Process Safety Management Tips for the Little Guy

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.

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 .


1910.  To adequately address this section. specifying which processes at the facility are covered and why. identify what brings you into coverage by the standard.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. .

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 .

May 25. 2004 Conyers GA .

their involvement in the development of the programs.  An OSHA inspector (CSHO) will attempt to verify participation by interviewing employees at random.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. and continuing participation in the process. .1910.

1910.  Consultation / participation with training and supervision to determine the frequency and content of initial and refresher training.  Consultation / participation in incident investigations regarding the covered process.119 (c) Employee Participation cont.  Consultation / participation to develop and review operating and maintenance procedures. .

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 .

119 (e) Process Hazard Analysis] So auditors and CSHOs can find everything!   .119 (c) Employee Participation] Available for Process Hazard Analysis and revalidations [requirement of 1910.  Available to all affected employees [requirement of 1910.1910.119 (d) Process Safety Information cont.

119 (e) Process Hazard Analysis .1910.

record. manage process .119 (e) Process Hazard Analysis  OSHA has suggested formats  Don’t start until all information is gathered  Use a software tool to guide.1910.




that presents serious danger to employees in the workplace.119(b) .119 (e) Process Hazard Analysis “Catastrophic release means a major uncontrolled emission. fire.” 1910.1910. or explosion involving one or more highly hazardous chemicals.


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 .

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

.119 (h) Contractors  Absolute  Requirements Documentation:  Employer 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.1910.


modifications.1910. double check. .119 (i) Pre-Start up Safety Review  Check. and review any changes. additions made in a PSM covered area – before you flip the switch.

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

Electrical generation and distribution equipment. Rotating equipment.1910. Heat exchange equipment.119 (j) Mechanical Integrity cont. Un-interruptable power supplies. Emergency power supply equipment. Fire protection equipment.        Pumps. .

1910.a.119 (k) Hot Work (a. braising – make sure only trained personnel perform these functions  Have trained fire watchers (align with fire extinguisher / fire response training)  Welding. Nonroutine Work Authorizations) cutting. .k.



119 (l) Management of Change  Create  Raw formalized system to review all changes to process areas including: material changes / substitutions  Personnel changes  Process parameters  Facility changes (HVAC / roof / fire protection / ……..) .1910.

1910.  PSI  Mechanical Integrity  PINDs  Hot Work  Contractor Safety  Employee Training  PSSR  Operating Procedures .119 (l) Management of Change cont.

119 (m) Incident Investigation Investigate Incidents & Near-Misses Begin within 48-hours Reatain Reports 5-years Incident Investigation Team with Process Knowledge Follow-up System for Recommendations Report with Conclusions & Recommendatons .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 .1910.

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 .


gov):   CPL 2-2.Resources  OSHA web site (www.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) Safety and Health – Chemical Process Industry – course #330A. PSM ‘boot camp’ – five days of fun and a three ring binder!  OSHA training institute   AIChE / CCPs .OSHA.

Please Visit! Booth # 1312 Booth # 1310 .

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