Safety Moment #66: The Most Important PSM Elements — Participation

In an earlier Safety Moment we saw that the term ‘Process Safety Management’ (PSM) can become diluted to the point where it loses any meaning. This is unfortunate. The term is not just another way of describing industrial safety — it has a tight and specific significance, as explained in Process Safety Management. The description discusses the three words that make up the term: ‘Process’, ‘Safety’ and ‘Management’, and how they should be applied. The discussion at that topic page notes that all PSM programs are made up of a set of management elements. The original set of elements, published by OSHA nearly 30 years ago, is as follows.

  1. Employee Participation
  2. Process Safety Information
  3. Process Hazards Analysis
  4. Operating Procedures
  5. Training
  6. Contractors
  7. Prestartup Safety Review
  8. Mechanical Integrity
  9. Hot Work
  10. Management of Change
  11. Incident Investigation
  12. Emergency Planning and Response
  13. Compliance Audits
  14. Trade Secrets

Since then, many other organizations and companies have developed their own set of process safety elements. In general, they are not usually all that different from one another — they are dialects of the same language. Each element is important, and must be implemented and managed properly. They also interact with one another in multiple ways; they comprise a management system. For a process safety program to be effective the connections between the elements should be understood and managed.

Of the 14 elements identified by OSHA, I suggest that three of them can be considered to be “the most important”. They are those that are highlighted in the above list: Employee Participation, Process Hazards Analysis and Management of Change.

Let’s start with Employee Participation. (In this context the word ‘Employee’ covers all people working at the facility, including managers, technicians, contractors and consultants.) Note that the element uses the word Participation, not Communication. Communication is an important part of Participation, but it is not the whole of it. Other PSM systems use the word ‘Culture’ to describe the same concept. However, it can be argued that the word Culture is too vague to be useful.

Employee Participation is critically important for two reasons. First, it is the foundation of all the other elements — it does not stand by itself. (This is why it is difficult to audit — how does the auditor evaluate a management element that is to do with attitudes, a ways of thinking and working, or even a state of mind?)

The second reason for the importance of this element is that it is the most effective way of developing and improving a PSM program. If a manger or consultant implements a new way of carrying out a task many employees will treat that initiative as being “theirs”, not “ours”. However, if the employees feel free to develop and implement their own process safety initiatives, they will want to make such initiatives work because they feel a sense of ownership.

An example of how Employee Participation affects other elements is provided in the book Process Risk and Reliability Management. The example is to do with the Process Hazards Analysis (PHA) element. When people hear the term Process Hazards Analysis, or related terms such as HAZOP, they usually visualize a team of multi-discipline experts sitting around a table working through a P&ID and other engineering documents trying to identify hazards in a systematic manner. Exercises of this type are certainly an important part of the PHA program, but maybe not the most important part.

In the example the scene is set in which a technician is working at night at a Tank Farm. He may be about to open a valve that connects two of the tanks. But, before doing so he pauses and says to himself, “You know, opening this valve could lead to reverse flow, which could lead to wrong chemicals mixing with each other and/or tank overflow. Before I open the valve, maybe I should talk over what I’m planning to do with my colleagues and supervisor.”

The technician has just participated in the facility’s PSM program by conducting a Process Hazards Analysis. He has,

  1. Identified the hazard: Unexpected reverse flow.
  2. Evaluated the consequences: Tank overflow and/or undesirable chemical reactions.
  3. Determined the likelihood: He recognizes that this scenario is plausible — he could see himself doing it.
  4. Evaluated the risk: This is serious enough to justify stopping work.

Note that his actions were not just a part of the company’s safety program. They were to do with the Process (the flow of liquids within the system), the Hazards (what could go awry), and he has conducted an Analysis (he is not just considering the existing safety rules).

If the technician and his colleagues decide that the risk is significant then they can forward their concern to a PHA team. The hazard could then be evaluated more formally, and additional safeguards recommended.

Process Safety Management