Page 55 - Occupational Health & Safety, November/December 2019

FACILITY SAFETY
Process Safety Management—
A Challenge for Small Businesses
Small businesses often find it difficult to execute PSM.
BY JANET PERSECHINO
OSHA’s Process Safety Management (PSM) of Highly Hazardous Chemicals regulation applies to facilities that handle a threshold quantity of specific chemicals listed in Ap-
pendix A of the standard.
The regulation calls out 14 mandatory ele-
ments, and within each element is a list of required items. Implementation can be complex and resource- intensive. The elements, or programs, are focused on decreasing the likelihood of a loss of containment and are somewhat performance-based, leaving room for interpretation. For this reason, a certain level of ex- perience, expertise, and understanding is needed to ensure that the programs actually meet the true intent of the standard.
Small businesses often find it difficult to execute PSM. OSHA points to a study for the chemical pro- cessing industry that estimates, “employers with one to 25 employees are 47 times more likely to have a release and 17 times more likely to suffer an injury, per em- ployee, than facilities with 1500 or more employees.”
Insurance companies and other Authorities Hav- ing Jurisdiction will also be interested in the quality of the PSM programs due to the risk and loss potential. These parties will want to confirm the facility’s aware-
ness of the process hazards and will look for assurance that they are reducing the risk to a level that is as low as reasonably practicable (ALARP).
Process Hazard Analysis
One mandatory PSM element is Process Hazard Analysis (PHA). This is a formalized and systematic approach that analyzes the design of a chemical pro- cessing system to ensure that it will operate safely. There are various PHA methodologies that are rec- ognized by the chemical industry and the regulation. The PSM standard specifically states:
“The process hazard analysis shall be performed by a team with expertise in engineering and process operations, and the team shall include at least one em- ployee who has experience and knowledge specific to the process being evaluated. Also, one member of the team must be knowledgeable in the specific process hazard analysis methodology being used.”
OSHA realizes that it can be difficult for some companies to comply with this requirement, and states in its document, Process Safety Management for Small Businesses:
“Some companies, particularly smaller ones, may not have the staff expertise to perform such an analy- sis. The employer, therefore, may need to hire an en- gineering or consulting company to perform and aug- ment the analysis.”
PSM Implementation
For the reason listed above it can prove helpful for your company to work with a PSM consultant that knows how to integrate the PSM system into your or- ganizational structure.
A good PSM consultant will stay abreast of de- velopments and advances in the industry that can facilitate compliance. This can result in increased ef- ficiency, safety, product quality, and a competitive ad- vantage. The benefits of hiring a consultant typically outweigh the upfront costs. These benefits include time saved in PSM implementation, process improve- ments, cost-effective solutions to corrective actions, potential savings on insurance and/or avoidance of a loss.
Janet Persechino is employed at Engineering Planning and Management, Inc. (EPM). She can be reached at jap@epm-inc.com, 508-532-7360, for a free chemical process safety consultation.
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