June 10, 2013
Process Safety Management, specifically the National Emphasis Program (PSM-NEP) might be terms and acronyms that don’t make any sense unless you are in a facility that works with or around highly hazardous chemicals (HHCs). It would be a very big mistake to think that this OSHA initiative doesn’t apply to you. Many of the activities that maintenance and engineering perform each day are applicable to PSM and Non-PSM plants. The only real difference would be in the level and degree of documentation required. Although it wouldn’t be a bad practice to document your activities as if you were under the watchful eyes of OSHA through a PSM program.
There is a significant chance that although your facility is not PSM mandated, you do follow some national or international quality initiative such as ISO or several of the other professional doctrines. All of which require extensive and ‘auditable’ documentation.
There is little doubt that many maintenance organizations are very good at ‘doing’ and not so good at ‘documenting’. Unfortunately, if it isn’t documented, in many cases, it didn’t happen.
OSHA even made it part of the official record in one of their Instructions that “employers may have an extensive written process safety management program, but insufficient program implementation.” In other words, we don’t do what we say we do. This probably doesn’t just happen with PSM processes.