Process Safety

Management for
Small Businesses

OSHA 3908-03 2017

Occupational Safety and Health Act of 1970
To assure safe and healthful working conditions
for working men and women; by authorizing
enforcement of the standards developed under
the Act; by assisting and encouraging the States
in their efforts to assure safe and healthful
working conditions; by providing for research,
information, education, and training in the field of
occupational safety and health.

This guidance document is not a standard

or regulation, and it creates no new legal
obligations. It contains recommendations as well
as descriptions of mandatory safety and health
standards. The recommendations are advisory
in nature, informational in content, and are
intended to assist employers in providing a safe
and healthful workplace. The Occupational Safety
and Health Act requires employers to comply
with safety and health standards and regulations
promulgated by OSHA or by a state with an
OSHAapproved state plan. In addition, the Acts
General Duty Clause, Section 5(a)(1), requires
employers to provide their employees with a
workplace free from recognized hazards likely to
cause death or serious physical harm.

Material contained in this publication is in the

public domain and may be reproduced, fully or
partially, without permission. Source credit is
requested but not required.

This information will be made available to

sensory-impaired individuals upon request.
Voice phone: (202) 693-1999; teletypewriter
(TTY)number: 1-877-889-5627.
Process Safety Management
for Small Businesses

U.S. Department of Labor

Occupational Safety and Health Administration

OSHA 3908-03 2017

Contents
Purpose . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Examples of Small Businesses with potential
PSM-covered processes. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Process Safety Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
Process Hazard Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
PHA Development Team . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
Mechanical Integrity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Compliance Audit. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
APPENDIX A: Frequently Asked Questions. . . . . . . . . . . . . . . . 19
APPENDIX B: Examples of PHA Methodology. . . . . . . . . . . . . 25
Workers Rights . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
OSHA Assistance, Services and Programs . . . . . . . . . . . . . . . 28
Establishing a Safety and Health Program . . . . . . . . . . . . . . 28
Compliance Assistance Specialists . . . . . . . . . . . . . . . . . . . . 28
Free On-site Safety and Health Consultation Services
for Small Business. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
Cooperative Programs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
Occupational Safety and Health Training Courses. . . . . . . . 29
OSHA Educational Materials. . . . . . . . . . . . . . . . . . . . . . . . . . 30
OSHA Regional Offices. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
How to Contact OSHA. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
Purpose
This guidance document does not cover the entire Process
Safety Management standard (PSM), but only focuses on
aspects of the standard that may be particularly helpful for
small businesses. For a full compliance guide to PSM, please
refer to OSHAs Process Safety Management Guide (OSHA
3132)1 or the full text of the standard at www.osha.gov.2
Although all elements of the PSM standard apply to a PSM-
covered small business, the following elements of the standard
are most relevant to hazards associated with small businesses.

Process Safety Information (PSI)

Process Hazards Analysis (PHA)
Training
Mechanical Integrity (MI)
Compliance Audits

PSM is critically important to small businesses with highly

hazardous chemicals. Implementing the required safety
programs help prevent fires, explosions, large chemical
spills, toxic gas releases, runaway chemical reactions, and
other major incidents. Compliance with the PSM standard
will help ensure that employees, contractors, facility visitors,
and emergency responders are safe from these hazards.
Compliance will also benefit employers by minimizing damage
to facility equipment and neighboring structures in the event of
an HHC release.

Managing HHCs is required by OSHA standards and a good

business practice.3 Catastrophic HHC release events continue
to occur among smaller companies. One study estimates that
employers with 1-25 employees are 47 times more likely to
have a release and 17 times more likely to suffer an injury,
per employee, than facilities with 1500 or more employees.4

1. www.osha.gov/Publications/osha3132.pdf
2. www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9760
3. See The Business Case for Process Safety, downloadable from www.aiche.org/ccps/about/
business-case
4. Process Safety Issues For Small Businesses M. Sam Mannan, Harry H. West, Nir Keren and T.
Michael OConnor, Mary Kay OConnor Process Safety Center, 2004. IChemE

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In addition to presenting risk to workers these companies are
often located in populated areas, and can pose a risk to the
surrounding population and structures.

Many small companies have the potential to realize cost

efficiencies and savings through improved safety practices,
such as adopting more effective work practices, inventory
controls, storage practices, and better handling, use and
disposal procedures, and instituting targeted PSM training to
improve and ensure employee competence. Where possible
and practical, finding alternative materials will help reduce
hazards and associated risks. The approaches in this guidance
document can help small businesses meet PSM requirements
without creating unnecessary or additional resource burdens,
and will give both employees and employers a better
understanding of the standard.

Many industry organizations have materials that may contain

guidance for specific industries and processes. Small
businesses may find this guidance helpful in developing a PSM
program. Such industries include, but are not limited to:

Refrigeration International Institute of Ammonia

Refrigeration (IIAR)
Compressed Gasses Compressed Gas Association (CGA)
Petrochemical and Chemical Manufacturers American
Petroleum Institute (API)
Chemical Manufacturers Society of Chemical
Manufacturers and Affiliates (SOCMA)
Chemical Distribution/Supply-chain National Association
of Chemical Distributors (NACD)
Agricultural Wholesalers Agricultural Retailers
Association (ARA) & The Fertilizer Institute (TFI)
Chlorine users (water/wastewater treatment and others)
The Chlorine Institute
Explosives Manufacturing Institute of Makers of
Explosives (IME)
Pyrotechnics American Pyrotechnics Association

