Meshing process safety management with total productive maintenance


Operating procedures

A common mistake with this PSM-NEP element is to think it applies only to operators. OSHA auditors reviewing this element are looking to see if employees are performing their work as described in operating procedures. This would include operators performing production duties properly, as well as maintenance technicians going about their work properly. Also, as with most audits, an operation that appears to be neat and orderly presents the best case for success.

Under TPM, the BEC teams, as directed by the steering committee, review and establish the operating procedures as well as set up standards for 5s implementation. 5s is an organizational process that is applied to equipment, the immediate area around the equipment, and to the tools used to maintain and operate the equipment. The 5s’s are:

  • Sort-organization; sorting out
  • Set In Order-orderliness; a place for everything and everything in its place
  • Shine-cleanliness; cleaning is inspecting
  • Standardize-neatness; a routine or sequence
  • Sustain-self discipline; adhering to the rules


The TPM steering committee initiates an implementation team and supports their efforts to satisfy the fundamental requirement that “employers develop a written plan to ensure employee training.”

Ironically, the actual success of a BEC exercise directly addresses this elements other key demand that “training includes demonstrated knowledge of routine tasks.” 


A Process Safety Management program requires that “the employer shall obtain and evaluate information regarding the contract employer’s safety performance and programs.” The wrong way, and maybe the worst way to approach this standard mandate is to push it off onto the safety department. Under TPM guidance, an implantation team is created and chartered to address this specific subject. Remember the guiding philosophy; we are all responsible for our equipment.

Pre-startup safety review

It is reasonable to believe that any company that utilizes HHCs already has a PSSR process. As stated in earlier editions of this series, it’s not that companies don’t have these processes, it’s that they don’t follow them. Under the TPM steering committee guidance and the BEC development, this element’s first need is met: “the employer shall perform a pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information.”

The second need is addressed through the process guides developed by the implementation teams: “the pre-startup safety review shall confirm that prior to the introduction of highly hazardous chemicals, confirmation is provided for a safe start.” 

Mechanical integrity

“The employer shall document each inspection and test that has been performed,” is clearly addressed in the process guides developed by the implementation teams. And the preventive and predictive maintenance processes and procedures are established through PMO and BEC activities. A TPM implementation also helps to establish solid metrics to measure the success of the actions in this element as well as the others. 

Hot work permit

The actual application of a solid hot work permit process is complex, but the establishment of the procedure is simple. An implementation team creates and trains employees on the process guide to be applied against the requirement that “the employer shall issue a hot work permit for hot work operations conducted on or near a covered process.”

Management of change

This PSM-NEP element is perhaps the most neglected of the 14 elements. The neglect is not with malice, but most organizations build a complex flow chart of required signatures and the MOC tends to get rushed to keep a project on schedule. The standard is simple: “the employer shall establish and implement written procedures to manage changes to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.”

This process, or better to say our approach to this process, gets exacerbated as our equipment gets older and we are dealing with obsolete components. The requirement to change to a different make, model, or brand can get us into trouble if the change is not well thought out and executed.

Fortunately, the same approach to developing process guides for other element functions applies here as well. Under TPM, the steering committee forms an implementation team to create, adapt, and oversee a process guide to control the success of our MOC process. 

Incident investigation

PSM-NEP requires that “the employer shall investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemical in the workplace.” As with the MOC element, a well-thought-out, fielded, and managed process guide will address this element and keep metrics to ensure that the guide is being followed. 

Emergency planning and response

A TPM steering committee, one that ensures the participation of the employees, will establish an implementation team whose process guides direct the address of this element. OSHA requires that “the employer shall establish and implement an emergency action plan for the entire plant, including the proper response for small releases.” This detail cannot fall upon the safety department; there are too many moving parts to this element and its direct ties to the PHAs. 

Compliance Audits

The Compliance Audits element brings into play several TPM principal processes; not only the establishment of process guides, but planning and scheduling, BEC, and the direct oversight of the TPM steering committee.

Failure to comply with this element could bring serious consequences; try complying without a solid support structure. The element demands are very significant. First, “employers shall certify that they have evaluated compliance with the provisions of compliance audits every three years.” Second, “the employer shall promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected.” 

