Top 5 "Best Implemented" PSM Processes
- A PSM Check-up
Recently, as a follow-up of our webinar series, you might have taken part in the Smith & Burgess' "PSM Check-up" industry survey. This article is a reality check on what areas the survey participants thought they were doing well in compared to OSHA PSM standards as defined in OSHA 1910.119. In addition to looking into historical findings that were defined by our numerous PSM audits, we have also included some statistics from OSHA NEP Citations/Violations along with reviewing the 804 Chemical Safety Board Recommendations. This helps us to ensure that our project PSM audit's results are consistent with regulatory findings.
We see quite often that outside reviews help a facility find the regulatory gaps in their PSM processes that may otherwise go unnoticed by the client's onsite staff. It is our hope that the following items will help you see that a properly executed PSM audit can shine a light in the areas that really could use a little TLC. This independent third-party audit is a proven way to find gaps in processes.
Best 5 Items from the Survey Responses:
These are the items that the PSM Managers that attended our webinar where most confident that their systems were adequate and well-practiced. We wrote this article to go over these items and compare them with our audit reports along with the cumulative NEP Audit results published by OSHA in May 2016. Additionally, we checked CSB investigations to see if they are finding systematic problems related to these areas.
#1) Employee Participation (Highest Score - tie)
This was tied for the highest scored question in our survey. Most of the PSM Managers feel that their facilities have "Employee Participation" well under control. Based on the OSHA NEP Audit survey results from FY14-FY16, only 1.7% of citations were related to this area (with only the PSSR Element having fewer citations). This is consistent with the CSB in that there are only 4 (0.5%) recommendations that reference "Employee Participation" out of a total of 804 recommendations listed at the time of this post (HERE). In general, our PSM Audits find few concerns with employee participation.
#1) Current Operating Procedures (Highest Score - tie)
Again, the PSM Managers are confident that operating procedures are up to date and based on the current operations of the facility. However, this confidence does not appear warranted based on the OSHA citations of the operating procedures PSM element (13.5% of all citation). Of this 3.1% of all citations were based on operating procedures not being developed and ~2.5% for both not having the operating procedures certified annually and/or not having emergency procedures. The CSB has significantly more recommendations related to operating procedures with ~3% of all recommendations related to operating procedures.
#3) MOC Feedback Loop is Affective
The survey results indicate that the confidence in MOCs effectiveness in updating associated PSM elements is high. This survey question will be a little bit more difficult to decipher. The general number of concerns OSHA associated with element "L" Management of Change is 6.4% of the total. So, of the 13 elements of PSM (there are no citations for "Trade Secrets"), this one is 5th. However, the largest concern was with element "D" PSI, 23.6%. So, while there are fewer concerns related to an actual MOC, is the effectiveness of a MOC program better measured in the number of PSI concerns? Our audits seem to indicate that this is the case. There are at least 52 relief devices (2.2%) of the recommendations address the direct and indirect consequences of changes (e.g. not managing personnel change).
Our audits show that the MOC program is the keystone for a solid PSM program. By design, the MOC element requires feedback to numerous elements (PSI, Training, Procedures, etc.). Time-after-time, we see facilities spend large amounts of money to develop a solid PSM Program only to see that investment deteriorates with time due to facility changes. This is an area were an outside audit can show PSM elements that are starting to get behind prior to needing a complete overhaul.
#4) Contractors Audit their Safety Performance
PSM Managers answered that they have a handle on auditing contractors. As a contracting company, we can validate first hand to the level of detail that we go through with third-party firms to ensure that we meet operator requirements. There only a single CSB recommendation related to auditing contractors as part of the selection process. The OSHA citation list has the element "H" contractors as 3.4% of the total number of concerns. Our audits show that sites are very good at ensuring contractors meet minimum safety requirements.
#5) Mechanical Integrity Inspections are Current
Some recent high-profile incidents have been attributed to poor mechanical integrity programs. The CSB has identified that 12 of the ~95 completed incident Investigations can be attributed to insufficient Mechanical Integrity practices to preventing incidents. Based on a summary of OSHA citations from the NEP Audits, 2-3% of all citations are related to the section in the PSM standard on Inspection & test documentation [1910.119(j)(4)(iv)]. However, over 18% of all the citations related to Mechanical Integrity [1910.119(j)]
With all this attention, we are concerned that only 2% of our survey respondents stated that their inspections were "Very Outdated" along with 58% and 32% believing that their inspections were "Very Current" and "Somewhat Outdated", respectively. In almost every PSM audit we have conducted, there are repeated inspection frequency gaps and the required inspection plans don't provide details for compliance.