PSM 15th Element: Quality

OSHA Process Safety Management (PSM) program is nearly two decades old and I believe that the 14 PSM elements provide a good basic framework for facilities to create a safety program.

What OSHA PSM lacks is quality metric.

Let me explain further.

For example, one of the elements of the OSHA PSM is emergency planning. As a part of emergency planning, a facility is required to develop an emergency action plan.

Now, an emergency plan can be 2-pages, 4-pages, 200-pages. What aspects should an emergency plan address? How can one be sure that the plan would work in case of an emergency? There is nothing in the PSM requirement to ensure a working emergency plan for a facility.

The difficulty is if one tries to make PSM too specific it may be more of a burden without additional benefits. This is because every facility, every unit is in a way unique and has its own subtleties. Thus solutions that are great for a facility may not always be applicable to another one. For example, an emergency plan for a facility close to a neighborhood has a different yardstick  than that of a facility located in an industrial complex. Geography may also influence emergency plan – e.g. a facility located in Texas has to think about hurricane preparedness.

So within the realms of PSM if one tries to impose more prescriptive requirements, it may overburden facilities and not necessarily reduce risks. Current PSM framework provides flexibility to attain safety goals without constraining to a solution.

I believe the key is for safety systems and programs meet intent of the PSM elements. During implementation of the PSM elements one needs to critically think about efficacy of the elements for the particular facility. Therefore, when I use the word quality in PSM elements, I mean it in a broader sense – quality of thinking in developing safety programs. Within quality element, I also include the systems you would have in place to ensure quality implementation of the well thought safety programs.

In my opinion the difference in safety performance of facilities is the quality of thinking that has gone into developing and implementing safety and risk management programs.