Ask someone what workplace safety means and they may think about working at height, machinery, manual handling, slips and trips, or exposure to hazardous substances. These are important risks, but Process Safety asks us to think on a different scale.
It is concerned with preventing major incidents such as fires, explosions and significant releases of hazardous substances or energy. Fortunately, these events are relatively rare, but when they do happen, the consequences can be catastrophic for workers, surrounding communities, the environment and the organisations involved.
Managing these risks requires more than individual procedures or risk assessments. Organisations need a structured and systematic approach to Process Safety Management (PSM) to understand their major accident hazards, establish appropriate controls and make sure those controls continue to work.
This is where Process Safety Management (PSM) frameworks can help.
What is a PSM framework?
A Process Safety Management (PSM) framework provides a structured approach for managing major accident hazards.
Rather than treating individual Process Safety activities separately, a framework brings them together as part of an overall management system. These activities can include leadership and accountability, understanding hazards and risks, safe operating procedures, workforce competence, maintaining safety-critical equipment, management of change, emergency preparedness, incident investigation and learning from experience.
In simple terms, a framework helps an organisation consider two important questions:
1. What needs to be in place to prevent a major accident?
2. How do we know those arrangements continue to be effective?
There is no single universal PSM framework. Different approaches have developed over time and organisations may encounter different frameworks depending on their industry, location, regulatory environment and needs.
Different frameworks, common principles
One internationally recognised approach is Risk Based Process Safety (RBPS), developed by the Center for Chemical Process Safety (CCPS).
RBPS is structured around four pillars: Commit to Process Safety, Understand Hazards and Risk, Manage Risk, and Learn from Experience. These contain 20 individual elements covering the systems and activities needed to manage Process Safety effectively.
Another recognised approach is the Energy Institute (EI) Process Safety Management framework. It is organised around four focus areas comprising Process Safety Leadership, Risk Identification and Assessment, Risk Management, and Review and Improvement. These are also supported by 20 individual elements.
Organisations operating in the United States may also encounter the Occupational Safety and Health Administration (OSHA) Process Safety Management standard. Unlike the EI and CCPS approaches, OSHA PSM is a regulatory standard and establishes mandatory requirements for covered processes involving highly hazardous chemicals.
At first, these different approaches can appear confusing. They use different structures, terminology and numbers of individual elements.
Look beneath those differences, however, and there is considerable common ground.
They recognise, in different ways, that major hazards need to be understood, risks controlled, equipment maintained, changes properly managed, people competent, emergencies anticipated and lessons learned.
The framework may change. The fundamental Process Safety principles remain remarkably similar.
Framework or regulatory requirement?
Another area that can cause confusion is the relationship between PSM frameworks and major accident legislation.
For example, within the European Union, the Seveso III Directive establishes requirements for controlling major accident hazards involving dangerous substances. In Great Britain, the Control of Major Accident Hazards Regulations 2015 (COMAH) apply to establishments where dangerous substances are present at or above specified threshold quantities.
It is important not to assume that these are simply alternative PSM frameworks.
They form part of regulatory regimes concerned with preventing and mitigating major accidents involving dangerous substances.
The distinction is useful. Regulation establishes requirements that an organisation must meet. A PSM framework can provide a structured approach to organising and improving the systems used to manage major accident hazards.
The two can therefore complement one another. An organisation may use a recognised PSM framework while also meeting the specific legal requirements that apply where it operates.
Which PSM framework should an organisation choose?
With several approaches available, you might reasonably ask:
Ø Which framework should we use?
Unfortunately, there isn’t a single answer — and perhaps a better question is:
Ø What does the organisation need its Process Safety Management system to achieve?
There is unlikely to be one answer that suits every organisation.
The nature and scale of the hazards are clearly important, but other factors also matter. These include regulatory obligations, industry sector, organisational structure, existing management systems, available competence and the maturity of current Process Safety arrangements.
An organisation beginning its PSM journey may value a Process Safety Management framework that provides a clear structure for assessing existing arrangements, identifying gaps and prioritising improvements.
A more mature organisation might use the same framework differently, perhaps for assurance, benchmarking and continual improvement.
International organisations may have another challenge. They can operate facilities across several countries with different regulatory requirements while wanting a consistent corporate approach to Process Safety. A common PSM framework can provide that overall structure, while individual facilities incorporate their local requirements.
Choosing a framework, therefore, should not simply be about adopting a recognised name or following a checklist. Organisations need to understand what they want the framework to achieve and how it will fit with the way they actually manage their major hazards.
Avoiding the checklist trap
This leads to perhaps the most important consideration when using any PSM framework.
Having the framework is not the same as managing Process Safety.
An organisation might have a Management of Change procedure, inspection programmes, emergency plans, hazard studies, operating procedures and Process Safety performance indicators. On paper, everything may appear to be in place.
But the real question is: does it work in practice?
Are changes properly assessed before they are introduced? Are safety-critical items inspected and maintained? Do people understand the major hazards associated with the processes they operate? Are warning signs acted upon? Are lessons genuinely learned from incidents and near misses?
And importantly, does leadership understand the organisation’s major accident risks and the condition of the controls relied upon to manage them?
These questions move Process Safety beyond procedures and documentation and into the everyday operation of an organisation.
A framework is the starting point
Process Safety Management frameworks can provide organisations with a valuable structure for understanding their existing arrangements, identifying gaps and continually improving how they manage major accident hazards.
But a framework cannot manage the risk on its own.
Its effectiveness ultimately depends on how it is understood, implemented and maintained.
Whatever framework an organisation uses, effective Process Safety requires committed leadership, competent people, reliable engineering, operational discipline, organisational learning and a willingness to continually ask whether critical controls remain effective.
For those looking to develop their knowledge further, RRC offers the NEBOSH HSE Certificate in Process Safety Management, covering key principles for understanding and managing process safety risks.
Different PSM frameworks may organise these activities in different ways and use different terminology, but their fundamental purpose is remarkably similar: to prevent catastrophic events, protect people and the environment, and help make work safer and more sustainable.
Ultimately, the framework provides the structure. What matters is what an organisation does with it.
Sonni Gopal
RRC Tutor
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