PSM Elements: Learnings since 1992 (Part 2 of 3)

Please note that I am writing a series of articles on PSM weakness.This article is part 2 of 3.

Birth of OSHA

On December 29, 1970, President Nixon signed the Occupational Safety and Health Act of 1970 into law, establishing OSHA. 

In each industry, PSM applies to those companies that deal with any of more than 130 specific toxic and reactive chemicals in listed quantities; it also includes flammable liquids and gases in quantities of 10,000 pounds (4,535.9 Kg) or more.

To understand PSM and its requirements, employers and employees need to understand how OSHA uses the term “process” in PSM. Process means any activity involving a highly hazardous chemical including using, storing, manufacturing, handling, or moving such chemicals at the site, or any combination of these activities.

Birth of PSM Elements:

On July 17, 1990, OSHA published the Federal Register (55 FR 29150) a proposed standard,—”Process Safety Management of Highly Hazardous Chemicals” containing requirements for the management of hazards associated with processes using highly hazardous chemicals to help assure safe and healthful workplaces.

• PART 1910 — OCCUPATIONAL SAFETY AND HEALTH STANDARDS
• Sub part H "Hazardous Materials"
• Standard number 1910.119: Process safety management of highly hazardous chemicals.

This standard contains the famous 14 elements of PSM. These elements are now being followed globally for PSM establishment. OSHA has also published Information booklet 3132 (Reprinted 2000) on 1910 standard. Some organizations practice more than 14 elements however I am not discussing them here because other elements are essentially sub elements of originally propose 14 elements.

NEP Refinery Citations

According to OSHA, since the promulgation of the Process Safety Management (PSM) standard in 1992, the petroleum refining industry has had more fatal or catastrophic incidents related to the release of highly hazardous chemicals (HHC) than any other sector. In June 2007, OSHA initiated the Petroleum Refinery Process Safety Management National Emphasis Program (NEP) to verify the compliance of refinery employers with PSM. It is worth noting that even after 25 years of publishing of PSM elements, OSHA also realized the need of reviewing PSM compliance process.

OSHA released a report in 2017 titled “Process Safety Management for Petroleum Refineries”, which includes lessons learned and highlights areas of PSM where OSHA issued the most citations during the Petroleum Refinery PSM NEP.

It is worth noting that the most cited element during the NEP Audits was Mechanical Integrity in Refinery and Chemical processing facilities. Also, 4 out of 14 PEM elements were dominating the process safety.

Risk Based PSM: New Perspective

Let us discuss something about Risk based Process Safety Management or RBPSM. American institute of Chemical Engineers (AIChE) created the Center for Chemical Process Safety (CCPS) in 1985, after the chemical disasters in Mexico City, Mexico, and Bhopal, India. I would like to attract readers to the following quotes from their findings;

Over the past 20 years, government mandates for formal process safety management systems in Europe, the U.S., and elsewhere have prompted widespread implementation of a management systems approach to process safety management. However, after an initial surge of activity, process safety management activities appear to have stagnated within many organizations. Incident investigations continue to identify inadequate management system performance as a key contributor to the incident. And audits reveal a history of repeat findings indicating chronic problems whose symptoms are fixed again and again without effectively addressing the technical and cultural root causes.

Whether it was NEP from OSHA or RBPSM from CCPS, few observations were quite clear:

1)    Catastrophic events were happening even after the compliance of PSM elements being mandated by Governments.

2)    OSHA found major non compliances in PSM elements (Remember my observation in first para)

3)    CCPS also realized that PSM activities started stagnating and lost their energy

4)    Investigations reveal inadequate management systems performance as a key contributor

5)    The technical and cultural root causes are not being addressed.

 Safety Culture

The findings from CCPS clearly indicates that the “Elixir” or “Magical Potion” of Safety or PSM culture does not have the capabilities to give intended impact. The question arises why “Culture” can't be treated as a barrier. My experience indicates following major reasons:

1) Actually, we could never make culture a SMART goal. It could be measured only over a length of time but Organizations are facing dynamic business environment. New people are joining and old ones are retiring off. Culture has become a legacy, difficult to maintain.

2) Refer the old adage “When cat is away, mice plays”. So is the case with employees. They forget culture when there is no one to watch.

3) Management also had conflicting targets of time, budget and profits. So developing a safety culture has become quite challenging.

Stagnation of PSM culture

Can anybody guess what is the root cause of this vital finding by CCPS. Actually, there is nothing called “Process Safety” discipline. The actual heroes behind this word are discipline engineers. PSM per say is governed by core engineering and it cannot standalone. It needs the support of discipline engineers. PSM programs and audits takes toll on time of these essential disciplines. They themselves do not gain anything but they have to slog for Safety Engineers. This was the root cause of stagnation or loss of interest of discipline engineers. The audits are not conducted by domain experts and they lack the experience in handling of “conflicting goals” management such as a maintenance engineer faces conflict of “time” and “resources”. 

In the last and concluding part of this series, I will conclude with learnings in NEP citations and how we need to prioritize PSM elements in modern business environment.