SAFETY MANAGEMENT

Peer-Reviewed

PROCESS SAFETY
MANAGEMENT
Improving Safety
Performance Beyond
the Chemical Industry
By Alex Sellers and Susan L. Murray

INDUSTRYVIEW/ISTOCK/GETTY IMAGES PLUS

20 PSJ PROFESSIONAL SAFETY NOVEMBER 2025 [Link]

P
PROCESS SAFETY MANAGEMENT (PSM) deals with the iden- have other hazards that may represent high safety and
tification, understanding and control of process hazards health risks to control, such as heat or pressure hazards.
to prevent process-related injuries and incidents (Amyotte While many different sectors could likely benefit from
et al., 2007). OSHA defines a “process” in 29 CFR 1910.119 the holistic approach PSM provides, mining, smelting and
as “any activity involving a highly hazardous chemical in- other non-PSM-covered manufacturing are some exam-
cluding any use, storage, manufacturing, handling, or the ples where the approach may have a significant impact.
on-site movement of such chemicals, or combination of The PSM standard establishes 14 individual elements.
these activities.” OSHA (2013a) goes on to define “highly Some elements are easily transferrable and usable for
hazardous chemical” to mean “a substance possessing non-process industries, while others might be more dif-
toxic, reactive, flammable, or explosive properties and ficult to apply. Some represent opportunities for large
specified by (the regulation),” and the organization pro- impacts in other sectors, while others may already exist
vides a full list of chemicals that fall into this category. to some degree or may be less impactful. In this article,
Because of the hazards associated with these chemi- each element is discussed in detail as well as some po-
cals and a string of major incidents, including the Bhopal tential methods for adapting them for use outside of the
incident in India that killed more than 3,800 people in traditional process industries for which they were origi-
1984 (Broughton, 2005), OSHA promulgated 29 CFR nally intended.
1910.119, commonly referred to as the PSM standard, in
1992 (Schmidt, 2012). This standard lays out a specific set History of Process Safety Management
of requirements that facilities under the standard must PSM has existed as long as people have been trying to
adhere to. These standards have largely been effective in protect themselves from getting hurt by the tools and
reducing risk in PSM-covered facilities, although some substances (or energy) used in work. From a modern
subsections of this group have experienced more success perspective, the roots lie in the industrial revolution. As
in implementation and results than others (Behie et al., processes were mechanized, new chemicals were being
2020). It is important to note that other regulatory frame- created and used, and higher energy levels came into play,
works and voluntary standards addressing PSM have been there was more need to protect workers (and equipment)
developed in other regions, including the European Union, from the new hazards associated with them. Throughout
U.K., India and China (Besserman & Mentzer, 2017) and by the late 1800s and early 1900s, societal expectations sur-
other standards organizations. In the context of this article, rounding safety and risk began to shift, driving further
OSHA’s PSM standard serves as the foundational frame- improvements. In the late 1950s and early 1960s, PSM
work for analysis of adaptation of PSM into other sectors. started to become a field of its own, with independent
Although OSHA focused PSM regulations on facilities studies, conferences and papers appearing on the subject
using highly hazardous chemicals, many of the tools and (Hendershot, 2009). Some key techniques, such as process
techniques associated with PSM can be leveraged to im- hazard analysis (PHA), were developed during this time.
prove safety and health in facilities in other sectors. This Because of the potential for high-consequence events
may be particularly true in facilities or sectors with high- affecting more than just a few onsite workers, many con-
risk environments that do not have enough of a covered sidered process safety more critical than functional safety
chemical to meet the thresholds in OSHA’s standard but from a risk perspective (Hendershot, 2009).
The focus on process safety increased exponentially
KEY TAKEAWAYS in the 1980s with a string of disasters involving highly
•utilized
Process safety management (PSM) techniques have been
by the traditional process industries (e.g., petro-
hazardous chemicals. Potentially the most influential
was the incident at Union Carbide in Bhopal, India,
chemical, refinery, food manufacturing facilities) for decades. where water entered a methyl isocyanate tank and began
Many industries with highly hazardous chemicals have been a series of events leading to a catastrophic release and
required to use PSM techniques for more than 30 years per more than 3,800 deaths and more than 100,000 injuries
OSHA’s PSM standard, which was promulgated in 1992. Tools (Schmidt, 2012). In 1985, the Center for Chemical Pro-
such as process hazard analysis, prestartup safety reviews, cess Safety (CCPS) was formed as part of the American
and mechanical integrity programs are second nature for Institute of Chemical Engineers by 17 charter compa-
these companies and have helped drive improvements in safe- nies and began work on Guidelines for Hazard Evalua-
ty metrics, as well as in other areas such as operational costs tion Procedures (Hendershot, 2009). This was the first
and quality performance. step toward modern PSM as we know it today. In 1992,
• Outside of these industries, much of the focus has remained
on personal or behavioral-based safety. The adoption of PSM-
OSHA promulgated 29 CFR 1910.119, also known as the
PSM standard. The requirements under this standard
style techniques and holistic review of facility risk has largely continue to serve as the framework for process safety for
been limited. those industries that fall under the standard’s jurisdic-
• The OSHA PSM standard establishes 14 separate elements
of process safety management. Some of these elements used
tion in the U.S.

