Process Safety Management (PSM)
Process Safety Management (PSM) is a regulation issued by the U.S.
Department of Labour’s Occupational Safety and Health
Administration (OSHA). The regulation is designated as OSHA 1910.119,
Process Safety Management of Highly Hazardous Chemicals. Its purpose
is to prevent or minimize the consequences of releasing hazardous
chemicals in a facility or the environment surrounding a facility. Hazardous
chemicals are those that may be toxic, reactive, flammable, explosive, or a
combination of these properties. Industries handling hazardous chemicals
are required to develop an effective PSM program that protects employees,
contractors, and visitors of the facility.
Elements of PSM of Highly Hazardous Chemicals
How do companies know they are complying with the OSHA regulation
when implementing a PSM program? To answer this question, companies
should be familiar with the following 14 elements that are required for PSM
program compliance. These elements are the minimum requirements
extracted from OSHA 1910.119. All information (date, equipment,
personnel, process safety information, and process hazard analyses)
should be recorded and stored in the event that future audits need to refer
back to historical information about the facility and equipment.
1. Employee Participation
Perhaps one of the most important mandates, the employee participation
clause requires that employees) including production and maintenance
staff (be involved in every aspect of the PSM programs at their respective
worksites. They must also be represented at the meetings where PSM-
related issues are discussed. OSHA requires employee participation to be
followed as written, so employers should create formal plans.
2. Process Safety Information
According to OSHA’s PSM mandates, “The employer shall complete a
compilation of written process safety information before conducting any
process safety hazard analysis required by the standard.” In other words,
all workers should be able to access and understand the technical data
regarding the HHC-related risks they face on the job.
3. Process Hazard Analysis
One of the most technical elements of PSM, Process Hazard Analysis
requires that engineers and maintenance leaders analyze the
consequences of safety failures. These analyses must be conducted in
teams, and each team must include one person who is “knowledgeable in
the specific process hazard methodology being used.”
4. Operating Procedures
There are plenty of potential chemical hazards following turnarounds and
emergency shutdowns. OSHA inspectors want to see that companies have
plans for keeping everyone safe as they start back up.
5. Training
Workers who carry out processes involving highly hazardous chemicals
need to be well-trained, and their training should have been accomplished
through a competent source, first-party or otherwise. Their training also
needs to be well-documented.
6. Contractors
Regular employees and contractors alike must be well-informed of the
hazards they face. Under the PSM National Emphasis Program, “The
employer shall inform contract employers of the known potential fire,
explosion or toxic release hazards related to the contractor’s work and the
process.”
7. Pre-Startup Safety Review
Are you reviewing your safety procedures every time a worksite starts back
up? You should be. OSHA expects employers to perform pre-startup safety
reviews for both new and modified facilities. This rule applies even if the
procedural changes only affect a single component or process.
8. Mechanical Integrity
Periodic, documented inspections are required for several systems,
including:
Pressure vessels
Storage tanks
Piping systems
Ventilation systems
The employers or contractors conducting these inspections must not only
be officially trained, their testing procedures must follow “recognized and
generally accepted good engineering practices,” according to OSHA. In
other words, your company must be able to explain WHY your inspectors
made their decisions.
9. Hot Work Permit
Every employer needs to issue permits to employees and contractors who
weld or perform other high-temperature work near covered processes.
They also need to train their personnel to post and file these permits when
necessary.
10. Management of Change
Companies need standard procedures for managing changes to process
chemicals, technology, equipment and procedures. Each change also
requires the following considerations:
The technical basis for the change.
The impact of the change on worker safety and health.
Necessary modifications to operating procedures.
The necessary time period for the change.
Authorization requirements for the proposed change.
11. Incident Investigation
OSHA’s state standard calls for investigations for all incidents that result
in/or could have resulted in) a catastrophic highly hazardous chemical
release( . Because of that ambiguous wording, cautious companies must
keep every potential HHC-related scenario in mind.
12. Emergency Planning and Response
Even minor chemical releases can lead to major incidents. This element
mandates employers to create emergency plans for handling smaller HHC
releases.
13. Compliance Audits
According to the PSM, “Employers shall certify that they have evaluated
compliance with the provisions of this section at least every three years to
verify that the procedures and practices developed under the standard are
adequate and are being followed.” This element also requires employers to
retain at least their two most recent audit reports.
14. Trade Secrets
Until recently, some companies attempted to protect proprietary information
by keeping process details from their employees. To prevent this scenario
and enhance worker safety, the “trade secrets” element gives employees
the right to know processes that may affect their health and safety.
