Since OSHA 1910.119, “Process Safety Management of Highly Hazardous Chemicals” came into effect more than 25 years ago, most facilities subject to its requirements (including CDI’s clients in the refining, chemical/petrochemical, and midstream/storage/logistics industries) have mature, long-established PSM programs encompassing the 14 elements of the regulation.
The challenge facing many of these facilities is keeping the program relevant, updated, and effective in meeting its original objectives, the prevention of major chemical accidents, and protection of employees and the public. CDI has developed a custom protocol for examining the status of our clients’ Process Safety Management Programs and comparing actual performance against the required performance – identifying the gap between what we’re actually doing and what we should be doing. A Gap Analysis is very different from the periodic PSM Compliance Audit.
The Gap Analysis:
- starts at the beginning – with your Vision and Mission for Process Safety Management.
- is an internal review, designed to map out the process and align resources with needs (load leveling).
- guides the Owner on where to begin – resume – or continue with its Compliance Efforts.
- can focus only on PSM or can be applied to any regulatory requirement.
The Gap Analysis Process begins (with pre-planning to establish the scope, objectives, and deliverables of the analysis) – proceeds (with review of data, tour of facilities, and interviews with stakeholders) – and concludes (with a draft report reviewed in depth with the Client, and a final report which meets the objectives established in the planning stage).
A Timely Opportunity
We at CDI recognize the disruption to the normal business and manufacturing processes that has been caused by the COVID pandemic. Even before COVID, our industry was reacting to the impact to our operations of depressed energy prices – whether that impact was positive or negative! As a result of these disruptions, in many of our client locations, people have taken on different roles, production plans have been changed, maintenance activities delayed, and other programs are ongoing with reductions or a skeleton crew. It is likely that Process Safety Management (PSM) programs have been among those affected.
It’s an excellent time to allow CDI to demonstrate our PSM capabilities, and how the gap analysis can help you get a handle on the current state of your program. A complimentary webinar / “lunch & learn” session is an excellent opportunity for us to introduce CDI and explain our approach more fully. Then, if you are interested, we will offer a proposal for a gap analysis of your PSM program (or some component thereof); and provide a gap analysis study and report for plant leadership to use in strategic planning.
Please contact us for more information – to request an introductory webinar – or if you have questions:
David Boucher, Sr. Process Consultant 225.663.4600 david.boucher@cdicorp.com
Robin Banta, Business Development Manager 225.921.0284 robin.banta@cdicorp.com
Allison Allen, Business Development Manager 985.233.9046 allison.allen@cdicorp.com