OSHA PSM Regulations

Slide 1: OSHA Process Safety Management (PSM) Standard Sanjeev Saraf, Ph.D.

Slide 2: 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

Slide 3: 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.

Slide 4: 14 Elements of PSM 1. Employee Participation 1. Process Safety Information 2. Process Hazard Analysis 2. Operating Procedures 3. Training 3. Contractors 4. Pre-startup Safety 4. Mechanical Integrity Review 5. Management of Change 5. Hot Work Permit 6. Emergency Planning 6. Incident Investigation 7. Trade Secrets 7. Compliance Audit

Slide 5: 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

Slide 6: 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

Slide 7: 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

Slide 8: 3. Process Safety Information (cont’d.) Equipment Information:  Materials of Construction  Piping and Instrument Diagrams  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

Slide 9: 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

Slide 10: 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

Slide 11: 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

Slide 12: 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

Slide 13: 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

Slide 14: 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

Slide 15: 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

Slide 16: 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

Slide 17: 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

Slide 18: 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

Slide 19: 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

Slide 20: 14. Compliance Audits  Conduct audit every three years  Audit team  Determine appropriate response to each finding  Correct deficiencies  Retain two most recent audits