Did OSHA Get The 14 Elements of PSM Correct? Part 5

In this series of articles, it was proposed that instead of a listing of activities or programs, OSHA’s 14 elements of PSM should be processes or performance criteria to achieve.

While OSHA proclaimed that the Process Safety Management of Highly Hazardous Chemicals (PSM) Standard was a performance-based standard, the 14 elements can really be characterized as activities or programs to implement for a process safety management system.?OSHA’s elements of PSM were pulled together by “benchmarking” the program elements from about 20 companies as well as those in industry standards (AIChE CCPS, API RP754). But the “benchmarking” effort copied a series of programs/activities without capturing the purpose of each of those programs or what objective that the program is to accomplish.

Meanwhile, since the promulgation of the PSM standard in 1992, the refining, oil production, and chemical processing industries continued to experience significant / catastrophic incidents.?Learnings from these incidents, as well as numerous audits, lead to the answer of what really needs to be achieved to have process safety.

These series of articles intend to make a case for the 14 elements to be processes or performance criteria to achieve.

In Parts 1 through 4 of this series, the following elements were examined:

• Training: The real objective is Competency Assurance and training is but one of many tools to accomplish that objective.
• Incident Investigation: The real objective is Learning From Incidents, and incident investigations are but one of many tools to accomplish that objective.
• Process Hazard Analysis: The real objective is to identify Critical Barriers wherein their integrity and reliability is managed such that the Risk is low as reasonably practicable.
• Compliance Audit:?It’s not just Compliance but achieving operational excellence.?The Audit is one of many tools to get Assurance that you are managing the Risks and discover when the means to managing a risk is defective or deficient – before it results in a significant/catastrophic incident.
• Employee Participation: The real objective is to have the organizations’ Leaders Engaged in a collaborative effort with the Employees having Ownership.

In Part 5 of this series, let’s examine the Pre-Startup Safety Review (PSSR) element (29CFR1910.119 (i)): The employer shall perform a pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information.

Prescriptive requirements are listed and, technically, all that’s needed to comply is to address the following:

[] Written program that defines a process that involves:

- Construction and equipment are in accordance with design specifications.

- Safety, operating, maintenance, and emergency procedures are in place

and are adequate.

- PHA has been performed and recommendations have been resolved for

new facilities.

[] Records/checklists of completed reviews.

[] Training of each employee involved in operating a process.

Note that the PSSR is required for new or modified facilities when the modification requires a change in the process safety information.?The facility/operation presenting the documentation/records listed above within the seemingly narrow criteria, can be considered as having “checked the box” in meeting this element of the PSM Standard.

A check-the-box approach can create tunnel vision. A facility/operation may successfully meet the minimum requirements to meet Compliance, but it may narrow the operations’ focus so much, important safety issues are missed, and gaps and vulnerabilities left exposed putting the operation at greater risk.

The real objective is Operational Readiness for all cases:?

• Consider existing processes that have been shut down for new or modified equipment/devices or repairs not specific to a MOC or change in PSI.?
• Review existing processes that have been administratively shut down for other reasons, ranging from minor, short-term/temporary shutdowns for maintenance, to extended shutdowns for maintenance turnarounds or due to lack of demand for the product or availability of raw materials??
• Engage PSSR’s not only for continuous operations when starting up of a unit following shutdown but also consider batch operations – an operational readiness review between the start of each batch operation.

Since the initiation of Operational Readiness is predicated upon new, modified or repaired equipment/devices that are managed by the other elements of the process safety management program, there must be clear linkage or interfaces to insure safe operation.

• How are PSSR’s linked to the process for managing change (MOC)??
• Where are the requirements to confirm the integrity of new/modified/repaired process equipment, thereby linking this element to the Mechanical Integrity element.

In essence, the real objective is determining if the unit, equipment, device, process, or facility is ready for safe and reliable operation.?The PSSR is one tool used to verify Operational Readiness that the Risks are being managed and discover when the means to managing a risk is defective or deficient – before it results in a significant/catastrophic incident.