If the Process Safety Management (PSM) regulation was a person in the United States, it could enlist in the armed forces, vote in elections, and serve jury duty. The PSM regulation was promulgated in 1992.
And yet…
One regularly will hear managers in companies and plants plaintively ask, “Is this a new regulation ? I haven’t heard of all of these requirements before this…” usually prefacing a lengthy (and sometimes vituperative) complaint about the inequities and inconveniences of compliance efforts. Another side of this will be a full-out assault on compliance because it’s “not value-added effort” or “it’s not a contributor” to the company.
Simply put, that ship has sailed out of the harbor, that train has left the station, the bus is long gone down the route. Regardless of the politics of regulation in the United States, PSM is established law. There is no more question about compliance with PSM than Lockout-Tagout or fall protection, each is a requirement for continued legal operation.
And while the Risk Management Plan regulation from EPA is still only a young teenager, having been brought into force in 1996, there’s no question that it, too, is a requirement. OSHA may be leading the charge with the National Emphasis Programs, Petroleum Refining NEP and Chemical NEP both, but there aren’t too many ESH managers who relish a fight with EPA either.
This blog isn’t and won’t be complaints about regulations.
This blog is going to be oriented around management, specifically managing the PSM and RMP programs in companies and plants. A lot of discussion about PSM and RMP seems to miss the point that both regulations use the term “management” very deliberately, and with a few exceptions, set few technical standards. There’s no “maximum acceptable exposure to poly-di-chloro-death” in the PSM and RMP standards, but there’s a clear expectation that companies and sites will set out a performance basis for compliance with the standards, and then meet or exceed that basis consistently.
Meeting a performance basis consistently requires clear and well-defined management systems, documented in a straightforward manner that can be understood by everyone from the plant manager to the person who loads the photocopy machine with paper each day. There might be some terms to be defined, some systems to be explained, but the emphasis on understandable management systems is undeniable.
Some upcoming topics will include a discussion on what’s meant by “timely action” and what’s a “safe location” for PSV atmospheric vents with some emphasis on basic approaches to manage these issues. There will be some discussion on citations made by OSHA, not to place undue emphasis on “paper compliance”, but to show where compliance efforts have been deemed insufficient by the regulator.
After all, the tagline for this blog is “…Putting the management into PSM”