Process Safety Management

29 CFR 1910.119
Principles and Applications

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 Why Process Safety?
To prevent Catastrophic Release of Highly
Hazardous Chemicals

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 Why Process Safety Management
• Higher temperature and pressure in plant systems
• More stored energy in processes
• Integrated, interconnected plants
• Public demand safer chemical plant operations
• Management system failures are root cause of over
90% of incidents
• There should be an integrated approach to chemical
hazard control
• In the US, fourteen integrated elements to process
safety

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 PSM Elements in USA
OSHA 1910.119
Application 7) Pre-start up Safety
Definitions Review
1) Employee participation 8) Mechanical Integrity
2) Process Safety 9) Hot Work
Information 10) Management of Change
3) Process Hazard Analysis 11) Incident Investigation
4) Operating Procedures 12) Emergency Planning
5) Training 13) Compliance Audit
6) Contractors 14) Trade Secret

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 Employee Participation
What is Employee Participation?
• To develop information using knowledge and
expertise of employees
• Employees input in development of plans,
process hazard analyses
• Employees have access to information
• Consult with employees

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 Process Safety Information
• Chemical, Equipment, and Technology Information
• Chemical, physical, reaction hazards of the materials
used
• Equipment design basis and codes, P&ID, electrical
classifications, material of construction, safety systems
• Process block diagram and chemistry, chemical
inventories (safe upper and lower limits)
• Material and energy balances
• Consequences of deviations

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 Process Hazards Analysis
Purpose
• Systematic approach to identify, evaluate, and
control process hazards

Scope
• All areas identified in the Technical Analysis
• New or modified equipment or systems
– Capital projects, maintenance changes, process or
procedural changes
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 Process Hazard Analysis
After the PHA
• Draft report of recommendations
• Include rankings of recommendations
• Set dates for evaluating recommendations

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 Operating Procedures
Procedures required for operations
• Initial start up
• Normal operations
• Emergency shutdown
• Emergency operations
• Normal shut down
• Start up after shut down

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 Training
• Overview training
• Initial training for operators
• Refresher training
• Training documentation

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 Contractors
• Coverage is intended to assure a safe interface
of contract employers and employees with the
work environment

• Employers and the Contractor both have

significant responsibilities to assure a safe
work place

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 Pre-Start Up Safety Review
To assure that new or modified facilities are safe
to operate
• Designed and installed properly
• Procedures in place
• PHA done
• People trained

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 Mechanical Integrity
Mechanical Integrity Program covers
• Vessels – Pressure, storage tanks, piping
• Rotating equipment
• Process control, emergency shutdown systems
• Pressure relieve systems
• Emergency response systems

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 Hot Work
• All hot work requires a permit

• Hot work includes cutting, grinding, welding,

heating

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 Management of Change
Purpose
• To ensure that any changes to
– Process chemicals
– Process technology
– Procedures
– Equipment
Are adequately reviewed and approved prior to
being made

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 Management of Change
Following considerations must be addressed:
• Technical bases for change
• Impact of safety and health
• Modification to operating procedures done
• Time period for the change
• Training affected employees
• Authorization for change

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 Incident Investigation
Definitions
• A PSM incident or near miss is one which did
result, or could have resulted, in a
catastrophic release of any highly hazardous
chemical

• A non-PSM incident is any other incident that

does not involve a highly hazardous chemical

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 Emergency Planning and Response
• Emergency action plan for releases of HHCs,
fire, explosion

• Program to include who is to do what action in

event of emergency

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 Compliance Audit
Purpose
• To comply with self-Audit requirement of PSM
rule

How Audit Is Conducted

• Team familiar with process, specific elements,
assessment techniques

Audit frequency
• Must be done at least every 3 years
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 Trade Secrets
• Trade secret in information needed to comply
with all section of the PSM rule will be
available to all employees and their
designated representatives, and contractors

• The company reserves the right to require

confidentiality agreements

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 EPA RMP REGULATIONS

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EPA’s Accidental Release Provisions
• Mandated by 1990 Clean Air Act (Part 12R)
• OSHA focus: The workplace (employees and
contractors)
• EPA focus: The community (offsite exposures
to people and the environment

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 EPA RMP Rule
• PSM “Outside the Fence”
• 40 CFR Part 68, effective date 19 Aug 99
• Complements OSHA 1910.119
• Significant differences with OSHA
• Risk Management Plan Document
• Three Different “Programs”
• Quantitative Consequence Analysis
• New Emergency Preparedness Requirements
• 5 Year Incident History

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 Who is subject to theis new
regulation?
• List of 77 toxic materials with TQ (threshold
quantity)
• List of 63 flammable materials with TQ
• EPA list is different from OSHA PSM list
• Special cases for mixtures
• Designated SIC (Standard Industrial
Classification) Codes

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 Risk Management Plan Document
• Executive Summary
• Registration
• Consequence Analysis Of-site Impacts
• 5 Year Incident Summary
• Prevention Program Summary
• Emergency Response Program Summary
• “Certification”

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 Risk Management Program
Implementation Flowchart
• VOID

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