Process Safety Management (PSM) Gap Assessment
Overview
Mayford conducted a Process Safety Management (PSM) gap assessment for a chemical manufacturing facility in Pakistan, evaluating the plant's existing safety management practices against the 14 elements of OSHA 29 CFR 1910.119, the CCPS Risk-Based Process Safety (RBPS) framework, and relevant local regulatory requirements. Over a 6-week on-site engagement, the team reviewed documentation, interviewed 42 personnel across operations, maintenance, engineering, and HSE functions, and inspected field conditions. The assessment identified 38 gaps — including 7 critical findings related to Management of Change (MOC), mechanical integrity, and operating procedure currency — and delivered a prioritized 18-month improvement roadmap.
The Challenge
The facility had been operating for over 20 years and had never undergone a formal PSM assessment against international standards. While the plant maintained an acceptable lost-time injury rate, two recent process safety incidents — a relief valve failure on a reactor vessel and an uncontrolled exothermic reaction during a batch changeover — indicated underlying weaknesses in process safety management. The client's insurance underwriter recommended a comprehensive PSM evaluation as a condition of policy renewal, and the parent company's corporate governance framework required alignment with CCPS RBPS guidelines within 24 months.
Our Solution
Mayford evaluated the facility against all 14 elements of OSHA PSM (Process Safety Information, Process Hazard Analysis, Operating Procedures, Training, Contractors, Pre-Startup Safety Review, Mechanical Integrity, Hot Work, Management of Change, Incident Investigation, Emergency Planning, Compliance Audits, Trade Secrets, and Employee Participation). For each element, the team reviewed existing documentation, interviewed frontline operators and supervisors, and conducted field verification walks. Gap severity was classified on a 3-tier scale (Critical, Major, Improvement Opportunity) with each finding mapped to specific CCPS RBPS pillars. The final deliverable included a gap register, a risk-prioritized closure plan with estimated resource requirements, and a recommended KPI framework for tracking PSM performance going forward.
