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OSHA Process Safety
Management
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On 24 February 1992, OSHA promulgated the Final Rule for Process Safety
Management of Highly Hazardous Chemicals. The requirements of the PSM
standard are intended to eliminate or mitigate the consequences of
releases of highly hazardous chemicals which may be toxic, reactive,
flammable, or explosive. The standard emphasizes the application of
management controls when addressing the risks associated with handling or
working near hazardous chemicals.
The regulations regarding OSHA Process Safety Management appear at 29 CFR
1910.119. To view these regulations on-line, visit the DOL OSHA
OCIS Home
Page
OSHA PSM Standards apply to:
- A process which involves a chemical at or above the specified
quanitites listed in Appendix A of 29 CFR 1910.119. (Visit OSHA's web
site by clicking on the link above.)
- A process which involves a flammable liquid or gas (as defined in
1910.1200 (c)) on site, in one location, in a quantity of 10,000 pounds or
more except for:
- Hydrocarbon fuels used solely for workplace consumption as a fuel if
such fuels are not a part of a process containing another highly
hazardous chemical covered by this standard.
- Flammable liquids stored in atmospheric tanks or transferred, which
are kept below their normal boiling point without benefit of chilling or
refrigeration.
OSHA PSM Standards do not apply to:
- Retail facilities;
- Oil or gas well drilling or servicing operations; or,
- Normally unoccupied remote facilities.
The OSHA Process Safety Management Standards consist of fourteen programs.
When
reviewing each program, one should be concerned with:
- Records Review - Required documentation;
- On-site Conditions - Confirmation that programs are implemented; and
- Interviews - operators, maintenance personnel, engineering support
staff, and contractors and contractor employees
In addition, think in terms of Who, What, When, Where, Why, and How.
- Who are the officials responsible for developing and implementing
each of the program elements?
- What are the requirements and the contents of each programs element?
- When are the required actions for each element completed and when are
they required to be completed?
- Where have actions been implemented or changed?
- Why have the implementation decisions and priorities been made as
recorded in the PSM documentation?
- How is the program implemented and how is the programs effectiveness
evaluated and improved (monitoring performance, follow-up and closure of
outstanding items, etc.)?
Program Summaries
- Employee participation
- Process safety information
- Process hazard analysis
- Operating procedures
- Training
- Contractors
- Pre-start up safety review
- Mechanical integrity
- Hot work permit
- Management of change
- Incident investigation
- Emergency planning and response
- Compliance audits
- Trade secrets
Program Summaries (Expanded)
- Employee participation (1910.119 (c)):
Minimum requirements for
an Employee Participation Program for PSM must include a written plan of
action for implementing employee consultation on the development of
process hazard analyses and other elements of process hazard management.
The employer must also provide ready access to all the information
required to be developed under the standard.
- Process safety information (1910.119 (d)):
Compile written
process safety information on process chemicals, process technology, and
process equipment before conducting any process hazard analysis. Such
information is essential for an effective process safety management
program and for conducting process hazared analyses.
- Process hazard analysis (1910.119 (e)):
Requires the employer to
develop a thorough, orderly, systematic approach for identifying,
evaluating and controlling processes involving highly hazardous
chemicals. Minimum requirements include:
- setting a priority order and conducting analyses according to the
required schedule;
- using an appropriate methodology to determine and evaluate the
process hazards;
- addressing process hazards, previous incidents with catastrophic
potential, engineering and administrative controls applicable to the
hazards, consequences of failure of controls, facility siting, human
factors, and a qualitative evaluation of possible safety and health
effects of failure of controls on employees;
- performing PHA by a team with expertise in engineering and process
operations, the process.
Methodologies
- What-if?
- Checklist?
- What-if/Checklist?
- Hazard and Operability Study (HAZOP)
- Failure Mode and Effects Analysis (FMEA)
- Fault Tree Analysis (FTA)
- Operating procedures (1910.119 (f)):
Should provide clear
instruction for conducting activities involved in covered processes that
are consistent with the process safety information. The operating
procedures must address steps for each operating phase, operating limits,
safety and health considerations, and safety systems and their
functions.
