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What Is Process Safety Management
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 .
To adequately address this section. .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. specifying which processes at the facility are covered and why.119 (a) Application Appendix A of 29 CFR 1910. identify what brings you into coverage by the standard.
119 (a) Application cont.1910. 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 .
2004 Conyers GA .May 25.
An OSHA inspector (CSHO) will attempt to verify participation by interviewing employees at random. and continuing participation in the process. their involvement in the development of the programs.1910. .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.
Consultation / participation in incident investigations regarding the covered process. . Consultation / participation with training and supervision to determine the frequency and content of initial and refresher training.119 (c) Employee Participation cont. Consultation / participation to develop and review operating and maintenance procedures.1910.
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 (c) Employee Participation] Available for Process Hazard Analysis and revalidations [requirement of 1910. Available to all affected employees [requirement of 1910.119 (e) Process Hazard Analysis] So auditors and CSHOs can find everything! .1910.119 (d) Process Safety Information cont.
1910.119 (e) Process Hazard Analysis .
manage process .1910. record.119 (e) Process Hazard Analysis OSHA has suggested formats Don’t start until all information is gathered Use a software tool to guide.
” 1910. fire.119 (e) Process Hazard Analysis “Catastrophic release means a major uncontrolled emission. or explosion involving one or more highly hazardous chemicals.1910. that presents serious danger to employees in the workplace.119(b) .
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 .1910.
refresher training shall be provided at least every three years and more often if necessary to each employee involved in operating a process.1910. Means to verify that employee understood training At a minimum. Date of training. Identity .119 (g) Employee Training The employer shall prepare a record: of employee.
119 (h) Contractors Absolute Requirements Documentation: Employer Contract employee injury and illness logs related to work in covered process areas. .1910. 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.
119 (i) Pre-Start up Safety Review Check. double check. and review any changes.1910. . additions made in a PSM covered area – before you flip the switch. modifications.
alarms. and equipment that is important to safety of the process.1910. and interlocks). . Relief and vent systems and devices. Pressure vessels and storage tanks.119 (j) Mechanical Integrity The employer shall develop and maintain a master list of all equipment specifically covered by the standard. Emergency shutdown systems. Piping systems including valves and other piping components. Controls (including monitoring devices and sensors.
Un-interruptable power supplies. Electrical generation and distribution equipment. Rotating equipment. Heat exchange equipment.119 (j) Mechanical Integrity cont. Fire protection equipment. Emergency power supply equipment. .1910. Pumps.
.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.1910. Nonroutine Work Authorizations) cutting.k.a.
.1910.) .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 / …….
1910.119 (l) Management of Change cont. PSI Mechanical Integrity PINDs Hot Work Contractor Safety Employee Training PSSR Operating Procedures .
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.
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 .
1910.119 (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 .
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.OSHA.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 .gov): CPL 2-2.
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