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1. Process Safety Management
of Highly Hazardous &
Explosive Chemicals
Contractor Pre-Qualification, Emergency
Preparedness, Incident Investigation, Audits
& EPA Risk Management Plans (RMP)

2. Now That We’ve Developed
 Process Safety Information
 Process Material Toxicity Information
 Process Hazard Analysis (PHA’s)
 Mechanical Integrity Certificates
 Management of Change
 Inspection/Testing/Maintenance
 Operating Procedures
 Safe Work Procedures
 Training Programs
 Training for Contractors
Now…

3. Contractor Management
1910.119(h)

4. PSM Contractors
 The employer, when selecting a
contractor, shall obtain and
evaluate information regarding
the contract employer's safety
performance and programs.
 The employer shall inform
contract employers of the
known potential fire, explosion,
or toxic release hazards related
to the contractor's work and the
process

5. Contractor Pre-Qualification &
Authorization
 The Standard Requires You to:
 Explain contractor qualification requirements
 List what is required for contractor pre-bid
awareness - pre-qualification
 List what is required for contractor post-bid
awareness - training & orientation
 Specify contractor responsibilities
 Describe contractor 300 Log Requirements
 Evaluate Contractor Performance
 List documentation requirements for contractors to
complete
 Explain the use of a work authorization system

6.  Typical Pre-Qualification Elements:
 Years Experience in Work Process
 Experience Modification Rate (EMR)
 OSHA Total Recordable Incident Rate and
Lost Work day Case Rate Information
 Safety Programs
 Training Documentation
Contractor Pre-Qualification &
Authorization

7. Emergency Preparedness
1910.119(f)(1)(I)(D)

8. Emergency Preparedness
 Our Written Plan Must:
 Define an emergency action plan
 Define an emergency response plan
 Describe a Minimum emergency response plan
 Describe procedures for handling small releases
 List the three levels of emergency response
 List procedures for emergency evacuation
 List requirements of alarm systems
 List training requirements

9. Emergency Preparedness
 The Standard Requires You to:
 Develop a Early Warning Method for Releases
(Sensors/Alarms)
 Train on the Meaning of the Alarms (May be
Multiple Alarms)
 Develop Emergency Evacuation Written Plans,
Evacuation Maps & Assembly Points based on
Release Characteristics
 Determine Emergency PPE Requirements
 Train Employees & Contractors in the Emergency
Evacuation Plans
 Drill The Emergency Evacuation Plan At Last
Once Per Year

10. Emergency Preparedness
 Warning Systems
must:
 Clearly Notify
Employees of the
Hazardous Release
 Employees &
Contractors must be
Trained in the
Meaning of the
Alarm(s)

11. Emergency Preparedness
Evacuation Maps

12. Emergency Preparedness
Assembly Points
Alternate
Assembly
Point
Alternate Assembly
Points Depending
on Prevailing
Weather Affecting
Release

13. Emergency Preparedness
Emergency PPE
 Hazardous
Chemicals May
Require Emergency
PPE to be Worn
 FRP
 Escape Respirators
 Eye Protection i.e..
Refinery Goggles

14. Emergency Preparedness
Drills
 At Least Annual
Emergency
Preparedness Drills
 This is not Just an
Emergency
Evacuation…
 but Could Include
HAZWOPR
Response
 Must Document
Results

15. Incident Investigation
1910.119(m)

16. Incident Investigation Program
Must Include the Following
 Describe the purpose of incident investigation
 List the circumstances or occurrences, which require
formal incident investigation
 List the major investigation procedures that should be
followed
 Explain the list the responsibilities of the incident
investigation team
 Explain the contents of an "Incident Summary" form
 Explain the contents of an "Incident Description" form
 Explain the contents of an "Approvals, Follow-up and
Review" form
 Explain the contents of a "Close-out" form
 Explain Corrective Actions Taken

17. Incidents Can Be Minor or Major -
Both Require Investigation

18. Incident Investigation
Documentation Must Include
 Date of incident
 Date investigation began
 Description of the incident
 Factors contributing to the incident
 Recommendations resulting from
the investigation

19. Incident Investigation
 Will Include Written
Documentation of all
Required Elements

20. Incident Investigation
Might Even Include a Flow Chart

21. Compliance Audits
1910.119(o)

22. Compliance Audits
 1910.119 states, "Employers shall certify that
they have evaluated compliance with the
provisions of this section at least every three
years to verify that the procedures and
practices developed under the standard are
adequate and are being followed."

