29CFR1910.119 29CFR1910.119 Simple Keys to Compliance Simple Keys to Compliance Process Safety Management of Highly Hazardous & Explosive Chemicals
Mar 29, 2015
29CFR1910.11929CFR1910.119Simple Keys to ComplianceSimple Keys to Compliance
29CFR1910.11929CFR1910.119Simple Keys to ComplianceSimple Keys to Compliance
Process Safety Management of Highly Hazardous & Explosive Chemicals
Process Safety Management of Highly Hazardous & Explosive Chemicals
ObjectivesObjectives
Define what is PSM and who is covered Define what is PSM and who is covered by the standardby the standard
List the elements of the PSM standardList the elements of the PSM standardLocate additional resourcesLocate additional resources
Define what is PSM and who is covered Define what is PSM and who is covered by the standardby the standard
List the elements of the PSM standardList the elements of the PSM standardLocate additional resourcesLocate additional resources
2
What Is Process Safety Management?What Is Process Safety Management?
PSM:PSM: Addresses the management of Highly Addresses the management of Highly
Hazardous Chemicals (HHC)Hazardous Chemicals (HHC)
Integrates Integrates TechnologyTechnologyOperating ProceduresOperating ProceduresStandard management protocolsStandard management protocols
PSM:PSM: Addresses the management of Highly Addresses the management of Highly
Hazardous Chemicals (HHC)Hazardous Chemicals (HHC)
Integrates Integrates TechnologyTechnologyOperating ProceduresOperating ProceduresStandard management protocolsStandard management protocols
3
Why Did OSHA Develop PSM?Why Did OSHA Develop PSM?
Past DisastersPast DisastersCurrent DisastersCurrent DisastersPerceived Weakness in PSM Perceived Weakness in PSM
ProgramProgram
Past DisastersPast DisastersCurrent DisastersCurrent DisastersPerceived Weakness in PSM Perceived Weakness in PSM
ProgramProgram
4
Why Did OSHA Develop PSM?Why Did OSHA Develop PSM?
Bhopal, India (1984)Bhopal, India (1984) 2,000 deaths 2,000 deaths
Isocyanate releaseIsocyanate release Pasadena, TX (1989)Pasadena, TX (1989)
23 deaths, 132 injuries 23 deaths, 132 injuries Petroleum explosionPetroleum explosion
Cincinnati, OH (1990)Cincinnati, OH (1990) 2 deaths 2 deaths
ExplosionExplosion Sterlington, LA (1991) Sterlington, LA (1991)
8 deaths, 128 injuries 8 deaths, 128 injuries Chemical releaseChemical release
Bhopal, India (1984)Bhopal, India (1984) 2,000 deaths 2,000 deaths
Isocyanate releaseIsocyanate release Pasadena, TX (1989)Pasadena, TX (1989)
23 deaths, 132 injuries 23 deaths, 132 injuries Petroleum explosionPetroleum explosion
Cincinnati, OH (1990)Cincinnati, OH (1990) 2 deaths 2 deaths
ExplosionExplosion Sterlington, LA (1991) Sterlington, LA (1991)
8 deaths, 128 injuries 8 deaths, 128 injuries Chemical releaseChemical release
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In 1991, OSHA and In 1991, OSHA and EPA respectively, EPA respectively, Released the Released the Standards, PSM & Standards, PSM & RMP that Applies to RMP that Applies to Those Companies Those Companies that are Affected by that are Affected by The Standards.The Standards.
In 1991, OSHA and In 1991, OSHA and EPA respectively, EPA respectively, Released the Released the Standards, PSM & Standards, PSM & RMP that Applies to RMP that Applies to Those Companies Those Companies that are Affected by that are Affected by The Standards.The Standards.
Why Did OSHA Develop PSM?Why Did OSHA Develop PSM?
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Process Safety Process Safety ManagementManagement is a is a regulation, promulgated regulation, promulgated by OSHA, intended to by OSHA, intended to prevent an incident like prevent an incident like the 1984 Bhopal Disasterthe 1984 Bhopal Disaster
And…to Prevent Release And…to Prevent Release of:of: Toxic, Toxic, Reactive, Reactive, Flammable, or Flammable, or Explosive chemicalsExplosive chemicals
Process Safety Process Safety ManagementManagement is a is a regulation, promulgated regulation, promulgated by OSHA, intended to by OSHA, intended to prevent an incident like prevent an incident like the 1984 Bhopal Disasterthe 1984 Bhopal Disaster
And…to Prevent Release And…to Prevent Release of:of: Toxic, Toxic, Reactive, Reactive, Flammable, or Flammable, or Explosive chemicalsExplosive chemicals
Why Did OSHA Develop PSM?Why Did OSHA Develop PSM?
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Not Only PSM, But RMPNot Only PSM, But RMP
A great many industrial A great many industrial facilities must comply facilities must comply with OSHA's Process with OSHA's Process Safety Management Safety Management (PSM) regulations as (PSM) regulations as well as the CAA 112(r) well as the CAA 112(r) EPA Risk EPA Risk Management Program Management Program (RMP) regulations (RMP) regulations (Title 40 CFR Part 68). (Title 40 CFR Part 68).
A great many industrial A great many industrial facilities must comply facilities must comply with OSHA's Process with OSHA's Process Safety Management Safety Management (PSM) regulations as (PSM) regulations as well as the CAA 112(r) well as the CAA 112(r) EPA Risk EPA Risk Management Program Management Program (RMP) regulations (RMP) regulations (Title 40 CFR Part 68). (Title 40 CFR Part 68).
