Professional Documents
Culture Documents
Process Safety Management
Process Safety Management
Management
U.S. Department of Labor
Occupational Safety and Health Administration
OSHA 3132
2000 (Reprinted)
This informational booklet is
intended to provide a generic,
non-exhaustive overview of a
particular standards-related topic.
This publication does not itself
alter or determine compliance
responsibilities, which are set
forth in OSHA standards them-
selves and the Occupational
Safety and Health Act. Moreover,
because interpretations and
enforcement policy may change
over time, for additional guidance
on OSHA compliance require-
ments, the reader should consult
current and administrative inter-
pretations and decisions by
the Occupational Safety and
Health Review Commission
and the Courts.
OSHA 3132
2000 (Reprinted)
Contents iii
Contents
The Problem 1
The Problem
2
The Problem
4
1Note: Material Safety Data Sheets (MSDSs) meeting the requirements of the
Hazard Communication Standard (20 CFR 1910.1200) may be used to comply with
this requirement to the extent they contain the required information.
At least every five years after the completion of the initial process
hazard analysis, the process hazard analysis must be updated and
revalidated by a team meeting the standard’s requirements to ensure
that the hazard analysis is consistent with the current process.
Employers must keep on file and make available to OSHA, on
request, process hazard analyses and updates or revalidation for each
process covered by PSM, as well as the documented resolution of
recommendations, for the life of the process.
Operating Procedures
14 Employee Participation
Initial Training
OSHA believes that the implementation of an effective training
program is one of the most important steps that an employer can take
to enhance employee safety. Accordingly, PSM requires that each
employee presently involved in operating a process or a newly
assigned process must be trained in an overview of the process and in
its operating procedures. The training must include emphasis on the
specific safety and health hazards of the process, emergency opera-
tions including shutdown, and other safe work practices that apply to
the employee’s job tasks. Those employees already involved in
operating a process on the PSM effective date do not necessarily
need to be given initial training. Instead, the employer may certify in
writing that the employees have the required knowledge, skills, and
abilities to safely carry out the duties and responsibilities specified in
the operating procedures.
Refresher Training
Refresher training must be provided at least every three years, or
more often if necessary, to each employee involved in operating a
process to ensure that the employee understands and adheres to the
current operating procedures of the process. The employer, in
consultation with the employees involved in operating the process,
must determine the appropriate frequency of refresher training.
Training Documentation
The employer must determine whether each employee operating a
process has received and understood the training required by PSM.
A record must be kept containing the identity of the employee, the
date of training, and how the employer verified that the employee
understood the training.
Training
16 Contractors
Application
Many categories of contract labor may be present at a jobsite; such
workers may actually operate the facility or do only a particular
aspect of a job because they have specialized knowledge or skill.
Others work only for short periods when there is need for increased
staff quickly, such as in turnaround operations. PSM includes special
provisions for contractors and their employees to emphasize the
importance of everyone taking care that they do nothing to endanger
those working nearby who may work for another employer.
PSM, therefore, applies to contractors performing maintenance or
repair, turnaround, major renovation, or specialty work on or adja-
cent to a covered process. It does not apply, however, to contractors
providing incidental services that do not influence process safety,
such as janitorial, food and drink, laundry, delivery, or other supply
services.
Employer Responsibilities
When selecting a contractor, the employer must obtain and
evaluate information regarding the contract employer’s safety
performance and programs. The employer also must inform contract
employers of the known potential fire, explosion, or toxic release
hazards related to the contractor’s work and the process; explain to
contract employers the applicable provisions of the emergency action
plan; develop and implement safe work practices to control the
presence, entrance, and exit of contract employers and contract
employees in covered process areas; evaluate periodically the perfor-
mance of contract employers in fulfilling their obligations; and
maintain a contract employee injury and illness log related to the
contractor’s work in the process areas.
Training
18 Pre-Startup Safety Review
Mechanical Integrity
20
Incident Investigation
24 Emergency Planning and Response
Compliance Audits
26 Trade Secrets
*Appendices C and D are not reprinted here. See OSHA 3133 Process Safety
Management Guidelines for Compliance for text of Appendix C. See Federal
Register (FR 56(36) 6416-6417, February 24, 1992), for Appendix D - Sources of
Further Information.
release hazards related to his/her job and the process, and the appli-
cable provisions of the emergency action plan.
(iii) The contract employer shall document that each contract
employee has received and understood the training required by this
paragraph. The contract employer shall prepare a record which
contains the identity of the contract employee, the date of training,
and the means used to verify that the employee understood the
training.
(iv) The contract employer shall assure that each contract em-
ployee follows the safety rules of the facility including the safe work
practices required by paragraph (f)(4) of this section.
