Most of us, I’m sure, have seen OSHA statistics regarding the most cited elements of the PSM regulation. In the past 10 years, I have conducted well over 250 compliance audits and either led or participated in another 25 plus incident investigations. Based on that experience, I have come to realize that the OSHA data is not an accurate reflection of where the problems lie in process safety. As many of you may know, I spent five (5) years with OSHA as a PSM specialist. During that time, I experienced first-hand the strengths and weaknesses within the agency from a PSM perspective. One of the major weaknesses, in my opinion, is that many of the compliance officers that deal with PSM do not have a process safety, engineering, or process industry background. Without this background knowledge and experience, it is extremely difficult to understand and apply the PSM element’s intent to engineering design principals and then to process safety. Even when it comes to simple processes such as ammonia refrigeration, understanding key engineering concepts is important in applying process safety principals.

As a result of these weaknesses, most OSHA citations will reflect the knowledge that the compliance officer is comfortable with applying, and at the end of the day, defending it in court if necessary. In most cases, most of the citations issued today, are normally “low hanging fruit” items. That is not to say that there are not some compliance officers that understand process safety better than others, but generally speaking, a deep dive into process safety requirements falls short of what its really needed. Therefore, the OSHA PSM citation statistics are skewed to reflect these weaknesses in knowledge, and subsequently this has a direct effect on enforcement, and continuous improvement in process safety in all industries. OSHA data regarding injuries and fatalities in the process industry, has not really changed that significantly since the promulgation of the PSM regulation, even though the number of facilities that handle highly hazardous chemicals have decreased. Based on data we at PSS have compiled from our compliance audits and incident investigations, it is clear to us, that there is one area that can have significant effect on reducing process safety incidents and events. That area is to ensure that the safeguards identified in the PHA to mitigate identified potential hazards actually work as intended. Surprisingly, over 67% of all the safeguards that we have reviewed through audits and incident investigations lack sufficient process safety information, have not either been inspected or tested at all, or the testing was done in such a way as to not to be able to ascertain whether the device worked as intended or not. We have also found that when testing has been done and done correctly, over 37% of those devices failed on demand! Think about these statistics for a second, and let that sink in. That means that 67% of the devices/safeguards that were indicated to mitigate a credible hazardous scenario identified in the PHA, did not have the PSI or could be shown to work as intended! If this statistic alone does not concern you and I, then we are not interested in process safety, but rather in just in “checking a box”. Why would we expend the effort to identify potential process safety hazards in our process, and identify mitigating safeguards, yet not make sure the device works as it was intended or designed? It is a total waste of time and resources and gives us a false sense of process safety security. We need to do better as an industry and we can, if we focus on the things we already know and continue to apply our knowledge and experience in areas where we can have the greatest impact to process safety.