OSHA PSM NEP Inspection Results and Refinery PSM System Upgrade

PSM Upgrade in Response to PSM NEP

Implementing a Process Safety Management
System Upgrade in Response to an OSHA
Refinery PSM NEP Inspection

A Practical Approach that Supports Operational
Excellence
Principal Author: Robert Walter
Co-Author: Richard Foottit
Company: AntiEntropics, Incorporated
P.O. Box 692
New Market, MD 21774
rjwalter@antientropics.com

Co-Author: Brian Nelson
Company: Suncor Energy USA
Commerce City Refinery
5801 Brighton Blvd.
Commerce City, CO 80022
bnelson@suncor.com

Prepared for Presentation at
American Institute of Chemical Engineers
2009 Spring National Meeting
43rd Annual Loss Prevention Symposium
Tampa, FL

April 27-30, 2009

© AntiEntropics, Inc. 2009

AIChE shall not be responsible for statements or opinions contained in papers or printed in its publications.

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Abstract
This paper presents a brief analysis of the Occupational Safety and Health Administration (OSHA) Petroleum
Refinery Process Safety Management National Emphasis Program (NEP) citation results as of early 2009. It
includes trends and data convergences distilled from the OSHA inspections performed to date.
Recommendations for preparing for PSM NEP level inspections are provided as well since preparation is often
essential to an efficient inspection and helpful to a thorough abatement effort.

A proven approach to designing and implementing an upgrade project for OSHA process safety management
systems and EPA risk management program – program 3/prevention programs is described. The model
presented can be targeted to a facility’s NEP specific citations or used for a general PSM system effectiveness
upgrade.

One key aspect of implementing an effective process safety management system is a need for a corporate and
facility culture that supports operational discipline that leads to operational excellence in all four of the
industry’s primary sustainability drivers: safety (both personnel and process), environmental responsibility,
product quality, and long term economic success.

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Contents
1. What have we learned about refinery process safety performance? ................................................................... 4
1.1 – What does the current data show? ............................................................................................................. 4
2. How can we prepare for an efficient refinery PSM NEP Inspection? ................................................................ 9
2.1 Self Analysis Against the Directive .............................................................................................................. 9
2.2 Prepare your management, technical staff, and hourly employees for the audit ........................................ 10
2.3 Additional resources to consider ................................................................................................................. 11
2.4 Tools to assist in an efficient inspection ..................................................................................................... 11
3. Upgrading a Refinery PSM System after a PSM NEP Audit ........................................................................... 15
3.1 Citation Abatement ..................................................................................................................................... 15
3.2 Designing and Implementing a PSM Upgrade in Response to the Inspection ........................................... 16
3.3 Employee Participation Upgrade ................................................................................................................ 17
3.4 Process Safety Information Upgrade .......................................................................................................... 18
3.5 Process Hazard Analysis Upgrade .............................................................................................................. 20
3.6 Operating Procedures Upgrade ................................................................................................................... 21
3.7 Training Upgrade ........................................................................................................................................ 22
3.8 Contractors Upgrade ................................................................................................................................... 23
3.9 Pre-startup Safety Review Recommendation ............................................................................................. 24
3.10 Mechanical Integrity Upgrade .................................................................................................................. 24
3.11 Hot Work Permit Upgrade ........................................................................................................................ 26
3.12 Management of Change Upgrade ............................................................................................................. 27
3.13 Incident Investigation Upgrade ................................................................................................................. 28
3.14 Emergency Planning and Response Program ........................................................................................... 29
3.15 Compliance Audits Upgrade ..................................................................................................................... 29
3.16 Trade Secrets............................................................................................................................................. 30
3.17 Planning a PSM Implementation Upgrade Project ................................................................................... 30
3.18 ORGANIZATIONAL CULTURE: A Necessary Commitment to Operational Discipline ..................... 33
4. Conclusion ........................................................................................................................................................ 35

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1. What have we learned about refinery process safety performance?
Human beings, who are almost unique in having the ability to learn from the experience of others, are also
remarkable for their apparent disinclination to do so.
Douglas Adams

Directive CPL 03-00-004 - Petroleum Refinery Process Safety Management (PSM) National Emphasis
Program was born in the aftermath of an escalating number of fatal or catastrophic refinery incidents. The BP
Texas City refinery accident of 2005 served to focus both government and public attention to the issue of
refinery incidents involving fatalities or catastrophic loss or potential for such loss.

It appears that after almost 20 years since its promulgation, many refineries have still not fully implemented the
programs required to support the philosophy behind 29 CFR 1910.119, Process Safety Management of Highly
Hazardous Chemicals. OSHA as an organization accepted some of the responsibility for the apparent state of
affairs regarding industry’s implementation of its own process safety management regulation. The agency had
simply not focused enough on enforcing the process safety management standard. Whatever the reasons may
have been for the lack of focus by industry or government on this important rule; governmental reductions in
force, an economy that grew dramatically and shrank just as dramatically during that period, the burden of
existing personnel safety issues, the performance based nature of the PSM standard, it seemed the refining
industry was proving that closer OSHA oversight was a necessary piece of the equation.

The agency brought its national emphasis program tool to bear on this situation in order to detail…policies and
procedures for implementing a National Emphasis Program (NEP) to reduce or eliminate the workplace
hazards associated with the catastrophic release of highly hazardous chemicals at petroleum refineries. With
this tool, OSHA inspectors could better analyze a company’s performance based approach to PSM and refiners
gained an immediate re-education on critical aspects of a high quality process safety management system. The
directive’s appendix A - Static List of Inspection Priority Items (questions that will be asked of every refinery)
and X.E. 3. - Documentation to be Requested - General and Process Related sections helped refiners understand
the depth to which the OSHA inspection teams would be delving. The directive focuses on actual
implementation of a refinery’s process safety system, not its mere existence.

In the nearly two years since the petroleum refinery PSM NEP was announced and initiated, both OSHA and
the refining industry have learned much about where the major issues may lie regarding PSM implementation
and new ways organizations can implement this performance based standard. It should be added that the
Environmental Protection Agency’s (EPA) 40 CFR Part 68, Risk Management Programs for Chemical
Accidental Release Prevention, which contains PSM’s sister rule – Subpart D, Program 3 Prevention Program
essentially mirrors the requirements of the process safety management standard and applies to almost all the
refineries affected by the PSM NEP. With this being the case, the learning experienced from the OSHA
Refinery PSM NEP can be applied in some fashion to any site covered by either rule – whether the learner is a
government inspector, a refinery manager, or an industry process safety resource.

1.1 – What does the current data show?

By using the informative OSHA web-based database Integrated Management Information System (IMIS), a user
can search for information about how the national emphasis program is proceeding and where the inspectors are
finding issues. By following this information since the PSM NEP’s inception, it is also possible to identify

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probable trends and changes in how the inspections are being carried out. As an aside, the website helps with
determining such information as:

 Frequently Cited OSHA Standards
 Industry Profile for an OSHA Standard
 General Duty Standard Search

Another interesting statistic is that as of this writing, ~ 670 citations have been issued and ~480 are PSM
related. This means that ~ 28% of the citations are non-PSM related. This is critical information that can be
effectively worked on during the wait time for a site’s inspection to commence. Proactive safety improvement
during this period can reduce the number of total citations resulting from the inspection.

