Ester Brawley, Steve Maher
“Unique Challenges Facing Small Companies Developing and Implementing PSM”
Small Companies that are subject to PSM face many challenges to developing and implementing PSM. These challenges can be grouped into three major categories: knowledge and expertise, limited resources, and approaching PSM as another “safety program”.
Oftentimes, smaller companies simply “do not know what they don't know”. The individual responsible for developing and managing the program is juggling a multitude of responsibilities including, but not limited to, facilities/plant manager, head of operations, managing maintenance personnel, and sometimes is the actual owner. Although these individuals can eventually develop a system for managing operations or maintenance, they lack the engineering background or experience with codes and standards to properly meet the requirements of Process Safety Information or assist with Management of Change. There is a large reliance on consultants by the PSM Coordinator/Plant Manger without the ability to know if the work being performed is complete and without adequate training to know the consultant cannot completely perform the day-to-day involvement this living program requires.
The second category of unique challenges would include lack of resources. The resources cover a broad spectrum of areas such as monetary funding to get beyond a fix-at-failure, truly preventive maintenance program. Many key pieces of equipment are found to be disabled or bypassed. There is frequently a lack of personnel or manpower available to adequately develop detailed site specific operating procedures and/or annually certify the procedures. If MOC's are initiated, they can often stall due the individuals not able to allocate time to the documentation and closure of items. There is often no internal engineering expertise to assist with Management of Change process, assist with determining if the system is consistent with published codes and standards, or available to draft P&IDs. True training of all thirteen elements is not fully covered in depth and to the degree that all disciplines are involved in the PSM Program. The PSM program is allocated to one individual and often times ends up a binder on a shelf.
Many small companies either over-simplify or over-complicate PSM making it destined for failure. PSM is misunderstood as a “Safety and Environmental” program. Unfortunately PSM can often not be completely simplified to checklists and forms. It is supposed to evolve with the facility and incorporate lessons learned. However, PSM does stem from good management practices. Systems and mechanisms need to fold into personnel's day-to-day operations and not be too cumbersome and hard to manage. Instead of forcing the people to fit the paper, the paper needs to be modified to match the people.
The key objective of this paper is to provide practical tips on key issues that should be used to guide the small business on the intent of PSM, what to expect when delegating who the PSM Coordinator is, working with consultants, getting other departments and disciplines involved.