DPCAC-PSM-Feb-2020-1.pptx

What is OSHA’s Process Safety Management
Program?
Trilby Cressman, CSP | February 24, 2020
Deer Park Community Advisory Council
29 CFR 1910.119

OSHA Process Safety Management
Topics:
1.What is PSM?
2.Which industries must comply?
3.Why did OSHA implement PSM?
4.What are the 14 elements of PSM?
5.A Little More Detail on Mechanical Integrity
6.Closing Comments
7.Questions?

What is PSM?
Process Safety Management is program implemented by OSHA, which
became effective on February 24, 1992…
HAPPY 28th BIRTHDAY, PSM!
In order to understand the intent of PSM, you need to understand what
OSHA means by “PROCESS”:
“Process means any activity involving a highly hazardous chemical including using, storing,
manufacturing, handling, or moving such chemicals at the site, or any combination of these
activities. For purposes of this definition, any group of vessels that are interconnected, and
separate vessels located in a way that could involve a highly hazardous chemical in a
potential release, are considered a single process.”
PSM is a detailed program, which provides a uniform set of rules for specific
industries to safely manage the use, storage, handling, etc. of highly hazardous
chemicals.

Which industries must comply?
What industries are required to comply?
The standard mainly applies to manufacturing industries, in particular-
- chemicals
- transportation equipment
- fabricated metal products
- natural gas liquids
- farm product warehousing,
- electric, gas, and sanitary services
- pyrotechnics & explosives
There are special provisions for the protection of contract workers working
inside a “covered process” as well.

Why did OSHA set up the PSM standard?
Unintended, accidental releases of highly hazardous chemicals pose a strong threat for
catastrophic disasters
• December 1982 – Bhopal, India – Union Carbide pesticide plant had a gas leak,
which made its way in and around small towns bordering the plant. >500,000
people were exposed to Methyl Isocyanate, resulting in >2,000 deaths
• October 1989 – Pasadena, TX - Phillips Petroleum Company polyethylene plant had
a series of 6 explosions due to the accidental release of extremely flammable
process gases. 23 workers died and 314 were injured.
• July 1990 –Channelview, TX - ARCO Chemical had an explosion that killed 17
workers and flattened an area of the plant the size of a city block.

Why did OSHA set up the PSM standard? (cont.)
• July 1990 – Cincinnati, OH – BASF plant experienced 2 explosions, resulting in a fire
that took several hours to extinguish before rescue personnel could get inside. The
explosions were due to an over-pressurization of a reactor being cleaned with a
flammable solvent. 2 workers died and >70 were injured.
• May 1991 – Sterlington, LA – IMC Fertilizer plant experienced an explosion in the
nitroparaffin unit, which killed 8 people and injured 120.
• Records of hazardous chemical releases have been kept for years before
these incidents, but these are the “high-profile” incidents which OSHA
sites for developing the PSM standard.

Happening in Conjunction
OSHA proposed the PSM standard on July 17, 1990, meaning it
was entered into the Federal Register.
The proposed standard emphasized the management of hazards associated
with highly hazardous chemicals and established a comprehensive
management program that integrated technologies, procedures, and
management practices.
Meanwhile, the EPA was establishing an amendment to the Clean Air Act
(CAA), working with the Secretary of Labor and under the OSH Act of 1970,
requiring promulgation of a chemical process safety standard to prevent
accidental releases of chemicals that could pose a threat to employees.

Happening in Conjunction
Four months later, the Clean Air Act Amendments (CAAA) became law – November
15, 1990
The CAAA required that the standard include a list of highly hazardous chemicals
which includes toxic, flammable, highly reactive, and explosive substances.
The CAAA also specified minimum elements that the OSHA standard must require
employers to do…these elements became the Process Safety Management
standard, 29 CFR 1910.119.
The CAAA established the EPA Risk Management Program (RMP) that requires risk
management plans of certain facilities. PSM focused primarily on workers and RMP
on the community.
February 24, 1992 - 29 CFR 1910.119 was officially adopted and the requirements
were mandated.

What are the 14 Elements of PSM?
Employee Participation
Process Safety
Information
Process Hazard Analysis
Operating Procedures
Hot Work Permits
Management of
Change
Pre-Startup Safety
Reviews
Mechanical Integrity
Emergency Planning
Incident Investigation
Contractors
Training
Compliance Audits
Trade Secrets

Employer Requirements: Employee Participation
All employees involved with chemical processes covered under OSHA 29 CFR
1910.119 must be involved with the PSM Program.
Employee participation means:
 Provide input on process
 Consult with employees on process
 Data available to employee
 Training
Ways to Participate:
P&ID review/verify SDS
Operating Procedures PSSR
Monitor and evaluate contractors Work Permits
Management of change Emergency planning/drills
Process hazard analysis MI: preventive maintenance, corrosion

Employer Requirements: Process Safety Information

Employer Requirements: Process Hazard Analysis
The PHA is a thorough, orderly, systematic approach for identifying, evaluating,
and controlling the hazards of processes involving highly hazardous chemicals.
PHAs must include:
The hazards of the process
The review of previous incidents that had a potential for catastrophic
consequences
Engineering and administrative controls applicable to the hazards and their
interrelationships, such as appropriate application of detection methodologies
to provide early warning of releases. Acceptable detection methods might
include process monitoring and control instrumentation with alarms, and
detection hardware such as hydrocarbon sensors
Consequences of failure of engineering and administrative controls
Facility siting
Human factors
A qualitative evaluation of a range of the possible safety and health effects on
employees in the workplace if there is a failure of controls.