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PSM vs. RMP - What’s the Difference?PSM vs. RMP - What’s the Difference?
RMP-Like Sara Title IIIRMP-Like Sara Title III Protects the Protects the
CommunityCommunity Protects the General Protects the General
Public Around the Public Around the FacilityFacility
Protects Adjacent Protects Adjacent Facilities Such as Facilities Such as Schools & HospitalsSchools & Hospitals
RMP-Like Sara Title IIIRMP-Like Sara Title III Protects the Protects the
CommunityCommunity Protects the General Protects the General
Public Around the Public Around the FacilityFacility
Protects Adjacent Protects Adjacent Facilities Such as Facilities Such as Schools & HospitalsSchools & Hospitals
PSM - Like HAZCOMPSM - Like HAZCOM Protects the Protects the
WorkforceWorkforce Protects ContractorsProtects Contractors Protects Visitors to Protects Visitors to
the Facilitythe Facility Basically Protects the Basically Protects the
Workplace Workplace
PSM - Like HAZCOMPSM - Like HAZCOM Protects the Protects the
WorkforceWorkforce Protects ContractorsProtects Contractors Protects Visitors to Protects Visitors to
the Facilitythe Facility Basically Protects the Basically Protects the
Workplace Workplace
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The Standard Was Promulgated in 1991 - Is it Working?The Standard Was Promulgated in 1991 - Is it Working?
10
BP Products Texas BP Products Texas City - City - March 2005March 2005 15 Workers Killed15 Workers Killed 170 Injured170 Injured Major Property Major Property
DamageDamage $50.6 Million in Fines$50.6 Million in Fines
BP Products Texas BP Products Texas City - City - March 2005March 2005 15 Workers Killed15 Workers Killed 170 Injured170 Injured Major Property Major Property
DamageDamage $50.6 Million in Fines$50.6 Million in Fines
The Standard Was Promulgated in 1991 - Is it Working?The Standard Was Promulgated in 1991 - Is it Working?
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ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the Technology of the
ProcessProcess Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance
ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the Technology of the
ProcessProcess Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance
The Elements of the PSM StandardThe Elements of the PSM Standard
Process Hazard Process Hazard AnalysisAnalysis
Management of ChangeManagement of Change Operating ProceduresOperating Procedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &
ResponseResponse Incident InvestigationIncident Investigation Compliance AuditsCompliance Audits Trade SecretsTrade Secrets
Process Hazard Process Hazard AnalysisAnalysis
Management of ChangeManagement of Change Operating ProceduresOperating Procedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &
ResponseResponse Incident InvestigationIncident Investigation Compliance AuditsCompliance Audits Trade SecretsTrade Secrets
12
ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the Technology of the
ProcessProcess Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing
ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the Technology of the
ProcessProcess Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing
The Elements of the PSM StandardThe Elements of the PSM Standard
Process Hazard Process Hazard AnalysisAnalysis
Management of ChangeManagement of Change Operating ProceduresOperating Procedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &
ResponseResponse Incident InvestigationIncident Investigation Compliance AuditsCompliance Audits Trade SecretsTrade Secrets
Process Hazard Process Hazard AnalysisAnalysis
Management of ChangeManagement of Change Operating ProceduresOperating Procedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &
ResponseResponse Incident InvestigationIncident Investigation Compliance AuditsCompliance Audits Trade SecretsTrade Secrets
13
ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the Technology of the
ProcessProcess Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance
ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the Technology of the
ProcessProcess Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance
The Elements of the PSM StandardThe Elements of the PSM Standard
Process Hazard AnalysisProcess Hazard Analysis Management of Management of
ChangeChange Operating ProceduresOperating Procedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &
ResponseResponse Incident InvestigationIncident Investigation Compliance AuditsCompliance Audits Trade SecretsTrade Secrets
Process Hazard AnalysisProcess Hazard Analysis Management of Management of
ChangeChange Operating ProceduresOperating Procedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &
ResponseResponse Incident InvestigationIncident Investigation Compliance AuditsCompliance Audits Trade SecretsTrade Secrets
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ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the Technology of the
ProcessProcess Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance
ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the Technology of the
ProcessProcess Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance
The Elements of the PSM StandardThe Elements of the PSM Standard Process Hazard AnalysisProcess Hazard Analysis
Management of ChangeManagement of Change Operating Operating
ProceduresProcedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &
ResponseResponse Incident InvestigationIncident Investigation Compliance AuditsCompliance Audits Trade SecretsTrade Secrets
Process Hazard AnalysisProcess Hazard Analysis Management of ChangeManagement of Change Operating Operating
ProceduresProcedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &
ResponseResponse Incident InvestigationIncident Investigation Compliance AuditsCompliance Audits Trade SecretsTrade Secrets
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ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the Technology of the
ProcessProcess Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance
ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the Technology of the
ProcessProcess Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance
The Elements of the PSM StandardThe Elements of the PSM Standard
Process Hazard AnalysisProcess Hazard Analysis Management of Management of
ChangeChange Operating ProceduresOperating Procedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &
ResponseResponse Incident InvestigationIncident Investigation Compliance AuditsCompliance Audits Trade SecretsTrade Secrets
Process Hazard AnalysisProcess Hazard Analysis Management of Management of
ChangeChange Operating ProceduresOperating Procedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &
ResponseResponse Incident InvestigationIncident Investigation Compliance AuditsCompliance Audits Trade SecretsTrade Secrets
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ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee Employee
ParticipationParticipation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the ProcessTechnology of the Process Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance
ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee Employee