1.1.1 – Citations per PSM Element

Of the 14 elements of process safety, paragraph (p) trade secrets has had no citations issued to date. The chart
below shows the current citations per element for approximately 30 refineries for which we have data:

Figure 1.1 – NEP Inspection Citations by PSM Element

Four elements stand out as attracting the most citations. The top four elements in regard to total citations are:

1. Operating Procedures – 90 citations
2. Mechanical Integrity – 88 citations
3. Process Hazard Analysis – 83 citations
4. Process Safety Information – 70 citations

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These four elements provide a large target for any auditor or inspector due to the documentation needs inherent
to each. One oddity noticed is that management of change, an element also having great documentation
requirements and arguably the heart of an effective process safety management system, was not cited more
often. To any process safety professional, it is apparent that for almost every citation in the top four elements:
operating procedures, mechanical integrity, process hazard analysis, or process safety information, there might
be a matching management of change failure indicated.

1.1.2 – Total Citation Cost by PSM Element

Since the refining industry is focused on costs and benefits, as is any business, it is interesting to note the total
citation costs per element. The chart below provides this data.

Figure 1.2 – NEP Citation Total Cost per Element

The same top four elements are notably receiving the greatest total amount in citation costs; however, the order
has changed.

1. Mechanical Integrity – $695K
2. Process Hazard Analysis – $547K
3. Process Safety Information – $365K
4. Operating Procedures – $347K

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1.1.3 – Average Citation Cost by PSM Element

The fact that the order of the top four elements changed concerning number of citations and distribution of total
citation costs directs attention to the average citation cost per PSM element to see whether some elements are
receiving higher ranges of penalty costs. The following chart provides this data.

U.S. Department of Labor - Occupational Safety and Health
Administration
NEP Inspection Citations - Average Cost/Citation
Last Updated: 12/18/2008
9,000

8,000

7,000

6,000

5,000

4,000

3,000

2,000

1,000

0
Com
Hot Inc.
EP PSI PHA OP Trn. Cont. PSSR MI MOC EP&R p.
Work Inv.
Audit
Dollars 2,502 5,218 6,588 3,860 2,175 3,077 4,500 7,896 3,375 3,845 3,730 5,556 2,899

Figure 1.3 – Average NEP Citation Cost by Element

Notably, operating procedures drops from the top four elements in terms of average cost per citation and
emergency planning and response takes the third highest average position.

1. Mechanical Integrity – $7.8K per citation
2. Process Hazard Analysis – $6.6K per citation
3. Emergency Planning and Response – $5.5K per citation
4. Process Safety Information – $5.2K per citation

If average cost per citation is related to the OSHA inspection teams’ view of element criticality to worker
safety, this data shows the relative weight of an element in general combined with the seriousness of the
violations cited.

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1.1.4 – What can we derive from this analysis?

One refinery undergoing a PSM NEP inspection revisited all of its past compliance audits to compare against
the OSHA inspections by industry data. They found that the top four elements in regard to OSHA’s citations
matched the top four elements in terms of self-assessed numbers of findings over the past 6 years in compliance
audits. The order of their self analysis for audit findings was:

1. Mechanical Integrity
2. Process Safety Information
3. Operating Procedures
4. Process Hazard Analysis

And, as their NEP document requests showed during the inspection, these same four top elements were
simultaneously getting the most scrutiny from the regional inspectors performing the site inspection. One
conclusion could be that even knowing the elements that present opportunities for improvement in PSM does
not make it easier to implement a bulletproof system. The top elements being cited by OSHA in the refinery
PSM NEP effort present managerial, resource, and logistical issues that are not easily resolved.

If an organization has undergone past OSHA audits, they also know that the citation cost can be quite
misleading. A relatively small OSHA penalty can have real abatement costs serveral times the amount of the
OSHA fine.

Two things were also noted when standing back and observing the citation data build. The early NEP
inspections varied widely in the number of citations and the penatilites assessed. Later citations, those occuring
after July 2008, seem to match better in terms of target elements, citation numbers, and citation costs. This
could indicate organizational learning on behalf of the OSHA inspection teams.

Additional wording not seen in the early citations appeared. A typical notification of penalty adheres to a very
specific set of issues/finding and abatement requirements are most often very specific to the citation. Remember
that the OSHA team will normally look at just a couple of selected units in a given refinery. For example, if a
penalty is received specific to 4 randomly selected procedures that fulfill part of the operating procedure
element for a selected unit, abatement would be to correct those four procedures to abate the citation with no
additional company requirements. Through networking and the freedom of information act (FOIA), companies
began sharing the actual citations to enhance each other’s NEP preplanning, inspection support, and abatement
activities. In the fall of 2008 the following phrase (and variations of it) began to be included in some citation
details:

This may be a system-wide occurrence that requires evaluation of process equipment throughout the facility.

This phrase and its variations imply a new look at the proper way to abate an OSHA citation. Discussions are
ongoing among PSM managers and legal support staffs to analyze the impact.

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2. How can we prepare for an efficient refinery PSM NEP Inspection?
Before everything else, getting ready is the secret to success
Henry Ford

What are some of the things a refinery can do to prepare for an NEP inspection? An NEP inspection will
probably be the most rigorous PSM audit a site ever undergoes. This section provides recommendations to
consider and examples where appropriate. The general recommendations for preparation are straightforward:

 Perform a self analysis of those PSM NEP directive aspects of your process safety management system
that can be pre-considered.
o until the OSHA team selects the unit(s), specific actions are limited for many static questions and
document requests
o identify the best human resources for each question and document request type. This is a useful
preparation exercise as it prepares personnel for their roles in the OSHA team’s inspection.
 Prepare your management, technical staff, and hourly employees for the audit
o Educate them on an overview of the PSM NEP directive
o Educate them on their rights as workers in regard to an OSHA inspection
o Prepare key people on their roles in the onboarding and opening conference activities
o Select and train your NEP response team
 PSM group
 Escorts
 Security
o Predetermine how you will efficiently support and escort the OSHA inspectors when they are on
site
 Safety orientation
 Interviews
 Analyze the need for additional paralegal assistance and specific equipment to support the inspection
and the refinery’s legal needs (for example, bates stamping, high speed copying, high speed scanning)
 Provide a suitable workspace for the OSHA inspection team
 Create documents and tools that can assist in helping the OSHA inspectors and your organization track
and respond to the team’s requests
o Document request and transmittal form
o Document request and transmittal log
o Escort Logs
 Create a method for tracking each document request as it is provided by the OSHA inspectors
o Consider tracking the document request item, due date, responsible person, date copied for the
company files, date delivered to OSHA, and special notes

2.1 Self Analysis Against the Directive

Performing a self analysis of a site’s anticipated strengths and weaknesses against the static questions and the
documents request list is a good exercise.

