Process Safety Management Elements
This post continues our discussion to do with the process safety discipline. Previous posts in this this series include,
Management Elements
Process safety programs are typically organized and controlled using a set of management elements. The choice of these management elements and the manner in which they are organized varies — different regulators and companies have slightly different approaches. But, in general, they are quite similar to one another — they are more like dialects of the same language rather than different languages.
One of the first set of management elements was developed by the United States Occupational Safety & Health Administration (OSHA) in the early 1990s. Although their list is rather dated, it is still the controlling regulation in the United States. Moreover, as discussed in Appendix A, the latest proposals from OSHA to update their standard do not change this list, which is organized around the fourteen management elements shown in Table 1.1.
Table 1.1
The OSHA Management Elements
Employee Participation
Process Safety Information
Process Hazards Analysis
Operating Procedures
Training
Contractors
Prestartup Safety Review
Mechanical Integrity
Hot Work Permit
Management of Change
Incident Investigation
Emergency Planning and Response
Compliance Audits
Trade Secrets
The above list is not only a legal requirement in the United States, it also provided a basis for rules in other nations and for company-specific standards.
Other organizations have developed newer lists of management elements. The Center for Chemical Process Safety (CCPS), for example, has developed the list shown in Table 1.2.
Table 1.2
CCPS Process Safety Management Structure
Process Safety Culture
Compliance
Competence
Workforce Involvement
Stakeholder Outreach
Knowledge Management
Hazard Identification and Risk Management
Operating Procedures
Safe Work Practices
Asset Integrity / Reliability
Contractor Management
Training / Performance
Management of Change
Operational Readiness
Conduct of Operations
Emergency Management
Incident Investigation
Measurement and Metrics
Auditing
Management Review
Some of the elements in Table 1.2, such as Management of Change, are identical to those in Table 1.1. Others are modified — for example, Prestartup Safety Review becomes Operational Readiness. Other elements in Table 1.2, such as Measurements and Metrics, are new. One of the topics in the original OSHA list — Trade Secrets — has been removed.
Other organizations, such as the American Petroleum Institute and the American Chemistry Council, have their own methods for organizing PSM programs, as have many of the larger companies in the process and energy industries. In general, these systems are generally quite similar to one another. Therefore, if a company develops a process safety program to meet one standard, it is likely that it will address the requirements of other organizations without too much modification being needed.
The ‘Most Important’ Element
A question that sometimes arises is, ‘What is the most important element in process safety management?’ Here are some possible responses.
Knowledge Management is the ‘most important’ because accurate information is the foundation of all other process safety activities. If the information is wrong, then we cannot trust the results from other activities such as incident investigation or hazards analysis.
Management of Change is the ‘most important’ because all incidents are caused by uncontrolled change.
But maybe Incident Investigation is what really matters because incidents reveal what is really going on in the organization.
Culture/Employee Participation is the ‘most important’ because the manner in which people behave and think affects all aspects of process safety.
The final response ― Culture and Participation ― is probably the best answer. However, process safety management is a system — the elements interact with one another in myriad ways. All of them are important, none of them are ‘the most important’. Therefore, an even better answer would be,
No single element is the most important.
When the artificial intelligence program ChatGPT was asked,
What is the most important element in process safety management?
it provided the following response.
There is no one specific element that can be considered the most important in Process Safety Management (PSM), as it is a comprehensive system that aims to prevent releases of hazardous chemicals and to minimize the consequences of such releases if they do occur.
Process Safety Management consists of many specific elements such as hazards analysis, management of change and operating procedures. They all interact with one another — they are components of a holistic system.
No single element is the “most important”.
This is a good response because it highlights the fact that PSM is a system.
