Non-Digital Method of Process Safety Management (PSM) Compliance, OSHA PSM and EPA RMP Rulemaking Initiatives, and Methodology to Estimate Related Economic Impact on PSM Facilities in the United States of America

Over the years, process safety management (PSM) program development and implementation has benefited the operating facilities in terms of successful avoidance of process safety incidents, and related business losses arising due to equipment damage, production interruption and environmental damage. PSM covered facilities have also reported improved personal injury record through successful implementation of an applicable, regional PSM standard. However, there is still a need to address both the efficiency and effectiveness aspects related to non-digital (manual) PSM program development, implementation, audit, and compliance. There has been continuous reporting of significant process safety incidents even after the promulgation of process safety management regulations both in the United States and globally. The uncertain macroeconomic and political conditions have also forced the governments to allocate less than required fiscal budget to their regional regulatory bodies to address any ongoing operational efficiency concerns in successful enforcement of their PSM regulation. This research paper will investigate and discuss the key issues faced by both the government regulatory bodies and process plant facilities, with the current non-digital (manual) method of PSM implementation, audit, and compliance. Moreover, recent modernization initiatives of safety regulations undertaken by federal regulatory bodies such as OSHA and EPA in the United States are described and discussed in the context of achieving the PSM compliance effectively and efficiently. The paper will also discuss detailed comparison between OSHA’s 1992 regulatory impact analysis study and 2023 information collection requirement burden hour and cost estimate and will outline a methodology to estimate the total economic burden of PSM compliance on the existing and future PSM covered facilities in the United States. The methodology to adjust (correct) OSHA’s PSM compliance cost estimates are based on accounting key regulatory, industrial, organizational, and economic factors prevalent in the global process plant industry.