It is important to know, that the order of the PSM elements in the OSHA Process Safety Management Regulation is relevant. Understanding some reasoning for the order is important from an overall management system standpoint, but also in helping us to better understand PSM in general. Immediately following the scope, application, and definitions within the PSM regulation, is the first of the traditional fourteen (14) “elements” entitled “Employee Participation”. Before delving into this element, it is important to take a step back and see these first elements in the context of a safety and health management system (SHMS).

For those of us who have been involved in project design and installation within the process industry can more fully understand these first six elements and the design process in general. For example, most all process designs, no matter the type or size, go through similar design process steps. The first step, though not always apparent, is the need to have employees participate. The best process designs will always result from utilizing the best from the various skills sets involved including operations (operators), engineering, mechanics, and a host of others. Talk to any good engineer or project manager, they will tell you that the best teams produce the best results, and that those best teams always incorporate participation from many sources. This should make it obvious then that employee participation should NOT be a “passive” role, but rather an active one, meaning that it MUST be more than attending a meeting, as so many think it is, as indicated through many audits.

True, communication is an important part of a management system, but participation MUST go well beyond communication or a meeting. How many of us can remember what was said in detail from our last meeting, versus the detail from the last time we actually participated or took an active role or provided input during a meeting? As a PSM Compliance auditor and process safety engineer, I could care less about how many documents you show me on what meetings employees attended to fulfill the "Employee Participation" requirement. I can always ascertain knowledge through an interview and know who actually participates and who does not. Actual participation results are evident. Employees clearly exhibit process safety knowledge, knowledge of hazards, and how their role within the organizations helps to achieve a higher level of process safety. An employee who demonstrates this knowledge is absolutely what we want and need in our organizations and our industry!