Process Safety Management (PSM) is a critical function to any corporation handling highly hazardous materials and companies know they must diligently continue implementation during the pandemic. Industry is feeling the ramifications of the COVID-19 pandemic and quickly implementing their pandemic plans to address these severe challenges.
A few key points to consider for process safety during this time:
- PSM should be included in the pandemic plan – Ensure the company’s pandemic (or crisis management plan for any wide-scale event) includes process safety management considerations specifically. If not, develop a plan to address all of the elements of the PSM management system that are critical to maintain safe operations. This has to be flexible and adaptive to the ongoing events and the eventual ‘new normal’ future we can all expect.
- Develop a PSM Related Task Force – Assign a team to focus on the specific issues of PSM implementation during the COVID-19 emergency. This team may report to a corporate crisis management or business continuity team, but the particular issues of process safety should have its own sub-organization. The American Petroleum Institute has developed excellent guidance on COVID-19 response: https://www.api.org/~/media/Files/EHS/Process-Safety/API-PandemicGuide.pdf
- Management of Organization Change (MOOC) – A Management of Organizational Change (MOOC) study should be done and revisited as required to understand all of the implications of staffing and culture that may be affected. Continuity of operations staffing may be different that adequate process safety functionality. Key issues include:
- Adequate staffing for all operational and PSM activities
- Sufficient supervisory experience and skills present
- Critical qualifications being present
- Emergency management capabilities
- Process hazards analysis continuity
- Audits and other forms of assurance of compliance to standards
- MOC program assurance
- Maintenance and inspection sufficiency
- Supply chain assurance
- And the continuity of other fundamental aspects of PSM
DHS guidance on the essential critical infrastructure workforce is an excellent guide to support State, Local, and industry partners in identifying the critical infrastructure sectors and the essential workers needed to maintain the services and functions need to be able to operate resiliently during the COVID-19 pandemic response.
- Develop Criteria for Process Safety Performance – have a clear path for making decisions on maintaining safe operations. Define minimal requirements and plan action should the situation change to maintain safe operations especially at reduced or shutdown conditions.
- Adapt to a new set of working conditions – Develop plans to allow for an effective remote workforce and limited staffing onsite. This may include the need for:
- Remote access tools and procedures for running the business and managing PSM activities
- Access to company systems (which may not be digitized or available online)
- Rules for working under principles of social distancing.
- Escalation of the event including workers becoming ill or government actions to curtail operations or non-essential personnel
Industry has stepped up to the challenge and it is encouraging to see the rapid adaptation to manage PSM. NPRA nicely summarized the longstanding dedication to managing such events and the resiliency of the industry https://www.afpm.org/newsroom/blog/covid-19-afpm-expert-industries-preparedness
SOCMA, for example, has developed guidance for maintaining safe operations including an Essential Personnel Template Letter and a Guide to Pandemic Plan Framework.
The multifaceted challenges of COVID-19 present an unprecedented event since process safety was formalized. We have to recognize that this is an inflection point to how process safety is to be managed in the foreseeable future and adapt accordingly.