(102a) PSM Challenge for Unregulated Upstream Facilities

Upstream oil and gas facilities are typically exempt from the OSHA Process Safety Management (PSM) standard; however, in light of recent regulatory scrutiny on the safety of upstream operations, many operating companies have extended their safety management programs to their upstream facilities creating challenges for implementation.  Many of these facilities have been operating without significant incidents for many years without proper Process Safety Information, Process Hazard Analyses, Management of Change programs, etc. making the challenge of accepting and implementing these programs difficult to embrace.  This paper is focused on providing insights and practical tips for the implementation of safety programs at upstream facilities to enhance the commitment to implementing process safety with limited resources.