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 Composite Manufacturers American Composites
Manufacturers Association (ACMA)
Petrochemical Manufacturing American Fuel and
Petrochemical Manufacturers (AFPM)
Dairy Manufacturing The International Dairy Foods
Association (IDFA)
Paint Coating - American Coatings Association (ACA)

Applicability
The Process Safety Management standard covers processes
which involve threshold quantity (TQ) of chemicals listed in
Appendix A of the PSM standard.5 The PSM standard also
applies to processes containing 10,000 pounds (4535.9 kg) or
more of either a Category 1 flammable gas (as defined in 29
CFR 1910.1200(c)) or a flammable liquid with a flashpoint below
100 F (37.8 C) on site in one location, and to the manufacture
of explosives or pyrotechnics in any quantity, except for:

Retail facilities
Hydrocarbon fuels used solely for workplace consumption
as a fuel (e.g., propane used for comfort heating, gasoline
for vehicle refueling), if such fuels are not a part of a
process containing another highly hazardous chemical
(HHC) covered by the PSM standard
Flammable liquids with a flashpoint below 100 F (37.8 C)
stored in atmospheric tanks or transferred which are kept
below their normal boiling point without benefit of chilling
or refrigeration. (Note: Atmospheric tanks are storage tanks
designed to operate at pressures from atmospheric through
0.5 psig)
Oil or gas well drilling or servicing operations
Normally unoccupied remote facilities6

5. Calculation of TQ for mixtures is explained in an OSHA Letter of Interpretation at www.osha.gov/

pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=30848
6. Letter of Interpretation: www.osha.gov/pls/oshaweb/owadisp.show_document?p_
table=INTERPRETATIONS&p_id=22592

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Although OSHA believes PSM will have a positive effect on
the safety and health of employees and will offer potential
benefits to employers such as increased productivity, smaller
businesses with limited resources might consider alternative
approaches to decreasing HHC-associated risks at their
workplaces. One possible approach is reducing their HHC
inventories to below the PSM TQ by improving inventory
control and accepting smaller deliveries. Inventory reduction
may help reduce the consequences of a catastrophic incident.
When reduced inventory is not feasible, the employer might
consider dispersing inventory among several on-site locations
such that a release/incident in one location will not cause a
release in another.

However, reducing inventories below the PSM TQs does

not relieve employers of their responsibility under the
OSH Act to provide safe and healthful working conditions
for their employees. Simply reducing inventories has no
effect on the properties of the HHCs, which, depending on
their use in a process, may still present hazards to workers.
OSHA encourages employers handling HHCs who are not
subject to the PSM standard to implement safety and health
management systems to protect their employees.

Small businesses may contact OSHAs free On-site Consultation

Program for help with identifying and mitigating workplace
hazards. OSHAs On-site Consultation Program offers free
and confidential occupational safety and health services to
small and medium-sized businesses in all states and several
territories, with priority given to high-hazard worksites. To locate
the OSHA On-site Consultation Program nearest you, call 1-800-
321-6742 (OSHA) or visit www.osha.gov/consultation.

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Examples of Small Businesses with potential
PSM-covered processes
The following list contains examples of businesses potentially
affected by the PSM standard (NAICS codes are included for
clarity, but they are not used to determine the PSM standards
applicability):

Asphalt Paving/Roofing Materials (NAICS 32412)

Chemical and Allied Products (NAICS 4246)
Chemical Products-Misc (NAICS 42469)
Drugs (NAICS 4242)
Fabricated Metal (NAICS 332)
Fabricated Rubber Products, (NAICS 32521)
Food and Kindred Products (NAICS 31199)
Industrial Organic Chemicals (NAICS 32519)
Inorganic Chemical Manufacturing (NAICS 32518)
Lumber, Wood Products (NAICS 321)
Natural Gas Liquids (NAICS 2212)
Paints, Varnishes, Enamels (NAICS 3255)
Paper and Allied Products (NAICS 32229)
Plastics Products-Miscellaneous (NAICS 3261)
Plastics, Rubber, Cellulosics (NAICS 325211)
Petroleum & Coal Products-Misc (NAICS 32419)
Petroleum Refining (NAICS 32411)
Primary Metals Industries (NAICS 331)
Stone, Glass & Concrete (NAICS 21232, 3272, 3273)
Textile Mill Products (NAICS 3131)
Wholesale Trade (NAICS 42)

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Process Safety Information
Employers are required to compile written process safety
information (PSI) about highly hazardous chemicals and
process equipment for all PSM covered processes. Complete
and accurate compilation of PSI is critical to the effective
implementation of all other aspects of the PSM standard and
will help employers and employees involved in operating the
process identify and understand the hazards involved in their
processes. PSI must include information concerning the hazards
of the highly hazardous materials used, produced, stored, or
transported on-site by/for the process, the technology of the
process, and all the equipment used in the process.

The PSI compiled by the employer must include information on

toxicity, permissible exposure limits, physical data, reactivity
data, corrosivity data, thermal and chemical stability data,
and hazardous effects associated with inadvertent mixing of
materials that may occur. Facilities are required by OSHAs
Hazard Communication standard (29 CFR 1910.1200) to
maintain Safety Data Sheets (SDSs) for hazardous chemicals
in their workplaces, which often contain some of the required
information. If an employer does not already have SDSs, it
must obtain them from its chemical suppliers. Employers
should confirm that the SDSs contain all of the information
required under PSM.

