Does your worksite have a covered process?

Do you have on-site storage of chemicals?

Do your workers handle or move highly hazardous chemicals?

If you answered yes to any of these questions, it is likely that you need to develop an OSHA compliant Process Safety Management (PSM) program.

The unexpected release of highly hazardous toxic, reactive, or flammable chemicals creates the possibility of a disaster for workers, employers, and communities.  It is not uncommon that a new chemical is brought into a workplace and without analyzing possible risks, it can be extremely dangerous.  A series of catastrophic chemical incidents in the 1980s led to OSHA initiating its Process Safety Management of Highly Hazardous Chemicals standard (PSM) in 1992 and later a National Emphasis Program (NEP) for refineries in 2007.

Many industrial worksites do not understand OSHA’s 1910.119 Process Safety Management Standard, or think it is not needed at their facilities.  This can be extremely dangerous as catastrophic process safety incidents are often more severe and tragic than other types of workplace incidents.  This article will define what Process Safety Management is, review the basics of the 14 elements that must be implemented to develop an OSHA compliant PSM program and discuss expert resources to help you implement your program.

What is Process Safety Management (PSM)?

Process safety management is a set of principles used to assess the potential dangers associated with the operation of plant equipment or processes that could release highly hazardous chemicals (HHCs).  Process Safety focuses on controlling the potential release of hazardous substances caused by mechanical failures, process upsets and/or procedure/human error.

The Occupational Safety and Health Administration (OSHA) 1910.119 Process Safety Management Standard contains guidance to help prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals.   This is extremely important as catastrophic process safety incidents are often more severe than other types of incidents.  In addition, the 1910.119 standard offers best practices for the storage, transportation, application, and creation of highly hazardous chemicals.

14 Elements of a PSM Program

Once you have determined that your worksite meets the criteria defined by 29 CFR 1910.119, you must develop a program compliant with the OSHA requirements.  There are 14 elements that must be implemented in a Process Safety Management program.  They are as follows:

Employee Participation. It is critical to develop a written participation plan by consulting with employees.  Once the appropriate PSM content is developed, make sure that all employees have access to this information.

Process Safety Information.  Details on hazards, technology and equipment should be compiled before analysis to be used by employees to gain an understanding of the hazards that the process equipment and chemicals present.

Process Hazard Analysis.  This task involves a team of employees identifying potential hazards and the effects of control failure on the health and safety of employees.  Often details are compiled from facility siting, human factors, previous incidents, and control failures.  It should be noted that the Process Hazard Analysis must be revalidated every five years to ensure sufficient control.

Operating Procedures should be created for each operating phase as well as operating limits. The worksite should have documented procedures certified annually for startup/shutdown, normal, temporary, and emergency operations, operating limits, deviations, and potential hazards/controls.

Staff Training is to be conducted regularly and documented. This training includes a process overview, safety and health hazards, procedures emphasizing emergency in addition to safe work practices.  Training on PSM should be repeated and documented at a minimum every three years.

A Contractor according to PSM is defined as an individual performing work on or adjacent to a covered process, not applying to incidental services (janitorial, food & beverage, mail or laundry service).  It is the employer’s responsibility to inform the contractor of known hazards related to work performed and the process as well as evaluate contractor safety performance.  Contractors should be educated on the emergency plan and safe work practices such as lockout/tagout, confined space entry and opening process equipment.  Periodic safety performance evaluation should be completed to ensure contractors are working to OSHA obligations.

A Pre-startup Safety Review is to be performed for new and modified facilities.  This review helps verify that the construction is in accordance with design specs, procedures are in place, changes have been reviewed for hazard (PHA/MOC), actions from hazard review have been resolved and employee training is complete.

Mechanical Integrity is to be maintained through inspections, testing and quality assurance.  Mechanical Integrity inspections are required on a periodic timeframe and must be well documented.  Inspections include maintenance procedures and training, inspection/testing on process equipment and documentation of test and frequency and method per good engineering practices.  All deficiencies should be corrected before further use and added to a quality assurance program.

Hot Works Permits are issued whenever there are hot work operations.  It is important to document that the required fire protection has been implemented prior to work and that personnel and equipment are authorized to setup where hot work is to be performed.

Utilize Management of Change procedures to evaluate hazards whenever changes are made to the process, chemicals, technology, equipment, procedures, or facilities before startup.  Those reviewing need to consider the impact on health and safety, process safety information, operating procedures, training of employees and contractors, technical basis of the change and time authorization requirements for the change.

Incident Investigation is to be promptly performed on events which have or could have resulted in a catastrophic chemical release.  The investigation should be initiated no later than 48 hours after the incident occurred.  It is important to involve employees knowledgeable in the process and to document and report findings.

Emergency Planning & Response for the entire plant.  This action plan must include a pre-plan for catastrophe, as well as how to train and equip workers and drills to run.

Compliance Audits ensure that the employer complies with the OSHA 1910.119 standard. This internal evaluation is to be conducted at least every 3 years.  Upon evaluation, employer is to develop a report of findings as well as address deficiencies.

Trade Secrets within information related to the PSM are kept confidential.   An employer can enforce confidentiality agreements if necessary.  Examples include Investigations, Procedures and Emergency Planning.

Implementing a PSM Program

In summary, Process Safety Management in the workplace is essential to preventing incidents caused by the release of Highly Hazardous Chemicals and should be taken very seriously.  Fortunately, there are resources available to help you solve your compliance challenges.

The IFO Group can assist you with analyzing the potential causes and consequences of a variety of hazards ranging from fires and explosions to the release of hazardous chemicals and put a PSM plan into place.  By focusing on the people, processes and equipment that make up your PSM program, we can provide sound recommendations to enable you to reduce or eliminate significant risks to your organization.  Contact us at info@ifogroup.com or +1-832-403-2135 to request a free consultation.