process_safety_management

1. Process Safety Management -
Tips for the Little Guy

2. What Is Process Safety Management
 Process Safety Management is the
application of management principles
and systems to the identification,
understanding, and control of process
hazards to protect employees, facility
assets and the environment.

4. What Is Process Safety Management
14 Elements
 Application
 Employee
Participation
 Process Safety
Information
 Process Hazard
Analysis
 Operating Procedures
 Employee Training
 Contractors
 Pre-Start up Safety
Review
 Mechanical Integrity
 Hot Work (Non-routine
Work Authorizations)
 Management of
Change
 Incident Investigation
 Emergency Planning
and Response
 Compliance Audits

6. 1910.119 (a) Application
 Appendix A of 29 CFR 1910.119 contains a
listing of toxic and reactive highly hazardous
chemicals which present a potential for a
catastrophic event at or above the threshold
quantities listed.
 To adequately address this section, identify
what brings you into coverage by the
standard, specifying which processes at the
facility are covered and why.

7. 1910.119 (a) Application
cont.
Consider what you can do to get out of the
situation
 Reduce inventories of highly hazardous
chemicals
 Receive smaller shipments
 Enhance inventory control
 Break up storage locations within the plant to
reduce the amounts on hand to below the
threshold quantity (TQ)
 Substitute listed with non-listed

8. May 25, 2004 Conyers GA

9. 1910.119 (c) Employee
Participation
 Employees are required to be an active part
of the process and your written programs
need to document what roles employees play,
their involvement in the development of the
programs, and continuing participation in the
process.
 An OSHA inspector (CSHO) will attempt to
verify participation by interviewing employees
at random.

10. 1910.119 (c) Employee
Participation cont.
 Consultation / participation with training
and supervision to determine the
frequency and content of initial and
refresher training.
 Consultation / participation to develop
and review operating and maintenance
procedures.
 Consultation / participation in incident
investigations regarding the covered
process.

11. 1910.119 (d) Process Safety
Information
 Material Safety Data
Sheets (MSDS)
 Piping and
instrumentation
diagrams (PINDs)
 Block flow diagrams
 Material and energy
balance calculations
 Relevant consensus
standards
 Materials of
construction

12. 1910.119 (d) Process Safety
Information cont.
 Available to all affected employees [requirement of
1910.119 (c) Employee Participation]
 Available for Process Hazard Analysis and
revalidations [requirement of 1910.119 (e) Process
Hazard Analysis]
 So auditors and CSHOs can find everything!

13. 1910.119 (e) Process Hazard
Analysis

14. 1910.119 (e) Process Hazard
Analysis
 OSHA has suggested formats
 Don’t start until all information is
gathered
 Use a software tool to guide, record,
manage process

18. “Catastrophic release means a major
uncontrolled emission, fire, or explosion
involving one or more highly hazardous
chemicals, that presents serious danger to
employees in the workplace.” 1910.119(b)
1910.119 (e) Process Hazard
Analysis

20. 1910.119 (f) Operating
Procedures
 Standard Operating Procedures
 Do in tandem with Job Hazard Analysis
(JHAs)
 Mesh with training program
 Partner with Quality Team (ISO 9001) to
create training matrix and managed
documents

21. 1910.119 (g) Employee
Training
 The employer shall prepare a record:
 Identity of employee.
 Date of training.
 Means to verify that employee
understood training
 At a minimum, refresher training shall be
provided at least every three years and more
often if necessary to each employee involved
in operating a process.

22. 1910.119 (h) Contractors
 Absolute Requirements
 Employer Documentation:
 Contract employee injury and illness logs
related to work in covered process areas.
 Contract Employer Documentation:
 Records showing employees received
training in and understands safe work
practices related to the process on or near
where they will be working so they perform
their jobs safely.

24. 1910.119 (i) Pre-Start up
Safety Review
 Check, double check, and review any
changes, modifications, additions made
in a PSM covered area – before you flip
the switch.

25. 1910.119 (j) Mechanical
Integrity
 The employer shall develop and maintain a master
list of all equipment specifically covered by the
standard, and equipment that is important to safety of
the process.
 Pressure vessels and storage tanks.
 Piping systems including valves and other piping
components.
 Relief and vent systems and devices.
 Emergency shutdown systems.
 Controls (including monitoring devices and sensors,
alarms, and interlocks).

26. 1910.119 (j) Mechanical
Integrity cont.
 Pumps.
 Rotating equipment.
 Heat exchange equipment.
 Electrical generation and distribution
equipment.
 Un-interruptable power supplies.
 Emergency power supply equipment.
 Fire protection equipment.

27. 1910.119 (k) Hot Work (a.k.a. Non-
routine Work Authorizations)
 Welding, cutting, braising – make sure
only trained personnel perform these
functions
 Have trained fire watchers (align with
fire extinguisher / fire response training)

30. 1910.119 (l) Management of
Change
 Create formalized system to review all
changes to process areas including:
 Raw material changes / substitutions
 Personnel changes
 Process parameters
 Facility changes (HVAC / roof / fire
protection / ……..)

31. 1910.119 (l) Management of
Change cont.
 PSI
 Mechanical Integrity
 PINDs
 Hot Work
 Contractor Safety
 Employee Training
 PSSR
 Operating Procedures

32. 1910.119 (m) Incident
Investigation
Investigate
Incidents
&
Near-Misses
Begin within
48-hours
Team
with Process
Knowledge
Report with
Conclusions &
Recommendatons
Follow-up
System for
Recommendations
Reatain
Reports 5-years
Incident
Investigation

33. 1910.119 (n) Emergency
Planning and Response
 Call in all resources and make plan
comprehensive:
 Information Technology (IT) Disaster
Recovery Plan
 Business Continuity Plan (session #554 @ 4:30)
 Security
 Communications / Public Relations
 Employee Assistance

34. 1910.119 (o) Compliance
Audits
 Ask for the audit protocol ahead of time
 Have a system in place to identify the
location of all PSM documentation
 Identify what's in or out of audit scope
 Ask for money to correct audit items
before the audit is conducted
 Prepare management for report

36. Resources
 OSHA web site (www.OSHA.gov):
 CPL 2-2.45 – Process Safety Management of
Highly Hazardous Chemicals – Compliance
Guidelines and Enforcement Procedures – 78
pages of gold!
 Appendix C to §1910.119 Compliance Guidelines
and Recommendations for Process Safety
Management (Nonmandatory)
 OSHA training institute
 Safety and Health – Chemical Process Industry –
course #330A. PSM ‘boot camp’ – five days of fun
and a three ring binder!
 AIChE / CCPs

37. Please Visit!
Booth # 1312
Booth # 1310