Employers must also understand their reactive hazards, which

can include runaway reactions, side reactions, and possible
inadvertent interactions. For more information, the CCPS
Reactive Material Hazards Alert7 and the NOAA/EPA/CCPS
Chemical Reactivity Worksheet8 are excellent resources on
chemical reactivity hazards.

Process technology information must include a block or

simplified process flow diagram (as shown below and in
Appendix B of the PSM standard). Block flow diagrams
and process flow diagrams (PFDs) are used to show the

7. www.aiche.org/sites/default/files/docs/pages/reactmat.pdf
8. www.aiche.org/ccps/resources/chemical-reactivity-worksheet-40

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major process equipment and interconnecting process flow
lines. PFDs may also show flow rates, stream composition,
temperatures, pressures, heat exchanger duties, and the
process heat and material balance. Employers must also
compile information on the process chemistry, establish
maximum intended inventory levels for process chemicals,
safe upper and lower process limits beyond which would
be considered upset conditions, and an evaluation of the
consequences of deviation, including those affecting the safety
and health of employees, that could occur if operating beyond
the established process limits.

Figure 1. Block Flow Diagram and Process Flow Diagram,

1910.119 Appendix B

Process Flow Diagram (Sample)

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 Block Flow Diagram (Sample)

Finally, employers must compile information on the equipment

used in the process. This includes piping and instrument
diagrams (P&IDs), materials of construction, electrical
classification, relief system design and basis, ventilation
system design, safety systems, and for processes built after
May 26, 1992, material and energy balances.

Small businesses should find it easy to compile this information

from existing sources and doing so will usually require minimal
staff time. See Table 1 below for examples of potential existing
PSI sources that may be used to fulfill requirements.

OCCUPATIONALSAFETYANDHEALTHADMINISTRATION
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Table 1. Existing PSI Sources and Applicability

Potential Existing PSI Sources Potential applicability to PSI requirements

Chemical shipping and receiving Physical data;

manifests, chemical delivery Reactivity data;
receipts, and associated SDSs
Corrosivity data;
Thermal and chemical stability data;
Hazardous effects of inadvertent mixing of
different materials that could foreseeably occur

Equipment design and Maximum intended inventory;

operatingdocuments Safe upper and lower limits for temperatures,
pressures, flows or compositions

Manufacturer specifications Materials of construction;

Equipment electrical classification (used for
electrical classification);
Relief device specifications ( used for relief
system design and design basis);
Ventilation system design;
Safety Systems

Job hazard analyses and Toxicity information;

associatedSDSs Permissible exposure limits;
Hazardous effects of inadvertent mixing of
different materials that could foreseeably occur;
An evaluation of the consequences of
deviations, including those affecting the safety
and health of employees

Emergency planning information An evaluation of the consequences of

including assessments from, deviations, including those affecting the safety
insurance audits, Fire Marshall and health of employees;
inspections, local fire departments, Safety Systems
or emergency responders

Related process documents Electrical classification;

Design codes and standards employed;
Material and energy balances

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Employers must also document that all equipment complies
with recognized and generally accepted good engineering
practices (RAGAGEP). For more information on OSHAs
interpretation of RAGAGEP see OSHA Memorandum,
RAGAGEP in Process Safety Management Enforcement.9 Below
is a non-exhaustive list of institutions that publish standards
that may contain applicable process equipment RAGAGEP:

American National Standards Institute (ANSI)

American Petroleum Institute (API)
American Society of Heating, Refrigeration and Air
Conditioning Engineers (ASHRAE)
American Society for Testing and Materials (ASTM)
American Society of Mechanical Engineers (ASME)
American Welding Society (AWS)
Center for Chemical Process Safety (CCPS)
Compressed Gas Association (CGA)
Chlorine Institute (CI)
International Institute of Ammonia Refrigeration (IIAR)
International Code Council (ICC)
International Organization for Standardization (ISO)
National Association of Corrosion Engineers (NACE)
National Fire Protection Association (NFPA)
Society of Chemical Manufacturers and Affiliates (SOCMA)

Process Hazard Analysis

A process hazard analysis (PHA) is an organized and
systematic effort to identify and analyze the significance
of potential hazards associated with the processing and
handling of highly hazardous chemicals. The PHA analyzes
the hazards of the process including potential causes and
consequences of fires, explosions, and releases of toxic or
flammable chemicals. The PHA must make recommendations
for additional safeguards to adequately control identified
hazards or to mitigate their effects, or these may be generated

9. www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=30785

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by post-PHA evaluations of the teams findings. Safeguards
may include inherently safer or passive approaches to hazard
control, new engineering controls (e.g., improved fire detection
and suppression systems) or administrative controls (e.g., new
operating procedures, inventory control measures, separation
of highly hazardous chemicals into different storage areas).

Small businesses will often have processes that have fewer

quantities of HHCs, and may be less complicated than processes
at a large facility. Therefore, OSHA anticipates that often less
complex PHA methodologies could be used to meet the process
hazard analysis requirement in the standard. These process
hazard analyses methodologies can be applied in less time
than more complex approaches. For example, a less complex
process could mean that less process data, fewer P&IDs, and
less equipment information are needed to perform a process
hazard analysis. As a result, simpler methodologies, such as
What-if/Checklist, may be appropriate for these processes.

However, some small businesses have complex processes.

In these instances, employers must use a PHA methodology
appropriate to the process, such as a Hazard Operability Study
(HAZOP), or Failure Mode and Effects Analysis (FMEA). In
such instances, small businesses may find that PHA contractor
assistance is beneficial.

