Using Leading Metrics for PSM Compliance

The Occupational Safety and Health Administration (OSHA) is suggesting that you use metrics to analyze and improve your Process Safety Management (PSM) program. Can that idea work for you? Yesterday we will looked at the idea of metrics for environmental, health, and safety (EHS) programs and OSHA’s suggestions for using lagging metrics. Today we will review how OSHA suggests leading metrics can help you track your compliance with PSM requirements.

Note: OSHA surveyed examples of metrics that are used by facilities enrolled in its Voluntary Protection Program (VPP) to track their PSM program performance.

Leading the way

Lagging metrics look behind to see what happened. Leading metrics are more predictive and can help you prevent major incidents.

Let’s review six leading metrics associated with PSM programs and how VPP facilities are tracking them.

Management of Change (MOC)

EHS managers at PSM facilities must establish and implement written procedures to manage changes (except for “replacements in kind”). There are various changes at PSM facilities that should be tracked to prevent, or reduce the likelihood of, failures or releases. For the MOC, VPP facilities commonly track:

  • Overdue MOCs;
  • Approved MOCs;
  • Open MOCs; and
  • MOCs performed each month.

One VPP facility noted a problem with tracking expiration dates for their temporary MOC process. It was difficult to search databases for the dates because they were not in the same place. As a solution, the PSM department added a searchable data designation that allowed the entry of a duration of no more than 180 days for any temporary MOC. This enabled them to identify expiration dates for temporary MOCs and establish time limits for them.

Preventive maintenance

This is maintenance that is regularly performed on a piece of equipment to decrease the likelihood of failure. VPP facilities commonly track:

  • Completion rates;
  • Open items;
  • Overdue safety critical preventive maintenance; and
  • Number of inspections.

Process hazard analysis (PHA)

PHAs monitor equipment, instruments, utilities, human actions, and external factors that might affect a process. For the PHA, VPP facilities generally track:

  • PHA actions open;
  • PHAs overdue;
  • PHAs completed;
  • Scheduled vs. completed PHAs;
  • Status of PHA/incident recommendations; and
  • Status of scheduled PHA revalidations.

Mechanical integrity (MI)

Critical process equipment must be designed and installed correctly and operated properly to ensure safe operation. VPP facilities commonly track these leading metrics as part of their MI programs:

  • Number of inspections scheduled for relief valves, piping, pressure vessels, and storage tanks;
  • Status of variance requests;
  • Routine inspections; and
  • Number of overdue work orders.


Workers involved in operating a process or a newly assigned process must be trained in an overview of the process and in its operating procedures. VPP facilities generally track:

  • Safety/refresher training completed;
  • Training planned vs. completed;
  • Training exceptions; and
  • Contractor training.

Safety action items

VPP facilities commonly keep track of certain safety action items. These are actions that need to take place to manage processes and stay in compliance. They include such things as following up on PHAs, planned inspections, maintenance activities, training—basically any safety-related activity. Along these lines, VPP facilities generally track:

  • Past action items;
  • Initiated vs. completed items; and
  • Open action items.

Metrics are just one useful tool all EHS managers should have in their safety toolboxes. With all the confusion and anxiety currently surrounding OSHA’s plans for the PSM program, you can be sure to stay up to date with®.