New/Proposed Standards

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OSHA PROCESS SAFETY MANAGEMENT
STANDARD CHECKLIST 29 CFR 1910.119
A U.S. HealthWorks Company
Date:

This Health & Hygiene/ELB OSHA Process Safety Management Standard 29 CFR 1910.119 checklist is
provided to assist employers in complying with the standard. All the standard details are not covered by this
checklist. Refer to the complete standard for detailed compliance information.
Organization: Facility: Location:

REFERENCE CHECK
NO. ITEM 29 CFR 1910.119 YES NO
APPLICATION

1 Are there processes or a process with chemicals at or (a)(1)

above the specified threshold quantities (TQ’s) listed
in the Appendix A?

2 Is there a process involving a flammable liquid or gas (a)(1)(ii)

per 1910.1200 (c) on site in one location, in a
quantity of 10,000 pounds or more?

NOTE: Hydrocarbon fuels used solely for workplace (a)(1)(ii)(A)(B)

consumption, such as propane for heating
and gasoline for vehicles, if not a part of a
process covered by the standard, and
flammable liquids stored in atmospheric
tanks or transferred below their normal
boiling point without chilling are not
covered.

3 Are the following exempted facilities involved? (a)(2)

• Retail (a)(2)(i)
• Oil or gas well drilling on servicing (a)(2)(ii)
• Normally unoccupied remote facilities (a)(2)(iii)

EMPLOYEE PARTICIPATION

4 A written plan of action for employee participation (c)(1)

developed.

5 Employees and their representatives are consulted with (c)(2)

on the conduct and development of process hazard
analysis (PHA) and other elements of process safety
management.

6 Employees and their representatives are provided (c)(3)

access to PHA’s and other information required by the
standard.

© 1997, Health & Hygiene/ELB Greensboro, North Carolina 18-5

New/Proposed Standards

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OSHA PROCESS SAFETY MANAGEMENT
STANDARD CHECKLIST 29 CFR 1910.119
A U.S. HealthWorks Company
Date:

REFERENCE CHECK
NO. ITEM 29 CFR 1910.119 YES NO
PROCESS SAFETY INFORMATION

7 Is a compilation of written process safety information (d)

completed before conducting any PHA?

8 Is the following information pertaining to the hazards (d)(1)

of highly hazardous chemicals provided?

• toxicity, (d)(1)(i)
• permissible exposure limits,(d)(1)(ii)
• physical data, (d)(1)(iii)
• reactivity, (d)(1)(iv)
• thermal and chemical stability, and (d)(1)(v)
• hazardous effects of inadvertent mixing of (d)(1)(vi)
different materials

9 Is the following information pertaining to the (d)(2)

technology of the process provided?

• block flow diagram or process flow diagram, (d)(2)(i)(A)

• process chemistry, (d)(2)(i)(B)
• maximum intended inventory, (d)(2)(i)(C)
• safe upper and lower limits such as (d)(2)(i)(D)
temperature, pressures, flows or
compositions, and
• evaluation of consequences of deviations, (d)(2)(i)(E)
including those affecting employee safety
and health.

10 Where original technical data no longer exist, is it (d)(2)(ii)

developed during the initial PHA?

11 Is the following information pertaining to process (d)(3)

equipment provided?

• materials of construction, (d)(3)(i)(A)

• piping and instrument diagrams, (d)(3)(i)(B)
• electrical classification, (d)(3)(i)(C)
• relief system design and basis, (d)(3)(i)(D)
• ventilation system design, (d)(3)(i)(E)
• material and energy balances for processes (d)(3)(i)(F)
built after May 26, 1992, and
• safety systems (interlocks, detection or (d)(3)(i)(H)
suppression)

18-6 © 1997, Health & Hygiene/ELB Greensboro, North Carolina

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Page 3 of 13
OSHA PROCESS SAFETY MANAGEMENT
STANDARD CHECKLIST 29 CFR 1910.119
A U.S. HealthWorks Company
Date:

REFERENCE CHECK
NO. ITEM 29 CFR 1910.119 YES NO
12 Are there documents showing that the equipment (d)(3)(ii)
complies with recognized and generally accepted
good engineering practices?

13 Has it been determined and documented that the (d)(3)(iii)

existing equipment designed and constructed in
accordance with codes, standards, or practices that
are no longer in general use is designed, maintained,
inspected, tested, and operating in a safe manner?