OSHA has provided examples of two different PHA methodologies

that small businesses can review for information and potential use.
These two PHA examples are contained in an OSHA February 1,
2005 letter of interpretation10 and in APPENDIX B: Examples of PHA
Methodology of this document.

Many small businesses have processes that are not unique,

such as ammonia refrigeration systems or water treatment
facilities. Industry associations have developed template PHAs
for common processes used by their membership that can be
made site-specific for a particular facilitys process. However,
any template PHA must be customized to accurately identify
and address the hazards of the process.
10. www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25051

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Moreover, small employers who use batch processes may be
able to use a generic approach for the PHA that may help to
further reduce the cost of compliance. For example, a generic
PHA based on a representative batch might be used for other
similar batches where there are only small changes in the
process chemistry and this is documented for the range of
batch processes. Specifically, a paint mixing batch process may
differ only in pigment being used or slight variations in solvents
used for each pigment. In this case, the employer may not need
a separate PHA for every different pigment/color batch, but
only one generic PHA that considers the overall paint mixing
process, including all the potential amounts of solvent used, and
potential chemical hazards of the different pigments (which may
be similar, if not the same). However, if the batch processes are
dissimilar, or use chemicals with substantially different hazards,
a separate PHA would be required. Furthermore, reactive batch
processes can be very sensitive to small changes in quantities,
compositions, or operating conditions and may require highly
individualized evaluations.

Employers must develop systems to promptly address hazards

identified and the process hazard analyses findings and
recommendations, document how each item was resolved,
and inform affected employees of any process changes made.

PHAs must be updated and revalidated at least every five years

to assure that the process hazard analysis is consistent with
the current process.

PHA Development Team

An effective and comprehensive process hazard analysis shall
be performed by a team with expertise in engineering and
process operations, and the team shall include at least one
employee who has experience and knowledge specific to the
process being evaluated. Also, one member of the team must
be knowledgeable in the specific process hazard analysis
methodology being used.

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Some companies, particularly smaller ones, may not
have the staff expertise to perform such an analysis. The
employer, therefore, may need to hire an engineering or
consulting company to perform and augment the analysis.
Employers may also want to sponsor their employees in taking
appropriate training courses or provide opportunities for
acquiring professional experience.

Training
Employers must provide initial and refresher training to every
employee involved in operating a PSM-covered process.
Training must cover process-specific safety and health hazards,
operating procedures, safe work practices, and emergency
shutdown procedures. The level of training may vary for each
employee. For example, those who work in the area or operate
the equipment will receive more extensive training than visitors
or other non-operational personnel who are in the general area,
who would require awareness training. Employers must also
train contractors or temporary employees on known potential
fire, explosion, or toxic release hazards associated with their
work and the processes. Additional training in subjects such as
emergency evacuation and response, routine and nonroutine
work authorization activities, and other areas pertinent to
process safety and health should be covered by an employers
training program. Training must also be conducted in
compliance with 1910.1200, the Hazard Communication standard
to help employees to become more knowledgeable about the
hazardous properties of the chemicals they work with and better
able to read and understand SDSs.

As most small business owners already regularly train their

employees, OSHA does not expect that employers will need
substantial additional effort to come into compliance with the
PSM training requirements. All employers (both operator and
contractor) are required to document the training given to their
employees and document that each employee has completed
and understood that training.

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In the training program documentation, employers should
clearly identify the employees to be trained and the subjects to
be covered. One non-mandatory best practice to consider is to
determine clear and measurable learning goals or objectives
before the training begins. The employer shall ascertain that
each employee involved in operating a process has received
and understands the training required by this paragraph. The
employer shall prepare a record which contains the identity
of the employee, the date of training, and the means used
to verify that the employee understood the training. These
goals and objectives should be tailored to each of the specific
training modules or segments. Employers should describe how
the employee will demonstrate competence and knowledge as
well as what is acceptable performance.

Employers should periodically evaluate their training programs

to ensure the necessary skills, knowledge, and procedures
are properly understood and implemented. Training program
evaluation will help employers to determine the amount of
training their employees understood, and whether the desired
results were obtained. If, after the evaluation, it appears that
the trained employees are not at the level of knowledge and
skill that was expected, the employer will need to revise the
training program, provide retraining, or provide more frequent
refresher training sessions until the deficiency is resolved.
Those who conducted the training and those who received
the training should also be consulted as to how to improve the
training process. If there is a language barrier, the language
known to the trainees should be used.

Mechanical Integrity
The Mechanical Integrity (MI) element of the PSM standard
requires employers to implement rigorous and systematic
written procedures to ensure that all critical process
equipment are properly designed, tested, inspected, repaired,
and maintained. Mechanical integrity programs must address
pressure vessels, storage tanks, piping systems (including
piping components such as valves), pumps, relief and vent
systems and devices, emergency shutdown systems, and

OCCUPATIONALSAFETYANDHEALTHADMINISTRATION
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controls (including monitoring devices and sensors, alarms,
and interlocks). While large chemical manufacturing facilities
and petroleum refineries sometimes have hundredsor even
thousandsof such components, small businesses with PSM-
covered processes typically have less equipment to maintain,
making compliance easier.

