OSHA Process Safety Management (PSM) Standard Sanjeev Saraf, Ph.D.

OSHA PSM 29 CFR 1910.119 Promulgated on 24 February 1992 Process safety management of highly hazardous chemicals Applicability Processes with specified chemicals above the threshold quantity Processes with 10,000 pounds or more of flammable liquid or gas Please refer to PSM standard for details for exact definitions

29 CFR 1910.119

Promulgated on 24 February 1992

Process safety management of highly hazardous chemicals

Applicability

Processes with specified chemicals above the threshold quantity

Processes with 10,000 pounds or more of flammable liquid or gas

Please refer to PSM standard for details for exact definitions

PSM Applicability Processes with certain chemicals above specified thresholds Processes with 10,000 lbs or more of flammable gas or liquid Risk-based criteria General duty and obligation Loss prevention OSHA PSM Standards do not apply to: Retail facilities Oil or gas well drilling or servicing operations Normally unoccupied remote facilities.

Processes with certain chemicals above specified thresholds

Processes with 10,000 lbs or more of flammable gas or liquid

Risk-based criteria

General duty and obligation

Loss prevention

OSHA PSM Standards do not apply to:

Retail facilities

Oil or gas well drilling or servicing operations

Normally unoccupied remote facilities.

14 Elements of PSM Employee Participation Process Hazard Analysis Training Pre-startup Safety Review Hot Work Permit Incident Investigation Compliance Audit Process Safety Information Operating Procedures Contractors Mechanical Integrity Management of Change Emergency Planning Trade Secrets

Employee Participation

Process Hazard Analysis

Training

Pre-startup Safety Review

Hot Work Permit

Incident Investigation

Compliance Audit

Process Safety Information

Operating Procedures

Contractors

Mechanical Integrity

Management of Change

Emergency Planning

Trade Secrets

1. Employee Participation Written plan of action Consult with employees on the conduct and development of process safety programs Provide access to Process Hazard Analysis (PHA) and all other information developed for the process safety programs Objective: Accountability

Written plan of action

Consult with employees on the conduct and development of process safety programs

Provide access to Process Hazard Analysis (PHA) and all other information developed for the process safety programs

Objective: Accountability

2. Process Safety Information Chemical information: Toxicity information Permissible exposure limits Physical data Reactivity data Corrosivity data Thermal and chemical stability data Hazardous effects of inadvertent mixing Objective: Knowledge and Control of the Operation

Chemical information:

Toxicity information

Permissible exposure limits

Physical data

Reactivity data

Corrosivity data

Thermal and chemical stability data

Hazardous effects of inadvertent mixing

Objective: Knowledge and Control of the Operation

3. Process Safety Information Technology information: Block or simplified Process Flow Diagram (PFD) Process chemistry Maximum inventory Safe upper and lower limits Consequences of deviation Objective: Knowledge and Control of the Operation

Technology information:

Block or simplified Process Flow Diagram (PFD)

Process chemistry

Maximum inventory

Safe upper and lower limits

Consequences of deviation

Objective: Knowledge and Control of the Operation

3. Process Safety Information (cont’d.) Equipment information: Materials of construction (MOC) Piping and Instrument Diagrams (P&IDs) Electrical classification Relief systems design and design basis Ventilation system design Design codes employed Material and Energy Balances Safety systems Objective: Knowledge and Control of the Operation

Equipment information:

Materials of construction (MOC)

Piping and Instrument Diagrams (P&IDs)

Electrical classification

Relief systems design and design basis

Ventilation system design

Design codes employed

Material and Energy Balances

Safety systems

Objective: Knowledge and Control of the Operation

4. Safe Work Practices Hot Work permit Fire prevention and protection requirements Safe conduct of operating, maintenance, and modification activities Control of materials and substances Control of access to process areas Objective: Knowledge and Control of the Operation

Hot Work permit

Fire prevention and protection requirements

Safe conduct of operating, maintenance, and modification activities

Control of materials and substances

Control of access to process areas

Objective: Knowledge and Control of the Operation

5. Contractors (Host Employer Responsibilities) Host employer must: Consider safety records in selecting contractors Inform contractors of potential process hazards Explain the facility's emergency action plan Evaluate contractor safety performance Maintain injury/illness log for contractors working in process areas Objective: Knowledge and Control of the Operation

Host employer must:

