Comparision of Process Safety Management System: CCPS Risk-Based & OSHA PSM

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All process safety management programs cover the same basic requirements, although the number of program elements may vary depending on the criteria used. Regardless which government, company or association source document is used as a guide, there are a number of basic requirements which should be included in every chemical process safety management program.

The Table below provides a comparison of two different PSM standards. The similarities and differences highlight both the common elements that define process safety and differences that underscore the challenges.

OSHA are regulatory, generally simple but mandatory. The requirements of CCPS are highly recommended, generally higher and open and unlimitation, the factory selects the level of enforcement in accordance with the situation. CCPS has the advantage that there are important elements that OSHA does not have, and the requirements are to open and allow to develop in future, whereas OSHA has the advantage that the requirements are relatively simple, very clear and easy to apply. At SEN we are applicable both of them.

 

CCPS Risk-based 20 PSM Elements

 

Entry	CCPS Risk-Based 20 PSM Elements	OSHA PSM Required 14 Elements	Definition and Description
1	Process safety cultute	Do not apply	Developing, sustaining, and enhancing the organization’s process safety culture is one of five elements in the Commit to Process Safety Pillar (Foundational Block). Process safety culture has been defined as, “the combination of group values and behaviors that determine the manner in which process safety is managed”1
2	Compliance with Standards	Process safety information (PSI)	Standards is a system to identify, develop, acquire, evaluate, disseminate, and provide access to applicable standards, codes, regulations, and laws that affect process safety. The standards system addresses both internal and external standards; national and international codes and standards; and local, state, and federal regulations and laws. The system makes this information easily and quickly accessible to potential users. The standards system interacts in some fashion with every RBPS management system element. Knowledge of and conformance to standards helps a company (1) operate and maintain a safe facility, (2) consistently implement process safety practices, and (3) minimize legal liability. The standards system also forms the basis for the standards of Responsible Care used in an audit program to determine management system conformance.
3	Process safety competency	Do not apply	Developing and maintaining process safety competency encompasses three interrelated actions: Ccontinuouslyy improving knowledge and competency Ensuring that appropriate information is available to people who need it Consistently applying what has been learned.
4	Workforce involvement	Employee participation	Workforce involvement provides a system for enabling the active participation of company and contractor workers in the design, development, implementation, and continuous improvement of the RBPS management system.
5	Stakeholder Outreach	Do not apply	Stakeholder outreach is a process for (1) seeking out individuals or organizations that can be or believe they can be affected by company operations and engaging them in a dialogue about process safety, (2) establishing a relationship with community organizations, other companies and professional groups, and local, state, and federal authorities, and (3) providing accurate information about the company and facility’s products, processes, plans, hazards, and risks.
6	Process knowledge management	Process safety information (PSI)	The knowledge element primarily focuses on information that can easily be recorded in documents, such as (1) written technical documents and specifications, (2) engineering drawings and calculations, (3) specifications for design, fabrication, and installation of process equipment, and (4) other written documents such as material safety data sheets (MSDSs). The term process knowledge will be used to refer to this collection of information.
7	Hazard Identification & Risk Analysis	Process hazard analysis	Hazard Identification and Risk Analysis (HIRA) is a collective term that encompasses all activities involved in identifying hazards and evaluating risk at facilities, throughout their life cycle, to make certain that risks to employees, the public, and/or the environment are consistently controlled within the organization’s risk tolerance. These studies typically address three main risk questions to a level of detail commensurate with analysis objectives, life cycle stage, available information, and resources. The three main risk questions are: Hazard – What can go wrong? Consequences – How bad could it be? Likelihood – How often might it happen?
8	Operating Procedures	Operating Procedures	The RBPS element that ensures proper development, timely maintenance, and consistent use of operating procedures (procedures)
9	Safe Work Practices	Operating Procedures Hot work permit	safe work practices helps control hazards associated with maintenance and other non-routine work
10	Asset Integrity & Reliability	Mechanical Integrity	Asset integrity, the RBPS element that helps ensure that equipment is properly designed, installed in accordance with specifications, and remains fit for use until it is retired
11	Contractor management	Contractors	Contractor management is a system of controls to ensure that contracted services support both safe facility operations and the company’s process safety and personal safety performance goals. This element addresses the selection, acquisition, use, and monitoring of such contracted services.
12	Training & Performance Assurance	Training	Training is practical instruction in job and task requirements and methods. It may be provided in a classroom or workplace, and its objective is to enable workers to meet some minimum initial performance standards, to maintain their proficiency, or to qualify them for promotion to a more demanding position. Performance assurance is the means by which workers demonstrate that they have understood the training and can apply it in practical situations. Performance assurance is an ongoing process to ensure that workers meet performance standards and to identify where additional training is required.
13	Management of Change	Management of Change (MOC)	The MOC element helps ensure that changes to a process do not inadvertently introduce new hazards or unknowingly increase risk of existing hazards. The MOC element includes a review and authorization process for evaluating proposed adjustments to facility design, operations, organization, or activities prior to implementation to make certain that no unforeseen new hazards are introduced and that the risk of existing hazards to employees, the public, and/or the environment is not unknowingly increased. It also includes steps to help ensure that potentially affected personnel are notified of the change and that pertinent documents, such as procedures, process safety knowledge, and other key information, are kept up–to-date.
14	Operational Readiness	Pre-Startup Safety review	Ensuring the safe startup of processes over the life of a facility
15	Conduct of Operations	Do not apply	Conduct of operations (operations) is the execution of operational and management tasks in a deliberate and structured manner. It is also sometimes called “operational discipline” or “formality of operations”, and it is closely tied to an organization’s culture. Conduct of operations institutionalizes the pursuit of excellence in the performance of every task and minimizes variations in performance. Workers at every level are expected to perform their duties with alertness, due thought, full knowledge, sound judgment, and a proper sense of pride and accountability.
16	Emergency Management	Emergency Planing and Response	Emergency management includes: (1) planning for possible emergencies, (2) providing resources to execute the plan, (3) practicing and continuously improving the plan, (4) training or informing employees, contractors, neighbors, and local authorities on what to do, how they will be notified, and how to report an emergency, and (5) effectively communicating with stakeholders in the event an incident does occur.
17	Incident Investigation	Incident Investigation	Incident investigation is a process for reporting, tracking, and investigating incidents that includes: (1) a formal process for investigating incidents, including staffing, performing, documenting, and tracking investigations of process safety incidents and (2) the trending of incident and incident investigation data to identify recurring incidents. This process also manages the resolution and documentation of recommendations generated by the investigations.
18	Measurements and Metrics	Do not apply	The metrics element establishes performance and efficiency indicators to monitor the near-real-time effectiveness of the RBPS management system and its constituent elements and work activities
19	Auditing	Compliance Audits	The audits element is intended to evaluate whether management systems are performing as intended. It complements other RBPS control and monitoring activities in elements such as management review, metrics, and inspection work activities that are part of the asset integrity and conduct of operations elements.
20	Management Review and Continuous Improvement	Do not apply	Management review is the routine evaluation of whether management systems are performing as intended and producing the desired results as efficiently as possible. It is the ongoing “due diligence” review by management that fills the gap between day-to-day work activities and periodic formal audits. Management review is similar to a doctor giving a routine physical examination – even when no overt signs of illness are present, life-threatening conditions may be developing that are best addressed proactively. Management reviews have many of the characteristics of a 1st party audit as described previously. They require a similar system for scheduling, staffing, and effectively evaluating all RBPS elements, and a system should be in place for implementing any resulting plans for improvement or corrective action and verifying their effectiveness.
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