ParticipationParticipation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the ProcessTechnology of the Process Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance
The Elements of the PSM StandardThe Elements of the PSM Standard Process Hazard AnalysisProcess Hazard Analysis
Management of ChangeManagement of Change Operating ProceduresOperating Procedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &
ResponseResponse Incident InvestigationIncident Investigation Compliance AuditsCompliance Audits Trade SecretsTrade Secrets
Process Hazard AnalysisProcess Hazard Analysis Management of ChangeManagement of Change Operating ProceduresOperating Procedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &
ResponseResponse Incident InvestigationIncident Investigation Compliance AuditsCompliance Audits Trade SecretsTrade Secrets
17
ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the ProcessTechnology of the Process Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance
ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the ProcessTechnology of the Process Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance
The Elements of the PSM StandardThe Elements of the PSM Standard Process Hazard AnalysisProcess Hazard Analysis
Management of ChangeManagement of Change Operating ProceduresOperating Procedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor Contractor
ManagementManagement Emergency Planning & Emergency Planning &
ResponseResponse Incident InvestigationIncident Investigation Compliance AuditsCompliance Audits Trade SecretsTrade Secrets
Process Hazard AnalysisProcess Hazard Analysis Management of ChangeManagement of Change Operating ProceduresOperating Procedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor Contractor
ManagementManagement Emergency Planning & Emergency Planning &
ResponseResponse Incident InvestigationIncident Investigation Compliance AuditsCompliance Audits Trade SecretsTrade Secrets
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ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the ProcessTechnology of the Process Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance
ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the ProcessTechnology of the Process Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance
The Elements of the PSM StandardThe Elements of the PSM Standard Process Hazard AnalysisProcess Hazard Analysis
Management of ChangeManagement of Change Operating ProceduresOperating Procedures Pre-Start up Safety Pre-Start up Safety
ReviewReview Hot Work PermitHot Work Permit Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &
ResponseResponse
Process Hazard AnalysisProcess Hazard Analysis Management of ChangeManagement of Change Operating ProceduresOperating Procedures Pre-Start up Safety Pre-Start up Safety
ReviewReview Hot Work PermitHot Work Permit Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &
ResponseResponse
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ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the ProcessTechnology of the Process Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance
ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the ProcessTechnology of the Process Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance
The Elements of the PSM StandardThe Elements of the PSM Standard Process Hazard AnalysisProcess Hazard Analysis
Management of ChangeManagement of Change Operating ProceduresOperating Procedures Pre-Start up Safety Pre-Start up Safety
ReviewReview Hot Work PermitHot Work Permit Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &
ResponseResponse
Process Hazard AnalysisProcess Hazard Analysis Management of ChangeManagement of Change Operating ProceduresOperating Procedures Pre-Start up Safety Pre-Start up Safety
ReviewReview Hot Work PermitHot Work Permit Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &
ResponseResponse
20
ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the ProcessTechnology of the Process Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance
ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the ProcessTechnology of the Process Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance
The Elements of the PSM StandardThe Elements of the PSM Standard Process Hazard AnalysisProcess Hazard Analysis
Management of ChangeManagement of Change Operating ProceduresOperating Procedures Pre-Start up Safety Pre-Start up Safety
ReviewReview Hot Work PermitHot Work Permit Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning Emergency Planning
& Response& Response
Process Hazard AnalysisProcess Hazard Analysis Management of ChangeManagement of Change Operating ProceduresOperating Procedures Pre-Start up Safety Pre-Start up Safety
ReviewReview Hot Work PermitHot Work Permit Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning Emergency Planning
& Response& Response
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ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the ProcessTechnology of the Process Equipment in the Equipment in the
ProcessProcess Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance
ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the ProcessTechnology of the Process Equipment in the Equipment in the
ProcessProcess Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance
The Elements of the PSM StandardThe Elements of the PSM Standard Process Hazard AnalysisProcess Hazard Analysis
Management of ChangeManagement of Change Operating ProceduresOperating Procedures Pre-Start up Safety Pre-Start up Safety
ReviewReview Hot Work PermitHot Work Permit Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &
ResponseResponse
Process Hazard AnalysisProcess Hazard Analysis Management of ChangeManagement of Change Operating ProceduresOperating Procedures Pre-Start up Safety Pre-Start up Safety
ReviewReview Hot Work PermitHot Work Permit Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &
ResponseResponse
22
ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the ProceTechnology of the Processss Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance
ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the ProceTechnology of the Processss Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance
The Elements of the PSM StandardThe Elements of the PSM Standard Process Hazard AnalysisProcess Hazard Analysis
Management of ChangeManagement of Change Operating ProceduresOperating Procedures Pre-Start up Safety Pre-Start up Safety
ReviewReview Hot Work PermitHot Work Permit Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &
ResponseResponse
Process Hazard AnalysisProcess Hazard Analysis Management of ChangeManagement of Change Operating ProceduresOperating Procedures Pre-Start up Safety Pre-Start up Safety
ReviewReview Hot Work PermitHot Work Permit Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &
ResponseResponse
23
ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the ProceTechnology of the Processss Equipment in the Equipment in the
ProcessProcess Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance
ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the ProceTechnology of the Processss Equipment in the Equipment in the
