(162b) "Selling" Process Safety Concepts for Non-PSM Applications

Many production plant facilities are not governed by OSHA PSM or have areas that lie outside a self-determined PSM boundary. That doesn’t mean those processes are inherently safe. It doesn’t mean those plants do not have hazards. It quite literally means that those plants (or areas of the plant) merely do not exceed the Threshold Quantity of any Highly Hazardous Chemical. Since the inception of PSM, many facilities have been reluctant to apply PSM elements to processes that lie outside the defined PSM boundary.

The process safety industry rightfully focuses on PSM facilities. This presentation makes the case that non-PSM facilities also deserve attention and offers some personal experience-based propositions to help bring Risk-Based Process Safety (RBPS) principles to non-PSM facilities and areas. Hazards can be identified qualitatively through PHA methodologies, then investigated further using semi-quantifiable methods like LOPA to define the level of risk. Following that, a Cost Benefit Analysis (CBA) can be done with the inclusion of financial or risk-management staff to determine which non-PSM processes should be managed with an RBPS program. The adoption of even just some of the RBPS elements can improve safety, operability and maintainability of the process.

Particular attention will be given to food and pharmaceutical industries. They may have some PSM areas or combustible dust hazards that make the likely to benefit from adopting PSM principles facility-wide. The existence of FDA food safety and cGMP programs at these facilities also put them only a few small steps away from improving process safety by implementing RBPC elements in full or even only in part. Other likely beneficiaries of RBPS principles would be technical manufacturing like semiconductors. Their quickly evolving product lines require frequent process equipment changes, which would benefit from implementation of RBPS elements.