PROCESS HAZARDS ANALYSIS (PHA)

14 Are the initial PHA’s: (e)(1)

• appropriate to the complexity of the process,

• performed so as to identify, evaluate, and
control the hazards involved, and
• conducted on a priority basis which has
been determined and documented based on
the:
- extent of the process hazards,
- number of potentially affected
employees,
- age of the process, and
- operating history of the process?

15 Were the initial PHA’s performed on the following

schedule?

• 25% by May 26, 1994 (e)(1)(i)

• 50% by May 26, 1995 (e)(1)(ii)
• 75% by May 26, 1996 (e)(1)(iii)
• 100% by May 26, 1997 (e)(1)(iv)

16 Are the following methodologies used? (e)(2)

• what-if, (e)(2)(i)
• checklist, (e)(2)(ii)
• what-if checklist, (e)(2)(iii)
• hazard and operability study (HAZOP), (e)(2)(iv)
• failure mode and effects analysis (FMEA), (e)(2)(v)
• fault tree analysis (FTA), or (e)(2)(vi)
• an appropriate equivalent methodology? (e)(2)(vii)

© 1997, Health & Hygiene/ELB Greensboro, North Carolina 18-7

New/Proposed Standards

Page 4 of 13
OSHA PROCESS SAFETY MANAGEMENT
STANDARD CHECKLIST 29 CFR 1910.119
A U.S. HealthWorks Company
Date:

REFERENCE CHECK
NO. ITEM 29 CFR 1910.119 YES NO
17 Does the PHA address: (e)(3)

• hazards of the process (e)(3)(i)

• previous incident(s) with catastrophic (e)(3)(ii)
consequences,
• engineering and administrative controls (e)(3)(iii)
(detection methodologies for early warning
of releases such as process monitoring and
control instrumentation with alarms, detection
hardware, etc.),
• consequences of failure of engineering and (e)(3)(iv)
administrative controls,
• facility siting, (e)(3)(v)
• human factors, and (e)(3)(vi)
• qualitative evaluation of a range of possible (e)(3)(vii)
safety and health effects of failure of controls
on employee safety and health.

18 PHA’s are performed by a team with expertise in (e)(4)

engineering and process operations, including at least
one employee having experience and knowledge
specific to the process being evaluated and one team
member knowledgeable in the specific hazard analysis
methodology used?

19 Has a system been established to promptly address (e)(5)

the PHA team’s findings and recommendations and
resolve them in a timely manner, and documentation
of the actions taken as well as communicating the
actions to operating, maintenance and others affected
employees?

20 Are the PHA’s updated and reevaluated by PHA teams (e)(6)

at least every 5 years?

21 Are PHA’s, updates or revalidations retained for the (e)(7)

life of the process?

OPERATING PROCEDURES

22 Have written operating procedures been developed (f)(1)

and implemented which provide clear instructions
for safely conducting activities addressing:

18-8 © 1997, Health & Hygiene/ELB Greensboro, North Carolina

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Page 5 of 13
OSHA PROCESS SAFETY MANAGEMENT
STANDARD CHECKLIST 29 CFR 1910.119
A U.S. HealthWorks Company
Date:

REFERENCE CHECK
NO. ITEM 29 CFR 1910.119 YES NO
• the steps for each operating phase (f)(1)(i)

- initial startup (f)(1)(i)(A)

- normal operations, (f)(1)(i)(B)
- temporary operations, (f)(1)(i)(C)
- emergency shutdown, (f)(1)(i)(D)
- emergency operations, (f)(1)(i)(E)
- normal shutdown, and (f)(1)(i)(F)
- startup following a turnaround, or (f)(1)(i)(G)
after an emergency shutdown.

23 Are operating limits included in operating procedures (f)(1)(ii)

including:

• consequences of deviation, and (f)(1)(ii)(A)

• steps required to correct or avoid deviation? (f)(1)(ii)(B)

24 Are the following safety and health considerations (f)(1)(iii)

involved in developing and implementing written
operating procedures?

• chemical properties and hazards, (f)(1)(iii)(A)

• precautions to prevent exposure including (f)(1)(iii)(B)
– engineering controls,
- administrative controls, and
- personal protective equipment,

• control measures taken if physical contact (f)(1)(iii)(C)

or airborne exposure,
• quality control for raw materials and control (f)(1)(iii)(D)
of hazardous chemical inventory levels, and
• any special or unique hazards. (f)(1)(iii)(E)

25 Are safety systems and their functions included in (f)(1)(iv)

operating procedures.

