OSHA Process Safety Management Programs
We have developed numerous site-wide and process-specific Process Safety Management (PSM) programs to help our clients achieve full compliance with the OSHA PSM Standard 29 CFR 1910.119. Since our clients generally begin with certain elements of a PSM program already in place, we are careful not to intrude on existing successful practices, and seek to help achieve full compliance using an economy of resources.
Compliance, however, is not the sole objective.
We seek to help establish programs that demonstrate return,
not only through enhanced safety culture and performance,
but through the improvement of process reliability and operability.
Since a primary objective of PSM is the minimization of unwanted deviations from normal process operations, improved process reliability,
measured, for example, as decreased process downtime, should be a collateral benefit of the program.
The objective of achieving this benefit can be explicitly incorporated into the program through,
for example, the means by which process hazard analyses are conducted, and the way in which risk/reliability criteria form the basis for the mechanical integrity program.
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In developing PSM programs we:
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take advantage of what has and has not worked for peers
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advise on precedents set by OSHA in the interpretation and enforcement of the PSM Standard
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establish a dynamic, flexible program addressing activities, recordkeeping and accountabilities, that can be systematically and conveniently revised as improvements in practice are identified
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fully integrate the program with other safety and reliability programs in place at the site, such as an EPA Risk Management Program (RMP) or other related OSHA, EPA, corporate, or industry standard-based programs
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support specific technical needs under the program related to areas such as emergency response planning, mechanical integrity program development, written operating procedures, process hazard analyses, compliance audits, training, evaluation of safety instrumented systems, and facility siting assessment.
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