The History of Process Safety Management

The 1910.119 Process Safety Management (PSM) Standard, established by the Occupational Safety and Health Administration (OSHA), was created to enhance the safety of workplaces that handle highly hazardous chemicals. This standard was prompted by several catastrophic industrial incidents that highlighted the need for more stringent safety regulations.  These incidents led to wide recognition in the safety community that accidental releases of highly hazardous chemicals can result in multiple worker injuries or fatalities.

Bhopal Toxic Release, 1984:  In the early hours of December 3, 1984, a catastrophic incident occurred at a chemical plant when a relief valve on a storage tank released highly toxic methyl isocyanate (MIC) gas. The cloud of MIC drifted over nearby housing, leading to approximately 2,000 deaths and tens of thousands of injuries. Precursors included an observed increase in tank pressure and a MIC leak on December 2, but efforts to mitigate the situation failed due to inoperative safety systems. This disaster, the worst in the chemical industry, significantly influenced the development of process safety management (PSM) standards worldwide.

Phillips 66 Explosion, 1989:  On October 23, 1989, a catastrophic chemical release occurred at Phillips 66’s polyethylene plant in Pasadena, near Houston. At around 1:00 PM, a flammable vapor cloud formed and ignited, causing a massive explosion followed by subsequent blasts and fires. The incident resulted in 23 deaths and injured between 130 and 300 people, with extensive damage to the complex.  The disaster happened during maintenance work on reactor settling legs. A partial blockage in the pipework led to the vapor release and ignition. Contributing factors included deficiencies in maintenance procedures, leak detection, plant layout, fire protection, permit-to-work systems, warning signs, and emergency response.

BP Texas City Refinery Fire and Explosion, 2005:  On March 23, 2005, the BP Texas City refinery experienced a series of explosions during the restart of the hydrocarbon isomerization unit, resulting in 15 deaths and 180 injuries. The incident was caused by a flooding distillation tower, which released hydrocarbons from the vent stack, impacting nearby work trailers.  Key factors included inadequate oversight by BP’s Group Board, a lack of focus on process safety, insufficient resources, and managerial shortcomings in reporting, design, and training. The incident stressed the importance of robust maintenance, leak detection, plant layout, and emergency response in the petrochemical industry.

Tesoro Anacortes Refinery Fatal Explosion and Fire, 2010:  In 2010, the Tesoro Anacortes Refinery experienced a fatal explosion and fire during the startup of the naphtha hydrotreater unit, resulting in seven deaths and severe injuries to others. A ruptured heat exchanger released highly flammable hydrocarbons, leading to the explosion.  The incident highlighted deficiencies in equipment integrity, inadequate inspection and testing practices, poor process hazard analysis (PHA), and insufficient emergency response measures. This tragedy highlighted the need for robust inspection protocols, thorough PHAs, and effective emergency response systems to prevent future incidents.

West Fertilizer Explosion and Fire, 2013:  In 2013, a significant explosion at a fertilizer plant in West, Texas, killed 15 people, including first responders, and injured over 160. Triggered by the ignition of ammonium nitrate, the blast caused extensive damage to nearby structures, with property damage estimated at $349 million.  This incident highlighted the critical importance of robust safety measures, regular maintenance, comprehensive risk assessments, effective leak detection systems, and strict adherence to safety standards in industrial facilities handling volatile substances.

Analyzing these catastrophic events helped to shape the current Process Safety Management (PSM) standard.  OSHA’s PSM standard focuses on the management of hazards associated with processes using highly hazardous chemicals that are toxic, flammable, reactive, or explosive. These substances pose significant risks if not handled with extreme care and adherence to specific protocols. PSM offers a structured set of guidelines comprised of 14 essential elements that organizations can adopt to strengthen safety procedures and align with OSHA’s guidelines.

14 Elements of a Process Safety Management Program

  1. 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.
  2. 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.
  3. 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.
  4. 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.
  5. 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.
  6. 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.
  7. 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.
  8. Mechanical Integrity is to be maintained through inspections, testing and quality assurance. Mechanical Integrity inspections are required over 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.
  9. 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 set up where hot work is to be performed.
  10. 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.
  11. 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 are knowledgeable in the process and to document and report findings.
  12. 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.
  13. 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, the employer is to develop a report of findings as well as address deficiencies.
  14. Trade Secrets within information related to PSM are kept confidential. An employer can enforce confidentiality agreements if necessary.  Examples include Investigations, Procedures and Emergency Planning.

Process Safety Management is not just a regulatory requirement; it is strategy that promotes a culture of safety, minimizes risks, and protects both employees and the community. By adhering to its principles and integrating its elements into everyday operations, organizations drive their commitment to safety while complying with regulatory standards.  IFO Group expert PSM consultants bring a wealth of knowledge and experience to help you navigate and secure industrial processes. Through comprehensive assessments, our experts evaluate the severity and likelihood of releases of toxic, reactive, flammable, or explosive chemicals, providing a clear understanding of potential hazards.  We then create tailored strategies to effectively mitigate these risks, ensuring a safer workplace.  Contact us at info@ifogroup.com or at 832-403-2135 to request a free consultation.