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PT Notes

OSHA RFI - Additional Management System Elements

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On December 3, 2013, the U.S. Occupational Safety and Health Administration (OSHA) announced a request for information (RFI) seeking public comment on potential revisions to its Process Safety Management (PSM) standard. Multiple issues were addressed in the RFI.

One issue deals with revising the PSM standard to require additional management system elements. In 1992, when OSHA promulgated the PSM standard, it adopted management system elements based on best practices from industry at the time. However, best practices have evolved and additional management system elements may now be necessary to protect workers.

The Center for Chemical Process Safety (CCPS) has defined a Risk-Based Process Safety (RBPS) program that contains 20 different management system elements, a number of which are not included in the PSM standard. One such element is Measurement and Metrics which is described by CCPS as a system for establishing leading and lagging safety indicators to track the effectiveness of the management system in order to identify opportunities for improvement. Another RBPS element is Management Review and Continuous Improvement which is described by CCPS as an ongoing due diligence review by management that fills the gap between day to day work activities and periodic formal audits. A further RBPS element is Process Safety Competency.

Also, OSHA is considering adopting management system elements from safety standards that other federal agencies have promulgated since 1992, for example, the Bureau of Safety and Environmental Enforcement's Safety and Environmental Management System (SEMS) for the offshore industry. SEMS requires the development and implementation of a stop work authority that creates procedures and authorizes any and all industry personnel who witness an imminent risk or dangerous activity to stop work. Also, SEMS requires the development and implementation of an ultimate work authority that requires industry operators to clearly define who has the ultimate work authority on a facility for operational safety and decision making at any given time. Furthermore, SEMS requires an employee participation plan that provides an environment that promotes participation by industry employees as well as their management to eliminate or mitigate safety hazards.

Interestingly, OSHA does not mention other important RBPS management system elements such as process safety culture, operational readiness, and conduct of operations.

OSHA is inviting public comment on any additional management system elements, or on expanding existing elements, including those elements discussed in the RFI to improve worker protection in facilities covered under the PSM standard. OSHA requests that commenters submit data and information on management system elements from consensus standards, safety organizations, federal standards, or other sources.

OSHA has posed these questions on this issue in the RFI:

  1. Does your facility follow any management system elements not required under the PSM standard? If so, please describe the additional elements, the safety benefits, any economic impacts associated with following the elements, and any special circumstances involving small entities.
  2. Would expanding the scope of the PSM standard to require additional management system elements, or expanding the scope of existing PSM management system elements, prevent worker injuries and fatalities? If so, please describe the elements, the safety benefits, any economic impacts associated with expanding the scope of the standard in this way, and any special circumstances involving small entities that OSHA should consider.
  3. In systems using measurement and metrics, how do facilities develop useful leading indicators? Should the PSM standard require facilities to share these indicators with employees or OSHA?
  4. Would expansion of the employee participation provision in the PSM standard to include requirements such as the SEMS stop work authority, or other efforts to involve employees in all management system elements, prevent worker injuries and fatalities?
  5. Are there any other management system elements in the existing PSM standard that OSHA should expand with additional requirements, for example, a new requirement that employers perform a root cause analysis for incidents? If so, please describe the additional requirements, the safety benefits, any economic impacts associated with expanding the PSM elements in this way, and any special circumstances involving small entities that OSHA should consider.
  6. Please provide any data or information on workplace accidents, near misses, or other safety related incidents that the employer could have prevented by following management system elements not required under the existing PSM standard.

For more information, you can contact Primatech or click on this link:

Federal Register notice

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