PSM Program Development and Support
Cognascents Consulting Group provides Process Safety Management (PSM) consulting, PSM program development, and PSM program support for facilities handling hazardous chemicals. We help you build, implement, and maintain an integrated program that supports compliance and gives your team practical tools to manage process hazards as operations change.
When Clients Engage Us
Common reasons organizations engage PSM program services
Organizations typically engage Cognascents for PSM program development and support when they are facing:
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▸A new PSM-covered process with no program in place yet
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▸A PSM program that has grown inconsistent across sites or business units
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▸Gap analysis findings that need to turn into an actual program
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▸Leadership turnover that has left program ownership unclear
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▸Difficulty keeping all 14 PSM elements current and connected
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▸Preparing for growth into new PSM-covered operations
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Our Approach
A PSM program built to actually run, not just exist on paper.
A process safety management (PSM) program is the written and implemented management system OSHA 29 CFR 1910.119 requires to prevent or minimize catastrophic releases of highly hazardous chemicals, for any process at or above an Appendix A threshold quantity or holding 10,000 pounds or more of a flammable liquid or gas. It spans 14 elements, from employee participation (c) and process safety information (d) through process hazard analysis (e), operating procedures (f), training (g), mechanical integrity (j), management of change (l), incident investigation (m), and compliance audits (o). Cognascents builds and supports PSM programs that connect these elements to your daily operations and, where the process is also RMP-covered, to the parallel Program 3 prevention program under 40 CFR 68.65–68.87.
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Step 01
PSM Gap AnalysisOur PSM gap analysis starts with a coverage and applicability determination, then evaluates existing practices and documentation against 29 CFR 1910.119(c) through (p). We identify missing or inconsistent program elements, clarify roles and responsibilities, and develop a prioritized action plan based on risk and implementation needs. |
Step 02
Program DevelopmentWe develop facility-specific written PSM programs: policies, procedures, standards, and training materials. Deliverables connect hazard analysis findings, equipment integrity requirements, operating limits, and the management of change process so your team can put the program into practice. |
Step 03
Implementation & Ongoing SupportWe help you roll the program out across your organization and provide ongoing support to keep it current as your process, team, and regulatory landscape change. |
Why Cognascents
Why choose Cognascents for PSM program development
MULTIDISCIPLINARY EXPERTISE
Technical Depth Across the Process Safety Program
Cognascents brings together engineers across process safety, asset integrity, and process engineering. Our team includes Professional Engineers (PEs), Certified Safety Professionals (CSPs), Certified Process Safety Professionals (CCPSCs), and holders of API 510, 570, 571, 580, and 653 certifications. That breadth enables us to support the full program, from policies and procedures to hazard analysis and the engineering behind safeguards and equipment integrity. |
U.S. AND CANADIAN PROCESS SAFETY EXPERIENCE
A Consistent Framework With Facility-Specific Requirements
Our experience includes OSHA PSM, EPA RMP, and CSA Z767. We help organizations establish consistent management practices while accounting for the requirements and operating conditions relevant to each facility. |
COLLABORATIVE PROGRAM DEVELOPMENT
Ownership That Supports Sustainable Execution
We work with the people who will run the program, explain our methods, and incorporate their feedback as deliverables take shape. Clear responsibilities and usable procedures help your team implement and maintain the program with the resources available. |
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“A PSM program that only gets opened before an audit isn’t a program. It’s a binder.”
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Standards & Codes We Work To
The regulatory frameworks and guidelines that govern Process Safety Management.
OSHA 29 CFR 1910.119 — Process Safety Management of Highly Hazardous Chemicals, elements (c) through (p)OSHA 29 CFR 1910.119(a) and Appendix A — PSM applicability and threshold quantitiesCSA Z767 — Process Safety Management (Canadian national standard)EPA 40 CFR Part 68, Subpart D (68.65–68.87) — Program 3 prevention program for RMP-covered processesCCPS Guidelines for Risk Based Process Safety
IS YOUR PSM PROGRAM CONSISTENT ACROSS YOUR ORGANIZATION?
Let’s talk about where your program has drifted.
Our engineers will give you a direct read on where your PSM program has gaps and what it would take to close them.
Keep reading for what a well-built PSM program delivers and the services that connect to it. ↓↓
What You Gain
A PSM program that holds together under real operating conditions.
An integrated process safety management program connects hazard identification, safeguards, operating procedures, and mechanical integrity to help reduce the likelihood and consequences of major incidents.
