(40b) Simplified PSM for Smaller Non-Regulated Sites: Development History, Program Overview & Recommendations

Howat, C. S. III, C. S. Howat & Associates

            Consider the risk mitigation and management challenges facing a small, consumer-product-oriented facility.  This site may have fewer than 100 employees with a safety manager trained in personnel safety only.  There may be one mechanical engineer running the maintenance department.  The raw materials are principally commodities with currently high prices.  The products are consumable, relatively low value added.  Facility viability is based on production of high-quality product, meeting stringent timelines and rapid changeover of products and installation. 

            Hazards at the facility may include combustible dust, below TQ ammonia refrigeration, corrosive/toxic/incompatible raw materials, steam and carbon dioxide or nitrogen for direct cooling.  Processing steps may include separations, mixing, milling, grinding, blending, pneumatic conveying, compression, pumping and heat transfer.  A process accident at this facility is arguably more devastating to the company in personnel, business continuity and investment than one at a highly integrated chemical plant.

            This hypothetical facility does not fall under 29 CFR 1910.119.  Therefore, process risk has likely gone unevaluated.  There are various RAGAGEP standards, e.g. NFPA® 61, which might apply putting them at regulatory risk if they do not follow the prescriptive aspects of the standards.  These standards do allow or will soon allow performance compliance, yet this effectively requires appropriate hazard identification and risk assessment analyses.

            Facilities like this one require appropriate application of simplified PSM methods to mitigate and manage process risk and mitigate regulatory risk.  This paper discusses the approach used at twenty facilities such as the one described above.  Observations, trial and error, and ongoing program evaluation coupled with increasingly aggressive regulation oversight led to the current simplified PSM program.  The focus is training, informal and formal audits and documentation ensuring tolerable process risk and minimizing regulatory risk.  This paper will give snapshots of the program evolution, summarize the current program, address ongoing challenges and provide implementation recommendations to mitigate and manage risk at small, technically challenged, non-PSM facilities.


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