Program Ownership and Consolidation
A CSLM program must be appropriately organized and supported in order to be effective. The
owner(s) of the CSLM program should be designated by the site prime contractor, and the CSLM
program should consolidate the number of program owners to the greatest extent possible. The
CSLM program must include clearly-defined roles and responsibilities for all organizations with
chemical management responsibilities. The active involvement of a Program Steering
Committee can also help to strengthen the CSLM program.
The single most important issue to clarify in CSLM is program ownership. Clear program
ownership is essential to defining each organization's responsibilities and to ensuring effective
coordination between the various organizations involved in the CSLM program.
Failure to clearly establish program ownership can defeat the primary objectives of the CSLM
program, which are reduced frequency, severity, and cost of che mical incidents and reduced
chemical usage costs. Likewise, the lack of clear ownership can lead to increased inefficiency
and increased company liabilities. If program owners are not clearly identified, people may not
know where to go for answers, may seek guidance from those who are not qualified to give it or
may come to disagreement over requirement interpretations .
Consolidating the number of program owners and clearly defining their hierarc hy, roles, and
responsibilities can improve the efficiency of a CSLM program. Consolidating the program,
usually with the majority placed under one organization, enables better coordination between
program elements. This helps to eliminate potential friction between various program owners
while ensuring more seamless coverage of requirements. Program consolidation improves
accountability by assigning specific responsibilities, defining program element interfaces, and
providing a point of contact that can answer or resolve questions. Program consolidation is an
important tool to help organize and manage the complex tasks involved in CSLM.
Program Steering Committee
Consolidating a CSLM program increases the risk of the program owners losing touch with the
real needs of the actual chemical users on the site. In particular, program owners may fail to
consider the special needs of particular user groups and create unintentional but additional
quagmires. Examples of these special needs include: simplifying the procurement or
inventorying processes, resolving complex storage issues, or providing interpretations for
requirements or procedures that cannot be implemented in a reasonable manner.
To mitigate this risk, a CSLM program should have a Program Steering Committee whose
responsibilities and interfaces are established in site policy and procedure. These policies and
procedures need to address management support for and the independence of the Steering