in process safety, such as mechanical integrity, could easily 14 Elements of Process Safety Management
be applied to other sectors. Others such as process hazard The OSHA standard lays out 14 elements that must be
analysis may require some adjustment. This article reviews addressed by a PSM program to achieve compliance. Each
each of the individual 14 PSM elements to discuss how each element is shown in Figure 1 (p. 22).
one might be applied outside the process industries and ad- Each element is an important part of the whole pro-
dresses why this approach is worth consideration. gram and helps to guide employers through the three

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 phases of the safety life cycle FIGURE 1
analysis, implementation and 14 ELEMENTS OF OSHA PSM
operation. The life cycle takes
a cradle-grave-cradle ap-
proach, ensuring that process
information—including limits
and procedures—are docu-
mented and updated, process
hazards have been evaluated,
risks have been mitigated
and protections continue to
be validated. If changes are
made, the life cycle starts
again to ensure continuous
protection, confirming that
even incremental changes are
addressed and new hazards
are identified and mitigated.
Most of the 14 elements of
PSM correspond to the phases
of the life cycle, as shown in
Figure 1, although some may
manifest themselves in multi-
ple phases (Schmidt, 2012).
It should be noted that not
all elements are predicted to
have the same level of impact
on an organization’s safety and health performance. Ad- a shift in culture may be required at some organizations
ditional focus is provided on elements that would likely to allow frontline employee involvement in some of these
bring the most additional value, such as process hazard activities as well as to recognize the importance of that in-
analysis and prestartup safety review. That is not to say volvement and dedicate the time and resources to ensure
that other elements are not critical; They are all inter- that it is possible. While this element is unlikely to have a
connected, with each playing a key role in the success of major impact on safety performance itself, it is listed first
others, but some (e.g., training, contractors, trade secrets) in this article given the criticality of open communication
likely exist to some degree in most organizations or play and 360° feedback from employees in the overall success
a minor role in support of the others and would therefore of the other foundational elements. If the other elements
be less likely to provide the same added value as other are performed in a vacuum without the involvement of
elements. This should not be interpreted as a reflection frontline staff, much if not all the effectiveness is lost.
of their importance. As an example, incident investiga-
tion and emergency planning and response are critically Process Safety Information
important to successful safety and health programs, but The process safety information element requires em-
those do not receive particular focus in this context as ployers to share information related to the hazards of the
they are generally covered by other regulations or in- highly hazardous chemicals, technology and equipment in
dustry best practices. This article outlines a summary of the process. This information is meant to help employees
each element and how they could be applied outside of better understand the process and enable them to make
the process industry. Generally, these are arranged in an safer decisions involving the operations and maintenance
order that aligns with the safety life cycle shown in this of the process. OSHA also requires that this information be
article, a sequence that could also serve as a step-by-step kept up to date. Manufacturers outside the process indus-
instructional guide to facilitate an orderly rollout for tries may have a system in place to keep up with this type of
an organization wishing to implement a program based information and share it with employees, but it is certainly
around these elements. done in many industries and is not particularly specific to
process industries. For applications outside process indus-
Employee Participation (Involvement) tries, this information sharing would expand from process
Employee participation is included in the PSM standard specific to include all equipment and materials that may
to ensure that the employees working with the process create hazards for employees. OSHA’s hazard communica-
(frontline operations and maintenance staff) are involved tion standard already requires employers to provide safety
in the process safety program and understand the hazards data sheets that include the hazards of any chemicals that
and their roles in preventing harm from those hazards. their workers may encounter. However, that alone would
OSHA requires a written plan to be in place and followed. not meet the requirements of the PSM standard. Com-
It is easy to see that this requirement theoretically would panies must go further to include information about the
not be difficult to implement in any industry if the other equipment and technology being used and how employees
elements are in place for employees to participate in. Yet, might be affected.

