Process Safety Management Best Practices, Lessons Learned and Enforcement Trend

Chemical safety and process safety continue to garner significant media attention around the United States as chemical and process safety events continue to occur. OSHA's Process Safety Management (PSM) standard and EPA's Risk Management Program (RMP) standard provide a framework for preventing unwanted release of highly hazardous chemicals. It is also important to note that these are performance standards, meaning that regulated processes are told what the goal (unwanted release) is, not how to meet it. OSHA began a PSM National Emphasis Program (NEP) for Petroleum Refineries in June of 2007 and later implemented an additional PSM National Emphasis Program for Chemical Facilities in November of 2011. Enforcement data shows key trends and areas where both EPA and OSHA focus their efforts. This paper will review the key enforcement trends for PSM and RMP regulated processes, discuss how other OSHA regulations are pulled into the PSM NEP inspections, and provide some best practices for ensuring process safety is a way of life.