[This blog series derives from a technical paper written by Eli Macha, President of Macha PSM]
14 PSM Elements
While the RMP regulation has two additional requirements, the PSM regulation breaks down into 14 major program elements. We will begin with PSM Element number one: Employee Participation.
Employee Participation
Prior to the RMP’s recent SCAPP rule changes, the employee participation element was surprisingly easy to satisfy since there were so few explicit requirements. Contra the industry awareness, there is no requirement for monthly or quarterly employee participation meetings. While other safety programs or standards may require meeting at regular intervals, the major PSM requirement was that employees participate in developing the program (process safety information in particular) and that they participate in the process hazard analysis. With the new SCAPP rule changes, the employee participation element now includes requirements regarding employee notices, establishing shutdown authorities, and allowing employees to report unaddressed hazards.
If a new facility has just been purchased, or a PSM program is to be developed for some other reason, the first order of business under employee participation is to develop a written employee participation plan.[1] There are a variety of ways to satisfy this requirement.
Sometimes facilities will have separate policies for how employees will implement each element of the program.
A simpler approach is having one consolidated written plan that details how each element will be implemented.
It is recommended to keep this document’s requirements nearly identical to the regulation requirements, otherwise, the facility may be on the hook for a requirement that goes beyond what the law requires. There is one large corporation that keeps their employee participation plans to one or two pages in total to avoid increasing their liability.
The simple and obvious mistake to avoid is failing to include employees in program development or in the process hazard analysis. It would be a great oversight to hire a contractor or consultant to perform a process hazard analysis only to find out that they completed the activity completely isolated from the facility’s operators. Failing to include operators in the process hazard analysis would certainly result in a violation.
While regular employee participation meetings are not required by the PSM or RMP regulations, this is undoubtedly the best way to optimize a PSM program. If a PSM team only meets when there is a major activity—process hazard analysis, compliance audit, or management of change—it is highly unlikely that the PSM program will be in good shape. The most common frequencies for these meetings are either monthly or quarterly. This completely depends on the facility, but if a monthly meeting is not feasible, much can be accomplished through well-planned quarterly meetings.
[1] Title 29 CFR §1910.119(c)(1) & Title 40 CFR §68.83(a)
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