ProcessProcess Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance
The Elements of the PSM StandardThe Elements of the PSM Standard Process Hazard AnalysisProcess Hazard Analysis
Management of ChangeManagement of Change Operating ProceduresOperating Procedures Pre-Start up Safety Pre-Start up Safety
ReviewReview Hot Work PermitHot Work Permit Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &
ResponseResponse
Process Hazard AnalysisProcess Hazard Analysis Management of ChangeManagement of Change Operating ProceduresOperating Procedures Pre-Start up Safety Pre-Start up Safety
ReviewReview Hot Work PermitHot Work Permit Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &
ResponseResponse
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The Elements of the PSM Standard
The Elements of the PSM Standard
Let’s Explore Some of the Elements…Let’s Explore Some of the Elements…Let’s Explore Some of the Elements…Let’s Explore Some of the Elements…
25
ApplicationApplication
1910.119(a)1910.119(a)1910.119(a)1910.119(a)
26
What Facilities are CoveredWhat Facilities are Covered
Those Who Use Chemicals in Appendix A: A List of Those Who Use Chemicals in Appendix A: A List of highly hazardous chemicals, toxics and reactive highly hazardous chemicals, toxics and reactive (Mandatory). Contains a listing of toxic and reactive (Mandatory). Contains a listing of toxic and reactive highly hazardous chemicals which present a potential highly hazardous chemicals which present a potential for a catastrophic event at or above the threshold for a catastrophic event at or above the threshold quantityquantity
ExamplesExamples
Chemical Chemical Threshold Quantity (TQ) Threshold Quantity (TQ) Anhydrous Ammonia 10,000 lbsAnhydrous Ammonia 10,000 lbs Chlorine 1,500 lbsChlorine 1,500 lbs
Those Who Use Chemicals in Appendix A: A List of Those Who Use Chemicals in Appendix A: A List of highly hazardous chemicals, toxics and reactive highly hazardous chemicals, toxics and reactive (Mandatory). Contains a listing of toxic and reactive (Mandatory). Contains a listing of toxic and reactive highly hazardous chemicals which present a potential highly hazardous chemicals which present a potential for a catastrophic event at or above the threshold for a catastrophic event at or above the threshold quantityquantity
ExamplesExamples
Chemical Chemical Threshold Quantity (TQ) Threshold Quantity (TQ) Anhydrous Ammonia 10,000 lbsAnhydrous Ammonia 10,000 lbs Chlorine 1,500 lbsChlorine 1,500 lbs
27
A process which A process which involves a involves a flammable liquid or flammable liquid or gas (as defined in gas (as defined in 1910.1200(c) of this 1910.1200(c) of this part) on-site in one part) on-site in one location, in a location, in a quantity of 10,000 quantity of 10,000 pounds (4535.9 kg) pounds (4535.9 kg) or moreor more
A process which A process which involves a involves a flammable liquid or flammable liquid or gas (as defined in gas (as defined in 1910.1200(c) of this 1910.1200(c) of this part) on-site in one part) on-site in one location, in a location, in a quantity of 10,000 quantity of 10,000 pounds (4535.9 kg) pounds (4535.9 kg) or moreor more
What Facilities are CoveredWhat Facilities are Covered
28
Important Interpretation: 2007 - 06/11/2007 - OSHA Important Interpretation: 2007 - 06/11/2007 - OSHA defines "on-site in one location" for Process Safety defines "on-site in one location" for Process Safety Management of Highly Hazardous Chemicals standardManagement of Highly Hazardous Chemicals standard
OSHA interprets "on-site in one location" to mean that the OSHA interprets "on-site in one location" to mean that the standard applies when a threshold quantity of a highly standard applies when a threshold quantity of a highly hazardous chemical (HHC) exists within an area under hazardous chemical (HHC) exists within an area under the control of an employer or group of affiliated the control of an employer or group of affiliated employers. It also applies to any group of vessels that employers. It also applies to any group of vessels that are interconnected, or in separate vessels that are are interconnected, or in separate vessels that are close enough in proximity that the HHC could be close enough in proximity that the HHC could be involved in a potential catastrophic release.involved in a potential catastrophic release.
Important Interpretation: 2007 - 06/11/2007 - OSHA Important Interpretation: 2007 - 06/11/2007 - OSHA defines "on-site in one location" for Process Safety defines "on-site in one location" for Process Safety Management of Highly Hazardous Chemicals standardManagement of Highly Hazardous Chemicals standard
OSHA interprets "on-site in one location" to mean that the OSHA interprets "on-site in one location" to mean that the standard applies when a threshold quantity of a highly standard applies when a threshold quantity of a highly hazardous chemical (HHC) exists within an area under hazardous chemical (HHC) exists within an area under the control of an employer or group of affiliated the control of an employer or group of affiliated employers. It also applies to any group of vessels that employers. It also applies to any group of vessels that are interconnected, or in separate vessels that are are interconnected, or in separate vessels that are close enough in proximity that the HHC could be close enough in proximity that the HHC could be involved in a potential catastrophic release.involved in a potential catastrophic release.
What Facilities are CoveredWhat Facilities are Covered
29
Affect of the “Meer” Decision:Affect of the “Meer” Decision:
MEER ruling and theMEER ruling and the MEER Memorandum addressed in the MEER Memorandum addressed in the Secretary's letter, OSHA's enforcement policy that the Secretary's letter, OSHA's enforcement policy that the Agency would not cite employers forAgency would not cite employers for violations of 1910.119 violations of 1910.119 where stored flammable liquids in atmospheric tanks were where stored flammable liquids in atmospheric tanks were connected to a process, unless the process outside ofconnected to a process, unless the process outside of the the amount in storage contained more than 10,000 pounds of amount in storage contained more than 10,000 pounds of the substancethe substance
Affect of the “Meer” Decision:Affect of the “Meer” Decision:
MEER ruling and theMEER ruling and the MEER Memorandum addressed in the MEER Memorandum addressed in the Secretary's letter, OSHA's enforcement policy that the Secretary's letter, OSHA's enforcement policy that the Agency would not cite employers forAgency would not cite employers for violations of 1910.119 violations of 1910.119 where stored flammable liquids in atmospheric tanks were where stored flammable liquids in atmospheric tanks were connected to a process, unless the process outside ofconnected to a process, unless the process outside of the the amount in storage contained more than 10,000 pounds of amount in storage contained more than 10,000 pounds of the substancethe substance
What Facilities are CoveredWhat Facilities are Covered
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What Types of Industries?What Types of Industries?
