A Simplified PSM Guidance for Smaller Facilities using a Risk Based Approach

Abstract

“Safety matters at all levels”, even for small companies that may not be OSHA’s PSM level facilities, as long as they use highly hazardous chemicals which may be toxic, reactive, flammable, or explosive. Incidents aren’t restricted to “large” companies and the fallout from an incident - having to deal with loss of life and property, OSHA/CSB investigations and possible fines and legal ramifications, can actually have a more significant impact on a smaller company. That’s why a robust PSM program (Process Safety Management) is important. It will drive the development of a safety culture among plant personnel to have safer operating facilities free of incidents. Smaller facilities face major challenges in providing financing and resourcing to implement a standard PSM program. This paper presents a risk based approach towards a simplified PSM program that is not a drain on company resources and is feasible to implement in practice. A combination of CCPS Risk-Based Process Safety approach with an organization’s own risk tolerance for various factors and data from OSHA NEP citations (National Emphasis Program) is used as a basis to suggest a simplified PSM guidance by prioritizing specific elements.