OSHA’s PSM employee participation requirements

Employee participation is one of the 14 elements of OSHA’s PSM standard. If you want to achieve compliance, you’ll need to write a plan for meeting the employee participation requirement.

PSM employee participation overview

You can find the employee participation information in paragraph “c” of the PSM standard. It has three main requirements:

1. You must have a written plan that outlines how you’ll implement the employee participation requirements.
2. You must collaborate with your employees (or their representatives) to perform and create process hazard analyses and other PSM-related documents.
3. You must provide process hazard analyses and other PSM-related information to your employees.

Let’s break each of these requirements down in more detail.

Writing an employee participation plan

Your employee participation action plan doesn’t have to be super complicated or difficult to write. In fact, it’s better if you keep the format and writing style simple and straightforward.

Here’s a basic outline of what you should include in the plan:

• Company contact information
• Revision date and approver
• Scope and purpose of the plan
• Implementation procedures
  • Awareness
  • Involvement
  • Access to information
• Documentation

Consulting with employees

Paragraph two of the PSM standard says that you must “consult with employees and their representatives on the conduct and development of process hazards analyses and on the development of the other elements of [PSM].”

Here are some ways to involve your employees in the PSM program:

• Have employees review the safety procedures periodically and suggest changes.
• Get feedback from employees when you want to introduce a new procedure.
• Require at least one employee who’s trained and knowledgeable about the process to be involved in the hazard analysis.
• Involve employees in the PSSR and MOC processes.
• Ensure there’s at least one knowledgeable employee on the PSM review committee.

Don’t forget to list out these involvement strategies in your employee participation plan.

Providing PSM document access

The last requirement you need to plan for is employee access to information. It’s exactly what it sounds like. Provide your employees with the PSM documentation they need to understand their job hazards and know how to manage them.

I’d recommend having some sort of formal system in place for requesting or viewing these documents. That’s because it doesn’t make sense to send every single employee an individual copy. Instead, you can keep them in a central storage location that everyone can easily access.

You might also consider keeping a PSM binder of relevant materials in each department or a digital version that everyone can find. It just depends on what works best for your team. All you have to do for your PSM employee participation plan is state that you make the information available and describe how workers can access it.

PSM compliance tips

If you get too bogged down by the number of requirements, then the PSM standard might feel overwhelming. But as you can see, once you read through the details, you’ll find that the what isn’t so complicated—it’s the how that makes compliance difficult.

Make PSM compliance easier for your team by:

• Appointing a team to periodically review compliance and oversee procedure changes
• Creating procedures that are as user-friendly and non-disruptive as possible
• Focusing on the quality of your site’s documentation processes
• Implementing a formal change management process with MOC software
• Breaking down the standard into its separate parts and reviewing compliance line by line
• Treating your PSM program as a living, evolving entity that needs consistent upkeep

You can check out our PSM resource page for more information on the various components of PSM, helpful checklists and forms, and advice on how to set up your program.