Any time hazardous chemicals are not properly controlled, there is the potential for accidental release. Yet despite widespread awareness of these risks and attempts at risk management, releases continue to occur across various industries.
While the OSHA Process Safety Management of Highly Hazardous Chemicals standard outlines “requirements for the safe management of hazards associated with processes using, storing, manufacturing, handling, or moving highly hazardous chemicals onsite,” we’ve seen many organizations struggle to manage their PSM programs and remain compliant without getting complacent.
Taking a Closer Look
If you haven’t done so lately, now might be a good time to re-evaluate how the standard applies to you and how well your organization is currently doing. Here are a few questions to get you started:
- Do you use listed chemicals under OSHA’s PSM standard or EPA’s RMP rule?
- Do you have anhydrous ammonia freezer systems?
- Do you handle powders with the potential for explosions or deflagrations? If so, have your facilities carried out dust hazard analyses for powder handling operations?
- Have any of your facilities experienced fires, explosions, or loss-of-containment events, and/or regulatory encounters related to PSM or RMP standards? If so, are you confident the immediate situation has been resolved and that measures are in place to prevent a recurrence?
- Are you adding a new process that triggers the need to comply with PSM or RMP where previously you didn’t? Are you properly prepared to fully manage the consequences of this change?
- Do you understand your complete risk profile, including the impact of loss of containment to human life and the environment? Do you fully understand how these risks could impact your organization’s brand and reputation?
- Are you satisfied that you are continuously improving your risk management processes?
Once you understand your status quo (including any gaps you have uncovered), there are a few additional scenarios you need to watch out for.
Hidden Hazards
A common occurrence at many companies is for PSM auditors and program overseers to be an extension of the affected group. This approach, however, can lead to compliance gaps or change blindness. This can also trip up companies relying on the same external consultants year after year. With consistency can come complacency, and when the risk is this high you need to make sure to shake up the system occasionally and bring in fresh eyes. You want to ensure you are seeking out more than one perspective and getting the full picture.
Mergers and acquisitions can be another trigger to pay closer attention, as PSM failures can represent a high risk for the acquiring organization. Risk identification and analysis are invaluable to the transaction and provide much-needed visibility to the environmental and human health risks the target company encompasses. It’s crucial to take the time to validate any reports and risk assessments coming from the target to organization to ensure they are complete, thorough and reliable.
A Fresh Perspective on PSM
While systems are only regulated over their respective threshold quantities (TQs), there is lots of room to manage risk proactively on setups below those thresholds. Bear in mind that TQs are a relatively artificial cutoff, and you can still encounter very serious consequences below that threshold. Risk supersedes quantity parameters, so make sure you approach PSM from this higher level and not limit your thinking. Armed with this new insight into your programs and procedures, you are prepared to truly manage your risk, moving away from strict compliance and into more advanced risk management.
If your program is in need of a tune-up (or just a second opinion), our PSM experts are standing by to partner with you. With experience in many different industries and facility types, we can offer informal benchmarking insights and help you put your needs in context. We have a proven auditing track record and can add another layer of review and validation to your existing efforts, keeping your workers and operations safe and compliant.
