The document outlines the key elements of the OSHA Process Safety Management (PSM) Standard including: 1) The PSM standard applies to processes involving certain chemicals above threshold quantities and requires facilities to implement 14 elements to prevent accidental releases. 2) The 14 elements include procedures for employee participation, process hazard analysis, operating procedures, contractor management, emergency planning, and compliance audits. 3) The goal of the PSM standard is to ensure facilities have the necessary information to safely manage processes involving highly hazardous chemicals and prevent accidental releases.

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

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

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.

4. 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

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

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

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

8. 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

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

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

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

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

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

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

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

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

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

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

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

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