My assumption is if you are reading this, you have some involvement in, or responsibility for, Process Safety Management (PSM) in your facility. OSHA’s Standard for Hazardous Materials, 29 CFR 1910.119, is a mere 21 pages long including 12 pages of “non-mandatory” appendices -- but should it be your responsibility, what a daunting task to implement! I remember Otter from the movie Animal House being quoted when everything looked so bleak - “Now we could do it with conventional weapons, but that would take years and cost millions of lives. No, I think we have to go all out. I think that this situation absolutely requires a really futile and stupid gesture to be done on somebody’s part!”
You could immediately start looking elsewhere for employment, focus on the daily emergencies that will always be there and hope your boss values crisis management more than you being a change agent. OR you could look at this as a unique opportunity to bring more safety, consistency and structure to your operations. The effort is difficult and makes others uncomfortable. You have some long days wondering whether it is all worth it (but I can assure you it is). However, you will sleep at night knowing you are improving vital processes that will protect lives and the company’s investment. I was lucky and blessed to have worked for the same multinational corporation for 37 years. Retirement now allows me to reflect on what was my most important contribution. Being part of the institutionalization of PSM ranks right at the top. It was an arduous road but seeing facilities “doing it right the first time and every time” reflects the core of PSM. You can feel that internal pride of watching an organization grow and become safer because of your efforts.
An assessment of where you are in relationship to the Standard is the first step. This assessment identifies your strengths and weaknesses. Next is a review with management to gain alignment on timing of each element to strengthen and the required resources. This might be management’s first realization regarding the full width and depth of a strong PSM program. Having participated as an auditor or an auditee in over 300 audits, the first element assessed is management. Are they committed? Are they supplying resources such as people and funding? Are they sharing their personal commitment? Are they setting completion timing goals and holding people accountable? Have they taken the time to become fully knowledgeable of the PSM requirements and, most importantly, “are they walking the walk”?
From my audit experience I have seen the complete spectrum of management commitment. I have seen managers who just could not be bothered. One manager in particular - after the week long audit - chose not to attend the final audit. I took it personally and walked into his office before flying out late on a Friday afternoon and demanded to know why he could not show any more value for PSM and his organization. The people working in that Gulf Coast facility were running an extremely highly hazardous and highly toxic facility. I had friends there, the community was close and the shareholders’ investment was at risk. He set me back on my heels by saying that he was confident in people like myself were going to “be the heavies” so he could focus on other more pressing business needs. That multi-million dollar facility with hundreds of employees has since been retired – it no longer exists. There are many reasons an asset is shutdown but having a weak commitment to safety can lead to terminal results.
At the other end of the spectrum, there are managers who attend and participate in every element of the audit and review each step during the process. These are caring and supportive leaders who value everyone’s efforts to find weaknesses…convinced that their organization could improve and make their facility safer. I was lucky to have heard college and pro coach Lou Holtz speak several times when I was young -- he is an incredible motivational speaker. At the end of his talks, if he had looked at me and told me to run through that brick wall, I would have done it. We are seldom fortunate enough to find leaders like that in the huge corporate bureaucracies but they are there. Sometimes you need to motivate the lesser ones to be better leaders. Your commitment to get a difficult task accomplished with enthusiasm (along with your knowledge of the subject) can be just what management needs. I once had an incredible boss who was truly a leader-servant and taught me to “lead up!”
Often it felt like I was on a personal mission to make businesses safer. In the facility where I worked prior to becoming a corporate consultant, we had an employee die from exposure to a highly toxic chemical. At that time, I no longer had been responsible for PSM but felt a commitment to alert management to signs of distress in the site program; but I did not. To this day I feel responsible for his death. To this day I am not sure what may have been. But maybe that alert could have saved his life -- and I would not lie in bed at night wondering what might have been.
PSM is doing it right the first time and every time. Management commitment is essential.
There are many elements of PSM other than management commitment. We will explore those elements in future posts as well as the steps following the initial assessment/review with management. Otter was wrong about it taking millions of lives but he was right that it may take years.
For more information on Becht's PSM services Click Here or you may post a comment at the bottom of this blog.
Contact Becht Process Safety Consulting
or Call Derek Becht at (908) 394-1248
Richard T. Lackey, Jr. is a Process Safety Management Specialist with Becht and has over 35 years experience as a mechanical engineer in the chemical industry -- much of it from his long-term career with DuPont. His experience includes mechanical integrity and quality assurance (MIQA), quality control, compliance auditing to industry codes and standards, and Process Safety Management (OSHA Standard 29CFR 1910.119; PSM) with respect to hose assembly, welding, fabrication, relief devices, pressure vessels, tanks, piping, valves, fasteners, gasketing, and boilers. Mr. Lackey has performed over 200 site assessments over his extensive career including all elements of OSHA 1910.119 Process Safety Management.
Mr. Lackey holds a Bachelor of Science degree in Mechanical Engineering from Clemson University, Clemson, South Carolina. He is a Registered Professional Engineer and a Registered Professional Land Surveyor in the State of West Virginia.
Amazing tips! It will help me to determine the boundaries of the equipment and processes that will be subject to the applicable regulations.
Click to View Becht’s Current Technical Training Public Course Calendar