26 Are operating procedures readily accessible to (f)(2)

employees.

27 Are operating procedures reviewed as often as (f)(3)

necessary to ensure they are current, including changes
resulting from process chemical changes, technology,
and equipment, and facility changes.

28 Are operating procedures certified annually as being (f)3)

current and accurate?

© 1997, Health & Hygiene/ELB Greensboro, North Carolina 18-9

New/Proposed Standards

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OSHA PROCESS SAFETY MANAGEMENT
STANDARD CHECKLIST 29 CFR 1910.119
A U.S. HealthWorks Company
Date:

REFERENCE CHECK
NO. ITEM 29 CFR 1910.119 YES NO
29 Have safe work practices been developed and (f)(4)
implemented to provide control of hazards during
operations such as lockout/tagout, confined space
entry, opening process equipment or piping, and
control over entry into the facility by maintenance,
contractors, laboratory, or other support personnel.

TRAINING

30 Has each employee presently involved in operating (g)(1)(i)

a process, and each employee before being involved
in operating a newly assigned process been trained in:

• an overview of the process and

• in the operating procedures?

31 Does the training include: (g)(1)(i)

• emphasis or specific safety and health

hazards,
• emergency operations including shutdown,
and
• safe work practices?

32 In lieu of initial training on May 26, 1992, where (g)(1)(ii)

current employees certified in writing to have the
required knowledge, skills, and abilities to safely carry
out the duties and responsibilities specified in the
operating procedures?

33 Is refresher training provided each employee at least (g)(2)

every three (3) years, and more often as necessary to
assure he or she understands and adheres to current
operating procedures?

34 Were employees consulted to determine the (g)(2)

appropriate frequency of refresher training?

35 Has it been ascertained that each employee has (g)(3)

received and understood the required training?

36 Has a training record been prepared which contains (g)(3)

the identity of the employee, date of training, and
means used to verify understanding?

18-10 © 1997, Health & Hygiene/ELB Greensboro, North Carolina

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Page 7 of 13
OSHA PROCESS SAFETY MANAGEMENT
STANDARD CHECKLIST 29 CFR 1910.119
A U.S. HealthWorks Company
Date:

REFERENCE CHECK
NO. ITEM 29 CFR 1910.119 YES NO
CONTRACTORS

37 Contractors performing maintenance, repair, turnaround, (h)(1)

major renovation, or specialty work on or adjacent to a
covered process are covered by the standard?

38 Contractors providing incidental services which do not (h)(1)

influence process safety such as janitorial work, food
and drink services, laundry, delivery, or other supply
services are not covered by the standard?

39 When selecting a contractor, information regarding the (h)(2)(i)

contractors’ safety performance and programs are
obtained and evaluated?

40 Contractor employers are informed of known potential (h)(2)(ii)

fire, explosion, or toxic release hazards related to the
contractors’ work and the process?

41 Applicable provisions of the emergency action plan (h)(2)(iii)

are explained to contract employers?

42 Safe work practices are developed and implemented (h)(2)(iv)

to control entrance, presence, and exit of contract
employers and employees?

43 The performance of contract employers is periodically (h)(2)(v)

evaluated to assure they are fulfilling their obligation
per (h)(3)?

44 Contract employers assure that each contract employee (h)(3)(i)

is trained in the work practices necessary to safely
perform his or her job?

45 Contract employers assure that each contract employee (h)(3)(ii)

is instructed in the known potential fire, explosion, or
toxic release hazards related to his or her job and the
process, and the applicable provisions of the
emergency action plan?

46 Contract employers document that each contract (h)(3)(iii)

employee has received and understood the required
training?

© 1997, Health & Hygiene/ELB Greensboro, North Carolina 18-11

New/Proposed Standards

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OSHA PROCESS SAFETY MANAGEMENT
STANDARD CHECKLIST 29 CFR 1910.119
A U.S. HealthWorks Company
Date:

REFERENCE CHECK
NO. ITEM 29 CFR 1910.119 YES NO
47 Contract employers have prepared a training record (h)(3)(iii)
with the identity of the employee, date of training,
and the means used to verify the training was
understood?

48 Contract employers assure each contract employee (h)(3)(iv)

follows the safety rules of the facility including safe
work practices per (f)(4)?

49 Contract employers advise of any unique hazards (h)(3)(v)

presented by the contract employer’s work, or any,
hazards found by the contractors’ work?

PRE-STARTUP SAFETY REVIEW

50 Pre-startup safety reviews are performed for new (i)(1)

facilities and for modified facilities when the
modification is significant enough to require a change
in the process safety information?

