The PSM Challenge for Smaller Companies

This session is focused on smaller companies which may or may not fall, directly or indirectly, under OSHA’s 29CFR1910.119 Process Safety Management regulation. Papers are invited which provide observations, practices, legal-insight and experiences developing, implementing and maintaining PSM in smaller companies. The practices suitable for large, well-staffed, high-risk sites may be overly burdensome and ineffective for small, staff-challenged, low risk ones. The PSM regulation strictly applies to those sites having highly hazardous materials exceeding the threshold quantities. To a small site, quantities of highly hazardous chemicals below the threshold limit can inflict proportionally more damage to them than for those larger sites with quantities just above threshold quantity. Furthermore, this regulation is being indirectly applied (and required) through performance-compliance standards, such as those invoked by the Combustible Dust National Emphasis Program RAGAGEP. Consequently, companies below the PSM TQ’s are using some or all aspects of PSM to control process and regulatory risk. Papers which provide insight to assist those now embarking on the development of a PSM program for such companies will receive strong consideration.