How to Keep an Updated and Accurate PSM Program
Master the keys to effectively meeting OSHA’s standard.
In recent years, process safety management (PSM) has emerged as one of the hottest topics in the cooling realm. It also has emerged as one of the biggest headaches thanks to its many moving parts, including audits, documentation and training.
The U.S. Occupational Safety and Health Administration (OSHA) established the PSM standard to keep employees safe from highly hazardous chemicals, and facilities with an ammonia threshold of more than 10,000 lb must comply by developing and implementing a PSM plan.
OSHA defines 14 elements of PSM:
- Employee participation.
- Process safety.
- Process hazard.
- Standard operating procedures.
- Contractor safety.
- Pre-startup safety.
- Mechanical integrity.
- Hot-work permits.
- Management of change.
- Incident investigation.
- Emergency planning and response.
- Compliance audits.
- Trade secrets.
Despite the many elements involved, PSM compliance does not have to be overwhelming. Here are some key things you can do to keep an updated and accurate PSM program — without losing your cool.
Ditch the Paper, Go Digital for PSM Recordkeeping
For many manufacturers, PSM means reams of paper and heavy, thick books overflowing with numerous forms, operating procedures manuals, permits, process documents, training certificates and more. But relying on paper, disks and flash drives is often wieldy and inefficient. Opting for a digital PSM solution — one that does not have to be physically installed on site — can offer numerous benefits.
Rather than licensing software and running it on company servers, many modern digital PSM solutions are Internet based (in the so-called “cloud”), providing online access and use of the software from any location.
With cloud-based digital PSM solutions, PSM programs and procedures are stored and accessed online rather than being printed and bound. Online accessibility allows corporate safety personnel to perform program audits or retrieve and review documentation from the comfort of their own office instead of traveling to the facility.
Employee training or equipment maintenance tasks can be viewed instantly and assigned to individuals. And, instead of searching through stacks of paper work orders, equipment maintenance history is documented and quickly retrieved with a click of a mouse. PSM audits, process hazard analysis studies and mechanical integrity inspection history and tracking are conveniently accessible online.
Management of change (MOC) and other PSM forms also can be more accurately managed, reducing the potential for error. With everything stored in one place, there is no need to search through offices, filing cabinets and file folders for paperwork. You also do not have to stress about accidental destruction of paperwork through fires, floods or misplacement. In fact, each facility has separate and secure digital storage areas with frequent backup protection. Digital PSM provides increased security, storage flexibility and cost reduction.
Keep Detailed PSM Standard Operating Procedures
Standard operating procedures (SOPs) embody one of OSHA’s 14 key PSM elements. These must be clearly documented in sufficient detail, providing specific direction so employees can determine how to safely perform service and maintenance activities. (See more about the steps to sound and effective SOPs in the sidebar here.)
The lack of procedural clarity and specificity in SOPs can cause employee confusion and error. For example, if valves are not labeled clearly and specifically, an employee may open them and get exposed to hazardous chemicals. Table 1 shows the elements to address to ensure that you keep detailed SOPs.
Once they are written and implemented, SOPs should be updated as often as necessary. Also, they must be certified as accurate annually to ensure they reflect current operating practices, changes in the process chemicals, technology, equipment and facilities. Remember that an SOP revision requires a management of change in accordance with PSM best practices.
Ace the PSM Compliance Audit
PSM compliance audits — both comprehensive and intensive — ensure you are effectively meeting OSHA’s PSM standards through the collection of facts and statistical information. (Learn about 7 common audit mistakes in here.)
The process includes an evaluation of the design and effectiveness of the PSM program as well as a field inspection of the safety and health conditions and practices. According to OSHA, the essential elements of the audit process include planning, staffing, conducting the audit, noting deficiencies, performing a followup and documenting actions taken.
The audit also includes:
- Kick-off meeting with the auditor to review agenda
- Interviews with key employees and contractors (if applicable)
- Review of written PSM program elements and all required documentation
- Review of ammonia system operating and maintenance procedures
- Observations of on-site conditions
- Post-audit meeting to review findings
A well-planned and organized audit process, including cross-trained personnel, audit checklists and self-audits, can help ensure a successful outcome.
Assemble a PSM Audit Team
A productive audit team is critical to the success of your program. The team’s size will vary depending on the size and complexity of your program. However, no matter the size, team members should be chosen based on their experience, knowledge and familiarity with auditing techniques, practices and procedures. Members could include those in roles such as:
- PSM/RM coordinators or managers
- Refrigeration supervisors or technicians
- Facility environmental, health and safety managers
- Facility engineers
The team leader is responsible for reviewing each item on the audit checklist with the team and for explaining what criteria are acceptable for full compliance. All team members should have input on the findings for each element of the checklist. If an item is not in full compliance, the team must establish recommendations so it is.
In conclusion, PSM does not have to serve as a source of stress for your plant. If you ensure your PSM program is updated and accurate by giving it the attention it needs, you can prevent costly fines and dangerous incidents.