Safetip #64: Lagging and Leading Indicators for PSM
PSM Is More Than About OSHA Compliance
OSHA’s Process Safety Management of Highly Hazardous Chemicals standard (29 CFR 1910.119) includes requirements for the management of hazards associated with processes using highly hazardous chemicals. The standard aims to help prevent accidental releases of toxic, reactive or flammable liquids and gases in processes involving hazardous chemicals. It emphasizes the management of chemical hazards and establishes a program that integrates technologies, procedures and management practices.
But OSHA compliance is just one reason why a PSM program should be established, especially for organizations with global operations. The EU’s Seveso III Directive and the UK’s Control of Major Accident Hazards regulations (COMAH) also include similar requirements for Process Safety Management. An effective PSM program also leads to operational improvements and better safety performance.
What Indicators Should You Track?
Both lagging and leading indicators should be used for PSM, especially because you can run correlations between them. Lagging indicators measure what has already happened, such as accidents and injuries. Leading indicators measure the effectiveness of proactive activities and programs that aim to prevent future incidents and improve safety.
OSHA surveyed metrics used by facilities participating in its Voluntary Protection Programs (VPP). The VPP recognize employers and workers who have implemented effective safety and health management systems, and maintain injury and illness rates below national averages for their respective industries. OSHA compiled a list of metrics used by VPP facilities to track PSM program performance. The lagging metrics, mentioned in an EHS Daily Advisor article, include:
- Injury and Incident Reports
- Near-miss incidents that did not cause a loss of containment
- Recordable injuries and first-aid incidents that resulted from a loss of primary containment
- Number of incidents vs. number of incidents with formal reports
- Status of incident investigations
- Loss of Containment (unplanned or uncontrolled release of materials)
- Number of incidents
- Whether there was primary or secondary containment
- Causes and locations incidents
What about leading indicators? A second EHS Daily Advisor article mentions the following six leading metrics associated with PSM programs and how VPP facilities are tracking them:
- Management of Change (MOC)
- Overdue, approved and open MOCs
- MOCs performed each month
- Preventive Maintenance
- Completion rates
- Number of inspections
- Process Hazard Analysis (PHA)
- Overdue, open and completed PHAs and PHA revalidations
- Scheduled vs. completed PHAs
- Mechanical Integrity (MI)
- Number of inspections scheduled for relief valves, piping, pressure vessels and storage tanks
- Number of overdue work orders
- Safety/refresher training completed
- Planned vs. completed training
- Safety Action Items
- Open action items
- Initiated vs. completed items
Read both EHS Daily Advisor articles to learn more about these lagging and leading indicators for PSM. Also, if you feel that the list is overwhelming, remember that you don’t have to implement all of them at the same time. Start with a base list of indicators, and add an extra one or two every year.
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