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 Many industries outside of PSM requirements have require updated nondisclosure agreements with employ-
documentation and maintenance programs to ensure ees and a potential attitude shift for some executives.
that technical specifications related to their operation are This element is listed early along with the process safety
documented and kept current. If the employer has this information element to highlight the importance of
type of system in place already, this requirement is likely sharing complete information with employees, regard-
relatively easy to comply with, assuming that the com- less of trade secret status, as this is critical to ensuring
pany is willing to share this information with employees that the information employees receive to help them
in a way that helps them understand the hazards of their identify and mitigate hazards is complete. Implemen-
workplace. In cases where an employer does not have a tation of this requirement would likely take the form of
robust system in place for this documentation, building ensuring that information is not withheld unnecessarily
an information repository could be a large undertaking. as part of the employee involvement and process safety
This information is also key in other aspects of business information elements.
operations, as it can facilitate better operations and main-
tenance practices as well as help to reduce downtime and Process Hazard Analysis
increase efficiency and quality over the long term. This The process hazard analysis (PHA) element is one
information is critical for implementing other elements. It of the most technical elements of PSM and is likely to
could even be considered a prerequisite for other elements be one of the more difficult aspects for non-process-­
that follow, hence the importance of an early focus on oriented facilities to implement. It is also likely the
compliance in this area. element with the most opportunity for impact when im-
plemented correctly in a holistic manner. This element
Trade Secrets requires processes to be reviewed by someone familiar
The trade secret element of PSM essentially states that with the process’s engineering design as well as someone
companies cannot keep process details from employ- familiar with the operation of the process. Due to em-
ees by declaring them “trade secrets” (OSHA, 2013a). ployee involvement requirements from the first element
In the past, many companies would do this under the discussed, this is normally a diverse team that includes
guise of protecting their competitive advantage. OSHA frontline employees. The PHA element also requires that
ruled that this reasoning is not appropriate in the case someone who is “knowledgeable in the specific process
of companies working under the PSM standard, and it hazard methodology being used” participate in the pro-
could easily be argued that it is never appropriate when cess (OSHA, 2013a). The first two requirements for par-
those details could affect employee safety and health. ticipants are likely not an issue for most employers other
This requirement is not difficult to implement but could than the cost of the time these employees would dedicate

TABLE 1
HAZOP ALTERNATIVE DEVIATION EXAMPLE: CONVEYOR BELT
Deviation Cause Consequence Safeguards L C R
High flow VFD failure; Wrong setpoint Overwhelm downstream equipment, back up Operator monitoring speed
entered material leading to ergonomic strain or other with Estop button to shut
minor injuries, equipment or product damage down belt, Setpoint limitation
Low flow WFD failure; Wrong setpoint Loss of production-operational issue Operator monitoring speed
entered
Misdirected Guards failed on edges of belt; Employee exposure to falling material; Exposure to Lockout/tagout procedure;
flow Guards not replaced after moving parts; Trip hazard associated with spilling Employee rounds to identify
maintenance; Unevenly material; Fire hazard due to spilled material spills; preshift inspections
distributed material on belt
causing spillage
No flow VFD failure; Wrong setpoint Loss of production-operational issue Operator monitoring speed
entered; loss of power
Electrical Wiring short due to short in motor, Electrical shock Weekly inspection
deviation animal or pest activity, vibration, documented by maintenance
etc. department; Preshift
inspection by operator; Pest
control measures; High-
vibration alarm
Machine Vibration leading to machine See “misdirected flow”
guarding guarding failures; Guards not
replaced after maintenance
Human Manual handling of material from Confined space and moving parts hazards Permit-required confined
factors or end of the conveyor; Freeing stuck (asphyxiation, exposure to harmful environments, space program, job safety
ergonomics items or materials; Accessing head moving parts, etc.); Ergonomic exposure due to analysis program to identify
and tail pulleys for maintenance bodily exertion, requirement for abnormal work hazards associated with
angles; Repetitive motion specific activities; Job rotation
to limit repetitive motion
exposures

