PT Notes
Meaning of Process Safety Management
PT Notes is a series of topical technical notes on process safety provided periodically by Primatech for your benefit. Please feel free to provide feedback.
The Process Safety Management (PSM) standard promulgated in 1992 by the U.S. Occupational Safety and Health Administration (OSHA) is often described as a performance-based and risk-based standard, and sometimes as a management system. In actuality, it is none of these, although ideally it should be.
The PSM standard defines generally what is required of companies and can only be described as performance-based in that it allows companies to decide how they will meet the general requirements specified. A true performance-based standard would require the definition of measurable outcomes, i.e. performance targets, and the determination of compliance with them using performance measures. Given that the PSM standard is intended to prevent catastrophic accidents that could impact facility employees, such performance measures should reflect this goal. Ultimately, the overall performance of a facility in meeting this goal is what matters.
In its current form, the PSM standard is hazards-based and not risk-based. Indeed, the word "risk" is not used in the standard. The purpose of the standard is defined as providing requirements for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. The likelihood of such releases is not addressed specifically. Of course, what matters to facility personnel is not just the possible consequences of accidents but also their risk, that is the likelihood of adverse consequences from process hazards. Indeed, it is actually risk that is being managed by a process safety program rather than safety.
All modern industry standards are cast within a management systems framework, including the Responsible Care® Process Safety Code from the American Chemistry Council, the International Organization for Standardization's environmental protection standard, and the American National Standards Institute's occupational health and safety standard. Key aspects of such management systems are policies, roles and responsibilities, the Plan-Do-Check-Act model, a life cycle perspective, management review, and continual improvement, all of which are missing from the PSM standard.
These issues should be addressed by companies with process safety programs to ensure that process risks are being managed using modern methods.
This topic was addressed in a letter to the editor:
Process safety management, Process Safety Progress, Volume 33, Issue 4, page 407, December, 2014.
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