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Process Safety Management (PSM) is a regulation issued by the U.S. Department of Labor's Occupational Safety and Health Administration (OSHA). The regulation is designated as OSHA 1910.119, Process Safety Management of Highly Hazardous Chemicals. Its purpose is to prevent or minimize the consequences of releasing hazardous chemicals in a facility or the environment surrounding a facility. Hazardous chemicals are those that may be toxic, reactive, flammable, explosive, or a combination of these properties. Industries handling hazardous chemicals are required to develop an effective PSM program that protects employees, contractors, and visitors of the facility. These industries include: petrochemical, pharmaceutical, paints, adhesives and sealants, food processing, industrial organics and inorganics, and paper mills.
Elements of OSHA 1910.119 - PSM of Highly Hazardous Chemicals
How do companies know they are complying with the OSHA regulation when implementing a PSM program? To answer this question, companies should be familiar with the following 14 elements that are required for PSM program compliance. These elements are the minimum requirements extracted from OSHA 1910.119 [1]. All information (date, equipment, personnel, process safety information, and process hazard analyses) should be recorded and stored in the event that future audits need to refer back to historical information about the facility and equipment.
1. Employee Involvement
All employees that play a role in facility operations should be involved in a PSM program. Each of the following elements requires a competent and experienced team of individuals. Ideally, a team should include at least one person who specializes in the specific process being used.
2. Process Safety Information (PSI)
The PSI element requires that employers collect and document highly hazardous chemical (HHC) information before conducting a process hazard analysis. This information pertains to the chemicals, technology, and equipment used in the process. Furthermore, the information should be accessible to all employees in order to understand the HHC related risks they may face during the job.
3. Process Hazard Analysis (PHA)
A PHA is performed by a team of engineering and maintenance experts that are able to identify, evaluate, and control hazards. PHAs can be conducted using a number of techniques, including:
- "what-if" analyses
- checklist methods
- hazard and operability studies
- failure modes and effects analyses
- fault-tree analyses
Additionally, it’s important to make sure PHAs are performed in a timely manner as teams are expected to complete a certain amount of the analysis by specific deadlines. PHAs should be performed at least every 5 years [1].
4. Operating Procedures
Companies should document all operational procedures involving initial startup, normal operations, temporary operations, and emergency shutdowns. Operators should be aware of the operating limits of the process, the consequences if the process deviates from normal conditions, and be prepared to correct deviations when necessary.
5. Training
Employees should be trained on procedures, safety factors, and health hazards specific to the job task. Certification programs may help ensure that individuals are competent in specialized areas relative to their practices. Additionally, some practices require on-going training as methods and best practices continue to develop.
6. Contractor Safety
Companies should evaluate a contractor’s safety performance prior to starting a project (e.g. repair, turnaround, or renovation). Once a contractor passes clearance requirements, it is the responsibility of the company to inform the contractor of potential risks and health hazards related to the contractor’s project. The contractor’s responsibility is to inform the incoming contracted team of risks and health hazards and to ensure contracted employees have received and understood necessary training.
7. Pre-Start Up Process Safety Review
Companies are required to perform a safety review before new or modified facilities begin production. The pre-start up safety review confirms that an initial PHA has been performed and that all safety, operating, maintenance, and emergency procedures meet the requirements of codes, standards, and specifications [1].
8. Mechanical Integrity
Routine inspections are required for major process units and equipment, such as pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, control systems (e.g. monitoring devices and sensors), and pumps to ensure the mechanical integrity of the component meets requirements. All inspections and tests need to be well-documented and must follow recognized and generally accepted good engineering practices (RAGAGEP).
9. Hot Work Permit
This mandate requires that employers issue hot work permits for personnel performing high-temperature operations on equipment (e.g. welding).
10. Management of Change
A company needs to have an organized and efficient process for managing procedural changes regarding process chemicals, technology, and/or equipment. Under the OSHA 1910.119 standard, each change requires that the following considerations be addressed:
- The technical basis for the proposed change
- The impact of change on safety and health
- Modifications to operating procedures
- Necessary time period for the change
- Authorization requirements for the proposed change [1]
11. Incident Investigation
Investigations should be performed on incidents that resulted in (or could have resulted in) catastrophic HHC release. Incident investigations should report:
- The date of the incident
- The date of the investigation
- The description of the incident
- The root causes that contributed to the incident
- Any recommendations or solutions resulting from the investigation
12. Emergency Planning and Response
Companies are required to develop and implement emergency action plans for the entire facility. Emergency plans include procedures for mitigating large and small releases of HHCs.
13. Compliance Audits
Individuals should recertify their credentials at least every three years to keep up-to-date with evolving practices and technology. This element also states that companies should retain the 2 most recent compliance audit reports.
14. Trade Secrets
This mandate ensures that employees involved in elements 2-13 have access to the information about the process and health risks they may encounter during the job.
References
- 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals, OSHA.
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