23. Compliance Audits
 A List of factors that may increase the
frequency of compliance audits
 Results of Any OSHA Compliance Audits
Performed & Citations/Action Items
Developed
 An Explanation of audit certification
 List Compliance Audit documentation

24. Compliance Audits
 Employers shall certify that they have evaluated
compliance with the provisions of this section at least
every three years to verify that the procedures and
practices developed under the standard are adequate
and are being followed
 The compliance audit shall be conducted by at least
one person knowledgeable in the process
 A report of the findings of the audit shall be
developed
 Compliance Audits Must be Performed Every 3 Years

25.  The Compliance Audit Process Typically
Includes the Following:
 Definition of the guidelines for an audit team
 A List the PSM elements that must be audited
 A List of the minimum contents of a final report of an
audit
 An Explanation and list the Compliant Audit reports
that must be retained by the facility
Compliance Audits

26. Compliance Audits
 OSHA PSM Citations
# Initial Penalty Final Penalty
1393 $25,058,853 $18,884,463

27. Compliance Audits
 Typical Types of OSHA Serious Citations
 failure to maintain and follow normal operating
procedures
 failure to provide refresher training to process
operators
 failure to correct deficiencies in process equipment in
a safe manner
 failure to provide necessary training to emergency
responders and fire brigade members
 Failure to perform audits as required every 3 years

28. Compliance Audits
 There are Companies that have
Covered Process, but have not
implemented any PSM Program.
 The Regulatory Exposure is to:
 Willful Citations
 Criminal Willful Citations
 Serious Citations
 Major Citation Penalties

29. PSM Audit Example Checklist
Items (Partial)
 Management Commitment to the PSM Program
 Is there evidence that an effective process safety management
program has been set up and that explicit expectations,
objectives and goals have been set with clear-cut, desired
outputs?
 Have resources been provided in the form of personnel
assigned to provide implementation and continuation of each
element?
 Have clear lines of responsibility been established and roles and
responsibilities assigned?
 Is management commitment to using all available resources for
enhancing process safety knowledge at all levels of the
organization clearly demonstrated by actions?
 Does management encourage active participation in
professional and trade associations for key PSM personnel to
ensure the PSM system keeps pace withTest Practices?

30. PSM Audit Example Checklist
Items (Partial)
 Process Hazard Analysis
 Does the PSM program establish a process hazard analysis
procedure in accordance with the PSM rule?
 Have personnel, who will take part in PHA痴, been provided
with training in the PHA technique that will be used for their
study?
 Does the PHA procedure establish that the hazard identification
team be multi-disciplined in nature, capable of covering such
issues as maintenance, operations, design, inspection & testing,
safety, health and environment, etc?
 Does the PHA procedure require that the PHA team leader be
specially trained in the technique that will be used?
 Does documentation of the hazard identification process include
all issues, not only those resulting in findings or
recommendations?
 Have PHA been conducted on all PSM-covered processes and
if not, is there an established schedule for completing all PHA’s?

31. Compliance Audits
 Audit Findings must be Documented
 Actions must be Taken on All
Exceptions
 All Actions Affecting P&ID’s, PHA’s,
Mechanical Integrity Certificates,
Inspection/Testing/Maintenance,
Operating Procedures & Training
Procedures will Require Revision of
All of the Above

32. Compliance Audits
 Remember,
The Audit Process is Determine if there are
any weaknesses in the system or PSM
Program and to provide a report an
method to take action.
These actions can prevent catastrophic
release, injury and death.

