The 14 Elements to an Effective & Compliant Process Safety Management Program

Many businesses either don’t understand OSHA’s Process Safety Management standard (PSM), or they don’t realize it applies to them.  Once you have determined you have a covered process or on-site storage, handling and/or moving of a highly hazardous chemical (defined by 29 CFR 1910.119) at or above the threshold quantity set by OSHA, you must develop a PSM program compliant with OSHA’s specific requirements. There are 14 elements that must be implemented in such a program, and this post will cover the basics of those 14 elements.

  1. Employee Participation
  • All employees that play a role in facility operations should be involved in every aspect of the PSM programs at their respective worksites
  • Employees must be represented at meetings discussing PSM-related issues
  • Teams should include at least one person specializing in the specific process being used
  • Each of the following elements requires a competent and experienced team of individuals
  1. Process Safety Information
  • The employer shall complete a compilation of written process safety information before conducting any process safety hazard analysis required by the standard
  • Collect and document HHC information to ensure all employees can access and understand the technical data regarding the HHC-related risks they may face on the job
  1. Process Hazard Analysis
  • Must be performed at least once every five years
  • Identify processes posing the greatest risk and address those first
  • Must be performed by a team of engineering and maintenance experts to identify, evaluate, and control hazards
  • Each team must include one person who is knowledgeable in the specific process hazard methodology being used
  • Must use variety of techniques, such as “what if” analyses; checklist methods; hazard and operability studies; failure modes and effects analysis; etc.
  1. Operating Procedures
  • Document all operational procedures involving initial startup, normal operations, temporary operations and emergency shutdowns
  • Operators should be aware of operating limits of the process and consequences if the process deviates from normal conditions
  1. Training
  • Review procedures, safety factors, and health hazards specific to the job task
  • Sessions held through a competent source
  • Strong focus on documentation
  1. Contractor Safety
  • Evaluation of a contractor’s safety performance prior to starting a project
  • Once a contractor passes clearance requirements, it is the company’s responsibility to inform the contractor of potential risks and health hazards. Then, the contractor must relay this information to the contracted team and train them appropriately
  1. Pre-Startup Safety Review
  • Review of safety procedures every time a worksite starts back up at both new and modified facilities and even if the procedural change only affects a single component or process
  1. Mechanical Integrity
  • For major process units and equipment, such as pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, and control systems
  • Routine inspections must be conducted to ensure the mechanical integrity of the component meets requirements
  • All inspections/tests must follow recognized and generally accepted good engineering practices (RAGAGEP)
  1. Hot Work Permit
  • Issue hot work permits for personnel performing high-temperature operations on equipment (e.g., welding) and train personnel to post and file permits when necessary
  1. Management of Change
  • Implementation of standard procedures for managing changes to process chemicals, technology, equipment and procedures

For this procedure, one must consider:

  • Technical basis for proposed change
  • Impact of the change on safety and health
  • Modifications in operating procedures
  • Necessary time period for the change
  • Authorization requirements for the propose change
  1. Incident Investigation
  • All incidents that result in – or could have resulted in – a catastrophic HHC release
  • Every potential HHC scenario should be considered including: date of incident, date of investigation, description of the incident, root causes, recommendations/solutions
  1. Emergency Planning and Response
  • For the entire facility and mitigation of large and small HHC releases
  1. Compliance Audits
  • “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.”
  • Must retain at least their two most recent audit reports
  1. Trade Secrets
  • Employers must provide all information necessary to comply with PSM standards, regardless of the trade secret status of the information. This was established to prevent companies from trying to protect proprietary information by keeping process details from employees and ensures employees involved in elements 2-13 have access to necessary information about the process and health risks they may encounter

Once you have determined your business or facility is involved with a covered process, an effective PSM program compliant with these fourteen requirements must be developed.

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