Consider safety records in selecting contractors

Inform contractors of potential process hazards

Explain the facility's emergency action plan

Evaluate contractor safety performance

Maintain injury/illness log for contractors working in process areas

Objective: Knowledge and Control of the Operation

5. Contractors (Contractor Employer Responsibilities) Contractor employer must: Train their employees in safe work practices and document that training Assure that employees know about potential process hazards and emergency action plan Assure that employees follow safety rules of facility Advise employer of hazards Objective: Knowledge and Control of the Operation

Contractor employer must:

Train their employees in safe work practices and document that training

Assure that employees know about potential process hazards and emergency action plan

Assure that employees follow safety rules of facility

Advise employer of hazards

Objective: Knowledge and Control of the Operation

6. Operating Procedures Written operating procedures which are specific to each of the facility's operating areas The operating procedures must address: Initial startup Normal operation Temporary operations Emergency operations Normal shutdown Startup following turnaround Objective: Knowledge and Control of the Operation

Written operating procedures which are specific to each of the facility's operating areas

The operating procedures must address:

Initial startup

Normal operation

Temporary operations

Emergency operations

Normal shutdown

Startup following turnaround

Objective: Knowledge and Control of the Operation

7. Training and Certification Certified training must be provided to all personnel responsible for operating the facility Training should include: Initial training Refresher and supplemental training Communication of change Contractor training Objective: Knowledge and Control of the Operation

Certified training must be provided to all personnel responsible for operating the facility

Training should include:

Initial training

Refresher and supplemental training

Communication of change

Contractor training

Objective: Knowledge and Control of the Operation

8. Process Hazards Analysis (PHA) PHA should be performed at least every five years to minimize the likelihood of occurrence and the consequence of a dangerous substance release Recommended methods for conducting a PHA: What If Checklist What If/Checklist HAZOP FMEA FTA Objective: Hazards Identification and Control of Hazards

PHA should be performed at least every five years to minimize the likelihood of occurrence and the consequence of a dangerous substance release

Recommended methods for conducting a PHA:

What If

Checklist

What If/Checklist

HAZOP

FMEA

FTA

Objective: Hazards Identification and Control of Hazards

9. Management of Change (MOC) Establish and implement written MOC procedures addressing: Technical basis Impact on safety and health Modifications to operating procedures Necessary time period for the change Authorization requirements Objective: Hazards Identification and Control of Hazards

Establish and implement written MOC procedures addressing:

Technical basis

Impact on safety and health

Modifications to operating procedures

Necessary time period for the change

Authorization requirements

Objective: Hazards Identification and Control of Hazards

10. Pre-startup Safety Review Pre-Startup safety review for new and modified facilities should cover: Construction is in accordance with design specifications Safety, operating, and emergency procedures PHA recommendations Training of employees Objective: Hazards Identification and Control of Hazards

Pre-Startup safety review for new and modified facilities should cover:

Construction is in accordance with design specifications

Safety, operating, and emergency procedures

PHA recommendations

Training of employees

Objective: Hazards Identification and Control of Hazards

11. Mechanical Integrity Establish and implement written procedures to maintain the mechanical integrity of: Pressure vessels and storage tanks Piping systems Relief and vent systems ESD systems Controls, alarms, and interlocks Objective: Hazards Identification and Control of Hazards

Establish and implement written procedures to

maintain the mechanical integrity of:

Pressure vessels and storage tanks

Piping systems

Relief and vent systems

ESD systems

Controls, alarms, and interlocks

Objective: Hazards Identification and Control of Hazards

12. Emergency Planning and Response Establish and implement an emergency action plan Actions employees are to take when there is an unwanted release of highly hazardous chemicals Objective: Accidents and learning from accidents

Establish and implement an emergency action plan

Actions employees are to take when there is an unwanted release of highly hazardous chemicals

Objective: Accidents and learning from accidents

13. Incident Investigation Incidents that result in, or could reasonably have resulted in a major accident must be investigated. Incident investigation report should include: Date of incident Date investigation began Description Factors Recommendations Objective: Accidents and learning from accidents

Incidents that result in, or could reasonably have resulted in a major accident must be investigated. Incident investigation report should include:

Date of incident

Date investigation began

Description

Factors

Recommendations

Objective: Accidents and learning from accidents

14. Compliance Audits Conduct audit every three years Audit team Determine appropriate response to each finding Correct deficiencies Retain two most recent audits

Conduct audit every three years

Audit team

Determine appropriate response to each finding

Correct deficiencies

Retain two most recent audits