Process Safety Management -

Tips for the Little Guy

What Is Process Safety Management
 Process 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  Pre-Start up Safety

 Employee Review
Participation  Mechanical Integrity
 Process Safety  Hot Work (Non-routine
Information Work Authorizations)
 Process Hazard  Management of
Analysis Change
 Operating Procedures  Incident Investigation
 Employee Training  Emergency Planning
and Response
 Contractors
 Compliance Audits
1910.119 (a) Application
 Appendix A of 29 CFR 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.
 To adequately address this section, identify
what brings you into coverage by the
standard, specifying which processes at the
facility are covered and why.
1910.119 (a) Application
cont.
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
May 25, 2004 Conyers GA
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,
their involvement in the development of the
programs, and continuing participation in the
process.
 An OSHA inspector (CSHO) will attempt to
verify participation by interviewing employees
at random.
1910.119 (c) Employee
Participation cont.
 Consultation / participation with training
and supervision to determine the
frequency and content of initial and
refresher training.
 Consultation / participation to develop
and review operating and maintenance
procedures.
 Consultation / participation in incident
investigations regarding the covered
process.
1910.119 (d) Process Safety
Information
 Material Safety Data  Material and energy
Sheets (MSDS) balance calculations
 Piping and  Relevant consensus
instrumentation standards
diagrams (PINDs)  Materials of
 Block flow diagrams construction
1910.119 (d) Process Safety
Information cont.
 Available to all affected employees [requirement of
1910.119 (c) Employee Participation]

 Available for Process Hazard Analysis and

revalidations [requirement of 1910.119 (e) Process
Hazard Analysis]

 So auditors and CSHOs can find everything!

1910.119 (e) Process Hazard
Analysis
1910.119 (e) Process Hazard
Analysis
 OSHA has suggested formats
 Don’t start until all information is
gathered
 Use a software tool to guide, record,
manage process
1910.119 (e) Process Hazard
Analysis

“Catastrophic release means a major

uncontrolled emission, fire, or explosion
involving one or more highly hazardous
chemicals, that presents serious danger to
employees in the workplace.” 1910.119(b)
                    
           
1910.119 (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
1910.119 (g) Employee
Training
 The employer shall prepare a record:
 Identity of employee.
 Date of training.
 Means to verify that employee
understood training
 At a minimum, refresher training shall be
provided at least every three years and more
often if necessary to each employee involved
in operating a process.
1910.119 (h) Contractors
 Absolute Requirements
 Employer Documentation:
 Contract employee injury and illness logs
related to work in covered process areas.
 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.
1910.119 (i) Pre-Start up
Safety Review
 Check, double check, and review any
changes, modifications, additions made
in a PSM covered area – before you flip
the switch.
1910.119 (j) Mechanical
Integrity
 The employer shall develop and maintain a master
list of all equipment specifically covered by the
standard, and equipment that is important to safety of
the process.
 Pressure vessels and storage tanks.
 Piping systems including valves and other piping
components.
 Relief and vent systems and devices.
 Emergency shutdown systems.
 Controls (including monitoring devices and sensors,
alarms, and interlocks).
1910.119 (j) Mechanical
Integrity cont.
 Pumps.
 Rotating equipment.
 Heat exchange equipment.
 Electrical generation and distribution
equipment.
 Un-interruptable power supplies.
 Emergency power supply equipment.
 Fire protection equipment.
1910.119 (k) Hot Work (a.k.a. Non-
routine Work Authorizations)
 Welding, cutting, braising – make sure
only trained personnel perform these
functions
 Have trained fire watchers (align with
fire extinguisher / fire response training)
1910.119 (l) Management of
Change
 Create
formalized system to review all
changes to process areas including:
 Raw 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
1910.119 (m) Incident
Investigation
Investigate
Incidents Begin within
& 48-hours
Near-Misses

Reatain Incident Team

with Process
Reports 5-years
Investigation Knowledge

Follow-up Report with

System for Conclusions &
Recommendations Recommendatons
1910.119 (n) Emergency
Planning and Response
 Call
in all resources and make plan
comprehensive:
 InformationTechnology (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.OSHA.gov):
 CPL 2-2.45 – Process Safety Management of Highly
Hazardous Chemicals – Compliance Guidelines and
Enforcement Procedures – 78 pages of gold!
 Appendix C to §1910.119 Compliance Guidelines and
Recommendations for Process Safety Management
(Nonmandatory)
 OSHA training institute
 Safety and Health – Chemical Process Industry – course
#330A. PSM ‘boot camp’ – five days of fun and a three
ring binder!
 AIChE / CCPs
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