For some small businesses, the mechanical integrity section of

the PSM standard may appear daunting. MI is often the most
resource intensive PSM element once the PSM program is up
and running, as components of a successful MI program may
include tracking inspections, tests, repairs, and controlling
spare parts and materials. In some cases, a small employer
may already have a maintenance/inspection program for
PSM covered equipment. These employers will simply need
to ensure that their existing maintenance program and
inspection frequencies are appropriate under PSM. Employers
who do not have an MI program will first need to identify all
critical equipment that is part of the covered process. This
list would include pressure vessels, storage tanks, process
piping, relief and vent systems controls, monitoring devices,
interlocks, pumps, alarms, and emergency shutdown systems.
In addition, some utility piping and equipment, e.g., cooling
required to prevent run-away reactions, may be subject to MI
requirements. Employers should also consider including loss
of containment mitigation equipment, such as fire protection
system components, in their mechanical integrity provisions.

In many cases, the equipment that is part of the MI program

will have inspection and testing recommendations from the
manufacturer. If the covered equipment does not have any MI
related manufacturers recommendations, then employers should
look for applicable codes/standards or industry best practices.

Inspections and tests must follow Recognized and Generally

Accepted Good Engineering Practices (RAGAGEP), and
inspection and test frequency must be consistent with
manufacturers recommendations and good engineering
practices, or more frequently if indicated by operating
experience. Applicable codes and standards such as those

PROCESS SAFETY MANAGEMENT FOR SMALL BUSINESSES

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from the American Society for Testing and Materials,
American Petroleum Institute, National Fire Protection
Association, American National Standards Institute, American
Society of Mechanical Engineers, and other groups provide
information to help establish an effective testing and
inspection frequency, as well as appropriate methodologies.
Employers must document each inspection and test it
performs on critical process equipment, including the date,
the name of the person performing the test, the serial number
or other identifier of the equipment, a description of the test or
inspection, and its results.

Employers must train each employee involved in the

maintenance of the integrity of equipment used in an ongoing
process. These employees must be provided an overview of
the process, its hazards, and the procedures they must follow
in their assigned tasks to ensure they can perform the tasks
in a safe manner. This training may be covered in conjunction
with other training required by the standard.

Equipment deficiencies outside the acceptable limits defined

by the PSI must be corrected before further use. In some
cases, however, it may not be necessary that deficiencies be
corrected before further use, as long as the deficiencies are
corrected in a safe and timely manner, when other necessary
steps are taken to ensure safe operation. When equipment is
determined to be deficient, a management of change (MOC)
procedure must be established and implemented prior to
continuing operation of the deficient equipment outside of
established operating limits. The MOC procedure must include
a determination of the safety and health impacts of continued
operation of the deficient equipment.

Employers must have a quality assurance system to ensure

that equipment, maintenance materials, and spare parts
are suitable for the process applications in which they
are used. Employers must make appropriate checks and
inspections to insure that equipment is installed property and
consistent with design specifications and the manufacturers
instructions. As built drawings, together with documents

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containing testing, certification, construction, materials and
other pertinent information should be retained in the quality
assurance documentation.

Compliance Audit
PSM compliance audits are used to gather sufficient facts
and information to verify compliance with the requirements
specified in the PSM standard. A PSM compliance audit must
be conducted at least every three years.

Employers must select at least one individual who is

knowledgeable about the process to be audited. For some
complex and/or larger processes, OSHA believes that a
team of individuals would be beneficial for conducting an
audit. However, for less complex and/or smaller processes
an employer may need only one knowledgeable person to
conduct an audit.

The audit must include an evaluation of the compliance with

the provisions of PSM and to verify that the procedures and
practices developed are adequate and are being followed. The
audit should be conducted or lead by a person knowledgeable
in audit techniques and who can be impartial towards the area
being audited. The essential elements of an audit program
include planning, staffing, conducting the audit, evaluation and
corrective action, follow-up and documentation.

Planning is essential to the success of the auditing process.

It is helpful to establish the format, staffing, scheduling and
audit methods prior to conducting the audit. The format should
be designed to provide the lead auditor with a procedure or
checklist that details the requirements of each section of the
PSM standard. The checklist, if properly designed, should
provide the auditor with the necessary information to expedite
the review and ensure that no requirements of the standard are
omitted. This checklist would also identify PSM elements that
will require evaluation or a response to correct deficiencies.
This checklist could also be used for developing the follow-up
and documentation requirements.

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An effective audit includes a review of the relevant
documentation and process safety information, inspection
of the process, and interviews with employees. Using the
audit procedure and checklist developed in the planning
stage, the auditor can systematically analyze compliance
with the provisions of the PSM standard. For example, the
auditor will review operator training as part of the overall
audit. The auditor will typically review the employers training
program for adequacy of content, frequency of training, and
effectiveness of training in terms of its goals and objectives as
well as to how it fits into meeting the standards requirements.
Through interviews, the auditor can determine the operators
knowledge and awareness of the safety procedures, duties,
rules, and emergency response assignments. During the
inspection, the auditor can observe the operators actual
implementation of practices such as safety and health policies,
procedures, and work authorization practices. This approach
enables the auditor to identify deficiencies and determine
where corrective actions or improvements are needed.

The auditor must document the areas that require corrective

action. This provides a record of the audit procedures and findings,
and serves as a baseline for future audits. It will help future auditors
determine changes or trends from previous audits.

Corrective action is one of the most important parts of the

audit. The corrective action process normally begins with a
management review of the audit findings. The purpose of
this review is to determine what actions are appropriate, and
to establish priorities, timetables, resource allocations and
requirements and responsibilities. In some cases, corrective
action may involve a simple change in procedure or minor
maintenance effort to remedy the concern. Management of
change procedures must be used, when required, even for
what may seem to be a minor change. There may be instances
where no action is necessary and this can be a valid resolution
to an audit finding. However, all findings and corrective
actions taken, including an explanation where no action is

OCCUPATIONALSAFETYANDHEALTHADMINISTRATION
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taken, must be documented. Many employers have found that
establishing a common system for addressing findings and
recommendations from PHAs, Incident Investigations, and
Compliance Audits is a cost-effective approach.