A table can be prepared using the directive contents. Consider tracking:

 The question or document request
 The responsible person(s)
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 Internal hardcopy or software references and resources available for each item (for example, PSM
administrative procedures, safe work practices, MOC/PSSR tracking records, inspection data, piping
data)
 A yes, no, or not applicable column to identify things that are obviously ready, need work, or may not
apply (for example, none of the blowdown questions apply if the site has no blowdowns in accordance
with the OSHA definition.
 A text field for your self analysis of the status and issues related to responding to the inspection question
or document request

Update this report regularly during the waiting period before the unannounced inspection. Again, some items
cannot be fully prepared for until the OSHA team selects the unit(s) in accordance with the directive.

2.2 Prepare your management, technical staff, and hourly employees for the audit

Most refinery personnel are quite busy with day to day work requirements and may not pay attention to the
industry regulatory climate unless they work in the PSM, safety, or environmental groups. Consider a brief
training/discussion session to educate them on an overview of the PSM NEP directive. One refinery used the
following training objectives in their sessions. The entire refinery staff received a mandatory training session
where they reviewed these topics:

 Upon completion of this session, participants should be able to:
o Describe the OSHA Petroleum Refinery Process Safety NEP program.
o Describe an individual’s rights during an inspection, including rights during an interview.
o Identify the types of questions from the NEP directive that may be asked during an interview.
o State how and why we control inspection documents.
o Prepare to assist the OSHA NEP inspection team if asked

Preparing key people on their roles in the onboarding and opening conference activities will make the arrival of
an OSHA team more controlled and less impactful on day to day refinery operations (OSHA states in the
directive that the inspection should not disturb operation of the refinery). Some things to consider:

 Prepare site security staff for their role in OSHA’s arrival.
o The notifications to make
o Where to have the inspectors assemble while awaiting their escort
 Plan the level of training to be provided for the OSHA team’s entrance to the site
o Visitor level?
o Contractor level?
 Prepare your escorts for their roles. Emphasize that their visitor’s safety is the primary goal.
 Prepare the escorts to document (use an escort log) to note informal OSHA team questions and areas of
interest during the inspection. This will help the refinery staff understand the direction the audit is taking
and when specific elements are being analyzed.
 Prepare the selected site management and staff for the opening conference. The requirements are:
o To verify that the establishment's SIC/ (NAICS) code is 2911/ (32411) to confirm that the
workplace is a refinery within the scope of the instruction.
o Present the OSHA team with a review of emergency response procedures and emergency alarms.
o Prepare to provide them with an overview of the processes/units at the refinery, including block
flow and/or process flow diagrams indicating chemicals and processes involved.

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o Prepare to describe catastrophic release scenarios that might occur, what those results could be
(worst case scenarios), and what controls are in place to prevent them from happening.

One suggestion that is obvious but difficult due to human nature is – help management (refinery/corporate) to
truly see the OSHA inspection as a positive learning opportunity. An efficient, accurate OSHA inspection can
provide direction to upgrading a refinery’s PSM program into one that supports sustainability. Long term
maintenance of a rigorous refinery PSM system will prove its business case in terms of:

 Corporate Responsibility
 Business Flexibility
 Risk Reduction
 Sustained Value

An effective PSM system upgrade resulting from the inspection can actually increase a refienery’s reliability
and ability to sustain long term success.

2.3 Additional resources to consider

To ensure that the company and its legal staff have access to the same materials provided to OSHA in hard
copy, analyze the need for additional paralegal assistance and specific equipment to support the inspection and
the refinery’s legal needs. Thousands of pages of documents are often transferred to OSHA in response to the
PSM NEP inspection. Tracking each document and keeping a copy requires both preparation and logistical
support.

It may benefit the escorts and PSM staff to ensure special radios, safety equipment, and headsets for use out in
the units are available and that transportation is arranged for larger refineries. Preplan where the formal
interviews may take place and the impact on worker scheduling and refinery staffing needs.

Prepare the OSHA inspection team’s on-site work area. Consider the equipment that will be needed to handle
the to sheer volume of documents collected. Preplanning may reduce the time period that the inspectors will be
on-site.

2.4 Tools to assist in an efficient inspection

Creating tools to help the OSHA inspectors and your organization track and respond to the requests is another
item to consider

o Document request and transmittal form
o Document request and transmittal log
o Escort logs
o A tool for tracking each document request as it is provided by the OSHA inspectors and logging
the refinery’s responses

Some examples of such tools that one refinery developed in advance of their inspection are provided in the
following pages. Customize these as needed to be more formal or less formal to meet site needs.

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Figure 2.1 – Example Document Request and Transmittal Form Page 1

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Figure 2.2 –Example Document Request and Transmittal Form Page 2

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Figure 2.3 – Example Escort Log

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AEI NEP SUPPORT TEAM – Inspection Status Update - Document Requests 94 of 103 items prepared as of 10/6/08 (91%)
Revision 12 92 of 103 items transmitted to OSHA (89%)

OSHA Item Item Description – verbatim Due Primary Support Status Date to Date to Notes:
Reference no. Date Contact Contacts Legal OSHA
and Date [References]

List 0 Letter 1 A list of all PSM (29 CFR 1910.119) 9/10/08 J. Doe J. Smith Finished 9/10/08 9/10/08
9/8/08 covered process units with the date that
the unit was put in service and the
number of employees assigned to each
unit per shift.

[REF: X.E.3.b./m.]

Figure 2.4 – Example Inspection Status Update Table

3. Upgrading a Refinery PSM System after a PSM NEP Audit
It is not the strongest of the species that survive, nor the most intelligent,
but the ones most responsive to change.
Charles Darwin

The OSHA inspectors have finished with their document requests and personnel interviews. The team has left
their onsite workspace and demobilized. The closing conference has been held. The citations have been
finalized and delivered to the refinery manager. Any citation contest activity in accordance with OSHA protocol
has been completed. The refinery staff has almost recovered from a newly discovered medical condition PSM
NEP fatigue. Now the response begins.

Of course, the specific citation abatement efforts take first priority in the PSM NEP response activities.
However, forward thinking companies can use the experience of this surgical and in depth analysis of one or
more units at their refinery to uncover the opportunity to embark on a PSM system upgrade effort across the
entire facility as warranted. If the PSM group was successful in helping site and corporate management
understand the business case for a high quality PSM program, these opportunities are more likely to be taken.

3.1 Citation Abatement

If the refinery has prepared for the audit to some degree, provided the requested information to the best of their
ability, and has maintained a good relationship and open communications with the regional inspection team, the
OSHA inspectors can actually assist in clarification of the citations and discuss methods for closing the citations
in a timely manner as abatement progresses.

The example Gantt chart can only show an estimated period for abating the average of 15 citations seen in
inspections completed to date. The period allowed for abatement is often only one to two months – the time
from the issuance date to the date by which the violation must be abated – and the issuance date is typically the
same for all of the citations received. This situation could cause the refinery staff to have a relapse of PSM NEP
fatigue. Working closely with refinery legal staff may assist in negotiating additional time to abate citations that
are more complex.

