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Process safety is currently managed through OSHA’s Process Safety Management (PSM) of Highly Hazardous Chemicals standard and EPA’s Risk Management Program (RMP). Following the 2013 explosion of a fertilizer plant in West, Texas, the federal government has begun to draft and work towards implementing regulatory revisions to the RMP and PSM regulations with help from the Chemical Safety Board ¹. The USEPA issued a notice of proposed rulemaking that would revise the RMP on March 14, 2016, and the working group in charge of the changes to the RMP pledged to issue a final rule in 2016. Formally proposed changes to OSHA’s PSM have yet to be introduced, but a request for information was issued in late 2013 ². 

A game-changing proposed update to PSM could be the inclusion of oil and gas well drilling, production, and servicing operations, a sector that has, up until now, been exempted from the standard. In addition, one of the key RMP changes that could impact companies such as chemical manufacturers and petroleum refiners involves audit requirements. Companies with process units that fall under the PSM requirements are currently required to perform a compliance audit every three years. Changes to the regulations could increase the frequency that audits are required, and restrict the number of eligible auditors by requiring independent third parties to act as auditors. Another aspect of the proposed RMP changes includes a required assessment to consider the feasibility of implementing any “inherently safer technology” (IST), that falls under a hierarchy of “active, passive, and procedural measures” to control hazards ³. This hierarchy is conceptually similar to the hierarchy of controls commonly referenced in the field of industrial hygiene ³. 

Cardno ChemRisk consultants have experience in managing world-class environmental, health, and safety programs and can assist you in keeping up with regulatory and public expectations related to PSM. We have experience in improving PSM by establishing the following:

· Regular audits of their PSM program at predetermined intervals;

· Improved process safety lagging and leading indicators, such as increased near-miss reporting and analysis; reduced number of overdue PSM training and overdue mechanical integrity inspections; and tracking of the rate and severity of release events;

· Establishment of a process safety senior leadership team and a process safety engineering team with participation at various levels of the organization.