Note. L = a likelihood metric, C = consequence, and R = risk resulting from the stated likelihood and consequence

[Link] NOVEMBER 2025 PROFESSIONAL SAFETY PSJ 23

 to the process. The last requirement could be met by Note that this is meant to be a representative sample of
utilizing a third-party consultant who is familiar with some traditional PSM guide words that could be used and
hazard identification and analysis or by having someone the resulting cause-consequence pairs and safeguards.
on site trained in relevant methodology. It is not meant to be a complete review of this piece of
One of the main issues non-process facilities may have equipment. For this reason, the cause-consequence pairs
in implementing this requirement is that the methodolo- are not risk ranked. To complete the review, a company
gies available to facilitate PHAs focus on finding hazards would need to develop and utilize a risk tolerance criteria
in a chemical processing plant. This means that they fo- matrix and use it to risk rank each pair by estimating
cus on process equipment such as vessels, tanks, piping, likelihood and consequence ratings and adjusting for
heat exchangers and pumps. The most popular, the haz- safeguards. Once complete, a holistic view of risk for this
ard and operability (HazOp) study, uses deviations such piece of equipment has been generated. The key takeaway
as high and low pressure, temperature and flow to assist of this example is that tools such as HazOp can be adjust-
team members in identifying hazards by compelling them ed to facilitate reviews on nonstandard PSM equipment.
to review each deviation for each piece of equipment. An These methods and other traditional PHA methods
example of identifying a hazard using this technique in a could also be paired with other hazard identification tools
non-process setting is a potential of no cutting fluid flow- that are currently being used more frequently in other in-
ing during an operation, resulting in damage to equip- dustries such as job safety or hazard analysis or pretask risk
ment and potentially an operator injury. In this case, “no assessments to develop a comprehensive review of risk in
flow” could be the deviation. In the process industry, this a facility that is comparable to the thoroughness provided
technique and the traditional deviations generally provide by a process facility’s PHA. Opportunities exist to leverage
a comprehensive review. However, many of these con- artificial intelligence tools in conjunction with traditional
ventional deviations (e.g., high flow, low mixing, reverse tools and employee knowledge and experience to perform a
direction) may not apply in many situations outside the holistic, risk-based review of a facility. While not the focus
process setting and would be less effective in identifying of this article, this technology is having profound impacts
non-process-related hazards (e.g., those not related to on the field of worker safety and there are many use cas-
temperature, pressure or flow). es for improving worker safety and health in the future
While just having a diverse team set aside time to (Fiegler-Rudol et al., 2025). The PHA process likely may not
review a manufacturing facility for hazards is likely a be easy for all industrial facilities to replicate but attempting
worthwhile process, having a way to systematically review to replicate the holistic view of risk that this type of hazard
a facility and determine the risk associated with each analysis can provide is a worthwhile endeavor.
cause-consequence pair is key to ensuring a reasonably
holistic coverage of hazard assessment and risk mitiga- Operating Procedures
tion across the board. While the existing tools may not Operating procedures (as well as maintenance and
translate completely across to other situations, some ways start-up procedures) should be an important part of every
exist that a team could adapt the method to make it more industrial facility’s plan for safe operation. These should
broadly applicable. also be developed relatively early in the design of a pro-
One possible method would be to focus on consequenc- cess so staff can be trained as part of commissioning be-
es as a scenario development driver instead of causes. For fore operation commences. Some legal requirements exist
example, instead of considering that high temperature for procedures (e.g., lockout/tagout, emergency response),
could melt a gasket, cause a release of hot material and but they are not seen as a legal necessity in many cases.
burn an operator (which would be the traditional train Sometimes, this means that procedures are nonexistent,
of thought in a HazOp), the team instead could ask how insufficient, or not updated to reflect current practices
an operator could get burned in this situation (answer: by accurately. Procedures should include several elements,
this piece of equipment or by deviations of normal oper- including PPE requirements, any operating and safe lim-
ation associated with this piece of equipment) and work its that may apply, a way to highlight critical steps, and
backward to achieve the same cause-consequence pair enough detail to communicate steps clearly without un-
result. This approach is likely more ubiquitous, as conse- necessary requirements. Procedures should be written not
quences such as burns, struck-by, exposed-to and others only for normal operations but also for emergency situa-
can be caused by different types of equipment. Teams tions, start-ups, shutdowns and maintenance. The proce-
could also generate deviation keywords to focus on haz- dures should be reviewed at least annually and any time
ards outside of process causes (e.g., electricity, lifting or a change is made to equipment or practices. Employees
ergonomics) in addition to traditional guide words such should be trained on the procedures in their initial orien-
as high flow or low flow. If a team selects guide words that tation and any time the procedures are updated. If proce-
are applicable from a prepopulated list before or during dures are not updated often, refresher training should be
the review, a meaningful, comprehensive review could be considered annually. Procedures should be audited on a
facilitated. Table 1 (p. 23) provides an example of how a regular basis to ensure continued accuracy.
mixture of traditional and unconventional deviations or
guide words could apply to a conveyor belt. Note that “L” Training
is a placeholder for a likelihood metric, “C” is for conse- Workers should be trained on how to perform any task
quence, and “R” is for the risk resulting from the stated they are asked to complete and how to use any equipment
likelihood and consequence. In a real-world risk review, they are asked to operate. The requirements for training
these would be used to risk rank cause-consequence pairs. parallel those for procedures and were discussed in the

