Compliance with OSHA's Process Safety Management Performance Based Standard

OSHA published the Process Safety Management (PSM) standard in 1992. At that time it was viewed as one of the first performance-based regulations in the US. Previous OSHA regulations were viewed as prescriptive or specification based where all documentation and reporting requirements are included. What made the OSHA PSM standard performance-based was the expectation that each covered facility would need to develop a PSM program and would need to then implement the elements of that program.

A book on environmental, health and safety management describes the difference between specification and performance based standards.

"A specification standard is one where there is no subjectivity. Everything one needs is clearly stated in black and white. Performance based standards, on the other hand, leave much of the decision making to the employer."

The term performance based standard is used quite often in reference to the OSHA PSM Standard, but what does it mean? The only specific use of this term is in Section III, Summary and Explanation of the Final Rule, in this comment made by the CMA (The Chemical Manufacturer's Association).

“Initially CMA would like to commend OSHA on its efforts to craft a comprehensive performance based standard addressing process safety management of highly hazardous chemicals. As CMA has commented in past rulemakings, performance language capitalizes on industry’s ingenuity and capability to effectively reduce hazards as they may be uniquely applied to a particular safety concern.”

In a paper that discusses chemical process safety management within the Department of Energy, the term is also used:

“The PSM Rule is a performance-based standard that defines the elements of an effective chemical process safety program. This encourages innovative solutions to address fundamental safety issues. It does not prescribe how each element is to be implemented 1) due to the impossibility of addressing the diversity of chemical processes that exist, and 2) the performance-based approach developed by the chemical industry had been shown to be effective."