Can employers use consultants to develop Process Safety Management or PSM programs?

Yes. Many employers originally implemented and continue to run their PSM programs entirely on their own. Others seek outside assistance, typically by hiring consultants. This is not uncommon for businesses run by managers with limited or no engineering background. Either approach is acceptable, provided the PSM program focuses on and comprehensively addresses the facility-specific hazards, equipment, and operating procedures — and is not based on generic checklists, boilerplate language, or other resources that do not focus on the facility’s hazards. However, keep in mind that ultimately the employer is responsible for PSM compliance!