Industries that Process Chemicals Such As:Industries that Process Chemicals Such As: Industrial Organics & InorganicsIndustrial Organics & Inorganics PaintsPaints PharmaceuticalsPharmaceuticals AdhesivesAdhesives Sealants and FibersSealants and Fibers Petrochemical facilitiesPetrochemical facilities Paper MillsPaper Mills Food Processing with Anhydrous Ammonia over Food Processing with Anhydrous Ammonia over
the TQthe TQ
Industries that Process Chemicals Such As:Industries that Process Chemicals Such As: Industrial Organics & InorganicsIndustrial Organics & Inorganics PaintsPaints PharmaceuticalsPharmaceuticals AdhesivesAdhesives Sealants and FibersSealants and Fibers Petrochemical facilitiesPetrochemical facilities Paper MillsPaper Mills Food Processing with Anhydrous Ammonia over Food Processing with Anhydrous Ammonia over
the TQthe TQ
31
ExclusionsExclusions
1910.119(a)(1)(ii)(A)1910.119(a)(1)(ii)(A)1910.119(a)(1)(ii)(A)1910.119(a)(1)(ii)(A)
32
There are ExclusionsThere are Exclusions
An employer is exempt from the requirements of PSM An employer is exempt from the requirements of PSM when:when:
A threshold quantity of flammable liquids is stored in A threshold quantity of flammable liquids is stored in atmospheric tanks or transferred without the benefit of atmospheric tanks or transferred without the benefit of chilling or refrigeration chilling or refrigeration
Hydrocarbon fuels used solely for workplace Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling), heating, gasoline for vehicle refueling), If such fuels are not a part of a process containing If such fuels are not a part of a process containing
another highly hazardous chemical covered by this another highly hazardous chemical covered by this standardstandard
An employer is exempt from the requirements of PSM An employer is exempt from the requirements of PSM when:when:
A threshold quantity of flammable liquids is stored in A threshold quantity of flammable liquids is stored in atmospheric tanks or transferred without the benefit of atmospheric tanks or transferred without the benefit of chilling or refrigeration chilling or refrigeration
Hydrocarbon fuels used solely for workplace Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling), heating, gasoline for vehicle refueling), If such fuels are not a part of a process containing If such fuels are not a part of a process containing
another highly hazardous chemical covered by this another highly hazardous chemical covered by this standardstandard
33
Retail facilities;Retail facilities;
Oil or gas well drilling or Oil or gas well drilling or
servicing operations; or,servicing operations; or,
Normally unoccupied Normally unoccupied
remote facilitiesremote facilities
Retail facilities;Retail facilities;
Oil or gas well drilling or Oil or gas well drilling or
servicing operations; or,servicing operations; or,
Normally unoccupied Normally unoccupied
remote facilitiesremote facilities
There are ExclusionsThere are Exclusions
34
Employee ParticipationEmployee Participation
1910.119(c)1910.119(c)1910.119(c)1910.119(c)
35
Now that we are required to comply, then what? Now that we are required to comply, then what? Form a Team in Form a Team in
Your Company, i.e..Your Company, i.e.. Process EngineersProcess Engineers OperatorsOperators SafetySafety MaintenanceMaintenance ManagementManagement ConsultantsConsultants
Form a Team in Form a Team in Your Company, i.e..Your Company, i.e.. Process EngineersProcess Engineers OperatorsOperators SafetySafety MaintenanceMaintenance ManagementManagement ConsultantsConsultants
Remember…You Can’t Do it Alone!
36
Form a Plan, Form a Plan, Determine:Determine: ResponsibilitiesResponsibilities DutiesDuties ReportingReporting Document ControlDocument Control Progress ReportsProgress Reports Tracking ChangesTracking Changes
Form a Plan, Form a Plan, Determine:Determine: ResponsibilitiesResponsibilities DutiesDuties ReportingReporting Document ControlDocument Control Progress ReportsProgress Reports Tracking ChangesTracking Changes
Now that we are required to comply, then what? Now that we are required to comply, then what?
