PSM Program Development and Implementation
Following a strategy that has been successful with other clients, ABS Group recommends a three-phase approach to support clients as they develop and implement PSM/RMP systems at their facilities. The following sections describe our general approach to these phases.
Phase 1: Conduct PSM/RMP Gap Assessment
Our engineers will team with your personnel to conduct a PSM gap assessment at your facility. During a site visit, our engineers will:
- Interview your personnel
- Review existing management systems to determine what policies, procedures and information sources are available to help satisfy the OSHA PSM regulation and/or the EPA RMP rule
- Develop specific recommendations for improving the facility's PSM programs
Our activities and consulting will address PSM/RMP coverage issues and all of the elements required by the PSM and accident prevention requirements of the two regulations. During the visit, our PSM/RMP specialists will work with your personnel to outline the steps that your plant should take to improve PSM/RMP activities at the facility. If a PSM/RMP program exists at your facility, we will help ensure its effectiveness and that it covers all of the requirements of the regulations. Our engineers will guide the discussions and contribute ideas based on extensive experience at other facilities.
ABS Group's expertise in process safety and risk management should help your staff select an efficient and effective PSM improvement and maintenance strategy based on your available resources.
Our engineers will document the assessment and implementation plan in a report that will:
- Summarize the OSHA PSM and EPA accident prevention requirements
- Identify specific policy/procedure improvements needed
- Present our recommendations for the most effective way to provide the required improvements
The decision on how to proceed with PSM development and improvement activities is retained by the client, based on available facility and corporate resources.
Phase 2: Develop/Improve Selected PSM/RMP Programs
As a second phase, ABS Group will proceed to develop and/or improve specific PSM programs for the facility. The product of this effort will be draft programs for the selected PSM/RMP elements that also define roles and responsibilities for each PSM/RMP element. In developing or improving these programs, we will take full advantage of any existing programs, OSHA and EPA guidance, and industry standards and practices to develop cost-effective programs for your facility.
In our PSM/RMP development experience, we have found it very important to confirm that new (or extensively revised) PSM/RMP programs are consistent with the existing culture of the facility, and we strive to understand your specific organization's needs to develop such programs. Finally, a thorough review by your personnel of the new PSM/RMP programs can provide assurance that the programs meet that objective.
Phase 3: Execute/Implement Specific PSM Activities
We can provide process safety engineers and specialists to help your organization execute the steps outlined in your facility PSM programs. The level of assistance will depend on the specific tasks that are needed and the availability of qualified personnel in your company to perform these tasks.
We may be particularly helpful to facilities by leading and documenting PHAs/revalidations, developing management of change/pre-startup safety review programs, reviewing operating procedures, establishing mechanical integrity programs, conducting incident investigations, leading compliance audits, developing RMPlans for submittal to EPA and training your personnel to perform such activities.