we have a unit that has 100 SOPs.  Some of these SOPs may be 50 pages long, and some may be 2-3 pages long.  The unit super would pair two SOPs together over 50 weeks (we took Thanksgiving and Christmas Weeks off – used as make-ups if needed).  The trick is to BALANCE the workload as best we can.  We would pair short/easy SOPs with bigger, more complex SOPs, but each week, operators and supers knew they would be walking down SOPs.  And at the end of the year, all SOPs would have been reviewed and certified.  And the process begins again the week of January 1.  Of course, any SOP that had recently been reviewed and certified as part of a MOC would be accepted that year.

These details are what is needed to make 1910.119(f) and 68.69 a functioning element in a Process Safety Management System.