“Selling” process safety concepts for non‐<scp>PSM</scp> applications

Abstract Many production plant facilities are not covered by Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) or have areas that lie outside a self‐determined PSM boundary. That does not mean those processes are inherently safe. It does not mean those plants do not have hazards. It quite literally means that those plants (or areas of the plant) merely do not exceed the Threshold Quantity of any Highly Hazardous Chemical. Since the inception of PSM, many facilities have been reluctant to apply PSM elements to processes that lie outside the defined PSM boundary. The process safety industry rightfully focuses on PSM facilities. This paper makes the case that non‐PSM facilities also deserve attention and offers some personal experience‐based propositions to help bring Risk‐Based Process Safety (RBPS) principles to non‐PSM facilities and areas. The adoption of even just some of the RBPS elements can improve safety, operability, and maintainability of the process. Particular attention is given to the food and pharmaceutical industries. They may have some non‐PSM areas or combustible dust hazards likely to benefit from adopting PSM principles facility‐wide.