Employer Requirements Process Hazard Analysis
One or more of the following methods may be used, as appropriate, to
determine and evaluate the hazards of the process being analyzed.
What-If / Checklists
Hazardous and Operability Review (HAZOP)
Failure Mode and Effects Analysis (FMEA)
Fault Tree Analysis (FTA)
Line by Line Hazards Analysis
Any appropriate equivalent method
PHAs must be revalidated every 5 years.

Employer Requirements: Operating Procedures
Employers must develop and implement written operating procedures, consistent
with the process safety information, that provide clear instructions for safely
conducting activities involved in each covered process.
These procedures must include:
Steps for each operating phase:
Initial startup
Normal operations
Temporary operations
Emergency shutdown, including the conditions under which emergency shutdown is
required, and the assignment of shut down responsibility to qualified operators to
ensure that emergency shutdown is executed in a safe and timely manner
Emergency operations
Normal shutdown
Startup following a turnaround, or after an emergency shutdown

Employer Requirements: Operating Procedures
Operating Procedures cont.
Operating limits:
Consequences of deviation
Steps required to correct or avoid deviation
Safety and health considerations:
Properties of, and hazards presented by, the chemicals used in the process
Precautions necessary to prevent exposure, including engineering controls,
administrative controls, and personal protective equipment
Control measures to be taken if physical contact or airborne exposure occurs
Quality control for raw materials and control of hazardous chemical inventory
levels
Any special or unique hazards
Safety systems (e.g., interlocks, detection or suppression systems) and their
functions

Employer Requirements: Hot Work Permits
A permit must be issued for hot work
operations conducted on or near a
covered process.
What is “hot work”? Hot work is
any work that involves burning,
welding, cutting, brazing, soldering,
grinding, using fire- or spark-
producing tools, or other work that
produces a source of ignition.

Employer Requirements: Management of Change
Employers must implement and maintain procedures on managing changes to
the process chemicals, technology, equipment, procedures and facilities. These
procedures must cover both long-term and temporary changes. Process changes
must be documented and kept as part of the Process Safety Information. The
procedure shall ensure the following items are addressed prior to the change:
• The technical basis for the proposed change
• The impact of the change on safety & health
• Modifications to operating procedures
• Necessary time period for the change
• Authorization for the change

Employer Requirements: Management of Change
Management of Change cont.
Employees involved in operating the process and maintenance personnel and
contract employees whose job tasks may be affected by the change, must be
notified of and trained in the change.
"Replacement in Kind" is not considered to be a change. For example, if you
replace a pump in the process with one of the same design, this is not
considered to be a process change.

Employer Requirements: Pre-Startup Safety Review
The employer is required to perform a pre-startup safety review for new
facilities and for modified facilities when the modification is significant enough
to require a change in the process safety information. Prior to the introduction
of a highly hazardous chemical to a process, the pre-startup safety review must
confirm that the following:
Construction and equipment are in accordance with design specifications
Safety, operating, maintenance, and emergency procedures are in place and
are adequate
A process hazard analysis has been performed for new facilities and
recommendations have been resolved or implemented before startup, and
modified facilities meet the management of change requirements
Training of each employee involved in operating a process has been
completed.
THIS MUST BE DOCUMENTED AND THOSE WHO WERE PART OF THE REVIEW
MUST SIGN-OFF!

Employer Requirements: Mechanical Integrity
The employer must establish and implement written procedures to maintain the ongoing
integrity of process equipment.
• Pressure vessels and storage tanks
• Piping systems (including piping components such as valves)
• Emergency shutdown systems
• Controls (including monitoring devices and sensors, alarms, and interlocks)
• Pumps
Employees involved in maintaining the ongoing integrity of process equipment must be
trained in an overview of the process and its hazards and trained in the procedures
applicable to the employees' job tasks.

Employer Requirements: Mechanical Integrity
Inspection & testing must occur on all process equipment, using “recognized and
generally accepted good engineering practices” or RAGAGEP.
Frequency of testing is based on manufacturers’ recommendations & good engineering
practices. Inspections must be documented and include:
 type of testing
 name of person who performed the testing
 serial numbers (or other identifiers) of the equipment tested
 description of the testing performed
 results of the testing
Generally, deficiencies must be corrected before the equipment is put back in service.
The employer also must ensure that maintenance materials, spare parts, and equipment
are suitable for the process application for which they will be used.