However, this paper is about more than satisfying OSHA’s specific PSM NEP citation abatement needs.
Consider that the minimum effort. Remember that the PSM regulation may not even have existed if refineries
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and chemical plants had been following a similar philosophy in designing, building, and operating their
facilities over the past 50 plus years. The basic tenets of PSM are rooted in basic good engineering and
management practices.

A given refinery’s citations will be unique to it, although the industry inspection data provided above can point
to likely elements for which to prepare. Your pre-inspection self-analysis is helpful with this as well as the
tracking of the specific document requests that were logged and fulfilled.

One refinery identified the areas that received the most interest by the NEP inspectors during the on-site phase
along with the non-PSM personnel safety issues that were raised during the onsite inspection period. With these
identified, they were able to begin addressing issues that may likely appear in the final citations in advance of
their receipt. This displays to the regional office that the company is proactive concerning worker safety (and
creates extra time later to work on the more complex citation abatement activities).

3.2 Designing and Implementing a PSM Upgrade in Response to the Inspection

Upon satisfying the citation abatement requirements, a refinery has the opportunity to apply their learning from
the OSHA selected units across all the other refinery units for items like operating procedures and training and
to site-wide PSM systems such as management of change, pre-startup safety review, mechanical integrity, and
contractors.

Whether a facility is waiting for the inspection to begin, or they have already received the final citations, they
should begin looking at three aspects of their PSM program at a high level for upgrade opportunities.

 Administrative procedures – that describe the high level programmatic approach to compliance
 Work procedures – as indicated by a specific element’s needs (for example operating procedures,
maintenance procedures, safe work practices, emergency response procedures
 Documentation – the evidence that the administrative and work procedures are being used.

The wait time in advance of the PSM NEP inspection can be used to start upgrade of your PSM program. As the
inspection start is unannounced, it is not necessary to rush any changes to the more complex elements. Be
prepared for the OSHA team to arrive any day. However, diligently begin the self-analysis against the directive
to forestall surprises during the inspection. One refinery uses the following documents to capture the
methodology management has adopted to help comply with PSM and the EPA risk management program.

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If developing any of these administrative procedures, be sure to verify that you can do what you say you will
do. Avoid describing compliance methods going beyond the PSM requirements if you do not have the culture
and resources in place to apply that method thoroughly.

Document Number / Document Title
PSM-RMP-01 - PSM/RMP Compliance Manual Descriptions
PSM-RMP-02 - Employee Participation
PSM-RMP-03 - Process Safety Information
PSM-RMP-04 - Process Hazard Analysis
PSM-RMP-05 - PSM/RMP Procedure Program
PSM-RMP-06 - PSM/RMP Training Program
PSM-RMP-07 - Contractors
PSM-RMP-08 - Pre-Startup Safety Review
PSM-RMP-09 - Mechanical Integrity
PSM-RMP-10 - Hot Work Permit
PSM-RMP-11 - Management Of Change
PSM-RMP-12 - Incident Investigation
PSM-RMP-13 - Emergency Planning And Response
PSM-RMP-14 - Compliance Audits
PSM-RMP-15 - Trade Secrets
PSM-RMP-16 - RMP Management System
PSM-RMP-17 - RMP Executive Summary
PSM-RMP-18 - Risk-Based Process Safety Guidelines

Table 3.1 – Example PSM/RMP Administrative procedures

The best approach is to involve a representative from any group - and anyone with a specific title - called out in
the administrative procedure as having responsibilities or accountabilities in your program in a brief meeting to
compare procedure against practice. Make changes to reflect reality (and compliance) then send the resulting
document or revised document to more players in that element’s execution for their input prior to an approval
phase review by the owner. The owner of these administrative procedures is typically the facility manager,
although the PSM manager is often chartered with maintaining the PSM administrative procedures.

We examine some recommendations for each of the 14 elements of PSM in the following sections.

3.3 Employee Participation Upgrade
Verify that you have formally documented an employee participation plan that applies across the entire
complex. In this document, state how each of the other PSM/RMP compliance plan documents describes
opportunities for hourly and salaried employee participation. Reference those documents here as they provide
more detailed workflows that may call out employee participation opportunities in detail. Some basic items to
ensure are covered include:

 Does the facility’s written employee participation plan-of-action include information on how employees
will be consulted on how often operator refresher training is needed?

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 Has the facility implemented its plan-of-action to consult the employees about the operator refresher
training frequency?
 Can the facility demonstrate how they consulted employees to develop the PSM program?

Currently there have been 14 citations within this element. See the table below

Employee Participation Specific Citations No. of Citations
Employers shall develop a written plan of action regarding the implementation of the 9
employee participation required by this paragraph.
Employers shall consult with employees and their representatives on the conduct and 1
development of process hazards analyses and on the development of the other
elements of process safety management in this standard.
Employers shall provide to employees and their representatives access to process 3
hazard analyses and to all other information required to be developed under this
standard.

Table 3.2 – Employee Participation Citations

3.4 Process Safety Information Upgrade
This element is in the top four elements cited and in terms of cost. Process safety information is detail intensive
and documentation intensive. Although the standard essentially requires 100% accuracy, the reality is that
process and instrumentation drawings (P&IDs) and other PSI requirements may lag behind reality for many
reasons. Continue with any ongoing process safety information (PSI) upgrade efforts if already underway
during the waiting period. Focus on specific citations later.

If you receive process hazard analysis (PHA) citations, remember that a PHA redo cannot be started until the
PSI is accurate. Schedule any upgrade or development efforts to precede the next PHA revalidation scheduled
for each production unit. This will improve the quality of the PHA efforts and can help them be performed more
efficiently.

Use the updated process safety information to verify calculations threshold quantities for RMP compliance
purposes if indicated. Use Process and Instrumentation Drawings (P&IDs) rather than Process Flow Diagrams
(PFDs) for these calculations to help ensure all piping and vessels are evaluated.

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The table below shows that P&IDs, relief systems, and documentation of recognized and generally accepted
good engineering practices (RAGAGEP) have been vulnerable in inspections to date.

PSI Specific Citations No. of Citations
Process safety information. In accordance with the schedule set forth in 1
paragraph (e)(1) of this section, the employer shall complete a compilation of
written process safety information before conducting any process hazard analysis
required by the standard. The compilation of written process safety information is
to enable the employer and the employees involved in operating the process to
identify and understand the hazards posed by those processes involving highly
hazardous chemicals. This process safety information shall include information
pertaining to the hazards of the highly hazardous chemicals used or produced by
the process, information pertaining to the technology of the process, and
information pertaining to the equipment in the process.
Process chemistry; 1
Safe upper and lower limits for such items as temperatures, pressures, flows or 2
compositions; and,
An evaluation of the consequences of deviations, including those affecting the 1
safety and health of employees.
Where the original technical information no longer exists, such information may 1
be developed in conjunction with the process hazard analysis in sufficient detail
to support the analysis.
Information pertaining to the equipment in the process shall include: 2
Materials of construction; 2
Piping and instrument diagrams (P&IDs); 16
Electrical classification; 5
Relief system design and design basis; 12
Design codes and standards employed 2
Safety systems (e.g. interlocks, detection or suppression systems). 1
The employer shall document that equipment complies with recognized and 21
generally accepted good engineering practices.
For existing equipment designed and constructed in accordance with codes, 1
standards, or practices that are no longer in general use, the employer shall
determine and document that the equipment is designed, maintained, inspected,
tested, and operating in a safe manner.

