The Occupational Safety and Health Administration (OSHA)’s Process Safety Management (PSM) regulation applies to those companies whose processes involve any of the more than 130 specific toxic and reactive chemicals at or above listed quantities, as well as flammable liquids and gases in quantities of 10,000 pounds or more. Organizations must conduct triennial audits of their PSM-covered processes against the requirements in 29 CFR 1910.119 (PSM Rule). Below is a brief summary of the most common noncompliance findings identified during PSM audits.
Addressing Items from Process Hazard Analyses (PHAs)
Per 29 CFR 1910.119(e), PHAs must be conducted for processes covered by the PSM regulation. Each employer must develop a system to ensure that the PHA team’s findings and recommendations are addressed in a timely manner; this includes documenting actions that must be taken and completing the actions as soon as possible. Employers must also develop a written schedule specifying when the actions will be completed. It is a common PSM audit finding to observe actions and recommendations from a PHA meeting that not have been addressed at all, or within the required timeframe.
Standard Operating Procedures (SOPs) Development and Communication
Per 29 CFR 1910.119(f), each employer must develop and implement written SOPs for activities related to covered PSM processes. It is common for an auditor to find that SOPs have not been developed for new or replacement equipment within a covered process, or for employees to be unaware of the location or even existence of such SOPs.
Updates to SOPs and Process Safety Information (PSI)
Per 29 CFR 1910.119(l), PSI must be updated whenever there are changes to process chemicals, technology, equipment, and procedures, or changes to the facility that affects a covered process. Oftentimes, organizations neglect to update PSI when equipment is replaced with new or different models or when inventories change.
Per 29 CFR 1910.119(l)(4) and (5), SOPs must be updated if changes to covered processes are identified during the management of change (MOC) evaluation. Oftentimes, organizations overlook updating SOPs with new information about covered processes and their equipment after the MOC evaluation is complete.
Contractor Performance Reviews
Per 29 CFR 1910.119(h), employers must obtain safety performance and program information for any contractors who perform work on a covered or adjacent process. This must occur prior to the contractor being allowed to come on-site to perform work. Employers must periodically evaluate the performance of these contractors as well. Auditors frequently find that there is no documented evidence to demonstrate that contractors are evaluated prior to them coming on site nor to demonstrate that a periodic evaluation is occurring.
Incomplete Emergency Action Plan
Per 29 CFR 1910.119(n), employers must develop an Emergency Action Plan in accordance with 29 CFR 1910.38. There are numerous requirements of the plan.
- Procedures for reporting a fire or other emergency
- Procedures for emergency evacuation, including type of evacuation and exit route assignments
- Procedures for employees who remain to operate critical plant operations before they evacuate
- Procedures to account for all employees after evacuation
- Procedures to be followed by employees performing rescue or medical duties
- Name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan
It is common for an auditor to find that one or more elements of the plan are missing or outdated.
As with any formal management system, the PSM rule is intended to represent a dynamic process requiring continual efforts at maintaining and updating the various program elements so that optimal safety results can be achieved. It is a notable accomplishment for an organization to establish a PSM program initially, but perhaps an even more significant challenge to keep the system operating effectively over the long term. The common PSM audit findings described above underscore that challenge.
Organizations with “best-in-class” PSM programs tend to exhibit strong leadership and commitment from top management along with solid, consistent operational discipline on the part of all staff. Such organizations also fully understand that PSM program elements are interdependent. Information and analyses from one element tend to be connected to numerous other elements. Having an audit program that emphasizes the timely integration of new information and the prompt closure of follow-up actions required under certain program elements will help an organization achieve its desired process safety results.
For further information, please contact Jamie White, Managing Consultant, at (919) 462-9693 or firstname.lastname@example.org.