Employer Requirements: Emergency Planning
If an incident does occur, it is essential that
emergency pre-planning and training make
employees aware of, and able to execute, the
proper actions.
For this reason, an emergency action plan for
the entire plant must be developed and
implemented in accordance with the provisions
of other OSHA rules (29 CFR 1910.38(a)).
In addition, the emergency action plan must
include procedures for handling small releases
of hazardous chemicals.
These plans must be documented and reviewed
periodically to ensure they are still current.

Employer Requirements: Incident Investigations
PSM requires the investigation of each incident that resulted in, or could reasonably have
resulted in, a catastrophic release of a highly hazardous chemical in the workplace.
Incident Investigation must begin within 48 hours of the incident occurring.
Team will consist of:
- at least one person knowledgeable of the process
- a contractor, if one was involved in the incident
- a person with knowledge & experience in the investigation process & able to
analyze the incident thoroughly
The final report will consist of:
• Date of incident,
• Date investigation began,
• Description of the incident,
• Factors that contributed to the incident, and
• Recommendations resulting from the investigation.
These reports must be retained for at least 5 years!

Employer Requirements: Contractors
Employer responsibilities:
- obtain & evaluate safety performance and programs of the contract company
- make the contract employer aware of known potential fire, explosion, or toxic
release hazards related to the contractor's work and the process
- explain the applicable parts of the emergency action plans
- implement a safe work practice for accountability of contracted employees
- periodically evaluate the performance of the contracted employees
- maintain an injury & illness log for contracted employees

Employer Requirements: Contractors
Contractor employers’ responsibilities:
• Ensure that contract employees are trained in the work practices necessary to
perform their job safely
• Ensure that contract employees are aware of the known potential fire, explosion,
or toxic release hazards related to their job and the process, and the emergency
action plans
• Document that each contract employee has received and understood the training
required by the standard by preparing a record that contains the identity of the
contract employee, the date of training, and the means used to verify that the
employee understood the training
• Ensure that each contract employee follows the safety rules of the facility
including the required safe work practices
• Advise the employer of any unique hazards presented by the contract employer's
work.

Employer Requirements: Training
Each employee involved in operating a
process must be trained in an overview of
the process and in its operating
procedures.
The training must include emphasis on
the specific safety and health hazards of
the process, emergency operations
including shutdown, and other safe work
practices that apply to the employee's job
tasks.
Training must be done “initially” and
every 3 years, employees must have
“refresher” training. All training must be
documented with a way to verify the
employee understands the hazards of the
tasks as hand (i.e. tests).

Employer Requirements: Compliance Audits
Employers must certify that they have
evaluated compliance with the provisions of
PSM at least every three years.
This will verify that the procedures and
practices developed under the standard are
adequate and are being followed.
The compliance audit must be conducted by at
least one person knowledgeable in the process
and a report of the findings of the audit must
be developed and documented noting
deficiencies that have been corrected.
The two most recent compliance audit reports
must be kept on file.

Employer Requirements: Trade Secrets
Employers must make available all information necessary to comply with PSM to
personnel responsible for:
Compiling the Process Safety Information
Developing the Process Hazard Analysis (PHA), Operating Procedures, and
Emergency Response Plans
Conducting Incident Investigations & Compliance Audits
*may require employees/persons granted knowledge to sign a non-disclosure agreement

Key element to Mechanical Integrity inspections/testing is Preventative
Maintenance (PM)
On a set frequency, testing and/or inspection of critical equipment is performed.
To ensure proper functionality
To ensure warning systems function properly
To ensure safety first!
• Pressure vessels and storage tanks – internal & external inspections (i.e. confined
space entry to check for wall thickness, pitting, deformation of welds, junctions)
• Piping systems (including piping components such as valves) – external/visual
inspections to determine wall thickness of pipes.
• Emergency shutdown systems – to ensure they are functioning properly
• Controls (including monitoring devices and sensors, alarms, and interlocks)
• Pumps – to ensure all moving parts are in good condition, no leaks present at
seals, etc.

Storage tanks, blend vessels, piping, etc.
Corrosion under insulation
Wall thinning
Wall pitting
Holes
Welds verification

Non-Destructive Testing Techniques
(there are MANY, here are a few)
Ultrasonic thickness testing – ultrasonic
waves are passed through an object
(tank wall or piping) at specific
frequencies. The change in waves
absorbed detects abnormalities or
internal flaws in the object.
Industrial radiography – use X-rays or
gamma rays to verify structure and
integrity of an object
Acoustic resonance testing – use sound
waves to measure the integrity of an
object

Closing Comments
OSHA requires employers to follow the Process Safety Management
Standard, 29 CFR 1910.119
PSM was developed to protect workers from hazards associated with
the use of highly-hazardous chemicals in a process.
The requirements, when implemented successfully, GREATLY reduce
the chances of a catastrophic event from occurring.

DPCAC-PSM-Feb-2020-1.pptx

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