51 Pre-startup safety reviews confirm that prior to the (i)(2)

introduction of highly hazardous chemicals to a
process that -

• construction and equipment is in accordance (i)(2)(i)

with design specifications,
• safety, operating, maintenance, and (i)(2)(ii)
emergency procedures are in place and are
adequate,
• a PHA has been performed and (i)(2)(iii)
recommendations resolved or implemented
before startup of new facilities and that
modified facilities meet the requirements
contained in management of change per (l),
and
• training of each employee has been (i)(2)(iv)
completed?

18-12 © 1997, Health & Hygiene/ELB Greensboro, North Carolina

 New/Proposed Standards

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OSHA PROCESS SAFETY MANAGEMENT
STANDARD CHECKLIST 29 CFR 1910.119
A U.S. HealthWorks Company
Date:

REFERENCE CHECK
NO. ITEM 29 CFR 1910.119 YES NO
MECHANICAL INTEGRITY

52 Mechanical integrity requirements per (j)(2) through (j)(1)

(j)(6) apply to:

• pressure vessels and storage tanks, (j)(1)(i)

• piping systems (including pipe components (j)(1)(ii)
and valves)
• relief and vent systems and devices, (j)(1)(iii)
• emergency shutdown systems, (j)(1)(iv)
• controls (including monitoring devices and (j)(1)(v)
sensors, alarms, and interlocks), and
• pumps? (j)(1)(vi)

53 Have written procedures to maintain the on-going (j)(2)

integrity of process equipment been established and
implemented?

54 Has each employee involved in maintaining the on- (j)(3)

going integrity of process equipment been trained
in an overview of the process and its hazards and
procedures applicable to his or her tasks to assure the
tasks can be performed safely.

55 Are inspections and testing: (j)(4)

• performed on process equipment, (j)(4)(i)

• procedures prepared which follow recognized (j)(4)(ii)
and generally accepted good engineering
practices,
• performed at a frequency consistent with (j)(4)(iii)
applicable manufacturers’ recommendations
and good engineering practices, and more
frequent if determined necessary by prior
operating experience?

56 Does each documented inspection and test include: (j)(4)(iv)

• the date of inspection or test,

• the name of the person performing the
inspections or test,
• the serial number or other identified of the
equipment,
• a description of the inspection or test, and
• the results of the inspection or test?

© 1997, Health & Hygiene/ELB Greensboro, North Carolina 18-13

New/Proposed Standards

Page 10 of 13
OSHA PROCESS SAFETY MANAGEMENT
STANDARD CHECKLIST 29 CFR 1910.119
A U.S. HealthWorks Company
Date:

REFERENCE CHECK
NO. ITEM 29 CFR 1910.119 YES NO
57 Are equipment deficiencies corrected that are outside (j)(5)
acceptable limits as defined in (d) before further use
or in a safe and timely manner when necessary means
are taken to assure a safe operation?

58 Is effective quality assurance provided for the: (j)(6)

• construction of new plants and equipment to (j)(6)(i)

assure fabricated equipment is suitable for the
process application,
• appropriate checks and inspections performed (j)(6)(ii)
to assure equipment is installed properly and
consistent with design specifications and the
manufacturers’ instructions.
• assure maintenance materials, spare parts and (j)(6)(iii)
equipment are suitable for the process
application?

HOT WORK PERMIT

59 Hot work permits are issued for hot work operations (k)(1)
conducted on or near covered processes?

60 Hot work permits document fire prevention and (k)(2)

protection requirements per 29 CFR 1910.252 (a)
were implemented prior to beginning the hot work
including the:

• date authorized for hot work, and

• identity of the object on which hot work is to
be performed?

61 Hot work permits are kept on file until completion (k)(2)

of the hot work?

MANAGEMENT OF CHANGE

62 Written procedures are established and implemented (l)(1)

to manage change (except for “replacement in kind”)
associated with:

• process chemicals,
• technology,
• equipment,
• procedures, and
• facility changes affecting a covered process?