(v) The contract employer shall advise the employer of any unique
hazards presented by the contract employer’s work, or of any hazards
found by the contract employer’s work.
(i) Pre-startup review. (1) The employer shall perform a prestartup
safety review for new facilities and for modified facilities when the
modification is significant enough to require a change in the process
safety information.
(2) The pre-startup safety review shall confirm that prior to the
introduction of highly hazardous chemicals to a process:
(i) Construction and equipment is in accordance with design
specifications;
(ii) Safety, operating, maintenance, and emergency procedures are
in place and are adequate;
(iii) For new facilities, a process hazard analysis has been per-
formed and recommendations have been resolved or implemented
before startup; and modified facilities meet the requirements con-
tained in management of change, paragraph (1).
(iv) Training of each employee involved in operating a process has
been completed.
(j) Mechanical Integrity. (1) Application. Paragraphs (j)(2)
through (j)(6) of this section apply to the following process equip-
ment:
(i) Pressure vessels and storage tanks;
(ii) Piping systems (including piping components such as valves);
cated is suitable for the process application for which they will be
used.
(ii) Appropriate checks and inspections shall be performed to
assure that equipment is installed properly and consistent with design
specifications and the manufacturer’s instructions.
(iii) The employer shall assure that maintenance materials, spare
parts and equipment are suitable for the process application for
which they will be used.
(k) Hot work permit. (1) The employer shall issue a hot work
permit for hot work operations conducted on or near a covered
process.
(2) The permit shall document that the fire prevention and protec-
tion requirements of 29 CFR 1910.252(a) have been implemented
prior to beginning the hot work operations; it shall indicate the
date(s) authorized for hot work; and identify the object on which hot
work is to be performed. The permit shall be kept on file until
completion of the hot work operations.
(1) Management of change. (1) The employer shall establish and
implement written procedures to manage changes except for “re-
placements in kind”) to process chemicals, technology, equipment,
and procedures; and, changes to facilities that affect a covered
process.
(2) The procedures shall assure that the following considerations
are addressed prior to any change:
(i) The technical basis for the proposed change;
(ii) Impact of change on safety and health;
(iii) Modifications to operating procedures;
(iv) Necessary time period for the change; and
(v) Authorization requirements for the proposed change.
(3) Employees involved in operating a process and maintenance
and contract employees whose job tasks will be affected by a change
in the process shall be informed of, and trained in, the change prior
to start-up of the process or affected part of the process.
(4) If a change covered by this paragraph results in a change in the
operating procedures or practices required by paragraph (d) of this
section, such information shall be updated accordingly.
(o) Compliance audits. (1) Employers shall certify that they have
evaluated compliance with the provisions of this section at least
every three years to verify that the procedures and practices devel-
oped under the standard are adequate and are being followed.
(2) The compliance audit shall be conducted by at least one person
knowledgeable in the process.
(3) A report of the findings of the audit shall be developed.
(4) The employer shall promptly determine and document an
appropriate response to each of the findings of the compliance audit,
and document that deficiencies have been corrected.
(5) Employers shall retain the two (2) most recent compliance
audit reports.
(p) Trade secrets. (1) Employers shall make all information
necessary to comply with the section available to those persons
responsible for compiling the process safety information (required by
paragraph (d) of this section), those assisting in the development of
the process hazard analysis (required by paragraph (e) of this sec-
tion), those responsible for developing the operating procedures
(required by paragraph (f) of this section), and those involved in
incident investigations (required by paragraph (m) of this section),
emergency planning and response (paragraph (n) of this section) and
compliance audits (paragraph (o) of this section) without regard to
possible trade secret status of such information.
(2) Nothing in this paragraph shall preclude the employer from
requiring the persons to whom the information is made available
under paragraph (p)(1) of this section to enter into confidentiality
agreements not to disclose the information as set forth in 29 CFR
1910.1200.
(3) Subject to the rules and procedures set forth in 29 CFR
1910.1200(i)(1) through 1910.1200(i)(12), employees and their
designated representatives shall have access to trade secret informa-
tion contained within the process hazard analysis and other docu-
ments required to be developed by this standard.
