When Process Safety Management became applicable
A specialty materials manufacturer produces durable, environmentally sound overlay materials by combining paper substrates with specialty resins and controlled heat treatment. The facility maintained a strong focus on product performance and quality, with established practices for safely and consistently running the process.
A state regulatory visit changed the compliance landscape, creating immediate operational pressure. Based on the quantity and type of hazardous chemicals on site and the facility’s thermal processing conditions, the authority determined the operation met applicability for the Occupational Safety and Health Administration (OSHA) Process Safety Management standard (29 CFR 1910.119). The determination triggered an additional set of regulatory requirements and accelerated the next steps: confirm gaps against the standard and stand up a compliant program without disrupting production.
Choosing a practical starting point
The most practical move was to avoid overbuilding. Onterris worked alongside the client team to prioritize efficiency and define a starting point that matched the facility’s size, complexity and risk profile. Instead of attempting to implement every PSM element at once, the team completed a targeted assessment using 29 CFR 1910.119, the standard for processes involving highly hazardous chemicals, as a framework.
The assessment focused on what already worked, where requirements were not yet formalized and which actions would deliver compliance value fastest. This approach helped the site avoid unnecessary effort while still establishing a defensible compliance strategy that could scale as operations evolve.
Translating the standard into workable systems
Based on the assessment, Onterris delivered a clear roadmap that sequenced PSM program development and implementation by practical effort and operational fit. The team then supported hands-on execution where internal resources were limited, starting with process safety information that accurately reflected the current facility operations.
Onterris walked down more than 30 discrete process systems to develop process flow diagrams, piping and instrumentation diagrams (P&IDs) and design basis documentation. That foundation supported consistent decision-making, especially when changes or deviations arose.
Next, the team established management of change processes aligned with OSHA expectations, including defined triggers, technical review steps, documentation control and communication to affected personnel. Onterris also facilitated a Process Hazard Analysis (PHAs) and put a recommendation tracking approach in place so actions stayed assigned, visible and closed with evidence. All of this was executed under a month from pre-planning to closure.
Mechanical integrity requirements were integrated with existing maintenance contractor workflows. The work clarified covered equipment, inspection and test expectations, documentation needs and how deficiencies would be evaluated and resolved without rebuilding the maintenance program from scratch.
We focused on practical execution: document what is actually on site, formalize change control that fits the operation and keep the hazard review actions moving. That balance is what makes a PSM program usable and defensible.
Building capability through documentation and training
To support long-term compliance, Onterris developed PSM program documentation that described, element by element, how the site would implement and maintain each requirement. The documentation defined roles, responsibilities, required records and cadence so the program could operate consistently after initial buildout.
Over the course of a week, Onterris provided 5 separate bespoke training programs tailored to individual roles within the PSM program. Training educated personnel on PSM requirements and how individual roles contribute to compliance, with emphasis on day-to-day behaviors such as initiating change management processes, maintaining process safety information, participating in PHAs and sustaining mechanical integrity documentation. This ensured the program lived in operations, not just in a binder.
Demonstrating good-faith compliance and setting a foundation
With the assessment record, roadmap and program documentation in place, the client submitted a complete PSM program to the state regulator. Regulators recognized our client’s rapid, cooperative progress and lifted more than 50% of the assessed penalties, strengthening regulatory standing and easing near-term enforcement pressure. Today, the program operates as a practical management system, with current process information, usable change control and clear ownership that supports consistent decisions. That structure gives the facility a repeatable approach for managing process risk as equipment, throughput and requirements evolve over time.