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ENHANCED PROCESS SAFETY PERFORMANCE
A program that actually protects your people and assetsA well-integrated PSM program reduces incident risk in practice, not just on paper. |
REGULATORY COMPLIANCE
A clear path to regulatory compliance.Facility-specific policies, procedures, and records support 29 CFR 1910.119 compliance and make it easier to demonstrate how your organization implements the 14 PSM elements. |
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REDUCED OPERATIONAL RISK
Gaps identified and closed before they become incidentsOur gap analysis and program development work identifies weaknesses before they turn into audit findings or, worse, incidents. |
OPTIMIZED RESOURCE ALLOCATION
Safety effort focused where it actually mattersRisk-based priorities and ongoing PSM program support help you direct available resources toward the highest-impact gaps and maintain consistent practices across facilities. |
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Related Services
Supporting services that strengthen your PSM program
Cognascents connects PSM program development to the audits and elements it depends on.
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THE AUDIT THAT TESTS YOUR PROGRAM
PSM/RMP Compliance AuditsOnce your program is built, an independent audit confirms it holds up under scrutiny. |
THE ANALYSIS AT THE CORE OF YOUR PROGRAM
Process Hazard Analysis (PHA)PHA is one of the most visible PSM elements. We help make sure it’s integrated with the rest of your program. |
THE EPA-SIDE PROGRAM THAT PAIRS WITH PSM
Risk Management Program (RMP) Development and SupportMany PSM-covered facilities are also RMP-covered. We help you build both programs so they reinforce each other. |
Related Content
PSM program articles and case studies
Case studies and technical articles from the engineers who lead these engagements.
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ARTICLE | PROCESS SAFETY
Developing a Robust PSM Program: A Practical RoadmapA practical look at building a PSM program from scratch, including the planning and technical discipline it takes to make it sustainable. |
CASE STUDY | EV BATTERY MANUFACTURER
Fortifying Critical PSM Program Elements for a Lithium-Ion Battery ManufacturerStrengthening and hardening a PSM program for an EV battery manufacturer handling flammable and reactive chemicals. |
ARTICLE | PROCESS SAFETY
The Most Important PSM ElementA perspective on which PSM element matters most, drawn from decades of process safety consulting experience. |
PSM PROGRAM QUESTIONS, ANSWERED DIRECTLY
Frequently asked questions about OSHA PSM compliance
What is a PSM program?
A process safety management program is the written, implemented management system OSHA requires under 29 CFR 1910.119 to prevent or minimize the consequences of catastrophic releases of highly hazardous chemicals. It consists of 14 interdependent elements, from process safety information and process hazard analysis to mechanical integrity, management of change, and compliance audits. OSHA evaluates implementation, not just the written plan.
Which facilities are covered by OSHA PSM?
Under 29 CFR 1910.119(a)(1), PSM applies to processes involving a highly hazardous chemical at or above its Appendix A threshold quantity, or 10,000 pounds or more of a flammable liquid or gas in one location. Exemptions include hydrocarbon fuels used solely for workplace consumption, qualifying atmospheric storage, retail facilities, well drilling and servicing, and normally unoccupied remote facilities. Coverage is decided process by process, so document the determination itself.
What does a PSM gap analysis cover?
A PSM gap analysis confirms which processes are covered, then compares the written program and its implementation against each requirement of 29 CFR 1910.119(c) through (p). Unlike the compliance audit under (o), it is not a certified triennial obligation; it is typically used to build a new program, onboard an acquired site, or prepare for an audit. The output is a prioritized list of deficiencies with owners and a realistic implementation sequence.
How often must PSM program elements be reviewed?
The standard sets several fixed cycles: PHA revalidation at least every five years under (e)(6), annual certification that operating procedures are current and accurate under (f)(3), refresher training at least every three years under (g)(2), and certified compliance audits at least every three years under (o)(1). Mechanical integrity inspection frequencies follow manufacturer recommendations and RAGAGEP under (j)(4)(iii). Everything else must stay current through management of change.
How do OSHA PSM and EPA RMP requirements relate?
EPA modeled the Program 3 prevention program in 40 CFR 68.65–68.87 on OSHA PSM, so most elements map one-to-one. RMP adds an offsite consequence analysis, an emergency response program under Subpart E, and a Risk Management Plan updated at least every five years. Coverage triggers differ, with RMP using the 40 CFR 68.130 list, so one process can fall under one rule but not the other. Our RMP Development and Support service covers the EPA side.
Talk to a PSM consultant about your program
Tell us where your PSM program stands today. One of our engineers will give you a straight answer about what it would take to bring it current.