Table 3.3 – PSI Citations

Page 19 of 36


3.5 Process Hazard Analysis Upgrade
This element needs to be evaluated for three primary aspects:
 Is the PHA schedule on track?
 Was the appropriate methodology used in the original PHA and any revalidations or baseline PHA re-
performances?
 Are there open PHA action items that are overdue?

Ensure responsibility for PHA Action item closure is clear and documentation is complete. This provides an
excellent metric for evaluating PSM performance. The table below shows that facility siting, prompt closure of
PHA findings, and meeting your revalidation schedule are vulnerable areas in inspections to date.

PHA Specific Citations No. of Citations
The employer shall perform an initial process hazard analysis (hazard evaluation) 4
on processes covered by this standard. The process hazard analysis shall be
appropriate to the complexity of the process and shall identify, evaluate, and
control the hazards involved in the process. Employers shall determine and
document the priority order for conducting process hazard analyses based on a
rationale which includes such considerations as extent of the process hazards,
number of potentially affected employees, age of the process, and operating
history of the process. The process hazard analysis shall be conducted as soon as
possible, but not later than the following schedule:
The hazards of the process; 8
The identification of any previous incident which had a likely potential for 4
catastrophic consequences in the workplace;
Engineering and administrative controls applicable to the hazards and their 7
interrelationships such as appropriate application of detection methodologies to
provide early warning of releases. (Acceptable detection methods might include
process monitoring and control instrumentation with alarms, and detection
hardware such as hydrocarbon sensors.);
Consequences of failure of engineering and administrative controls; 5
Facility siting; 14
Human factors; and 8
The employer shall establish a system to promptly address the team's findings 18
and recommendations; assure that the recommendations are resolved in a timely
manner and that the resolution is documented; document what actions are to be
taken; complete actions as soon as possible; develop a written schedule of when
these actions are to be completed; communicate the actions to operating,
maintenance and other employees whose work assignments are in the process and
who may be affected by the recommendations or actions.
At least every five (5) years after the completion of the initial process hazard 9
analysis, the process hazard analysis shall be updated and revalidated by a team
meeting the requirements in paragraph (e)(4) of this section, to assure that the
process hazard analysis is consistent with the current process.
Employers shall retain process hazards analyses and updates or revalidations for 1
each process covered by this section, as well as the documented resolution of
recommendations described in paragraph (e)(5) of this section for the life of the
process.

Table 3.4 – PHA Citations

Page 20 of 36


3.6 Operating Procedures Upgrade

Operating procedures are typically open to citations again because of the number of tasks that may need to be
proceduralized. This element is in the top four cited by OSHA to date. Some things to consider for a general
upgrade of your operating procedures include:

 Perform a job task analysis to the level of a job task listing to identify all the tasks that occur within each
phase of operation. This will help ensure more complete capture of the work performed, better comply
with PSM/RMP intent, help with the changing workforce issues all refineries are faced with as less
experienced operators are hired due to retirement of experienced workers, and improve operational
excellence in general through thorough documentation of operational requirements.
 Consider adopting a standard operating procedure format across the entire refinery if one does not exist.
Though not required by law, this helps the users access information from the documents in several ways.
 Develop a procedure writing style guide to help refinery procedure writers use consistent terminology
and writing techniques when developing new and revised procedures.
 Train selected volunteer operators and technical staff on how to use the style guide, how to write in the
new format, and general effective procedure writing techniques. This will help ensure the facility can
maintain its operating, maintenance and safe work practice procedure quality and accuracy over the life
of the refinery.
 If self-analysis or citations indicate, consider initiating a project to upgrade the facility operating
procedures as soon as practical.
 If the PSM/RMP procedure program compliance plan document for the site will meet procedure
program requirements, consider establishing a permanent means to ensure the annual certification that
the operating procedures are current and accurate. When the management of change process and your
procedure program are working in synchronization, this certification becomes a simple administrative
task.

The table below shows that emergency shutdown procedures, emergency operations procedures (also termed
abnormal operating procedures), timely review and certification, and safe work practices (often overlooked as
being considered operating procedures) are vulnerable areas in inspections to date.

Operating Procedure Specific Citations No. of Citations
The employer shall develop and implement written operating procedures that 7
provide clear instructions for safely conducting activities involved in each
covered process consistent with the process safety information and shall address
at least the following elements.
Steps for each operating phase: 2
Normal operations; 6
Temporary operations; 3
Emergency shutdown including the conditions under which emergency shutdown 14
is required, and the assignment of shutdown responsibility to qualified operators
to ensure that emergency shutdown is executed in a safe and timely manner.
Emergency Operations; 9
Normal shutdown 1
Startup following a turnaround, or after an emergency shutdown. 3
Operating limits: 5
Page 21 of 36


Consequences of deviation 3
Steps required to correct or avoid deviation 3
Safety and health considerations 1
Properties of, and hazards presented by, the chemicals used in the process 1
Precautions necessary to prevent exposure, including engineering controls, 2
administrative controls, and personal protective equipment
Any special or unique hazards 1
Safety systems and their functions. 2
The operating procedures shall be reviewed as often as necessary to assure that 9
they reflect current operating practice, including changes that result from changes
in process chemicals, technology, and equipment, and changes to facilities. The
employer shall certify annually that these operating procedures are current and
accurate.
The employer shall develop and implement safe work practices to provide for the 12
control of hazards during operations such as lockout/tagout; confined space
entry; opening process equipment or piping; and control over entrance into a
facility by maintenance, contractor, laboratory, or other support personnel. These
safe work practices shall apply to employees and contractor employees.

Table 3.5 – Operating Procedure Citations

3.7 Training Upgrade

Revisit the site’s current method of performing and documenting initial training and refresher training and
consider other approaches if indicated. Some suggestions:

 Verify your process overview training is up to date with the process safety information and is designed
in accordance with instructional systems design (ISD) methodology.
 Take double credit for operating procedure training due to MOC related activities as refresher training
and MOC training/inform;
 Periodically poll workers to identify those procedures on which they would like training and provide it;
and
 Schedule planned periodic training within the 3-year window on the emergency operations or other
critical procedures to help ensure conditioned response to emergency shutdown and abnormal
operations.

Page 22 of 36


The table below shows that both initial and refresher training are vulnerable areas in inspections to date.

