Includes a Requirements Register and Compliance Calendar
COMPLIANCE
INITIATIVES
COMPLIANCE
INITIATIVES
FACILEX® CI targets Compliance Management requirements for efficient action item tracking and the means to organize all the supporting documentation and evidence collection. The CI business process engages subject matter experts to determine:
FACILEX® is derived from the CCPS Pillars of Process Safety. Compliance Management is integral to maintaining a safe workplace, preventing accidents, and ensuring compliance with safety regulations. It is a proactive approach to risk mitigation that enhances overall process safety.
There are several agencies that collectively ensure compliance with environmental laws, public safety, and national security.
Federal Regulatory Bodies
State Regulatory Bodies
Regional/Local Regulatory Bodies
Cross-Jurisdictional Authorities
A Compliance Solution ensures that highly regulated facilities operate safely, efficiently, and within regulatory frameworks, protecting employees, assets, and the environment.
Increasing Regulatory Burden
Industries face a growing number of regulations from agencies like OSHA, PHMSA, and Homeland Security. Compliance solutions streamline the management of these complex and overlapping requirements, preventing regulatory violations that can result in fines, shutdowns, or accidents.
Enhanced Safety and Risk Management
PSM-covered facilities handle hazardous materials, making safety paramount. Compliance solutions ensure that processes such as Management of Change (MOC), Incident Reporting, and Risk Determination are implemented effectively to minimize safety risks.
Accountability at All Levels
Compliance solutions clarify roles and responsibilities:
Efficiency in Managing Requirements
Facilities face a mix of public regulations (e.g., guidelines from DHS, EPA) and private rules (e.g., contracts, permits). Compliance solutions like FACILEX® simplify managing and integrating these requirements into day-to-day operations.
Systematic Assurance Activities
Staying compliant is an ongoing process. Compliance solutions support:
Adaptability to New Requirements
With constantly changing regulations, compliance solutions provide adaptability. Tools like FACILEX® can be reconfigured for new requirements without programming, ensuring that the facility can respond quickly and efficiently.
Improved Data Visibility and Reporting
Compliance solutions offer advanced reporting and visualization (e.g., through Power BI), providing insights into overdue tasks, upcoming deadlines, and overall performance. This data enables informed decision-making and resource allocation.
Cost Avoidance
Effective compliance management prevents costly incidents, regulatory penalties, and reputational damage. Non-compliance in economically significant facilities can lead to losses exceeding $100 million annually.
Robust compliance management solutions are required for PSM-covered facilities to enhance safety, reduce risks, and maintain regulatory alignment while achieving operational efficiency.
Complex and Overlapping Regulatory Landscape
High Stakes in Safety and Risk Management
Multi-Level Accountability
Managing Diverse Requirements
Assurance and Monitoring Challenges
Specialized Knowledge Requirements
Data Management and Reporting
Resource and Time Constraints
Organizational and Cultural Barriers
Adaptability to Change
A key element of OSHA Process Safety Management (PSM) is the requirement for, and adherence to, a Management of Change (MOC) procedure.
Before change Implementation:
After change Implementation:
The OSHA Process Safety Management (PSM) regulation requires a Management of Change (MOC) procedure to be initiated for asset changes (process chemicals, technology of the process, equipment and facilities) as well as procedures. Furthermore, there is an evolving consensus that organizational changes are also changes that should be managed by MOC. The exception is when the change is a Replacement in Kind (RIK).
“Replacement in Kind” (RIK) in the context of OSHA’s Process Safety Management (PSM) regulation, allows certain replacements that meet original design specifications to bypass the formal Management of Change (MOC) process.
There are three primary assumptions that guide Replacement in Kind (RIK) decisions.
The OSHA Process Safety Management (PSM) standard, identifies Process Hazard Analysis (PHA) as a critical component for identifying, evaluating, and controlling potential hazards associated with processes that involve hazardous chemicals. The analysis involves a systematic review of potential failure points, human errors, and equipment malfunctions that could lead to releases or other hazardous events.
API Recommended Practice 1173 (API RP 1173) outlines a Pipeline Safety Management System (PSMS) framework to help pipeline operators manage safety risks, improve operational reliability, and foster a culture of continuous safety improvement. It emphasizes proactive risk management, leadership commitment, stakeholder engagement, and learning from safety-related events to enhance overall pipeline safety.
API RP 1173 Pipeline Safety Management System (PSMS) and OSHA 1910.119 Process Safety Management (PSM) standard both focus on managing safety risks in industrial operations, but they have distinct scopes and emphases.
OSHA 1910.119, the Process Safety Management (PSM) standard, specifically targets facilities that handle hazardous chemicals above certain threshold quantities, such as refineries and chemical plants. In contrast, API RP 1173 is tailored to pipeline operators, addressing the unique risks associated with transporting hazardous liquids and gases over long distances.
Both standards emphasize risk-based safety management, but API RP 1173 is structured around a broader safety culture for continuous improvement and risk management tailored to the pipeline industry. OSHA PSM is more prescriptive, with specific requirements for elements like hazard analysis, mechanical integrity, and process design.
The Center for Chemical Process Safety (CCPS) guidelines complement both the OSHA PSM standard (29 CFR 1910.119) and API RP 1173 Pipeline Safety Management System (PSMS) by providing comprehensive best practices and tools that enhance safety management within hazardous industries.
CCPS guidelines were instrumental in shaping the OSHA PSM standard, and they continue to provide more detailed, in-depth guidance on implementing each PSM element. For example, CCPS covers advanced methodologies for hazard analysis, mechanical integrity, and emergency preparedness that support facilities in meeting OSHA’s regulatory requirements.
CCPS guidelines offer broader safety management principles that align well with RP 1173’s goals. CCPS emphasizes creating a safety culture, continuous improvement, and robust incident investigation—key areas also highlighted in RP 1173. CCPS guidelines provide a toolkit for API RP 1173’s framework, enabling pipeline operators to adapt best practices from the chemical process industry to their own safety systems.
Both API RP 1173 and OSHA PSM promote risk management and a proactive safety culture, and CCPS guidelines delve into these areas with additional strategies for leadership commitment, workforce engagement, and risk-based decision-making. CCPS’s focus on human factors and operational discipline can strengthen compliance with both standards and enhance an organization’s overall safety performance.
In summary, CCPS guidelines serve as a rich resource for both OSHA PSM and API RP 1173 by offering practical, advanced insights that support and enhance compliance while promoting an integrated approach to safety management across hazardous industries.
The EPA Clean Air Act Risk Management Plan (RMP) Rule, found in Section 112(r) of the Clean Air Act, is a regulation designed to prevent chemical accidents that could harm public health or the environment. The RMP rule requires facilities that use, store, or handle significant quantities of certain hazardous substances to develop and implement a Risk Management Plan. Key aspects of the RMP rule include:
The RMP rule applies to industries such as chemical manufacturing, oil and gas processing, and large-scale agricultural operations that use chemicals like ammonia or chlorine. The RMP rule ultimately seeks to protect public health, community safety, and the environment by preventing catastrophic chemical accidents and ensuring coordinated emergency response plans.
Federal EPA standards and regulations complement the OSHA Process Safety Management (PSM) standard, 29 CFR 1910.119, particularly through the Risk Management Plan (RMP) rule under the Clean Air Act, which focuses on preventing and mitigating chemical accidents. Here’s how they are integrated and aligned:
In essence, EPA standards supplement OSHA PSM by focusing on environmental and public safety impacts, while the two standards collectively ensure comprehensive risk management for facilities handling hazardous chemicals.
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