This article sets out to answer the basic question: what to know about PSM in a PSM-covered facility.
In an earlier article focusing on OSHA’s Process Safety Management regulation, also known as PSM, OSHA PSM inspector Brandi Davis of Oregon OSHA was nice enough to explain a lot of the basics of the OSHA PSM regulation and in particular what an OSHA inspector looks for during a PSM investigation.
That article was very well received and Ms. Davis, a Senior Health Compliance Officer (and Industrial Hygienist) with Oregon OSHA, agreed to follow up with a second interview focusing on education and training for people who work at PSM facilities. Many thanks for Ms. Davis for participating in both interviews and to Oregon OSHA for giving the OK.
With that introduction done, we hope you find the interview below interesting. The focus is on what people in various roles–PSM program administrators, employees, contractors, visitors, and vendors–have to know when working in a PSM-covered facility.
Let us know if you have additional comments or questions. Also, please know we’ve included a free PSM compliance checklist for you at the bottom of this article in addition to the tips Ms. Davis.
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The interview below is very lightly edited for readability. Thanks again for Ms. Davis’ contributions.
Answer (Brandi Davis): Ohhhhh my goodness. This is such a difficult question to answer. You are correct, PSM can be a complicated/challenging program to administer, depending on the process or chemical. I am going to give you the ideal world answer and the real world answer.
In the ideal world, the PSM program’s compliance would not rest solely on the shoulders of one individual. Rather, there would be a team of employees with expertise in differing areas that complement the process that is covered by the PSM regulation.
Ideally there would be a program administrator of the PSM program (some recommend that this is housed in the engineering department) and then the program would be implemented and coordinated by a series of departments: Engineering, Maintenance, Health and Safety and Production.
The PSM program administrator would have a good understanding of the chemical properties and the process, but also have the subject specific experience/training in the principals of process safety management.
Then the individual department members (Production, Maintenance, Health and Safety, and Engineering) would bring their expertise within their areas to the table to support the PSM program development and implementation.
In the real world, typically, facilities see the PSM requirements as an OSHA requirement, and then immediately think that this program belongs to the health and safety department. Some facility’s health and safety department is a person (or people) brought up through the ranks, and delegated the responsibilities for the health and safety program. These individuals may or may not get some basic training in health and safety rules, theories or requirements. It is not uncommon that the people responsible for the health and safety program have never been provided a specific training class in Process Safety Management. When facilities that have structured themselves in this manner are inspected, it is common for a number of deficiencies to be identified.
In general the type of training that would benefit anyone that has a role in the PSM program would include:
Answer (Brandi Davis): Now this one is a bit more straight forward to answer.
I consider an average employee as one that works with or near the covered process. These employees should have the following training:
Answer (Brandi Davis): The contractors working at a PSM covered facility have their own responsibilities outlined in the PSM regulation. That language in the regulation covers the following contract employer responsibilities (see 1910.119(f)(4)):
To me this list is pretty self-explanatory. The contractor has an obligation to ensure that their employees understand the hazards posed by working on a covered system. They should understand what a PSM covered facility entails and the consequences of not following protocols when working on the system. And all the standard health and safety topics apply (lockout/tagout, confined spaces, forklifts, etc.….).
In addition to that list, I’d add the following:
Quick tip: Click to learn about our Contractor LMS, ideal for delivering site-specific PSM (and other safety) orientations like the one described above to contractors online, even before they arrive at your facility.
Answer (Brandi Davis): There needs to be an awareness level of training provided to vendors and visitors.
Now, let me add a clarification to that. A vendor that can directly impact the system is NOT included with this response. For example, a driver that delivers a new batch of the covered chemical and off-loads it to the facility needs the same training as a contractor would.
However, a vendor delivering office supplies or cafeteria services and visitors to the facility that are passing through are included in this response. They need to understand that they are at a PSM-covered facility and what does that mean. They should have a brief overview of the hazards associated with the chemical at the facility and the emergency evacuation or emergency alert system in the event of a release or emergency involving the covered chemical. Most facilities provide this training through a brief powerpoint presentation at sign-in to the facility.
Quick tip: Click to learn about our Contractor LMS, ideal for delivering site-specific PSM (and other safety) orientations like the one described above to visitors and vendors online, even before they arrive at your facility.
Answer (Brandi Davis): If you sit down and read the PSM regulation, I hope you will notice that in almost every element of the PSM regulation there is a sentence that has the word “training” in it. And then, in addition, there is a stand-alone element of TRAINING in the PSM regulation [1910.119(g)]. This should impress on the reader that training is a VITAL element of a successful PSM program.
If the training is weak, ineffective, or nonexistent, then the PSM program will suffer a number of deficiencies.
With this said, compliance officers have been trained to start really evaluating the training programs within a PSM program. Especially if an inspection of the covered facility is identifying a number of deficiencies with the management program. If there are a number of issues with standard operating procedures, management of change, hot work, mechanical integrity, etc., the compliance office should be looking deeper at how does ineffective training play a role in those identified deficiencies.
We hope you found this interview with Brandi Davis of Oregon OSHA, offering a deeper look at the PSM regulations and offering suggestions of what managers, employees, contractors, visitors, and vendors should know. And of course we’d like to express sincere thanks to Ms. Davis for sharing her time, knowledge, experience, and expertise.
You might also find these other PSM-related articles interesting:
You may also be interested in our online Process Safety Management (PSM) training video. We’ve included a short sample immediately below.
Finally, enjoy the free downloadable PSM compliance guide below.
Here is a checklist to help your process safety management compliance.
