For the past many Springs, I have taught a Process Safety class at Rice University. I thoroughly enjoy imparting knowledge of my craft. I am also inspired every year by the promise of the students as they march towards the end of their undergraduate careers.
One of the questions I get asked a lot by students is “Which of the 14 PSM elements is the most important?” For your quick reference, the standard list of 14 PSM elements is provided below:
- Employee Participation;
- Process Safety Information;
- Process Hazard Analysis;
- Operating Procedures;
- Pre-Startup Safety Review (PSSR);
- Mechanical Integrity;
- Hot Work Permit;
- Management of Change;
- Incident Investigation;
- Emergency Planning and Response;
- Compliance Audits; and
- Trade Secrets.
Yes, I know there is a longer list under the banner of Risk-Based Process Safety from the CCPS, but I am sticking to what is required by law. There is obviously no right answer as every answer may be subjective. In this blog post, I offer my rationale as to what I believe the right answer to be, but please remember this is only my humble opinion.
Let us first start by crossing out certain elements. Remember, I am not saying these elements are not important. I am simply providing an argument as to why they may not be the “fairest of them all”.
Elements that focus on hazards after they have reared their ugly heads do not merit top shelf placement, in my humble opinion. This eliminates:
- Incident Investigation and
- Emergency Planning and Response.
And then there were 12…dramatic sound effect of your choice!
Next, I am going to dismiss Trade Secrets as this element primarily exists to ensure access to relevant PSM information by impacted personnel. While essential, this is not the element that makes or breaks a PSM program.
And then there were 11! Insert Agatha Christie movie music here.
Compliance Audits provide a learning loop to a facility’s PSM program, but they still serve as lagging safeguards at best.
And then there were 10! Duhn-duhn-duhhhhhn!
I am combining Management of Change and PSSR into a single bucket for the sake of brevity. PSSR has become an extension of most MoC programs and does not tend to stand on its own. MoC is a strong contender for the title; however, it is essentially an amalgam of other PSM elements (e.g., PSI, PHA, and PSSR) and therefore cannot claim the title outright.
And then there were 8! (Friday the 13th tune)
I am going to combine Hot Work Permit with Operating Procedures in my next batch to exit stage left. Most programs handle Hot Work Permits as a safe work practice in their suite of Operating Procedures. Procedures are essential to the safe operation of a PSM-covered facility; however, they are driven by PSI and PHAs with respect to process chemistry, safe operating limits, and consequences of deviation from safe operating limits.
And then there were 6! (Psycho shower scene sound effect)
Employee Participation, Training, and Contractors seem like easy ones to grant the crown; however, they are too soft for the likes of me to be awarded top spot. Yes, all impacted employees should be involved in the PSM program. All should have a voice and awareness with respect to hazards and risks. But these elements are more cultural issues (from my perspective) and should be inherent to any program at a facility, not just a PSM program.
And then there were 3! (Running out of steam here…perhaps Jeopardy theme song to mix it up?!)
We are down to what I consider the three most important PSM elements – Process Safety Information, Mechanical Integrity, and Process Hazard Analysis. But as the Kurgan originally uttered in Highlander, “There can be only one!”
PSI and MI are certainly vital organs of any PSM program, but they are not the heart – once again, in my humble opinion. Information is grand, but useless unless put to good use. Mechanical integrity is invaluable to assuring the availability of assets, but once again, the information provided by a MI program is typically an input to a risk assessment and business decision-making.
And then there was…Process Hazard Analysis! In my humble opinion, PHAs serve as the focal point of all PSM programs. PSI, operating procedures, MoCs (and PSSRs), incident investigations, and compliance audits are all inputs to a PHA. PHA worksheets and checklists intimately touch training, contractors, mechanical integrity, and emergency planning and response. The PHA activity is Employee Participation incarnate. At the end of the day, PHA embodies the essence of what PSM is trying to achieve – hazard identification, risk assessment, and risk management throughout the lifecycle of a covered process.
I know some of you disagree with me. I know some of you may reply with scathing rebuttals. Please share as you wish. You will not hurt my feelings and may even change my mind. I am a big believer in using information and competence to prevent incidents and injuries. This is what a PHA is all about.