The three levels of PSM Compliance…

I’ve always taught that there are three levels of PSM compliance. In my travels throughout the Ammonia Refrigeration Community I’ve seen facilities at every level. I’ve also found that you can fairly quickly figure out what their situation is by asking three questions. Ask yourself these questions about your PSM program and how comfortable you are with it:

Do you have a written plan? There are lots of requirements for a written plan in PSM, but by and large it’s best to adopt the “If it isn’t written, then it isn’t controlled” approach in your PSM program. So, you know that the PSM standard requires Employee Participation, for example. How do you go about making sure that actually happens? Are there clear directives to the person responsible for implementing the element to involve employees in parts of the programs and are examples provided as to how you expect them to actively solicit participation? Are there methods outlined so that people can bring concerns or improvement ideas to the appropriate people so they can be evaluated?

Another example in Mechanical Integrity: Do you have a written plan on how you will set up your maintenance/inspection/testing schedule on your process equipment? Does it include requirements to look at the appropriate RAGAGEP as well as the Manufacturer’s recommendations? Does it look at the PHA recommendations and Incident findings?

This is the first level of compliance: Being able to say Yes to this question is a good start, but to be even minimally compliant you have to be able to couple it with the next one as well.

Do you implement the written plan? OK, maybe some consultant put together a great written plan for you. Now, do you actually do the things that written plan says you do? When you review the program documentation (and if it wasn’t documented, it might as well not have happened) do you find that Employee Participation actually occurred? If the written plan said you would use a certain form, did you actually use it? If the plan said that you would have monthly PSM meetings, did they actually occur and were the appropriate people there? If the plan said that the responsible person was supposed to actively solicit operator input for SOP development, is there documentation that such input was asked for – even if the operators didn’t have anything they wanted to add.

For Mechanical Integrity, did the responsible person implement your written plan to create a maintenance/inspection/testing schedule? Is their evidence in the documentation that the schedule actually followed? If a PHA or Incident Investigation occurred, were recommendations bearing upon the MI element addressed?

This is the second level of compliance: Do I do the things my plan says and does the plan say the things I do? In Ammonia PSM, for the longest time, this was considered pretty much the gold-standard in PSM compliance.

Does the written plan – as implemented – solve the issue you wrote the written plan for? Let’s say that you are in the top 50% when it comes to PSM adherence. You’ve got a written plan. Not only are you implementing the plan, but you can document that you’ve implemented it. Now comes the tough question – is your plan actually working? Do the people in the process actually feel that they are being consulted? Do they feel like they have an avenue to improve the program? Are there issues that could have been avoided if the right people were consulted and those opportunities were missed?

On the Mechanical Integrity side, if you are religiously performing and documenting your maintenance/inspection/testing, but still experiencing breakdowns or MI-related releases, or the piping is simply rusting away, are there things you can do to improve the MI schedule so that these issues are avoided?

This is the third level of compliance. You could consider this the God-Tier in gaming parlance. If you can answer Yes to this level – AND you are continuing to ask and answer the question on a daily basis, then you should sleep well at nights.

Conclusion: Based on my experience and some long (and heated) conversations with some of my friends in the industry:

  • about 5-10% of the processes that are covered by the PSM standard honestly can’t say yes to even the first question. They don’t have a plan in writing so there is really no way of knowing if they’re implementing at all.
  • About 40% of the processes that are covered by the PSM standard honestly can’t say yes to the second question – at least reliably. They’ve got a plan, and maybe they follow it most of the time. Still you’ll find lots of things in their written plan that come as a complete surprise to them.  Some of these plants even have a great safety culture where people do the right things regardless of what the written plan says, but a plant without a plan as their standard is only as safe as long as those people are there and chose to work that way.
  • About 45% of the processes that are covered by the PSM standard honestly can’t say yes to the third question – usually because they haven’t realized they should (or could) ask it.

That leaves about 5-10% of the processes that are covered by the PSM standard where the situation is as it should be. In my opinion, part of the reason that the NEP is causing so many citations is because, for the first time, OSHA is looking at that 3rd level of compliance before the process safety fails and results in an accident.

About Brian Chapin

PSM / RMP Compliance Consultant
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