Training Specific Citations No. of Citations
Each employee presently involved in operating a process, and each employee 7
before being involved in operating a newly assigned process, shall be trained in
an overview of the process and in the operating procedures as specified in
paragraph (f) of this section. The training shall include emphasis on the specific
safety and health hazards, emergency operations including shutdown, and safe
work practices applicable to the employee's job tasks.
Refresher training. Refresher training shall be provided at least every three years, 4
and more often if necessary, to each employee involved in operating a process to
assure that the employee understands and adheres to the current operating
procedures of the process. The employer, in consultation with the employees
involved in operating the process, shall determine the appropriate frequency of
refresher training.
Training documentation. The employer shall ascertain that each employee 1
involved in operating a process has received and understood the training required
by this paragraph. The employer shall prepare a record which contains the
identity of the employee, the date of training, and the means used to verify that
the employee understood the training.

Table 3.6 – Training Citations

3.8 Contractors Upgrade

Evaluate your current contractor on-boarding and performance auditing methods (for both safety and work
quality). Consider developing safe work practices or other documents to capture the approach.

The table below shows that contractor training on process hazards and controls for contractor access are
vulnerable areas in inspections to date.

Contractor Specific Citations No. of Citations
The employer, when selecting a contractor, shall obtain and evaluate information 1
regarding the contract employer's safety performance and programs.
The employer shall inform contract employers of the known potential fire, 3
explosion, or toxic release hazards related to the contractor's work and the
process.
The employer shall develop and implement safe work practices consistent with 4
paragraph (f)(4) of this section, to control the entrance, presence and exit of
contract employers and contract employees in covered process areas.
The employer shall periodically evaluate the performance of contract employers 1
in fulfilling their obligations as specified in paragraph (h)(3) of this section.
The employer shall maintain a contract employee injury and illness log related to 2
the contractor's work in process areas.

Table 3.7 – Contractor Citations

Page 23 of 36


3.9 Pre-startup Safety Review Recommendation

Audit a random sampling of management of change activities requiring a pre-startup safety review (PSSR).
Evaluate if the basics have been met and chart your upgrade to correct the deficiencies found.

The table below shows that procedures, MOC Process hazard analyses, and training are the vulnerable areas in
inspections to date.

PSSR Specific Citations No. of Citations
Safety, operating, maintenance, and emergency procedures are in place and are 1
adequate;
For new facilities, a process hazard analysis has been performed and 2
recommendations have been resolved or implemented before startup; and
modified facilities meet the requirements contained in management of change,
paragraph (l).
Training of each employee involved in operating a process has been completed. 1

Table 3.8 – PSSR Citations

3.10 Mechanical Integrity Upgrade

In this one paragraph, the PSM standard describes one of the more complex elements of process safety
management. Some sites consider it a sub-management system of its own due to its complexity. Mechanical
integrity is also an argument for the business case of implementing high quality PSM as it improves plant
reliability and reduces unplanned outages. Some considerations for upgrade include:

 Consider reviewing your total mechanical integrity system to determine if it can be simplified. For
example, some requirements of mechanical integrity can be met by reference in the PSM/RMP
compliance plan documents to existing refinery software tools designed to plan, schedule, and document
maintenance activities, inspections, tests, and quality assurance methods.
 For the task level mechanical integrity procedures, consider adopting a user-friendly format and
gradually revising these documents to the new format as the need arises from management of change
activities or when employee recommendations are incorporated. Maintenance procedure needs due to
management of change are often overlooked.

The table below shows that written procedures, inspection and testing, and correcting deficiencies are the
vulnerable areas in inspections to date.

Page 24 of 36


Mechanical Integrity Specific Citations No. of Citations
Written procedures. The employer shall establish and implement written 17
procedures to maintain the on-going integrity of process equipment.
Training for process maintenance activities. The employer shall train each 1
employee involved in maintaining the on-going integrity of process equipment in
an overview of that process and its hazards and in the procedures applicable to
the employee's job tasks to assure that the employee can perform the job tasks in
a safe manner.
Inspections and tests shall be performed on process equipment. 13
Inspection and testing procedures shall follow recognized and generally accepted 11
good engineering practices.
The frequency of inspections and tests of process equipment shall be consistent 9
with applicable manufacturers' recommendations and good engineering practices,
and more frequently if determined to be necessary by prior operating experience.
The employer shall document each inspection and test that has been performed 9
on process equipment. The documentation shall identify the date of the
inspection or test, the name of the person who performed the inspection or test,
the serial number or other identifier of the equipment on which the inspection or
test was performed, a description of the inspection or test performed, and the
results of the inspection or test.
Equipment deficiencies. The employer shall correct deficiencies in equipment 18
that are outside acceptable limits (defined by the process safety information in
paragraph (d) of this section) before further use or in a safe and timely manner
when necessary means are taken to assure safe operation.
Appropriate checks and inspections shall be performed to assure that equipment 4
is installed properly and consistent with design specifications and the
manufacturer's instructions.
The employer shall assure that maintenance materials, spare parts and equipment 2
are suitable for the process application for which they will be used.

Table 3.9 – Mechanical Integrity Citations

Page 25 of 36


3.11 Hot Work Permit Upgrade

As the hot work element of PSM essentially reiterates the applicability of the fire prevention and protection
requirements in an existing standard 29 CFR 1910.252(a), one might think it would not be vulnerable in an NEP
inspection. But is has proven to be so.

Things to consider for evaluating the need to upgrade this element of your PSM program are:

 Evaluate feedback from the users of the refinery safe work practice covering hot work (it may be
addressed in your Safe Work Permit Policy and Instructions document) and revise the document and any
tracking software as appropriate.
 Check that safety audits show both refinery employees and contractors are following the policy. If not,
management must take steps to enforce this basic safety practice.

The table below shows that the details of the permit are the vulnerable areas in inspections to date.

Hot Work Permit Specific Citations No. of Citations
The permit shall document that the fire prevention and protection requirements in 2
29 CFR 1910.252(a) have been implemented prior to beginning the hot work
operations; it shall indicate the date(s) authorized for hot work; and identify the
object on which hot work is to be performed. The permit shall be kept on file
until completion of the hot work operations.

Table 3.10 – Hot Work Permit Citations

Page 26 of 36


3.12 Management of Change Upgrade

Management of change (MOC) in combination with PSSR forms the engine that is intended to keep the entire
process safety management program up-to-date and relevant to your facility’s success.

 Evaluate any electronic management of change work process your site may use. Do users understand it?
Does it encourage the communication essential to good MOC – or does it allow users to click a box and
move on without thorough evaluation of the change’s hazards? Please note that paper systems are fine if
that approach fits your site culture and resources. They actually have some advantages over electronic
MOC systems when thoroughly implemented.
 Revise the refinery PSM/RMP compliance plan management of change document to accurately reflect
changes to your MOC system.
 Randomly sample and audit past MOC packages to verify the system is working.
 If the system is broken, management must direct resources at correcting deficiencies and training the
users.
 Consider the value of adding management of change of personnel to the AEI management of change
work process if it is not addressed. This is not a regulatory requirement but has been recognized
industry-wide as a good practice. Many issues related to PSM quality arise when key personnel leave the
company or change positions.

The table below shows that having an established written MOC system and updating the process safety
information for a change are the more vulnerable areas in inspections to date.