Trade secrets

The TPM steering committee will establish the process by which they “make all information necessary to comply with this element available, regardless of its trade secrete value”—and thus be in compliance with the final PSM-NEP element.

Fundamentally, there are two types of manufacturing companies: those that have a high-level reliability philosophy and those that don’t. TPM is “a” high level reliability approach; it isn’t the only one. TPM, and processes like it, apply to all organizations, manufacturing or otherwise.

Consider a hospital, school, movie theater, or transportation company. Certainly all of these industries would benefit from employee participation. Perhaps these industries keep trade secrets and manage contractors from time to time. It’s even possible to imagine a well-managed and supported approach to emergency planning and incident investigation could round out solid contingency plans in almost any industry.

What OSHA has done through the Process Safety Management-National Emphasis Program is put some teeth behind its mandate “to reduce or eliminate workplace hazards associated with the release of Highly Hazardous Chemicals.”

What leaders, managers, supervisors, and those in responsible positions need to recognize is that these steps, these 14 elements, aren’t just applicable to companies with HHCs. At the most basic interpretation of the requirements, all industries have the need to comply with the processes that keep their organizations running well and running safe.

See below for more articles from John Ross on plant safety.

<< First < Previous 1 2 Next > Last >>

No comments
The Top Plant program honors outstanding manufacturing facilities in North America. View the 2013 Top Plant.
The Product of the Year program recognizes products newly released in the manufacturing industries.
The Engineering Leaders Under 40 program identifies and gives recognition to young engineers who...
The true cost of lubrication: Three keys to consider when evaluating oils; Plant Engineering Lubrication Guide; 11 ways to protect bearing assets; Is lubrication part of your KPIs?
Contract maintenance: 5 ways to keep things humming while keeping an eye on costs; Pneumatic systems; Energy monitoring; The sixth 'S' is safety
Transport your data: Supply chain information critical to operational excellence; High-voltage faults; Portable cooling; Safety automation isn't automatic
Case Study Database

Case Study Database

Get more exposure for your case study by uploading it to the Plant Engineering case study database, where end-users can identify relevant solutions and explore what the experts are doing to effectively implement a variety of technology and productivity related projects.

These case studies provide examples of how knowledgeable solution providers have used technology, processes and people to create effective and successful implementations in real-world situations. Case studies can be completed by filling out a simple online form where you can outline the project title, abstract, and full story in 1500 words or less; upload photos, videos and a logo.

Click here to visit the Case Study Database and upload your case study.

Maintaining low data center PUE; Using eco mode in UPS systems; Commissioning electrical and power systems; Exploring dc power distribution alternatives
Synchronizing industrial Ethernet networks; Selecting protocol conversion gateways; Integrating HMIs with PLCs and PACs
Why manufacturers need to see energy in a different light: Current approaches to energy management yield quick savings, but leave plant managers searching for ways of improving on those early gains.

Annual Salary Survey

Participate in the 2013 Salary Survey

In a year when manufacturing continued to lead the economic rebound, it makes sense that plant manager bonuses rebounded. Plant Engineering’s annual Salary Survey shows both wages and bonuses rose in 2012 after a retreat the year before.

Average salary across all job titles for plant floor management rose 3.5% to $95,446, and bonus compensation jumped to $15,162, a 4.2% increase from the 2010 level and double the 2011 total, which showed a sharp drop in bonus.

2012 Salary Survey Analysis

2012 Salary Survey Results

Maintenance and reliability tips and best practices from the maintenance and reliability coaches at Allied Reliability Group.
The One Voice for Manufacturing blog reports on federal public policy issues impacting the manufacturing sector. One Voice is a joint effort by the National Tooling and Machining...
The Society for Maintenance and Reliability Professionals an organization devoted...
Join this ongoing discussion of machine guarding topics, including solutions assessments, regulatory compliance, gap analysis...
IMS Research, recently acquired by IHS Inc., is a leading independent supplier of market research and consultancy to the global electronics industry.
Maintenance is not optional in manufacturing. It’s a profit center, driving productivity and uptime while reducing overall repair costs.
The Lachance on CMMS blog is about current maintenance topics. Blogger Paul Lachance is president and chief technology officer for Smartware Group.