by Melissa Langsdon Senior Principal Specialist
In the Clean Air Act Amendments of 1990, Congress required the Occupational, Safety and Health Administration (OSHA) to adopt the Process Safety Management (PSM) standard to protect workers and required the Environmental Protection Agency (EPA) to protect the community and environment by issuing the Risk Management Plan Rule (RMP). PSM and RMP were written to complement each other in accomplishing these Congressional goals. Both the PSM regulation in 29 CFR 1910.119 and the RMP Rule codified in 40 CFR Part 68 are critical aspects of industrial operations, aimed at protecting employees, facilities and communities from potential hazards associated with highly hazardous chemicals and regulated substances, respectively. To ensure adherence to regulatory standards, companies often seek the expertise of PSM/RMP consultants. In this blog post, we will delve into the role of process safety consultants and explore how they assist clients in understanding their compliance gaps, implementing effective safety programs, and continuously reducing risks.
Understanding the Need for PSM Consultants
PSM/RMP Program Development and Implementation can be overwhelming. In addition, many organizations require additional resources to support existing process safety programs due to a lack of dedicated resources or spending cutbacks. This is where PSM/RMP consultants come in. Their primary goal is to help clients bridge the gap between their existing safety programs and the requirements mandated by regulatory bodies such as OSHA and EPA with regard to process safety.
Compliance and Beyond
PSM/RMP consultants cater to a wide range of clients with varying objectives. Some clients approach consultants solely to ensure regulatory compliance by meeting the minimum requirements of regulations. Others seek to exceed regulatory requirements and proactively enhance their safety programs. Additionally, there are companies that are entirely new to the regulatory landscape, requiring guidance on implementing PSM/RMP programs for the first time.
In some cases, regulatory requirements may even mandate the involvement of third-party auditors. It is worth noting that future changes in regulations may further emphasize the use of third-party auditors.
The Dual Perspective of OSHA and EPA
OSHA and EPA approach process safety from different angles. OSHA focuses on mitigating workplace-related risks and injuries from highly hazardous chemicals. On the other hand, EPA addresses regulated substances and emphasizes community safety and the prevention of offsite impacts. Process safety consultants possess expertise in both perspectives, ensuring comprehensive safety measures that protect both employees and the community.
The Importance of Fresh Perspectives
Having an external consultant with a fresh set of eyes is invaluable in identifying potential non-compliance issues and process gaps. Long-standing internal employees may inadvertently overlook certain aspects of the site’s safety program, leading to compliance risks. By bringing in a different viewpoint, process safety consultants can help identify and rectify such issues, ensuring a more robust and effective safety program.
Real-Life Implications
Real-world incidents, such as the West Texas Fertilizer incident in 2013, have highlighted the need for continuous improvement in process safety. OSHA and EPA have pushed for regulatory changes as a result of these incidents. PSM/RMP consultants play a crucial role in helping facilities reduce their risk of chemical releases, thereby improving workplace and community safety, environmental contamination, and other onsite and offsite impacts.
The Capabilities of PSM/RMP Consultants
PSM/RMP consultants offer a range of services to assist organizations in enhancing their process safety programs. These include:
Process Hazard Analysis (PHA) Facilitation: PSM/RMP consultants facilitate PHA sessions, which are used to identify potential hazards and develop risk reduction strategies.
Overall Process Safety Program Development: PSM/RMP consultants assist in the development of comprehensive process safety programs, including management procedures, operating procedure development, and mechanical integrity procedure development.
PSM/RMP Compliance Audits: PSM/RMP consultants conduct regulatory required 3-year audits to assess the compliance and effectiveness of PSM and RMP programs, identifying areas for improvement.
Training: PSM/RMP consultants provide management-level training and internal training to equip employees with the necessary skills to facilitate PHA sessions and conduct internal audits.
Risk Assessment: PSM/RMP consultants perform different types of Risk Assessments including Quantitative Risk Assessments (QRA), Safety Case Development, Layer of Protection Analysis (LOPA), and Alarm Rationalization.
EPA Risk Management Plans: PSM/RMP consultants prepare initial and 5-year resubmission of EPA required Risk Management Plans, along with the Hazard Assessment for the development of Worst Case Release and Alternative Case Release Scenarios (WCRS and ACRS).
As a supplier of complete process safety and risk management solution consultants, aeSolutions is proud to provide engineers from industry with design, maintenance, operating, and process safety backgrounds. Our specialists understand how plants operate because they have actually worked in covered processes and facilities. Their knowledge supports a practical approach to risk reduction solutions for PSM and RMP compliance.