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previous section. All training should be documented, and emphasis is to ensure that the contractor understands the
trainers should document qualifications in both the area facility and job hazards and is properly trained to handle
of expertise and training methods. Training should also them. Many facilities have safety orientation processes for
be audited on a regular basis. This would likely not be a contractors that likely meet these requirements, even out-
new practice for most industries, although meeting the side the process industries.
detailed expectations of the PSM standard may require an
organization to improve in this key area. Mechanical Integrity
Mechanical integrity programs are vitally important
Emergency Planning & Response to operating a facility in a safe and economical fashion.
Emergency planning and response are particularly vital The PSM standard calls out specific equipment for which
at sites handling highly hazardous chemicals, so it should mechanical integrity programs are required such as pres-
come as no surprise that OSHA includes it as an element sure vessels, storage tanks, piping systems and ventilation
of the PSM standard. There are also requirements for systems. The PSM standard requires that documented
emergency planning and response for facilities in general inspection programs are required for these pieces of
that should be followed regardless of PSM status or the equipment with the expectation that any equipment
presence of highly hazardous chemicals. This is an area that does not meet inspection requirements is repaired
in which most companies of a certain size should already or replaced. Those conducting the inspections must be
have policies and procedures in place. If a company does trained, and the guidelines that are used to perform
not have these in place, it is likely behind and should do inspections must follow “recognized and generally ac-
so as soon as possible. cepted good engineering practices” (OSHA, 2013a). This
normally means finding an industry standard such as the
Prestartup Safety Review American Society of Mechanical Engineers, American
Prestartup safety reviews are required by the PSM stan- Petroleum Institute, National Fire Protection Associa-
dard for new and modified processes before the process is tion, or another nationally or internationally recognized
first put into service or returned to service. This process standard. Internal standards can also be developed but
normally reviews the process for physical hazards that require the same level of rigor as would be expected by a
could not be identified during the design review (PHA) recognized standard.
and ensures that the process has been built according to Mechanical integrity programs are another element
specifications with no new hazards introduced. It can that likely exists in some form in most industrial facili-
also serve as an opportunity to confirm assumptions ties, often to comply with warranty requirements, insur-
made during the design phase hazard review and ensure ance requirements or other industry best practices, but
that staff are prepared to safely interact with the process in many cases these programs are not developed to the
through proper training on operating procedures. To be extent required by PSM. This is another area where im-
clear, the “start-up” in this instance is more akin to the provements can not only drive improved safety metrics,
commissioning process for non-process equipment, al- but also reduce downtime, increase efficiency and reduce
though there may also be some cases where it could also overall operating expenses, particularly when leveraging
apply to the initial start-up of something like an oven or a computerized maintenance management system to
industrial furnace. However, it is not referring to every track activities and trend data. In many cases, mechanical
time a machine that is designed to be shut off frequently integrity programs have been found to have a relatively
(e.g., a drill, hydraulic press) is restarted, although a mini high return on investment, but these programs require
version of a prestartup safety review could be considered additional resources.
in some of those cases.
Some manufacturing companies may have a version Hot Work Permit
of prestartup safety reviews, but in many cases, it is Hot work permits require workers to fill out a written
not as robust as the expected standard in the process permit and take certain precautions before performing
industries. Templates are available to help facilitate pre- hot work such as welding. Hot work permits are common
startup safety reviews. Much of the content could apply outside the process industry, so it is likely that other in-
to industries outside the process industries as well as the dustries have already adapted a version of the hot work
process industries themselves, but they may need to be permit process. If they have not, examples and templates
modified to fit specific circumstances. The overarching are available, and the permits can easily be incorporated
principles remain the same: to ensure that the equip- into maintenance practices. It is important to keep re-
ment has been built as designed, to confirm that no new cords of hot work permits and to audit the permit system
hazards were introduced as a result of the new construc- to ensure that employees are following the company’s
tion or modification or new equipment, and to ensure policy. It can also be helpful to consider whether hazards
that operators are prepared to operate the equipment in other than fire hazards could require a permit system. Ex-
a safe and consistent manner. This element may require amples might include toxic fumes, high or low tempera-
some extra work for non-process industries but should tures, electrical or arc-flash exposure, working at height
be relatively easily obtainable. or crane lifts. A permit system for high-hazard work
requires additional scrutiny, risk assessment and mitiga-
Contractors tion, and documentation such as hot work as well as other
The PSM standard’s requirement for contractors mir- high-risk tasks is highly recommended for consideration.
rors some requirements for employees. The main point of In addition, many countries already require permits for