Then…Begin the Process of Developing & Implementing the PSM Program
37
Hazards of the ProcessHazards of the Process
1910.119(d)(1)1910.119(d)(1)1910.119(d)(1)1910.119(d)(1)
38
The Requirements of the Standard - Hazard Determination
The Requirements of the Standard - Hazard Determination
Determine:Determine:
Chemicals in Your ProcessChemicals in Your ProcessProcess ChemistryProcess ChemistryQuantity of Chemicals in lbsQuantity of Chemicals in lbsCompare to Appendix A List with Compare to Appendix A List with
Threshold Quantities (TQ’s)Threshold Quantities (TQ’s)
Determine:Determine:
Chemicals in Your ProcessChemicals in Your ProcessProcess ChemistryProcess ChemistryQuantity of Chemicals in lbsQuantity of Chemicals in lbsCompare to Appendix A List with Compare to Appendix A List with
Threshold Quantities (TQ’s)Threshold Quantities (TQ’s)
39
Toxicity InformationToxicity Information
1910.119(d)(1)(i)1910.119(d)(1)(i)1910.119(d)(1)(i)1910.119(d)(1)(i)
40
The Requirements of the Standard - Develop Toxicity Information
The Requirements of the Standard - Develop Toxicity Information
Obtain Toxicity Obtain Toxicity Information on the Information on the Chemical(s) in the Chemical(s) in the ProcessProcess
MSDS are Typical MSDS are Typical ResourceResource
You May Need You May Need Other References, Other References, NIOSH Pocket NIOSH Pocket Guide, ACGIH TLV’sGuide, ACGIH TLV’s
Obtain Toxicity Obtain Toxicity Information on the Information on the Chemical(s) in the Chemical(s) in the ProcessProcess
MSDS are Typical MSDS are Typical ResourceResource
You May Need You May Need Other References, Other References, NIOSH Pocket NIOSH Pocket Guide, ACGIH TLV’sGuide, ACGIH TLV’s
41
Technology of the ProcessTechnology of the Process
1910.119(d)(2)1910.119(d)(2)1910.119(d)(2)1910.119(d)(2)
42
The Requirements of the Standard - Process Technology
The Requirements of the Standard - Process Technology
Block flow diagram Block flow diagram or process flow or process flow diagramdiagram
Process chemistryProcess chemistry Maximum intended Maximum intended
inventoryinventory Upper and lower Upper and lower
limitslimits Consequences of Consequences of
deviationsdeviations
Block flow diagram Block flow diagram or process flow or process flow diagramdiagram
Process chemistryProcess chemistry Maximum intended Maximum intended
inventoryinventory Upper and lower Upper and lower
limitslimits Consequences of Consequences of
deviationsdeviations43
The Requirements of the Standard - Process Equipment
The Requirements of the Standard - Process Equipment
Materials of Materials of constructionconstruction
Process and instrument Process and instrument drawings (P&ID’s)drawings (P&ID’s)
Electrical classificationElectrical classification Relief system designRelief system design Ventilation system Ventilation system
designdesign Design codesDesign codes Material and energy Material and energy
balancesbalances Safety systemsSafety systems
Materials of Materials of constructionconstruction
Process and instrument Process and instrument drawings (P&ID’s)drawings (P&ID’s)
Electrical classificationElectrical classification Relief system designRelief system design Ventilation system Ventilation system
designdesign Design codesDesign codes Material and energy Material and energy
balancesbalances Safety systemsSafety systems
44
Equipment in the Process Equipment in the Process
1910.119(d)(3)1910.119(d)(3)1910.119(d)(3)1910.119(d)(3)
45
The Requirements of the Standard - Process Equipment
The Requirements of the Standard - Process Equipment
Now:Now: Identify Each Piece of Identify Each Piece of
Equipment in the Equipment in the Covered Process by Covered Process by P&ID, Block Diagram P&ID, Block Diagram and Number Themand Number Them
Remember - Must Remember - Must Follow Form Follow Form
Must be Able to Track Must be Able to Track Each Number Through Each Number Through the Entire Programthe Entire Program
Now:Now: Identify Each Piece of Identify Each Piece of
Equipment in the Equipment in the Covered Process by Covered Process by P&ID, Block Diagram P&ID, Block Diagram and Number Themand Number Them
Remember - Must Remember - Must Follow Form Follow Form
Must be Able to Track Must be Able to Track Each Number Through Each Number Through the Entire Programthe Entire Program
46
Mechanical IntegrityMechanical Integrity
1910.119(j)1910.119(j)1910.119(j)1910.119(j)
47
Mechanical Integrity CertificatesMust be Obtained for Each Element of the ProcessMust be Marked with Numbering System that Follows Form
Mechanical Integrity CertificatesMust be Obtained for Each Element of the ProcessMust be Marked with Numbering System that Follows Form
The Requirements of the Standard - Process Equipment
The Requirements of the Standard - Process Equipment
48
Process Hazard Analysis (PHA)
Process Hazard Analysis (PHA)
1910.119(e)1910.119(e)1910.119(e)1910.119(e)
49
Process Hazard Analysis (PHA’s)Process Hazard Analysis (PHA’s)
Arguably the Most Difficult Part of Arguably the Most Difficult Part of Performing the StandardPerforming the Standard
PHA process is dynamic and subject to PHA process is dynamic and subject to revision whenever changes are maderevision whenever changes are made
Performed by Your PSM TeamPerformed by Your PSM TeamTakes Significant Time & EffortTakes Significant Time & EffortPHA’s are Never EndingPHA’s are Never Ending
Arguably the Most Difficult Part of Arguably the Most Difficult Part of Performing the StandardPerforming the Standard
PHA process is dynamic and subject to PHA process is dynamic and subject to revision whenever changes are maderevision whenever changes are made
Performed by Your PSM TeamPerformed by Your PSM TeamTakes Significant Time & EffortTakes Significant Time & EffortPHA’s are Never EndingPHA’s are Never Ending
50
Process Hazard AnalysisProcess Hazard Analysis
A PHA Process Must be Performed on Each Element of the Covered Process:A PHA From Block Diagram to P&ID to Every Equipment Component to Determine What Might Happen if an Element of the Covered Process Fails
A PHA Process Must be Performed on Each Element of the Covered Process:A PHA From Block Diagram to P&ID to Every Equipment Component to Determine What Might Happen if an Element of the Covered Process Fails
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There is Much More to PSMThere is Much More to PSM Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance Management of ChangeManagement of Change Operating ProceduresOperating Procedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & ResponseEmergency Planning & Response Incident InvestigationIncident Investigation Compliance AuditsCompliance Audits Trade SecretsTrade Secrets
Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance Management of ChangeManagement of Change Operating ProceduresOperating Procedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & ResponseEmergency Planning & Response Incident InvestigationIncident Investigation Compliance AuditsCompliance Audits Trade SecretsTrade Secrets
52
Management of ChangeManagement of Change
Procedures to manage changes to the Procedures to manage changes to the covered process.covered process. Exception: “replacement in kind”Exception: “replacement in kind”
Management of Change includes:Management of Change includes: Process chemicalsProcess chemicals TechnologyTechnology EquipmentEquipment Operating ProceduresOperating Procedures FacilitiesFacilities
Procedures to manage changes to the Procedures to manage changes to the covered process.covered process. Exception: “replacement in kind”Exception: “replacement in kind”
Management of Change includes:Management of Change includes: Process chemicalsProcess chemicals TechnologyTechnology EquipmentEquipment Operating ProceduresOperating Procedures FacilitiesFacilities
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Management of Change AddressesManagement of Change Addresses
1.1. Technical basis of the changeTechnical basis of the change2.2. Impact to employee safety and healthImpact to employee safety and health3.3. Modification to operating proceduresModification to operating procedures4.4. Time period for changeTime period for change5.5. Authorization of changeAuthorization of change
1.1. Technical basis of the changeTechnical basis of the change2.2. Impact to employee safety and healthImpact to employee safety and health3.3. Modification to operating proceduresModification to operating procedures4.4. Time period for changeTime period for change5.5. Authorization of changeAuthorization of change
54
Operating ProceduresOperating ProceduresDevelop and implement written Develop and implement written
operating procedures that are clear operating procedures that are clear instructions for all expected phases of instructions for all expected phases of operations.operations.
AKA – Standard Operating Procedures AKA – Standard Operating Procedures (SOPs) (SOPs)
Must cover:Must cover: Operation phaseOperation phase Operational limitsOperational limits Safety & health considerationsSafety & health considerations
Develop and implement written Develop and implement written operating procedures that are clear operating procedures that are clear instructions for all expected phases of instructions for all expected phases of operations.operations.
AKA – Standard Operating Procedures AKA – Standard Operating Procedures (SOPs) (SOPs)
Must cover:Must cover: Operation phaseOperation phase Operational limitsOperational limits Safety & health considerationsSafety & health considerations
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OPs Must AddressOPs Must Address Initial start-upInitial start-upNormal operationsNormal operationsTemporary operationsTemporary operationsEmergency shutdownEmergency shutdownEmergency operationsEmergency operationsNormal shutdownNormal shutdownStart-up following turnaroundStart-up following turnaroundConsequences of deviationConsequences of deviationSteps required to correct or avoid deviationSteps required to correct or avoid deviation
Initial start-upInitial start-upNormal operationsNormal operationsTemporary operationsTemporary operationsEmergency shutdownEmergency shutdownEmergency operationsEmergency operationsNormal shutdownNormal shutdownStart-up following turnaroundStart-up following turnaroundConsequences of deviationConsequences of deviationSteps required to correct or avoid deviationSteps required to correct or avoid deviation
56
SOPsSOPsMust be readily available to employeesMust be readily available to employeesMust be reviewed as needed to ensure Must be reviewed as needed to ensure
they reflect current operating practicce.they reflect current operating practicce.Must cover:Must cover:
Process chemicalsProcess chemicals Technology and equipmentTechnology and equipment FacilitiesFacilities
SOPs must be certified annually that SOPs must be certified annually that they are correct and accurate.they are correct and accurate.
Must be readily available to employeesMust be readily available to employeesMust be reviewed as needed to ensure Must be reviewed as needed to ensure
they reflect current operating practicce.they reflect current operating practicce.Must cover:Must cover:
Process chemicalsProcess chemicals Technology and equipmentTechnology and equipment FacilitiesFacilities
SOPs must be certified annually that SOPs must be certified annually that they are correct and accurate.they are correct and accurate.
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Safe Work Practices (SWPs)Safe Work Practices (SWPs)Must be developed and implemented to Must be developed and implemented to
provide for the control of hazards during provide for the control of hazards during work activities such as:work activities such as: Lock-out/Tag-outLock-out/Tag-out Confined space entryConfined space entry Opening processes, piping or equipmentOpening processes, piping or equipment
Must be developed and implemented to Must be developed and implemented to provide for the control of hazards during provide for the control of hazards during work activities such as:work activities such as: Lock-out/Tag-outLock-out/Tag-out Confined space entryConfined space entry Opening processes, piping or equipmentOpening processes, piping or equipment
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TrainingTrainingPSM specific training is requiredPSM specific training is required
Must cover:Must cover: Safety and health hazards associated with Safety and health hazards associated with
the covered processthe covered process Safe work practicesSafe work practices
Refresher training is required every 3 Refresher training is required every 3 years or as needed to ensure years or as needed to ensure employees are complying with all PSM employees are complying with all PSM requirementsrequirements
PSM specific training is requiredPSM specific training is required
Must cover:Must cover: Safety and health hazards associated with Safety and health hazards associated with
the covered processthe covered process Safe work practicesSafe work practices
Refresher training is required every 3 Refresher training is required every 3 years or as needed to ensure years or as needed to ensure employees are complying with all PSM employees are complying with all PSM requirementsrequirements
59
ContractorsContractorsContractors involved in or around a Contractors involved in or around a
covered process must be informed of covered process must be informed of required PSM elements.required PSM elements.
