Process Safety Management

of Highly Hazardous &

Explosive Chemicals

Contractor Pre-Qualification, Emergency

Preparedness, Incident Investigation, Audits
& EPA Risk Management Plans (RMP)
Now That Weve Developed
Process Safety Information
Process Material Toxicity Information
Process Hazard Analysis (PHAs)
Mechanical Integrity Certificates
Management of Change
Inspection/Testing/Maintenance
Operating Procedures
Safe Work Procedures
Training Programs
Training for Contractors
Now
Contractor Management

1910.119(h)
PSM Contractors
The employer, when selecting a
contractor, shall obtain and
evaluate information regarding
the contract employer's safety
performance and programs.
The employer shall inform
contract employers of the
known potential fire, explosion,
or toxic release hazards related
to the contractor's work and the
process
Contractor Pre-Qualification &
Authorization
The Standard Requires You to:
Explain contractor qualification requirements
List what is required for contractor pre-bid awareness
- pre-qualification
List what is required for contractor post-bid
awareness - training & orientation
Specify contractor responsibilities
Describe contractor 300 Log Requirements
Evaluate Contractor Performance
List documentation requirements for contractors to
complete
Explain the use of a work authorization system
Contractor Pre-Qualification &
Authorization
Typical Pre-Qualification Elements:
Years Experience in Work Process
Experience Modification Rate (EMR)
OSHA Total Recordable Incident Rate and
Lost Work day Case Rate Information
Safety Programs
Training Documentation
Emergency Preparedness

1910.119(f)(1)(I)(D)
Emergency Preparedness
Our Written Plan Must:

Define an emergency action plan

Define an emergency response plan
Describe a Minimum emergency response plan
Describe procedures for handling small releases
List the three levels of emergency response
List procedures for emergency evacuation
List requirements of alarm systems
List training requirements
Emergency Preparedness
The Standard Requires You to:
Develop a Early Warning Method for Releases
(Sensors/Alarms)
Train on the Meaning of the Alarms (May be Multiple
Alarms)
Develop Emergency Evacuation Written Plans,
Evacuation Maps & Assembly Points based on Release
Characteristics
Determine Emergency PPE Requirements
Train Employees & Contractors in the Emergency
Evacuation Plans
Drill The Emergency Evacuation Plan At Last Once Per
Year
Emergency Preparedness
Warning Systems
must:
Clearly Notify
Employees of the
Hazardous Release
Employees &
Contractors must be
Trained in the
Meaning of the
Alarm(s)
Emergency Preparedness
Evacuation Maps
Emergency Preparedness
Assembly Points

Alternate Assembly
Points Depending
on Prevailing
Weather Affecting
Release

Alternate
Assembly
Point
Emergency Preparedness
Emergency PPE
Hazardous
Chemicals May
Require Emergency
PPE to be Worn
FRP
Escape Respirators
Eye Protection i.e..
Refinery Goggles
Emergency Preparedness
Drills
At Least Annual
Emergency
Preparedness Drills
This is not Just an
Emergency
Evacuation
but Could Include
HAZWOPR
Response
Must Document
Results
Incident Investigation

1910.119(m)
Incident Investigation Program
Must Include the Following
Describe the purpose of incident investigation
List the circumstances or occurrences, which require
formal incident investigation
List the major investigation procedures that should be
followed
Explain the list the responsibilities of the incident
investigation team
Explain the contents of an "Incident Summary" form
Explain the contents of an "Incident Description" form
Explain the contents of an "Approvals, Follow-up and
Review" form
Explain the contents of a "Close-out" form
Explain Corrective Actions Taken
Incidents Can Be Minor or Major -
Both Require Investigation
Incident Investigation
Documentation Must Include
Date of incident
Date investigation began
Description of the incident
Factors contributing to the incident
Recommendations resulting from
the investigation
Incident Investigation

Will Include Written

Documentation of all
Required Elements
Incident Investigation

Might Even Include a Flow Chart

Compliance Audits

1910.119(o)
Compliance Audits
1910.119 states, "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 developed under the standard are
adequate and are being followed."
Compliance Audits
A List of factors that may increase the
frequency of compliance audits
Results of Any OSHA Compliance
Audits Performed & Citations/Action
Items Developed
An Explanation of audit certification
List Compliance Audit documentation
Compliance Audits
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 developed under the standard are adequate
and are being followed
The compliance audit shall be conducted by at least
one person knowledgeable in the process
A report of the findings of the audit shall be
developed
Compliance Audits Must be Performed Every 3 Years
Compliance Audits
The Compliance Audit Process Typically
Includes the Following:

Definition of the guidelines for an audit team

A List the PSM elements that must be audited
A List of the minimum contents of a final report of an
audit
An Explanation and list the Compliant Audit reports
that must be retained by the facility
 Compliance Audits

OSHA PSM Citations

# Initial Penalty Final Penalty

1393 $25,058,853 $18,884,463

Compliance Audits
Typical Types of OSHA Serious Citations
failure to maintain and follow normal operating
procedures
failure to provide refresher training to process
operators
failure to correct deficiencies in process equipment in
a safe manner
failure to provide necessary training to emergency
responders and fire brigade members
Failure to perform audits as required every 3 years
Compliance Audits

There are Companies that have

Covered Process, but have not
implemented any PSM Program.
The Regulatory Exposure is to:
Willful Citations
Criminal Willful Citations
Serious Citations
Major Citation Penalties
PSM Audit Example Checklist
Items (Partial)
Management Commitment to the PSM Program
Is there evidence that an effective process safety management
program has been set up and that explicit expectations, objectives
and goals have been set with clear-cut, desired outputs?
Have resources been provided in the form of personnel assigned
to provide implementation and continuation of each element?