33. Trade Secrets
1910.119(p)

34. Trade Secrets
 All Information Regarding the Process
Must be Made Available to Persons
Involved in the PSM Program Including
Trade Secrets
 Confidentiality Agreements are Allowed

35. Summary of PSM Elements
 Process Safety Information
 Equipment ii the Process
 Process Hazard Analysis
 Operating Procedures
 Employee Training
 Training Contractors
 Pre-Startup Safety Review
 Mechanical Integrity of Equipment
 Management of Change
 Incident Investigation
 Emergency Preparedness
 Compliance Audits
 Trade Secrets

36. EPA Risk Management Plans
(RMP) Basics
CAA 112(r)

37. One More Thing to Discuss…
EPA Risk Management Plans
(RMP)
 Many Times Companies Who Must
Comply with PSM, must also Comply
with the Requirements of EPA Risk
Management Plans (RMP)
 The RMP Standard was to be a Mirror
of the PSM Standard…Didn’t happen!
 Remember…PSM Protects the
Workforce, RMP Protects the
Community

38. EPA RMP
 Basic Requirements
 Executive summary
 Registration
 Off-site consequence analysis
 Five-year accident history
 Emergency response plan
 Prevention program summary information
 Certification
Sound Much Easier than PSM…Right?

39. Release
Plume
All Public Facilities
in this Release
Plume Must be
Identified &
Surveyed

40. EPA RMP
 Emergency Response Plan &
Prevention Plans Must Be Developed to
Prevent Accidental Release of the
Covered Chemical

41. EPA RMP 1998 Changes
Compliance Elements
 Follow-up / completion of PHA
recommendation
 Re-validation of your PHA every 5
years
 Compliance audits (required every
3 years)
 Follow-up / completion of
compliance audit recommendations

42. EPA RMP 1998 Changes
Compliance Elements
 Annual review and certification of
operating procedures
 Employee training
 Updates related to system
modifications, inventory changes,
operational changes
 Off-site consequence analysis

43. Process Safety Management of
Highly Hazardous & Explosive
Chemicals & EPA Risk
Management Plans
Summary

44. Goals of the One Day Course
 Understand Why Process Safety Management
(PSM) Was Promulgated
 Understand That Even with PSM, Catastrophes
are Still Occurring
 Understand Who is Covered & Exemptions
 Understand the Team Process to Developing a
PSM Program
 Understand Each of the Elements of a Properly
Designed & Implemented Program and How to
Begin the Process
 Understand the Basics of How PSM & RMP
Work Together to Protect the Workforce &
Surrounding Community

45. Resources
 GTRI -
http://www.oshainfo.gatech.edu/index.html
 OSHA PSM Compliance Guidelines -
http://www.osha.gov/Publications/osha3133.html
 OSHA PSM for Construction 1926.64 -
http://www.osha.gov/doc/outreachtraining/htmlfile
s/psm.html

46. PSM One Day Review

47. PSM One Day Review
1. The Process Safety Management
Standard was drafted as a requirement
of the Clean Air Act. True or False
2. The PSM program must include a list
of highly hazardous chemicals. True or False
3. The initial start-up of a process is not
included as an operating phase under
the PSM Standard. True or False
4. List three items that the process hazard analysis must
address. ___________, __________ and __________.
5. PSM does not apply to contractors,
regardless of the work they are doing. True or False

48. PSM One Day Review (cont.)
6. The PSM Standard applies to companies that either process
highly _____________ materials or use _____________
liquids and gases in excess of 10,000 pounds.
7. Process safety information includes:
______________, _____________ and _____________.
8. Fault tree analysis is one form of an
approved method of performing a process
hazard analysis. True or False
9. A technical basis is not required to change
a process covered by the PSM Standard. True or False
10.Two types of training required by the PSM
standard are ________________ and_________________.