APPENDIX A: Frequently Asked Questions

This appendix documents many PSM-related questions that
small businesses commonly ask of OSHA. These questions
are meant to provide small business owners with helpful
responses that can be used in your workplace.

What is the Process Safety Management standard? OSHA

issued the Process Safety Management of Highly Hazardous
Chemicals standard (29 CFR 1910.119), which contains
requirements for the management of hazards associated with
processes using highly hazardous chemicals. The standard
is intended to help prevent or minimize unexpected releases
of toxic, reactive, or flammable liquids and gases associated
with these processes by emphasizing the establishment
of a comprehensive management program that integrates
technologies, procedures, and best management practices.

Why is the PSM standard necessary? Regardless of the

industry using highly hazardous chemicals, there is a potential
for a release of these chemicals any time the processes is not
properly controlled. Properties of these chemicals may be
toxic, reactive, flammable, or explosive, or they may exhibit
a combination of these properties. These releases have the
potential to cause significant damage to property and to
severely or fatally injure individuals in the workplace.

How do I know if my worksite is covered by the PSM

standard? You are required to comply with the PSM if you
use, manufacture/produce, store, handle, or are involved in
the on-site movement of chemicals that are on the List of
Highly Hazardous Chemicals (29 CFR 1910.119 AppendixA)
at or abovethe threshold quantity set by OSHA; have a
process which involves a flammable liquid or gas in a quantity

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of 10,000 pounds or more; or manufacture explosives or
pyrotechnics in any quantity. However, OSHA exempts three
types of facilities from the PSM standard: retail facilities; oil
or gas well drilling or servicing, and normally unoccupied
remote facilities. Additionally, hydrocarbon fuels used solely
for workplace consumption as a fuel (e.g., propane used for
comfort heating, gasoline for vehicle refueling); and flammable
liquids with a flashpoint below 100 F (37.8 C) stored in
atmospheric tanks or transferred and kept below their normal
boiling point without benefit of chilling or refrigeration, are
also exempt from PSM if such fuels are not a part of a process
containing another highly hazardous chemical (HHC) covered
by the PSM standard.

What industries does the rule cover? OSHAs standard applies

to a wide range of industriesparticularly those pertaining to
chemicals, transportation equipment, and fabricated metal
products. Other affected sectors include those involved with
natural gas liquids, chemical warehousing, food processing,
electric, gas, sanitary services, and wholesale trade. The standard
also applies to pyrotechnics and explosives manufacturers.

Does PSM apply to non-manufacturing facilities? Yes, the

PSM standard can apply to non-manufacturing processes
such as in the refrigeration industry, and services industries
such as food and sanitation, and chemical warehousing and
distribution industries. In fact, many PSM-covered processes
involve a non-manufacturing application of HHCs.

What does the PSM standard require? The PSM standard

starts with a compilation of process safety information,
followed by a process hazard analysis (PHA). A PHA consists
of a careful and thorough review of what could go wrong and
what safeguards must be implemented to prevent releases of
highly hazardous chemicals. In addition to the PHA, the standard
also mandates development of written operating procedures,
completion of relevant employee training, encouraging and
ensuring employee participation (according to a written plan),
pre-startup safety reviews, evaluation of the mechanical
integrity of critical equipment, contractor requirements, and

OCCUPATIONALSAFETYANDHEALTHADMINISTRATION
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a written management of change process. It also requires a
permit system for hot work, investigation of incidents involving
releases of covered chemicals or near-misses, emergency
action plans, compliance audits at least every three years,
and allows for trade secret protection as long as the relevant
information remains available to applicable parties.

Why do I need a written Process Safety Management

program? A written PSM program assists employers and
their workers in the development and uniform implementation
of PSM activities across their organization. EPAs Risk
Management Program rule also mandates that covered
employers submit a Risk Management Plan to their agency.
OSHAs PSM standard requires written documentation for a
number of elements, including employee participation, process
safety information, process hazards analysis, operating
procedures, operator training, contractor training, hot work
permits, mechanical integrity, management of change, incident
investigations, emergency planning and response, and
compliance audit elements.

What are the design and maintenance standards I will

have to follow at my facility? The PSM standard references
recognized and generally accepted good engineering Practices
(RAGAGEP). Businesses must be able to demonstrate that their
PSM-covered processes are designed and constructed to meet
requirements of the applicable engineering standards (e.g.,
ASME, API, ANSI). The facility is responsible for selecting the
RAGAGEP, and demonstrating how its processes are built to
the appropriate design standards and have been maintained
in accordance with those standards. See OSHAs Regional
Administrators Memorandum on RAGAGEP enforcement.11

Who should receive PSM training? The PSM standard

requires specific training for all employees involved in
operating a PSM-covered process. Operating employees
must complete initial training followed by refresher training
at least every three years. Training of operators and contract

11. www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=29414

PROCESS SAFETY MANAGEMENT FOR SMALL BUSINESSES

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employees must be documented to demonstrate that the
employee has received and understood the applicable
information. Maintenance personnel and contractors also must
receive training under the standard.

I am a contractor on a PSM-covered worksite. Do I need

PSM training? Yes. Contract employees and their employers
must meet the applicable requirements under the PSM
standard, including training. The standard outlines specific
responsibilities for both the employer and contract employer
to ensure the safety of the contract employees and the proper
operation of the process.