Management of Change Specific Citations No. of Citations
The employer shall establish and implement written procedures to manage 15
changes (except for "replacements in kind") to process chemicals, technology,
equipment, and procedures; and, changes to facilities that affect a covered
process.
The procedures shall assure that the following considerations are addressed prior 1
to any change:
Impact of change on safety and health 2
Modifications to operating procedures; 2
Necessary time period for the change; and, 2
Authorization requirements for the proposed change. 2
If a change covered by this paragraph results in a change in the process safety 7
information required by paragraph (d) of this section, such information shall be
updated accordingly.
If a change covered by this paragraph results in a change in the operating 2
procedures or practices required by paragraph (f) of this section, such procedures
or practices shall be updated accordingly.

Table 3.11 – Management of Change Citations

Page 27 of 36


3.13 Incident Investigation Upgrade

The fact that this element appears in the PSM standard shows that OSHA understands any management system
is open to failure. The prime goal of this element is to help ensure facilities learn from their failures and use that
learning to improve process safety performance.

Some things to consider for upgrading this element are:

 Evaluate the site’s existing incident investigation element documents, both the PSM/RMP compliance
plan administrative procedure and any safe work practice documents that describe the specific work
process, for any revision needs and updates.
 If you use an electronic incident investigation reporting tool, ensure it meshes with the work process
 Consider tracking categories of incidents (especially PSM incidents) so that analysis of trends is made
simpler. This demands a definition for your site of - what constitutes a PSM incident? Some companies
use the potential of an incident to release a threshold quantity (TQ) of a hazardous chemical or
flammable. Others categorize any breakdown of the PSM program work processes as a PSM incident.
 Audit your incident investigation reports for compliance with your program description.

The table below shows that identifying PSM incidents for investigation, the details of a thorough investigation,
and prompt follow up of action items and documentation of closure are the more vulnerable areas in inspections
to date.

Incident Investigation Specific Citations No. of Citations
The employer shall investigate each incident which resulted in, or could 7
reasonably have resulted in a catastrophic release of highly hazardous chemical
in the workplace.
An incident investigation shall be initiated as promptly as possible, but not later 2
than 48 hours following the incident.
An incident investigation team shall be established and consist of at least one 4
person knowledgeable in the process involved, including a contract employee if
the incident involved work of the contractor, and other persons with appropriate
knowledge and experience to thoroughly investigate and analyze the incident.
A report shall be prepared at the conclusion of the investigation which includes at 3
a minimum:
Date investigation began. 3
The factors that contributed to the incident; and, 5
Any recommendations resulting from the investigation. 2
The employer shall establish a system to promptly address and resolve the 10
incident report findings and recommendations. Resolutions and corrective actions
shall be documented.
The report shall be reviewed with all affected personnel whose job tasks are 2
relevant to the incident findings including contract employees where applicable.

Table 3.12 – Incident Investigation Citations

Page 28 of 36


3.14 Emergency Planning and Response Program

The emergency planning and response element also reiterates the applicability of existing regulations:

 29 CFR 1910.38 (a) – Emergency Action Plans and
 29 CFR 1910.120 (a), (p), and q) - Hazardous waste operations and emergency response.

A site may assume they have implemented these requirements, but the data show that there are still citations
within the industry. Many facilities affected by these regulations have chosen to use the integrated contingency
plan (ICP) approach – also called the one plan approach - to their various emergency response regulatory needs.
This method uses one combined program to comply with what may be overlapping areas of several similar
requirements – for example, spill prevention control and countermeasure and the oil pollution act of 1990 (OPA
90) facility response plan.

Some things to consider for an upgrade of this element are:

 Audit your emergency response plan against all of your related regulatory requirements to ensure they
are addressed.
 Audit your record of drills, emergency responses, and critiques to evaluate whether the plan is being
implemented appropriately.
 Revise the plan as needed and train refinery staff on any changes to the emergency response procedures
that they are expected to perform in their job assignment
 If not already using the ICP approach, evaluate the benefits of doing so.
 Communicate with the local emergency planning committee to coordinate the site plan with the
community emergency response plan and document this activity.

The table below shows that simply having a plan that meets the regulation is what the OSHA teams are finding.

Emergency Planning and Response Specific Citations No. of Citations
Emergency planning and response. The employer shall establish and implement 9
an emergency action plan for the entire plant in accordance with the provisions of
29 CFR 1910.38. In addition, the emergency action plan shall include procedures
for handling small releases. Employers covered under this standard may also be
subject to the hazardous waste and emergency response provisions contained in
29 CFR 1910.120 (a), (p) and (q).

Table 3.13 – Emergency Planning and Response Citations

3.15 Compliance Audits Upgrade

Compliance audits are a way to perform a periodic self-check of PSM performance. The data from inspections
to date in the table below shows that the industry has not been effective at self-analysis in general. The current
citations essentially sum up that a large percentage of refineries either missed the three year dates for their
audits, did not do the audits, or did not act upon and document closure of action items resulting from their self
audit.

Page 29 of 36


Some considerations for a compliance audits element upgrade are:

 Identify any outstanding action items from past audits and work to close them at the earliest possible
opportunity.
 Plan for you next scheduled compliance audit by selecting who will perform it:
o First party – refinery personnel
o Second party – corporate personnel or sister refinery personnel if your company has several PSM
covered facilities (or a combination of both categories of personnel )
o Third party – an outside firm – typically a PSM consulting company or an engineering firm
 If using first or second party personnel from your company, train them in the basics of process safety,
train them in your PSM administrative procedures, train them in the use of an established internal audit
protocol, and encourage sharing the learning from each completed compliance audit with any other PSM
covered sites within your organization.
 Track each compliance audit recommendation against its due date and complete the actions in a timely
fashion.

Compliance Audits Specific Citations No. of Citations
Employers shall certify that they have evaluated compliance with the provisions 12
of this section at least every three years to verify that the procedures and
practices developed under the standard are adequate and are being followed.
The employer shall promptly determine and document an appropriate response to 12
each of the findings of the compliance audit, and document that deficiencies have
been corrected.

Table 3.14 – Compliance Audits Citations

3.16 Trade Secrets

This element is seldom critical in a refinery, but it is a good practice to have a method in place. It can be very
straightforward if trade secrets are not an immediate concern. However, if it is possible a site may use
proprietary chemicals or processes in the future, this preparation may serve in compliance with the process
safety management standard. The OSHA PSM NEP effort has had no trade secrets citations to date.

3.17 Planning a PSM Implementation Upgrade Project

For the clarity of the paper, we show a three-year template for the schedule. A refinery may choose to show a
schedule based upon their actual 5-year PHA revalidation schedule. The suggestions above and other line items
provide a path to consider for a total PSM implementation upgrade after an NEP inspections.

