Did OSHA Get The 14 Elements of PSM Correct? Part 6

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 and activities without capturing the purpose of each of those programs or the objective that the program is to accomplish.

In making the case for the 14 elements to be processes or performance criteria, the following elements were examined Parts 1 through 5 of this series as to how to reimagine them from just programs and activities to a process with performance criteria to achieve process safety excellence.

In the discussion of a PSM Element within an article, the prescriptive requirements from the OSHA standard were listed for that Element.?Then it was shown how a list of limited activities with associated documentation/records a facility/operation could present such that they could then be considered as having “checked the box” in meeting that element of the PSM Standard.

Meanwhile, since the promulgation of the PSM standard in 1992, the refining, oil production, and chemical processing industries continue to experience significant / catastrophic incidents.?Learnings from these incidents, as well as numerous audits, brings to the forefront that a facility/operation can unintentionally set conditions for failure or, at the very least, not manage the risks to avert a significant / catastrophic event.?This may occur from either using a programmatic approach (focusing on executing programs) or compliance approach (“checking the box” for compliance).

Benchmark studies by ACC Process Safety Committee, the TEEX Mary Kay O’Connor Process Safety Center, AICHe Center for Chemical Process Safety, and learnings from the Chemical Safety Board and OSHA’s NEP, inform that those Companies/Operations with exceptional process safety are not just “checking the box” with programs but employ a systematic approach to evaluating the process design, process technology, operational and maintenance activities and procedures, emergency plans, training programs, and other elements which impact the process or operation. This is exceptionally noted in two CSB reports:

• BP Texas City (March 2005) incident: “A check the box mentality was prevalent at Texas City, where personnel completed paperwork and checked off on safety policy and procedural requirements even when those requirements had not been met.” CSB Report, March 2007
• BP/Macondo Platform (April 2010) Fire/Explosion: “There was no recognition that this was an opportunity to do some auditing, to check on competence of the people involved and to verify that they were complying with procedures that were critical to the safety of the well and the rig. Not only was an opportunity lost to do some informal auditing, but so too was an opportunity lost to avoid disaster.” CSB Report June 5, 2014

?For many organizations, compliance is seen as a necessary evil, similar to an insurance policy – an easily calculated cost with no intrinsic value. Organizations may become biased toward taking a check-the-box approach, neglecting the more comprehensive process approach.

Adopting a programmatic approach (focusing on executing programs) or a compliance approach (“checking the box” for compliance) has these fallacies:

May Overlook Vulnerabilities

• A check-the-box approach can create tunnel vision. A facility/operation may successfully meet the minimum standards to pass an impending audit, but it may narrow the operations focus so much, that they miss other important safety issues that place them at greater risk. This approach might accomplish a narrowly defined, short-term goal, but it may also leave gaps and vulnerabilities unexposed.

Compliance Doesn’t Guarantee Risks Are Being Managed Effectively

• Compliance is only a small part of an overall risk management program. With a check-the-box approach, a facility/operation may gain insight into a portion of their process safety posture at a single point in time, but it doesn’t provide a complete picture of the overall status outside the scope of the compliance audit.

Achieving Compliance Does Not Eliminate Risks

• Compliance does not necessarily equate to effective process safety, and the process of ensuring compliance may not eliminate key risks. While compliance may help identify and assess some short-term acceptable risk, the organization need to have a clear picture of the organizational risk appetite and how that appetite might change over time. And when it comes to risk, it’s not just about one department or team. Risk awareness is for the entire organization—now and in the future.

No Change in Program Maturity from Audit to Audit

• A set-it-and-forget-it approach is not advised.?It might seem reasonable that if there are no new issues from one audit to the next, the facility/operation is on the right path. But, in reality, it’s more than that. Not only there is a need to show a continuing effort to meet the minimum standards, but that the organization is maturing processes over time, especially if the organization is changing or scaling during that time.

When taking a pass-or-fail check-the-box approach to compliance, the scope may easily become too limited, obscuring visibility to the broader threat scenarios that may pose significant risks.?And, if the organization is just seeing compliance as pass or fail, then what can really be learned from the metrics? How can an organization benchmark their program? How does an organization know where they’re successful and where improvements are required?

It’s not just Compliance but achieving operational excellence.?And process safety helps achieve operational excellence by managing all risks to as low as reasonably practicable.??