Can small businesses receive help developing, initiating and

instituting a PSM program? Yes. OSHAs On-site Consultation
Program offers free and confidential occupational safety and
health services to small and medium-sized businesses in
all states and several territories, with priority given to high-
hazard worksites. On-site Consultation services are separate
from enforcement and do not result in penalties or citations.
Consultants from state agencies or universities work with
employers to identify workplace hazards, provide advice on
compliance with OSHA standards, and assist in establishing
and improving safety and health programs. To locate the
OSHA On-site Consultation Program nearest you, call 1-800-
321-6742 (OSHA) or visit www.osha.gov/consultation.

Where can I learn more about the PSM standard and its
requirements? In addition to this publication, you may refer to
29 CFR 1910.119 for specific requirements of the PSM standard,
which is available on the OSHA website (osha.gov). OSHA
offers two other publications that provide information about the
PSM standard and its application: Process Safety Management
(OSHA 3132) and Process Safety ManagementGuidelines
for Compliance (OSHA 3133); both are available, on the OSHA
web site. Small businesses may contact OSHAs free On-site
Consultation Program for help with identifying and mitigating
workplace hazards. OSHAs On-site Consultation Program offers
free and confidential occupational safety and health services

OCCUPATIONALSAFETYANDHEALTHADMINISTRATION
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to small and medium-sized businesses in all states and several
territories, with priority given to high-hazard worksites. To locate
the OSHA On-site Consultation Program nearest you, call 1-800-
321-6742 (OSHA) or visit www.osha.gov/consultation.

What are a few key safety management practices all

employees should know? All potentially affected employees
should know the hazards related to storing, mixing or
processing chemicals. Employees should know how each of
their processes work. They should also know when equipment
is operating improperly or outside safe limits. If equipment is
not operating properly or an emergency occurs, they should
know how to respond and who to contact.

What is the EPA Risk Management Plan (RMP)? EPA

regulations and guidance for chemical incident prevention at
facilities that use certain hazardous substances are contained
in the RMP rule (40 CFR Part 68). The information required from
facilities under RMP helps local fire, police, and emergency
response personnel prepare for and respond to chemical
emergencies. Making RMPs available to the public also fosters
communication and awareness to improve incident prevention
and emergency response at the local level.

Who must submit an RMP and how often? Facilities using

more than a threshold quantity of any chemical found in the
List of Regulated Substances (40 CFR 68.130) in a process
are required to comply with EPAs Risk Management Plan
regulations. The regulations require owners or operators of
covered facilities to implement a risk management program
and to submit an RMP to EPA. RMPs must be revised and
resubmitted to EPA every five years.

How is RMP different from PSM? The requirement for

development of RMPs is established by the Clean Air Act (as is
the requirement for PSM), and is primarily intended to protect
the population outside a facility. PSM is intended to protect
employees at the facility. The RMP rule is administered and
enforced by the EPA, while PSM is administered and enforced

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by OSHA. The RMP rule requires facilities to submit plans to the
EPA and local emergency responders so that they are aware of
potential environmental and exposure risks when responding to
an incident. Otherwise, the standards are nearly identical.

What chemicals must be reported under RMP? Any

chemical identified by EPAs RMP List of Regulated Substances
(40 CFR 68.130) that is present in more than a threshold
quantity must be reported under RMP. Many of the chemicals
on this list are also found on OSHAs List of Highly Hazardous
Chemicals (29 CFR 1910.119 Appendix A).

OCCUPATIONALSAFETYANDHEALTHADMINISTRATION
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APPENDIX B: Examples of PHA
Methodology

PROCESS SAFETY MANAGEMENT FOR SMALL BUSINESSES

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OCCUPATIONALSAFETYANDHEALTHADMINISTRATION
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PROCESS SAFETY MANAGEMENT FOR SMALL BUSINESSES
2 7
Workers Rights
Under federal law, workers are entitled to working conditions
that do not pose a risk of serious harm.
For more information on how to assure a safe and healthful
workplace, see OSHAs Workers page.

OSHA Assistance, Services and Programs

OSHA has a great deal of information to assist employers
in complying with their responsibilities under OSHA law.
Several OSHA programs and services can help employers
identify and correct job hazards, as well as improve their
safety and health program.

Establishing a Safety and Health Program

Safety and health programs are systems that can substantially
reduce the number and severity of workplace injuries and
illnesses, while reducing costs to employers.

Visit www.osha.gov/shpguidelines for more information.

Compliance Assistance Specialists

OSHA Compliance assistance specialists can provide
information to employers and workers about OSHA standards,
short educational programs on specific hazards or OSHA rights
and responsibilities, and information on additional compliance
assistance resources.

Visit www.osha.gov/dcsp/compliance_assistance/cas.html or
call 1-800-321-OSHA (6742) to contact your local OSHA office.

Free On-site Safety and Health Consultation

Services for Small Business
OSHAs On-site Consultation Program offers free and confidential
advice to small and medium-sized businesses in all states across
the country, with priority given to high-hazard worksites. On-site
consultation services are separate from enforcement and do not
result in penalties or citations.

OCCUPATIONALSAFETYANDHEALTHADMINISTRATION
2 8
For more information or to find the local On-site Consultation
office in your state, visit www.osha.gov/consultation, or call
1-800-321-OSHA (6742).

Under the consultation program, certain exemplary

employers may request participation in OSHAs Safety
and Health Achievement Recognition Program (SHARP).
Worksites that receive SHARP recognition are exempt from
programmed inspections during the period that the SHARP
certification is valid.

