Introduction to Compliance With Standards

Commitment to Process Safety

Resources in this section describe processes for maintaining adherence to applicable standards, codes, regulations, and laws (standards), the attributes of a standards system, and the steps an organization might take to implement the standards element.  

What Is It? 

Standards is a system to identify, develop, acquire, evaluate, disseminate, and provide access to applicable standards, codes, regulations, and laws that affect process safety.  The  standards system addresses both internal and external standards; national and international codes and standards; and local, state, and federal regulations and laws.  The system makes this information easily and quickly accessible to potential users.  The standards system interacts in some fashion with every RBPS management system element. 

Why Is It Important? 

Knowledge of and conformance to standards helps a company (1) operate and maintain a safe facility, (2) consistently implement process safety practices, and (3) minimize legal liability.  Changes in standards may occur at irregular intervals or on a fixed schedule, and the standards system must keep up with such changes so the company can adjust its compliance activities.  The standards system also forms the basis for the standards of care used in an audit program to determine management system conformance. 

Where/When Is It Done? 

To promote consistent interpretation, implementation, and efficiency, the initial identification of and ongoing monitoring of changes in standards is frequently done at a company level.  On the other hand, standards activities are also performed at each facility, where the staff are more familiar with state and local laws and  regulations.  Standards activities should begin early in the process life cycle to ensure that process designs meet applicable codes and standards from the outset, rather than having to make expensive changes later.  The MOC element should address changes initiated by the standards system, and the auditing element monitors the compliance actions that must be taken. 

Who Does It? 

Generally, identification of applicable standards and codes is done by someone with a technical background who has a need for such information, such as an equipment or facility designer.  Determination of applicable regulations and laws is typically done by someone knowledgeable with federal, state, and local agencies that  adopt such provisions.  Frequently, this person works closely with the company legal department to ensure accurate interpretations. 

What Is the Anticipated Work Product? 

The main products of a  standards system are an accurate, complete, up-to-date, and accessible set of documents, data, and information.  Categories of information include internal company guidelines, consensus codes and standards, applicable regulations, and laws.  Ancillary products include company guidance documents that may be created to help ensure efficient, consistent conformance to standards. Outputs of the standards element are used to facilitate the performance of other elements.  For example, determining the relevant external codes and standards to which a company must adhere will help form the scope of the auditing element. 

How Is It Done? 

If the  standards element work is done at a company level, then the responsible party keeps a list of all applicable requirements and copies of all such updated documents.  This information is typically communicated to division- and facility-level personnel responsible for local compliance activities. Facilities that exhibit a high demand rate for maintaining compliance with frequently changing standards may need greater specificity in the standards procedure and larger allocation of personnel resources to fulfill the defined roles and responsibilities.  Lower demand situations can allow facilities to operate a standards protocol with greater flexibility – possibly with a single person providing the advisory service at a divisional or corporate level for multiple facilities.  Facilities with strong process safety cultures generally will have more performance-based  standards  procedures, allowing trained employees to use good judgment in managing compliance.  Facilities with an immature or evolving  process safety culture may require more prescriptive standards procedures, more frequent auditing, and greater command and control management system features to ensure good standards implementation discipline. 

Read More

Section 4.2 of the Guidelines for Risk Based Process Safety book describes the key principles and essential features of a management system for this element; Section 4.3 lists work activities that support these essential features and presents a range of approaches that might be appropriate for each work activity, depending on perceived risk, resources, and organizational culture; Sections 4.4 through 4.6 include (1) ideas for improving the effectiveness of management systems and specific programs that support this element, (2) metrics that could be used to monitor this element, and (3) management review issues that may be appropriate.