(104c) The Challenge to Implement and Maintain An Effective PSM Program

While researching to develop responses to help a client respond to OSHA citations, we discovered a presentation to the same industry segment from 1997; we could change the date and present the same presentation today. OSHA is still finding the same gaps as 14 years ago. Chemical plants generally know how to complete a PHA, an MOC, an Incident Investigation, etc. What is incomplete are the work processes to ensure continuity and that all the work gets done.

It's imperative that your PSM program is functional. For example, OSHA has said that the best defense against a National Emphasis Program (NEP) inspection is a strong PSM program. Failures can result in citations and incidents; those can lead to repeat or egregious citations, financial losses, public disgrace and fatalities. Once your company has citations for minor offenses, you become a target for repeat inspections.

You can improve your PSM program, improve your efficiency and reduce the chance of citations by improving the documentation of what you already do. This paper will address reducing failures in the prompt completion of action items and dealing with the challenge of keeping track of changing RAGAGEP (recognized and generally accepted good engineering practices).