Cooperative Programs
OSHA offers cooperative programs under which businesses,
labor groups and other organizations can work cooperatively
with OSHA. To find out more about any of the following
programs, visit www.osha.gov/cooperativeprograms.

Strategic Partnerships and Alliances

The OSHA Strategic Partnerships (OSP) provide the opportunity
for OSHA to partner with employers, workers, professional or
trade associations, labor organizations, and/or other interested
stakeholders. Through the Alliance Program, OSHA works with
groups to develop compliance assistance tools and resources
to share with workers and employers, and educate workers and
employers about their rights and responsibilities.

Voluntary Protection Programs (VPP)

The VPP recognize employers and workers in private industry
and federal agencies who have implemented effective safety and
health management programs and maintain injury and illness
rates below the national average for their respective industries.

Occupational Safety and Health Training Courses

The OSHA Training Institute partners with 27 OSHA Training
Institute Education Centers at 42 locations throughout the United
States to deliver courses on OSHA standards and occupational
safety and health topics to thousands of students a year. For more
information on training courses, visit www.osha.gov/otiec.

PROCESS SAFETY MANAGEMENT FOR SMALL BUSINESSES

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OSHA Educational Materials
OSHA has many types of educational materials to assist employers
and workers in finding and preventing workplace hazards.

All OSHA publications are free at www.osha.gov/publications and

www.osha.gov/ebooks. You can also call 1-800-321-OSHA (6742)
to order publications.

Employers and safety and health professionals can sign-up for

QuickTakes, OSHAs free, twice-monthly online newsletter with
the latest news about OSHA initiatives and products to assist
in finding and preventing workplace hazards. To sign up visit
www.osha.gov/quicktakes.

OCCUPATIONALSAFETYANDHEALTHADMINISTRATION
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OSHA Regional Offices
Region I
Boston Regional Office
(CT*, ME, MA, NH, RI, VT*)
JFK Federal Building, Room E340
Boston, MA 02203
(617) 565-9860 (617) 565-9827 Fax

Region II
New York Regional Office
(NJ*, NY*, PR*, VI*)
201 Varick Street, Room 670
New York, NY 10014
(212) 337-2378 (212) 337-2371 Fax

Region III
Philadelphia Regional Office
(DE, DC, MD*, PA, VA*, WV)
The Curtis Center
170 S. Independence Mall West
Suite 740 West
Philadelphia, PA 19106-3309
(215) 861-4900 (215) 861-4904 Fax

Region IV
Atlanta Regional Office
(AL, FL, GA, KY*, MS, NC*, SC*, TN*)
61 Forsyth Street, SW, Room 6T50
Atlanta, GA 30303
(678) 237-0400 (678) 237-0447 Fax

Region V
Chicago Regional Office
(IL*, IN*, MI*, MN*, OH, WI)
230 South Dearborn Street
Room 3244
Chicago, IL 60604
(312) 353-2220 (312) 353-7774 Fax

PROCESS SAFETY MANAGEMENT FOR SMALL BUSINESSES

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Region VI
Dallas Regional Office
(AR, LA, NM*, OK, TX)
525 Griffin Street, Room 602
Dallas, TX 75202
(972) 850-4145 (972) 850-4149 Fax
(972) 850-4150 FSO Fax

Region VII
Kansas City Regional Office
(IA*, KS, MO, NE)
Two Pershing Square Building
2300 Main Street, Suite 1010
Kansas City, MO 64108-2416
(816) 283-8745 (816) 283-0547 Fax

Region VIII
Denver Regional Office
(CO, MT, ND, SD, UT*, WY*)
Cesar Chavez Memorial Building
1244 Speer Boulevard, Suite 551
Denver, CO 80204
(720) 264-6550 (720) 264-6585 Fax

Region IX
San Francisco Regional Office
(AZ*, CA*, HI*, NV*, and American Samoa,
Guam and the Northern Mariana Islands)
90 7th Street, Suite 18100
San Francisco, CA 94103
(415) 625-2547 (415) 625-2534 Fax

Region X
Seattle Regional Office
(AK*, ID, OR*, WA*)
300 Fifth Avenue, Suite 1280
Seattle, WA 98104
(206) 757-6700 (206) 757-6705 Fax

OCCUPATIONALSAFETYANDHEALTHADMINISTRATION
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* These states and territories operate their own OSHA-
approved job safety and health plans and cover state and local
government employees as well as private sector employees.
The Connecticut, Illinois, New Jersey, New York and Virgin
Islands programs cover public employees only. (Private sector
workers in these states are covered by Federal OSHA). States
with approved programs must have standards that are identical
to, or at least as effective as, the Federal OSHA standards.

Note: To get contact information for OSHA area offices, OSHA-

approved state plans and OSHA consultation projects, please visit
us online at www.osha.gov or call us at 1-800-321-OSHA (6742).

How to Contact OSHA

For questions or to get information or advice, to report an
emergency, fatality, inpatient hospitalization, amputation,
or lossof an eye, or to file a confidential complaint, contact
yournearest OSHA office, visit www.osha.gov or call OSHA
at1-800-321-OSHA (6742), TTY 1-877-889-5627.

For assistance, contact us.

We are OSHA. We can help.

PROCESS SAFETY MANAGEMENT FOR SMALL BUSINESSES

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 U.S. Department of Labor

For more information:

Occupational
Safety and Health
Administration
www.osha.gov (800) 321-OSHA (6742)