The PSM Challenge for Smaller Companies

This session is focused on smaller companies. Process Safety Management practices suitable for large, well-staffed, high-risk sites, i.e. those falling under OSHA’s 29CFR1910.119, may be overly burdensome and ineffective for small, staff-challenged, lower risk ones. However, this regulation is being indirectly applied to smaller sites through performance-compliance standards included in the RAGAGEP for National Emphasis Programs. To a small site, quantities of highly hazardous chemicals below the threshold limit can inflict proportionally more damage to personnel, investment and business continuity than they can inflict for larger sites with inventory above the threshold quantity. Consequently, there are compelling reasons for smaller companies to adopt some or all aspects of PSM to control process and regulatory risk. Papers are invited which provide observations, practices, legal-insight and experiences developing, implementing and maintaining PSM in smaller companies. Papers which provide insight to assist those now embarking on the development of a PSM program or which provide insight from the perspective of the company using consultants will receive strong consideration.