Appendix A to § 1910.119
44
Appendix A to § 1910.119
46 Appendix B to § 1910.119
Appendix B to § 1910.119
48 OSHA Consultation Directory
(H) - Health
(S) - Safety
Commissioner Director
Alaska Department of Labor Hawaii Department of Labor
1111 West 8th Street and Industrial Relations
Room 304 830 Punchbowl Street
Juneau, AK 99801-1149 Honolulu, HI 96813
(907) 465-2700 (808) 586-8844
Director Commissioner
Industrial Commission of Arizona Indiana Department of Labor
800 W. Washington State Office Building
Phoenix, AZ 85007-2922 402 West Washington Street
(602) 542-5795 Room W195
Indianapolis, IN 46204-2751
Director (317) 232-2378
California Department
of Industrial Relations Commissioner
455 Golden Gate Avenue - Iowa Division of Labor Services
10th Floor 1000 E. Grand Avenue
San Francisco, CA 94102 Des Moines, IA 50319-0209
(415) 703-5050 (515) 281-3447
Commissioner Secretary
Connecticut Department of Labor Kentucky Labor Cabinet
200 Folly Brook Boulevard 1047 U.S. Highway, 127 South,
Wethersfield, CT 06109 Suite 4
(203) 566-5123 Frankfort, KY 40601
(502) 564-3070
Commissioner Secretary
Maryland Division of Labor New Mexico Environment
and Industry Department
Department of Labor, Licensing, 1190 St. Francis Drive
and Regulation P.O. Box 26110
1100 N. Eutaw Street, Santa Fe, NM 87502
Room 613 (505) 827-2850
Baltimore, MD 21201-2206
(410) 767-2215 Commissioner
New York Department of Labor
Director W. Averell Harriman State Office
Michigan Department Building - 12, Room 500
of Consumer and Industry Albany, NY 12240
Services (518) 457-2741
P.O. Box 30643
Lansing, MI 48909-8143 Commissioner
(517) 322-1814 North Carolina Department
of Labor
Commissioner 4 West Edenton Street
Minnesota Department of Labor Raleigh, NC 27601-1092
and Industry (919) 807-7166
443 Lafayette Road
St. Paul, MN 55155-4307 Administrator
(651) 296-2342 Department of Consumer
and Business Services
Administrator Occupational Safety and Health
Nevada Division of Industrial Division (OR-OSHA)
Relations 350 Winter Street, NE,
400 West King Street Room 430
Carson City, NV 89710 Salem, OR 97310-0220
(775) 687-3032 (503) 378-3272
Secretary Commissioner
Puerto Rico Department Vermont Department
of Labor and Human Resources of Labor and Industry
Prudencio Rivera Martinez National Life Building -
Building Drawer 20
505 Munoz Rivera Avenue National Life Drive
Hato Rey, PR 00918 Montpelier, VT 05620-3401
(787) 754-2119 (802) 828-5098
Director Commissioner
South Carolina Department Virginia Department of Labor
of Labor, Licensing, and and Industry
Regulation Powers-Taylor Building
Koger Office Park, 13 South 13th Street
Kingstree Building Richmond, VA 23219
110 Centerview Drive (804) 786-2377
P.O. Box 11329
Columbia, SC 29210 Commissioner
(803) 896-4300 Virgin Islands Department
of Labor
Commissioner 2203 Church Street
Tennessee Department of Labor Christiansted
Attention: Robert Taylor St. Croix, VI 00820-4660
710 James Robertson Parkway (340) 773-1994
Nashville, TN 37243-0659
(615) 741-2582 Director
Washington Department
Commissioner of Labor and Industries
Labor Commission of Utah P.O. Box 44001
160 East 300 South, 3rd Floor Olympia, WA 98504-4001
P.O. Box 146650 (360) 902-4200
Salt Lake City, UT 84114-6650
(801) 530-6898
Administrator
Worker’s Safety and
Compensation Division (WSC)
Wyoming Department
of Employment
Herschler Building,
2nd Floor East
122 West 25th Street
Cheyenne, WY 82002
(307) 777-7786
Region I Region VI
(CT,* MA, ME, NH, RI, VT*) (AR, LA, MN,* OK, TX)
JFK Federal Building 525 Griffin Street
Room E-340 Room 602
Boston, MA 02203 Dallas, TX 75202
Telephone: (617) 565-9860 Telephone: (214) 767-4731
Region IV Region IX
(AL, FL, GA, KY,* MS, NC,* (American Samoa, AZ,* CA,*
SC,* TN*) Guam, HI,* NV,* Trust
Atlanta Federal Center Territories of the Pacific)
61 Forsyth Street, SW, Room 6T50 71 Stevenson Street
Atlanta, GA 30303 4th Floor
Telephone: (404) 562-2300 San Francisco, CA 94105
Telephone: (415) 975-4310
Region V
(IL, IN,* MI,* MN,* OH, WI) Region X
230 South Dearborn Street (AK,* ID, OR,* WA*)
Room 3244 1111 Third Avenue
Chicago, IL 60604 Suite 715
Telephone: (312) 353-2220 Seattle, WA 98101-3212
Telephone: (206) 553-5930
*These states and territories operate their own OSHA-approved job safety
and health programs (Connecticut and New York plans cover public employees
only). States with approved programs must have a standard that is identical to,
or at least as effective as, the federal standard.