[Link] NOVEMBER 2025 PROFESSIONAL SAFETY PSJ 25

 high-risk work, which is also starting to take hold in some hazards, unstable ground, insects). This approach al-
companies in the U.S. lows workers to capture information over time in the
base risk assessment document and benefit from that
Management of Change compilation of historical knowledge, and it ensures that
Management of change may be the most overlooked as- they are engaged in the dynamic aspects of work that
pect of PSM. According to the PSM standard, the purpose are likely to be impacted by circumstance. This prin-
of management of change is to manage changes to process ciple could be more broadly applied in similar ways to
chemicals, technology, equipment and procedures, as well address process or equipment-based hazards, focusing
as changes to facilities that affect a covered process and on aspects that do change.
their impacts on safety and health. This generally means Without a robust management of change, even the
that these types of changes are reviewed for hazards, and best PSM programs can fall apart over time. The keys
all relevant documentation is updated appropriately. If to implementing management of change are to clearly
implemented correctly, management of change can be identify what changes require action and what those ac-
a massive undertaking requiring many resources and tions are, and have a system (preferably software-based)
constant vigilance in a facility where change frequently that can handle tracking and sign-off. This piece of PSM
occurs. Whereas many of the other elements require a is often the last to be done correctly. It requires intense
large amount of upfront work but relatively little effort to dedication from management to implement and often
sustain, management of change requires a large amount of requires substantial resources. Although management of
continuing focus and ongoing work. It also is a vital piece change is difficult and time-consuming to implement, it
of the puzzle that helps ensure that all other elements are can be seen as the keystone to the process of sustaining a
up to date, documentation is updated appropriately, and PSM program. As with several other elements, this is not
changes are reviewed to assess hazards so that new hazards an insurmountable practice to apply to any facility. The
are not introduced into the workplace without an opportu- challenge is threefold: first defining what changes must be
nity for identification and risk mitigation. managed in a way that is clear, consistent, reasonable and
The critical aspects in setting up a management of change effective in preventing new hazards being created because
program are defining what changes qualify for inclusion of changes; second, providing the resources necessary to
or review under the program and, once identified, what carry out this program (both tools and time); and third,
type of review or action is necessary to ensure that hazards driving the culture in the organization to embrace the
associated with the change have been mitigated. While the mindset of continual evaluation of changes to identify
OSHA standard is relatively clear regarding what changes and mitigate new hazards.
are covered under the PSM standard, it may be less clear
when building a program in other sectors. Ultimately, the Incident Investigation
definition of a change should be tailored to meet the intent The PSM standard requires an investigation be per-
of the program—identifying and mitigating new hazards formed for incidents that result in or could have resulted in
associated with the change—but there are some standard a catastrophic highly hazardous chemical release. Incident
items to consider including. New chemicals or substances investigation has become mainstream regardless of the in-
(e.g., a new paint) being introduced into the workplace is a dustry and whether highly hazardous chemicals are in play.
good place to start, as there are likely other requirements Many examples and guidelines exist for non-process indus-
(such as hazard communication) within OSHA or other try companies to follow associated with incident investiga-
standards that must be met that can be managed through a tion and root-cause analysis for those companies that do
management of change process. Other changes to consider not already have a system in place. Incident investigation
can include material changes to equipment or new machin- and, to take it one step further, near-miss investigation is
ery, different modes of operation or human interfacing with critical to identifying root causes and gaps in current prac-
equipment, changes to the work environment, or changes tices that can drive better safety performance in the future.
to procedures or tasks. Once a covered change has been
defined, systems can be put in place within procurement, Compliance Audits
construction and maintenance processes to help facilitate The compliance audit element of PSM reads, “Employ-
hazard reviews or documentation updates in line with the ers shall certify that they have evaluated compliance with
hazards and risk of the change. the provisions of this section at least every three years
Management of change also brings both the tools and to verify that the procedures and practices developed
mindset to help make PSM more broadly applicable to under the standard are adequate and are being followed”
processes, equipment and work practices that are high- (OSHA, 2013a). This element is easy to understand and
ly dynamic. Templates or software that are specifically implement once a program is in place. The overarching
developed to pinpoint the hazards associated with a goal is to ensure that the organization is following the
change versus starting from scratch with a full hazard other elements per its requirements and the requirements
review can help turn a burdensome process into some- of the organization’s own internal procedures. A third
thing nimbler. A task-based example of this would be party is usually the most effective way to conduct a reli-
having baseline risk assessments or job safety analyses able audit, although it is not required. This element also
that outline normal risks associated with the task that requires employers to retain their two most recent audit
are fairly static, in addition to dynamic risk assess- reports at a minimum. This is a good practice in any in-
ments that focus on aspects of the job that may change dustry, as there are other legal ramifications associated
given a specific situation (e.g., weather hazards, traffic with not following internal policies and procedures.

