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.
Compliance with OSHA’s PSM Performance Based Standard requires considerable effort to stay in compliance with a performance based standard like OSHA PSM. It requires a good understanding of the RAGAGEPs that apply to your facility and ensuring that the PSM program procedures incorporate these requirements. It requires constant vigilance to stay up to date on changes to RAGAGEPs since many industry standards are reissued every few years. And it requires an effective compliance audit program to verify that procedures include all applicable RAGAGEPs and that the procedures are being implemented as written.
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