Page 30 of 36


Figure 3.1 – A Sample PSM Implementation Upgrade Gantt Chart – page 1

Page 31 of 36


Figure 3.1 – A Sample PSM Implementation Upgrade Gantt Chart – page 2

Page 32 of 36


3.18 ORGANIZATIONAL CULTURE: A Necessary Commitment to Operational Discipline

One aspect of the best performing high reliability organizations (HRO) - such as refineries, chemical plants, and
nuclear and fossil power plants – is a naturally high level of operational discipline that pervades individual,
team and organizational behavior. This means that these high performers have essentially created, either
naturally or by design, a values-based management style. An organizational culture displays a values-based
management style acts in ways that characterize a shared set of values and principles. These values are not
directly measurable, but are perceived as important by all.

In a world of change – changing technology, market conditions, regulations, and political climate to name a few
- the characteristics of operational discipline are always valued whenever displayed in the behaviors of:

 Organizations
 Teams
 Individuals

That sense of shared values throughout an organization is called operational discipline. What is operational
discipline? The simplest definition is:

Operational Discipline: a consistent pattern of behavioral choices that supports success

When a high level of operational discipline is realized throughout an organization, all stakeholders benefit:
shareholders, management, employees, and the public. There are fifteen characteristics of operational discipline.
These are the things we unconsciously seek in others (including teams and organizations) during any
interaction. These are also the things our co-workers and company seek in us.

People, teams, and companies display a high level of operational discipline when they:

 Hold a sense of personal responsibility for their actions.
 Honor commitments to themselves and others.
 Seek outcome-based results rather than activity-based results.
 View problem, setbacks, and mistakes as opportunities for improvement.
 Use time management techniques in achieving goals.
 Respect and attempt to understand others' ideas and worldviews.
 Seek fairness in all exchanges.
 Share recognition with others.
 Value their life & health & the lives & health of co-workers & the community.
 Use active, two-way communication so information is understandable to all parties.
 Seek to perform the duties & tasks required by their position.
 Desire to use informational, capital, and human resources efficiently.
 Assume a leadership role when needed, and conversely, follow when appropriate.
 Use existing systems to achieve goals & seek to improve the systems when needed.
 Trust that others are capable of a high level of operational discipline & treat them accordingly.

Page 33 of 36


Business Excellence - The Peak

 Business excellence is made up of a mixture of both perceptual and quantitative things. The way a
company is perceived in regard to worker satisfaction, environmentally sustainable and other
perceptions combine with the bottom line of profitability and share price performance. An organization
may achieve business excellence – but it is a temporal condition – much like self-actualization. It is very
difficult to maintain.

Operational Excellence - The Path

 Operational excellence is made up of those tangible, quantitative, business critical things that, when
done at close to 100%, make your organization most effective. These are your procedures (of all types),
business metrics, key performance indicators (KPIs). Those day-to-day things that define where we live
in our business life. When you streamline an organization’s operational excellence related tasks, it is
more likely to succeed.

Operational Discipline – The Power

 Operational discipline is the power to achieve operational excellence and stage an organization to be
considered an example of business excellence. It is made up of those cultural, qualitative, perceptual,
un-measureable things that we sometimes fail to recognize as important. Perfection is not our goal for
operational discipline, merely consistency in our display. Displaying a high level of operational
discipline requires us to learn from our mistakes.

o These are the characteristics that help high performing operations maintain that level of
performance.
o These are the characteristics that help any organization persevere through hardships – such as
market issues, natural disasters, catastrophic incidents.
o These are the characteristics that help maintain a rigorous PSM system.
o These are the characteristics that need to be displayed in the midst of a response to a fire, toxic
release, or explosion.

The refining industry PSM NEP and the upcoming chemical industry PSM NEP will both provide companies
with an opportunity to display a high level of operational discipline in their preparation, inspection support
tasks, and in their response activities.

Page 34 of 36


4. Conclusion
The refining industry will have a directed opportunity to improve overall performance in process safety due to
the OSHA refinery process safety management national emphasis program. Leveraging this opportunity
requires a pervasive organizational culture that views personnel and process safety as second nature – a
conditioned first response to address for any issue related to refinery operations or maintenance. High reliability
organizations whose upper management values long term growth and more predictable physical plant reliability
will embrace the chance to use the effort involved in a PSM program implementation based upgrade to bolster
these benefits.

The cultural level of operational discipline at the corporation, team, and individual level can better support a
high level of operational excellence – doing those critical measurable things that support success – when a
program is detailed and monitored. Business excellence can be attained when a company values a holistic sense
of what comprises quality.

The following figure graphically represents this view. OSHA inspectors and management have gained a new
level of process safety management expertise based upon their roles in the NEP. This can only enhance OSHA’s
ability to help industry protect the workforce from preventable risk. If refinery and chemical plant management
adopt this view, the industry’s level of catastrophic risk prevention will increase.

Catastrophic
Incident
Prevention

Safety & Quality
Health Must Profitability
Include

Operational Discipline

Environmental
Responsibility

Operating Excellence

Business Excellence

Figure 4.1 The Holistic View of Quality

Page 35 of 36


References:

The Report of the BP U.S. Refineries Independent Safety Review Panel, January 2007

Department of Labor (OSHA), 29 CFR part 1910.119, Process Safety Management of Highly Hazardous
Chemicals, 1992

Department of Labor (OSHA), 29 CFR 1910.252(a), Welding, Cutting, and Brazing, Fire Prevention and
Protection

CPL 03-00-004, Petroleum Refinery Process Safety Management National Emphasis Program, 6/7/2007

United States Department of Labor, Occupational Health and Safety Administration, Inspections within Industry
database, http://osha.gov/pls/imis/industry.html (accessed February 1, 2009)

Environmental Protection Agency (EPA), 40 CFR Part 68, Risk Management Programs for Chemical
Accidental Release Prevention, 1996

Discovering Operational Discipline, © AntiEntropics, Inc. HRD Press, Amherst, Massachusetts, Robert Walter,
2002.

Integrated Management Systems and Safety Culture: Operational Discipline as the Foundation of
Manufacturing Excellence. Robert Walter, American Institute of Chemical Engineers/Center for Chemical
Process Safety, 2005 Spring National Meeting, Process Plant Safety Symposium, 2004

The Business Case for Process Safety, American Institute of Chemical Engineers/Center for Chemical Process
Safety, 2003

Practical Compliance with the EPA Risk Management Program, American Institute of Chemical
Engineers/Center for Chemical Process Safety, Robert Walter, 1999

Local Emergency Planning Committee Guidebook: Understanding the EPA Risk Management Program Rule,
American Institute of Chemical Engineers/Center for Chemical Process Safety, Robert Walter, 1998

About the Authors:

Mr. Robert Walter (rjwalter@antientropics.com) is president of AntiEntropics, Inc. (www.antientropics.com) a
performance enhancement consulting firm specializing in OSHA, EPA, DOT, and ISO management system
development and upgrade as well as managerial competency assessment and training.

Mr. Richard Foottit is a senior OSHA process safety management and EPA risk management program
consultant with AntiEntropics and was the PSM coordinator for the Conoco Billings Refinery
(rafoottit@antientropics.com)

Mr. Brian Nelson, CSP is the PSM Manager for the Suncor Energy USA Commerce City Refinery
(bnelson@suncor.com)

Page 36 of 36

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