Have clear lines of responsibility been established and roles and

responsibilities assigned?
Is management commitment to using all available resources for
enhancing process safety knowledge at all levels of the
organization clearly demonstrated by actions?
Does management encourage active participation in professional
and trade associations for key PSM personnel to ensure the PSM
system keeps pace withTest Practices?
PSM Audit Example Checklist
Items (Partial)
Process Hazard Analysis
Does the PSM program establish a process hazard analysis
procedure in accordance with the PSM rule?
Have personnel, who will take part in PHA , been provided with
training in the PHA technique that will be used for their study?
Does the PHA procedure establish that the hazard identification team
be multi-disciplined in nature, capable of covering such issues as
maintenance, operations, design, inspection & testing, safety, health
and environment, etc?
Does the PHA procedure require that the PHA team leader be
specially trained in the technique that will be used?
Does documentation of the hazard identification process include all
issues, not only those resulting in findings or recommendations?

Have PHA been conducted on all PSM-covered processes and if not,

is there an established schedule for completing all PHA s?
Compliance Audits

Audit Findings must be Documented

Actions must be Taken on All
Exceptions
All Actions Affecting P&IDs, PHAs,
Mechanical Integrity Certificates,
Inspection/Testing/Maintenance,
Operating Procedures & Training
Procedures will Require Revision of
All of the Above
Compliance Audits

Remember,

The Audit Process is Determine if there are

any weaknesses in the system or PSM
Program and to provide a report an
method to take action.
These actions can prevent catastrophic
release, injury and death.
Trade Secrets

1910.119(p)
Trade Secrets

All Information Regarding the Process

Must be Made Available to Persons
Involved in the PSM Program Including
Trade Secrets
Confidentiality Agreements are Allowed
Summary of PSM Elements
Process Safety Information
Equipment ii the Process
Process Hazard Analysis
Operating Procedures
Employee Training
Training Contractors
Pre-Startup Safety Review
Mechanical Integrity of Equipment
Management of Change
Incident Investigation
Emergency Preparedness
Compliance Audits
Trade Secrets
EPA Risk Management Plans
(RMP) Basics
CAA 112(r)
One More Thing to Discuss
EPA Risk Management Plans
(RMP)
Many Times Companies Who Must
Comply with PSM, must also Comply
with the Requirements of EPA Risk
Management Plans (RMP)
The RMP Standard was to be a Mirror
of the PSM StandardDidnt happen!
RememberPSM Protects the
Workforce, RMP Protects the
Community
EPA RMP

Basic Requirements
Executive summary
Registration
Off-site consequence analysis
Five-year accident history
Emergency response plan
Prevention program summary information
Certification

Sound Much Easier than PSMRight?

All Public Facilities
in this Release Release
Plume Must be Plume
Identified &
Surveyed
EPA RMP

Emergency Response Plan &

Prevention Plans Must Be Developed to
Prevent Accidental Release of the
Covered Chemical
EPA RMP 1998 Changes
Compliance Elements
Follow-up / completion of PHA
recommendation
Re-validation of your PHA every 5
years
Compliance audits (required every
3 years)
Follow-up / completion of
compliance audit recommendations
EPA RMP 1998 Changes
Compliance Elements
Annual review and certification of
operating procedures
Employee training
Updates related to system
modifications, inventory changes,
operational changes
Off-site consequence analysis
Process Safety Management of
Highly Hazardous & Explosive
Chemicals & EPA Risk
Management Plans

Summary
Goals of the One Day Course
Understand Why Process Safety Management (PSM)
Was Promulgated
Understand That Even with PSM, Catastrophes are Still
Occurring
Understand Who is Covered & Exemptions
Understand the Team Process to Developing a PSM
Program
Understand Each of the Elements of a Properly Designed
& Implemented Program and How to Begin the Process
Understand the Basics of How PSM & RMP Work
Together to Protect the Workforce & Surrounding
Community
 Resources
GTRI -
http://www.oshainfo.gatech.edu/index.html
OSHA PSM Compliance Guidelines -
http://www.osha.gov/Publications/osha3133.html
OSHA PSM for Construction 1926.64 --
http://www.osha.gov/doc/outreachtraining/htmlfile
s/psm.html
PSM One Day Review
PSM One Day Review
1. The Process Safety Management
Standard was drafted as a requirement
of the Clean Air Act. True or False
2. The PSM program must include a list
of highly hazardous chemicals. True or False
3. The initial start-up of a process is not
included as an operating phase under
the PSM Standard. True or False
4. List three items that the process hazard analysis must
address. ___________, __________ and __________.
5. PSM does not apply to contractors,
regardless of the work they are doing. True or False
PSM One Day Review (cont.)
6. The PSM Standard applies to companies that either process
highly _____________ materials or use _____________
liquids and gases in excess of 10,000 pounds.
7. Process safety information includes:
______________, _____________ and _____________.
8. Fault tree analysis is one form of an
approved method of performing a process
hazard analysis. True or False
9. A technical basis is not required to change
a process covered by the PSM Standard. True or False
10. Two types of training required by the PSM
standard are ________________ and_________________.