- Training (1910.119 (g)):
Such training should help
employees understand the nature and causes of problems arising from
process operations, and increase employee awareness with respect to the
hazards particular to a process. An effective training program
significantly reduces the number and severity of incidents arising from
process operations, and can be instrumental in preventing small problems
from leading to a catastrophic release. Minimum requirements for an
effective training program include:
- Initial training
- Refresher training
- Documentation
- Contractors (1910.110 (h)):
Employers who use
contractors to perform work in and around processes
that involve highly hazardous chemicals are to establish a screening process
so that they hire and use
contractors who accomplish the desired job tasks
without compromising the
safety and health of employees at a facility. The
contractor must assure
that contract employees are trained on performing
the job safely, of the
hazards related to the job, and applicable provisions
of the emergency
action plan.
- Pre-startup safety review (1910.119 (i)):
For new facilities and
for modified facilities, when modifications necessitate
a change to
process safety information, certain important considerations are
addressed before any highly hazardous chemicals are introduced into the
process. Minimum requirements include that the pre-startup safety review
confirm the following:
- Construction and equipment are in accordance with design specifications;
- Safety, operating, maintenance, and emergency procedures are in place
and adequate;
- For new facilities, a PHA has been performed and recommendations
resolved or implemented;
- Modified facilities meet requirements;
- Management of change; and training of each employee involved in the
process has been completed.
- Mechanical integrity (1910.119 (j)):
Involves measures to be
taken to assure that equipment used to process, store, or handle highly
hazardous chemicals is designed, constructed, installed, and maintained
to minimize the risk of release of such chemicals. It is required that a
mechanical integrity program be in place to assure the continued
integrity of process equipment. The elements of the program are to include:
- the identification and categorization of equipment and instrumentation
- development of written maintenance procedures
- training for process maintenance activities
- inspection and testing
- correction of deficiencies in equipment that are outside acceptable
limits defined by the process safety information
- development of a quality assurance program
- Hot work permit (1910.119 (k)):
Requires employers to control, in
a consistent manner, nonroutine work conducted in process areas.
Concerns are associated with hot work operations associated with welding
and cutting in process areas.
- Management of change (1910.119 (l)):
Requires management of
all modifications to equipment, procedures, raw materials and processing
conditions other than replacement in kind by identifying and reviewing
them prior to implementation of the change. Minimum requirements for
management of change include:
- establishing written procedures to manage change
- addressing the technical basis, impact on safety and health,
modification to operating procedures, necessary time period, and
authorizations required
- informing and training affected employees
- updating process safety information and operating procedures or practices
- Incident investigations (1910.119 (m)):
Employers are required to
investigate each incident which resulted in, or could reasonably have
resulted in, a catastrophic release of highly hazardous chemicals in the
workplace. An investigation shall be initiated no later than 48 hours
following the incident. An investigation team shall be established and a
report prepared which includes:
- Date of incident
- Date investigation began
- Description of incident
- Factors that contributed to the incident
- Recommendations from the investigation
The employer is required to establish a system to promptly address the
incident report findings and recommendations, documenting all resolutions
and corrective actions. Incident reports shall be reviewed with all
affected personnel whose job tasks are relevant to the investigation and
retained for five years.
- Emergency planning and response (1910.119 (n)):
The employer is
required to address what actions employees are to take when there is an
unwanted release of highly hazardous chemicals. The employer must
establish and implement an emergency action plan in accordance with the
provisions of 29 CFR 1910.38(a) and include procedures for handling small
releases. Certain provisions of the hazardous waste and emergency
response standard, 29 CFR 1910.120(a), (p), and (q) may also apply.
- Compliance audits (1910.119 (o)):
Employers are required to
self-evaluate the effectiveness of their PSM program by identifying
deficiencies and assuring corrective actions. Minimum requirements include:
- audits at least every three years
- maintenance of audit reports for at least the last two audits
- audits conducted by at least one person knowledgeable in the process
- documentation of an appropriate response to each finding
- documentation that the deficiencies found have been corrected
- Trade secrets (1910.119 (p)):
Employers are to provide all the
information necessary to comply with the standard to personnel developing
paragraphs (d), (e), (f), (n) and (o) without regard to possible trade
secrets. In addition, employees and their designated representatives
shall have access to trade secret information contained within documents
required to be developed by the standard.
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