This article sets out to answer the basic question: what to know about PSM in a PSM-covered facility.
In an earlier article focusing on OSHA’s Process Safety Management regulation, also known as PSM, OSHA PSM inspector Brandi Davis of Oregon OSHA was nice enough to explain a lot of the basics of the OSHA PSM regulation and in particular what an OSHA inspector looks for during a PSM investigation.
That article was very well received and Ms. Davis, a Senior Health Compliance Officer (and Industrial Hygienist) with Oregon OSHA, agreed to follow up with a second interview focusing on education and training for people who work at PSM facilities. Many thanks for Ms. Davis for participating in both interviews and to Oregon OSHA for giving the OK.
With that introduction done, we hope you find the interview below interesting. The focus is on what people in various roles–PSM program administrators, employees, contractors, visitors, and vendors–have to know when working in a PSM-covered facility.
Let us know if you have additional comments or questions. Also, please know we’ve included a free PSM compliance checklist for you at the bottom of this article in addition to the tips Ms. Davis.
What to Know about PSM
The interview below is very lightly edited for readability. Thanks again for Ms. Davis’ contributions.
Question: Being the person primarily responsible for PSM compliance at a facility seems like a big and tough job. What type of education, training, and resources do you suggest for these people?
Answer (Brandi Davis): Ohhhhh my goodness. This is such a difficult question to answer. You are correct, PSM can be a complicated/challenging program to administer, depending on the process or chemical. I am going to give you the ideal world answer and the real world answer.
In the ideal world, the PSM program’s compliance would not rest solely on the shoulders of one individual. Rather, there would be a team of employees with expertise in differing areas that complement the process that is covered by the PSM regulation.
Ideally there would be a program administrator of the PSM program (some recommend that this is housed in the engineering department) and then the program would be implemented and coordinated by a series of departments: Engineering, Maintenance, Health and Safety and Production.
The PSM program administrator would have a good understanding of the chemical properties and the process, but also have the subject specific experience/training in the principals of process safety management.
Then the individual department members (Production, Maintenance, Health and Safety, and Engineering) would bring their expertise within their areas to the table to support the PSM program development and implementation.
In the real world, typically, facilities see the PSM requirements as an OSHA requirement, and then immediately think that this program belongs to the health and safety department. Some facility’s health and safety department is a person (or people) brought up through the ranks, and delegated the responsibilities for the health and safety program. These individuals may or may not get some basic training in health and safety rules, theories or requirements. It is not uncommon that the people responsible for the health and safety program have never been provided a specific training class in Process Safety Management. When facilities that have structured themselves in this manner are inspected, it is common for a number of deficiencies to be identified.
In general the type of training that would benefit anyone that has a role in the PSM program would include:
- A detailed class addressing the principles of the PSM management system
- A detailed class or on-the-job training to cover the process involving the covered chemical
- A detailed class in the methodology of the Process Hazard Analysis chosen by the facility
- A basic subject class in the additional health and safety requirements (i.e., respiratory protection, HAZWOPER, forklifts, lockout/tagout, confined spaces, etc.)
- A class in effective auditing
Question: What kind of training do you suggest for average employees working in a PSM-regulated facility?
Answer (Brandi Davis): Now this one is a bit more straight forward to answer.
I consider an average employee as one that works with or near the covered process. These employees should have the following training:
- Overview of the facility’s PSM program–they should understand the term and why it applies to the plant and understand the purpose of the PSM program
- Their role in the PSM program–why the PSM training is required, the importance of their participation in the PSM program, and the consequences of them not participating in effective training
- PSM-related standard operating procedures that impact their work (in some cases, there may be none)
- The principal of the management of change program and how it may apply to their work. For example, knowing not to change anything about the system without prior approval.
- Any specific health and safety topic that impacts their work (lockout/tagout, confined spaces, forklifts, personal protective equipment, etc.)
- Emergency procedures for the facility
- Ways they can contribute to the PSM program, report a safety concern, and/or suggest an improvement idea
- Who the main contact for the overall PSM program is and how to contact that person
Question: What about contractors working at a PSM facility?
Answer (Brandi Davis): The contractors working at a PSM covered facility have their own responsibilities outlined in the PSM regulation. That language in the regulation covers the following contract employer responsibilities (see ):
- (i) The contract employer shall assure that each contract employee is trained in the work practices necessary to safely perform his/her job.
