(32a) Implementing PSM: Perspective from a Process Engineer Turned PSM Attorney

Perspective from a Process Engineer turned PSM Attorney

OSHA’s PSM Standard was rolled out in 1992.  One year later I started my career as a Process Engineer in the Petrochemical Industry.  As any Process Engineer will tell you, PSM is a large part of your daily responsibilities when working in a production unit.  During my time as a Process Engineer, I developed process safety information, participated in numerous PHAs, wrote operating procedures, trained operations personnel on new equipment and new product lines, completed MOCs, conducted PSSRs, served on incident investigation teams and assisted with compliance audits.  Now as an attorney, I counsel industry on defending PSM citations, resolving facility siting issues, and addressing RAGAGEP questions (just to name a few).

Attendees will learn the distinction between how engineers view the elements of PSM, how attorneys view them, and how OSHA goes about enforcing them.  With these insights, attendees will return to their sites better equipped to minimize the risk of falling out of compliance with the PSM Standard.