26 PSJ PROFESSIONAL SAFETY NOVEMBER 2025 [Link]

Process Safety Management Justification Implementation of such a program requires resources and
According to a study performed by CCPS, process safe- support from management or executives, but multiple
ty provides benefits in four areas: corporate responsibility payoffs in the form of improved safety metrics, greater
and business flexibility—which are qualitative—and risk operational efficiency and lower operating costs are likely
reduction and sustained value—which are quantitative to result (Porter & Grubbe, 2018). PSJ
(Berger, 2012). The benefits associated with corporate
responsibility include developing a good company image References
and reputation toward both the public and employees, Amyotte, P.R., Goraya, A.U., Hendershot, D.C. & Khan, F.I.
(2007). Incorporation of inherent safety principles in process safe-
which go toward building a reputable brand, and good
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Conclusion
Process safety management consists of many tools Cite this article
that have value in other industries. It is possible to cre- Sellers, A. & Murray, S.L. (2025, Nov.). Process safety
ate a program for non-process industries that resembles management: Improving safety performance beyond the
chemical industry. Professional Safety, 70(11), 20-27.
PSM. Many of the main elements of PSM can be eas-
ily transferred, while others may require adaptation.

Alex Sellers, M.S., P.E., CSP, CHST, is a global programs across the construction, appointments as Professor of Psychological
Ph.D. candidate at Missouri University of Sci- facilities, finance and technology sectors. He Science and Professor of Engineering Man-
ence and Technology (Missouri S&T) specializ- is currently Director of EHS, Policy and Gov- agement and Systems Engineering at Missouri
ing in workplace safety and risk. He holds an ernance, at Ascent, a data center solutions S&T. She holds a Ph.D. and B.S. in Industrial
M.S. in Engineering Management and a B.S. company that designs, builds, and operates Engineering from Texas A&M University, and
in Civil Engineering. Sellers began his career mission critical infrastructure. Sellers is a an M.S. in Industrial Engineering from the Uni-
in process safety, later transitioning to lead member of ASSP’s St. Louis Chapter. versity of Texas-Arlington. Her research and
mining and smelting, where he became inter- teaching interests include occupational safety
ested in the expanded application of process Dr. Susan Murray, Ph.D., P.E., is the and health, human factors, and industrial
safety management methods. He has led EHS Associate Provost for Teaching and Curricular psychology. She frequently serves as an expert
and sustainability teams in implementing Excellence at Missouri S&T. She also holds in legal cases involving incidents and injuries.

[Link] NOVEMBER 2025 PROFESSIONAL SAFETY PSJ 27