Not a lightweight program, the fines for non-compliance are not insignificant either. Fines for individual workers may be as high as $250,000; for companies, $500,000 dollars. Although it may seem like actual release and outright injuries account for most or all the fines, not meeting necessary paperwork can also result in heavy regulatory penalties. Civil lawsuits and/or criminal liability may also come into play with violators.
Making PSM Work
Faced with a potentially catastrophic anhydrous ammonia incident, what’s the best way for a regulated company in the food industry to get the edge? The solution is three-part and comes under the heading of Risk Mitigation.
One, a specialist is worth his/her weight in gold. At most companies, people with specific skillsets are hired for positions fitting that expertise. Some positions, however, are considered fair game for a “Jack of all trades, master of none.” If a company has an individual filling its PSM coordinator position, it is usually the generalist. Unfortunately, experience has shown that PSM’s wide-ranging complexity and scope cannot be met with minimum resources or personnel wearing multiple hats.
The solution, even if it stretches the company budget, is hiring a PSM coordinator who is preferably an engineer with a minimum five years’ experience in the company’s industry and, ideally, with regulatory management experience. Bringing that type of experienced individual onboard will pay dividends in the savings recognized from avoiding potential penalties and fines. If hiring in this job area is not familiar to HR, work with the department and/or recruiters to develop a staffing plan for a coordinator and, optimally, a team.
Two, companies in the food industry should develop a budget that does not cut so close that it barely covers what must be done. Before anyone envisions a gloomy projection, however, OSHA does not see excessive spending as necessary. In a company’s initial five years of regulatory compliance, OSHA’s estimate is that worst case—not typical, but worst—budgeting would be 1.1 percent for large companies and 3.2 percent for small companies. When preparing the budget, imagine that this money will have a real, everyday impact on workplace safety.
Three, above all, arrive at a solution that addresses all the company’s requirements in a cost-effective way that works with the budget to accomplish compliance initiatives. Within this solution or plan is an emphasis on project management rather than dollars and cents to avoid penalties and ensure a safe workplace.
PSM is a real challenge but, when done right, it keeps a company at peace with regulators and reduces or eliminates workplace incidents, such as with anhydrous ammonia.
Steffens is process safety manager at Houston-based ACS Engineering. Reach him at firstname.lastname@example.org.