18-14 © 1997, Health & Hygiene/ELB Greensboro, North Carolina

 New/Proposed Standards

Page 11 of 13
OSHA PROCESS SAFETY MANAGEMENT
STANDARD CHECKLIST 29 CFR 1910.119
A U.S. HealthWorks Company
Date:

REFERENCE CHECK
NO. ITEM 29 CFR 1910.119 YES NO
63 Written management of change procedures assure the (l)(2)
following are addressed prior to any change:

• technical basis for the change, (l)(2)(i)

• impact on safety and health,(l)(2)(ii)
• modifications to operating procedures, (l)(2)(iii)
• necessary time period for the change, and (l)(2)(iv)
• authorization requirements for the change. (l)(2)(v)

64 Have employees involved in operating a process, (l)(3)

maintaining a process, and contract employees
affected by a change been informed of and trained
in the change(s) prior to startup of the process or
affected part of the process?

65 If the change results in a change in process safety (l)(4)

information required by (d), has the information been
updated?

66 If the change results in a change in operating (l)(5)

operating procedures or practices per (f), have the
procedures or practices been updated accordingly?

INCIDENT INVESTIGATION

67 Is each incident which resulted in, or could reasonably (m)(1)

have resulted in a catastrophic release of highly
hazardous chemical in the workplace investigated?

68 Are investigations initiated as promptly as possible, (m)(2)

but not later than 48 hours following the incident?

69 Are incident investigation teams established which (m)(3)

consist of:

• at least one person knowledgeable in the

process involved,
• a contract employee if the incident involved
contractor work, and
• other persons with appropriate knowledge and
experience to thoroughly investigate and
analyze the incident?

© 1997, Health & Hygiene/ELB Greensboro, North Carolina 18-15

New/Proposed Standards

Page 12 of 13
OSHA PROCESS SAFETY MANAGEMENT
STANDARD CHECKLIST 29 CFR 1910.119
A U.S. HealthWorks Company
Date:

REFERENCE CHECK
NO. ITEM 29 CFR 1910.119 YES NO

70 Is an incident investigation report prepared which (m)(4)

includes at a minimum the:

• incident date, (m)(4)(i)

• date investigation began, (m)(4)(ii)
• incident description, (m)(4)(iii)
• contributing factors, and (m)(4)(iv)
• recommendations? (m)(4)(v)

71 A system has been established to promptly address (m)(5)

and resolve the incident report findings and
recommendations and document the resolutions and
corrective actions?

71 The incident report is reviewed with all affected (m)(6)

personnel whose job tasks are relevant to the incident
findings including contract employees when
applicable?

72 Incident investigation reports are retained for 5 years? (m)(7)

EMERGENCY PLANNING AND RESPONSE

73 Has an emergency action plan been established and (m)

implemented for the entire plant per 29 CFR 1910.38
(a) and procedure implemented for handling small
releases?

COMPLIANCE AUDITS

74 Has a process safety management standard compliance (o)(1)

audit system been established to certify compliance
with the standard at least every 3 years which verifies
the procedures and practices are adequate and are
followed?

75 Are compliance audits conducted by at least one (o)(2)

person knowledgeable in the process?

76 A compliance audit report is prepared? (o)(3)

77 An appropriate response to each of the compliance (o)(4)

audit findings is promptly determined and
documented to ensure deficiencies have been
corrected?

18-16 © 1997, Health & Hygiene/ELB Greensboro, North Carolina

 New/Proposed Standards

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OSHA PROCESS SAFETY MANAGEMENT
STANDARD CHECKLIST 29 CFR 1910.119
A U.S. HealthWorks Company
Date:

REFERENCE CHECK
NO. ITEM 29 CFR 1910.119 YES NO
78 The two (2) most recent compliance audit reports are (o)(5)
retained?

TRADE SECRETS

79 All the information necessary to comply with the (p)(1)

standard is made available to those persons
responsible for:

• complying process safety information per (d),

• assisting in developing PHA’s per (e),
• developing operating procedures per (f),
• incident investigations per (m),
• emergency planning and response per (n), and
• compliance audits per (o) -

without regard to possible trade secret status?

80 Are persons required to enter into confidentiality (p)(2)

agreements per 29 CFR 1910.1200?

81 Do employees and their designated representatives (p)(3)

have access to trade secret information, per 29 CFR
1910.1200 (i)(12), contained within the process
hazard analysis and other documents required to be
developed by the standard?

Submitted by: Date: Time:

Submitted to: Assigned to: Date:

© 1997, Health & Hygiene/ELB Greensboro, North Carolina 18-17

New/Proposed Standards

OSHA PROCESS SAFETY MANAGEMENT

STANDARD CHECKLIST 29 CFR 1910.119
A U.S. HealthWorks Company
Date:

18-18 © 1997, Health & Hygiene/ELB Greensboro, North Carolina