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Gain tighter control over your own PSM programme.

Good governance of process safety requires a clear strategy, robust policies and procedures, and allocation of appropriate resources. But that alone is not enough. It also requires a positive culture, embodied by the right mix of individual and group values, attitudes, competencies, and behaviours to remain confident that everything is done as expected when no one is watching.

Every organised group of individuals develops a culture, but a good culture makes people feel safe and respected, enabling them to perform at their best.[1] Simply put, without this those involved in Process Safety Management (PSM) will just be a collection of individuals guided by their own values, knowledge, and experience. A good leader should determine and communicate the strategic direction, set standards and expectations, and encourage engagement throughout.

The Regulators and key industry stakeholders have been active in developing standards and guidance for good leadership and management of process safety. For example, establishments falling under the COMAH Regulations must prepare a Major Accident Prevent Policy (MAPP) covering senior management’s commitment to ensure that suitable measures are in place for managing major accident hazards. [2] Guidance is freely available on what the MAPP should cover, and in relation to requirements for the underpinning Safety Management System (SMS), which must:

  • be proportionate to the hazards, industrial activities and complexity of the organisation in the establishment;
  • be based on assessment of the risks; and
  • include within its scope the general management system including the organisational structure, responsibilities, practices, procedures, processes and resources for determining and implementing the major accident prevention policy. [3]

[It’s worth noting at this point, the MAPP document must address the management of the major accident hazards at a particular establishment and should be specific to that establishment.]

Importantly, the SMS should also incorporate the principles of continuous improvement in relation to management of major accident hazards but again, there is more than enough guidance available. Adopting a Plan, Do, Check, Act approach to PSM requires:

  • definition and communication of acceptable performance and the resources needed;
  • identification and assessment of process safety risks, and the controls necessary, based on sound and up to date process safety knowledge;
  • implementation and management of those controls; and
  • measurement and review processes to provide assurance that those controls are working effectively.

In turn, the Check and Act processes require a sound system of audit and review. The Regulations require operating companies to carry out audits of the SMS as a part of normal business. The audit should be a structured process of collecting information on the efficiency, effectiveness and reliability of the whole SMS and should lead to implementation of a plan for corrective action.[3, 4]

The audit programme should cover all relevant areas and activities and should be conducted at regular intervals by personnel with appropriate knowledge and expertise using structured protocols (which can include questionnaires, checklists, interviews, measurements and observations). Processes for reporting of findings and corrective action tracking should also be in place.

All this sounds easy, and in principle it is, but maintaining effective control across multi-site organisations can be challenging, especially when organisational change is constant, sites may be subject to different regulations, and where attitudes to risk can vary.[5] For sustainable continuous improvement, audit and review processes should be rooted in relevant standards and good practice (the vision), have structure, and promote ownership and engagement throughout. They should also allow activities to form part of an on-going programme of work that can be broken down into manageable tasks and mini projects to match available resources.

If you would like to know how OpenPSM® can help you do all this to gain tighter control over your own process safety management programme, then contact us today.

[1] Lead From the Top: 5 Core Responsibilities of a CEO | Entrepreneur

[2] The Control of Major Accident Hazards Regulations 2015 (legislation.gov.uk)

[3] A guide to the Control of Major Accident Hazards Regulations (COMAH) 2015 – L111 (hse.gov.uk)

[4] Managing for health and safety (hse.gov.uk)

[5] Sustaining effective corporate governance in process safety across global manufacturing sites (icheme.org)