- (ii) The contract employer shall assure that each contract employee is instructed in the known potential fire, explosion, or toxic release hazards related to his/her job and the process, and the applicable provisions of the emergency action plan.
- (iii) The contract employer shall document that each contract employee has received and understood the training required by this paragraph. The contract employer shall prepare a record which contains the identity of the contract employee, the date of training, and the means used to verify that the employee understood the training.
- (iv) The contract employer shall assure that each contract employee follows the safety rules of the facility including the safe work practices required by paragraph (f)(4) of this section.
- (v) The contract employer shall advice the employer of any unique hazards presented by the contract employer’s work, or of any hazards found by the contract employer’s work
To me this list is pretty self-explanatory. The contractor has an obligation to ensure that their employees understand the hazards posed by working on a covered system. They should understand what a PSM covered facility entails and the consequences of not following protocols when working on the system. And all the standard health and safety topics apply (lockout/tagout, confined spaces, forklifts, etc.….).
In addition to that list, I’d add the following:
- Contractors should have a clear line of communication to their plant contact. Too many accidents have resulted after the contractor makes an assumption and acts on it because the line of communication wasn’t easy or wasn’t clearly stated.
- Contractors should be trained on the facility-specific protocols, including emergency evacuation and spill control measures.
- Contractors should be trained on the protective measures (i.e., personal protective equipment, etc.) needed to protect their employees from the chemical hazard
- Contractors should be trained on the documentation that is expected of them, for the work or changes made to the system
Quick tip: Click to learn about our Contractor LMS, ideal for delivering site-specific PSM (and other safety) orientations like the one described above to contractors online, even before they arrive at your facility.
Question: What about visitors and vendors?
Answer (Brandi Davis): There needs to be an awareness level of training provided to vendors and visitors.
Now, let me add a clarification to that. A vendor that can directly impact the system is NOT included with this response. For example, a driver that delivers a new batch of the covered chemical and off-loads it to the facility needs the same training as a contractor would.
However, a vendor delivering office supplies or cafeteria services and visitors to the facility that are passing through are included in this response. They need to understand that they are at a PSM-covered facility and what does that mean. They should have a brief overview of the hazards associated with the chemical at the facility and the emergency evacuation or emergency alert system in the event of a release or emergency involving the covered chemical. Most facilities provide this training through a brief powerpoint presentation at sign-in to the facility.
Quick tip: Click to learn about our Contractor LMS, ideal for delivering site-specific PSM (and other safety) orientations like the one described above to visitors and vendors online, even before they arrive at your facility.
Question: Any other thoughts to share about training at a PSM facility?
Answer (Brandi Davis): If you sit down and read the PSM regulation, I hope you will notice that in almost every element of the PSM regulation there is a sentence that has the word “training” in it. And then, in addition, there is a stand-alone element of TRAINING in the PSM regulation [1910.119(g)]. This should impress on the reader that training is a VITAL element of a successful PSM program.
If the training is weak, ineffective, or nonexistent, then the PSM program will suffer a number of deficiencies.
With this said, compliance officers have been trained to start really evaluating the training programs within a PSM program. Especially if an inspection of the covered facility is identifying a number of deficiencies with the management program. If there are a number of issues with standard operating procedures, management of change, hot work, mechanical integrity, etc., the compliance office should be looking deeper at how does ineffective training play a role in those identified deficiencies.
Conclusion: What to Know To Work Safely in a PSM-Covered Facility
We hope you found this interview with Brandi Davis of Oregon OSHA, offering a deeper look at the PSM regulations and offering suggestions of what managers, employees, contractors, visitors, and vendors should know. And of course we’d like to express sincere thanks to Ms. Davis for sharing her time, knowledge, experience, and expertise.
You might also find these other PSM-related articles interesting:
- Facing the Challenges of PSM, an Interview with ASSE’s Safety Educator of the Year
- What to Know about PSM, an(other) Interview with Brandi Davis of Oregon OSHA
- New OSHA PSM Compliance Guidelines for Small Businesses
You may also be interested in our online Process Safety Management (PSM) training video. We’ve included a short sample immediately below.
Finally, enjoy the free downloadable PSM compliance guide below.
Process Safety Management Compliance (PSM) Checklist
Here is a checklist to help your process safety management compliance.