(71r) A Simplified PSM Guidance for Smaller Facilities Using a Risk Based Approach

“Safety matters at all levels”, even for small companies that may not be OSHA’s PSM level facilities, as long as they use highly hazardous chemicals which may be toxic, reactive, flammable, or explosive. No matter how small a company is, if an incident happens, it may still have to deal with loss of life and property, OSHA/CSB investigations and possible fines and legal ramifications. Consequently, a PSM program (Process Safety Management) is important to develop a safety culture among plant personnel to have safer operating facilities free of incidents.  However, smaller facilities face major challenges in providing financing and resourcing to implement a standard PSM program. This paper presents a risk based approach towards a simplified PSM program that is not a drain on resources and is feasible to implement in practice. A combination of technical expertise with smaller plants and data from previous NEP citations (National Emphasis Program) is used as a basis to suggest a simplified PSM guidance by prioritizing specific elements.