Contract work includes:Contract work includes: Maintenance and repairMaintenance and repair Turn aroundTurn around Major renovationsMajor renovations Specialty knowledge or servicesSpecialty knowledge or services
Does not include support services not Does not include support services not involved with the covered process, like involved with the covered process, like laundry or vending machine supplylaundry or vending machine supply
Contractors involved in or around a Contractors involved in or around a covered process must be informed of covered process must be informed of required PSM elements.required PSM elements.
Contract work includes:Contract work includes: Maintenance and repairMaintenance and repair Turn aroundTurn around Major renovationsMajor renovations Specialty knowledge or servicesSpecialty knowledge or services
Does not include support services not Does not include support services not involved with the covered process, like involved with the covered process, like laundry or vending machine supplylaundry or vending machine supply
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Emergency Action Plans (EAP)Emergency Action Plans (EAP)Must have EAP for entire facilityMust have EAP for entire facilityEAP must have provisions for small EAP must have provisions for small
releases of HHCsreleases of HHCsDevelop a Early Warning Method for Develop a Early Warning Method for
Releases Releases Train on the Meaning of the AlarmsTrain on the Meaning of the AlarmsDevelop Emergency Evacuation Written Develop Emergency Evacuation Written
Plans, Evacuation Maps & Assembly Plans, Evacuation Maps & Assembly PointsPoints
Must have EAP for entire facilityMust have EAP for entire facilityEAP must have provisions for small EAP must have provisions for small
releases of HHCsreleases of HHCsDevelop a Early Warning Method for Develop a Early Warning Method for
Releases Releases Train on the Meaning of the AlarmsTrain on the Meaning of the AlarmsDevelop Emergency Evacuation Written Develop Emergency Evacuation Written
Plans, Evacuation Maps & Assembly Plans, Evacuation Maps & Assembly PointsPoints
61
Incident InvestigationsIncident Investigations
Must be initiated ASAP, but within 48 Must be initiated ASAP, but within 48 hourshours
Team must include:Team must include: Person knowledgeable in the process Person knowledgeable in the process
involvedinvolved Includes contractor if work of the contractor Includes contractor if work of the contractor
involvedinvolved Other persons with appropriate knowledge Other persons with appropriate knowledge
of the covered processof the covered process
Must be initiated ASAP, but within 48 Must be initiated ASAP, but within 48 hourshours
Team must include:Team must include: Person knowledgeable in the process Person knowledgeable in the process
involvedinvolved Includes contractor if work of the contractor Includes contractor if work of the contractor
involvedinvolved Other persons with appropriate knowledge Other persons with appropriate knowledge
of the covered processof the covered process
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Incident Investigation ReportIncident Investigation ReportReport must be produced with the following:Report must be produced with the following:
Date of incidentDate of incident Date of start of investigationDate of start of investigation Description of incidentDescription of incident Factors contributing to incidentFactors contributing to incident RecommendationsRecommendations
System must be established to promptly address System must be established to promptly address recommendations and findings of reportrecommendations and findings of report
Resolutions and corrective action must be Resolutions and corrective action must be documenteddocumented
Report must be produced with the following:Report must be produced with the following: Date of incidentDate of incident Date of start of investigationDate of start of investigation Description of incidentDescription of incident Factors contributing to incidentFactors contributing to incident RecommendationsRecommendations
System must be established to promptly address System must be established to promptly address recommendations and findings of reportrecommendations and findings of report
Resolutions and corrective action must be Resolutions and corrective action must be documenteddocumented
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Compliance AuditCompliance AuditTo ensure that PSM is effective, employers To ensure that PSM is effective, employers
must certify every 3 years that they have must certify every 3 years that they have evaluated compliance with the standardevaluated compliance with the standard
Must be completed by at least on person Must be completed by at least on person knowledgeable in the processknowledgeable in the process
Report must be developed and documentedReport must be developed and documentedDeficiency corrections must be documentedDeficiency corrections must be documentedLast two compliance audits must be kept on Last two compliance audits must be kept on
filefile
To ensure that PSM is effective, employers To ensure that PSM is effective, employers must certify every 3 years that they have must certify every 3 years that they have evaluated compliance with the standardevaluated compliance with the standard
Must be completed by at least on person Must be completed by at least on person knowledgeable in the processknowledgeable in the process
Report must be developed and documentedReport must be developed and documentedDeficiency corrections must be documentedDeficiency corrections must be documentedLast two compliance audits must be kept on Last two compliance audits must be kept on
filefile64
Trade SecretsTrade SecretsEmployers must make all necessary Employers must make all necessary
information required to comply with information required to comply with PSM, regardless of trade secrets, PSM, regardless of trade secrets, available to persons involved in available to persons involved in developing or creating:developing or creating: Compiling process safety informationCompiling process safety information PHAsPHAs SOPsSOPs Incident investigationsIncident investigations Emergency planning and responseEmergency planning and response Compliance auditsCompliance audits
Confidentiality agreements are allowedConfidentiality agreements are allowed
Employers must make all necessary Employers must make all necessary information required to comply with information required to comply with PSM, regardless of trade secrets, PSM, regardless of trade secrets, available to persons involved in available to persons involved in developing or creating:developing or creating: Compiling process safety informationCompiling process safety information PHAsPHAs SOPsSOPs Incident investigationsIncident investigations Emergency planning and responseEmergency planning and response Compliance auditsCompliance audits
Confidentiality agreements are allowedConfidentiality agreements are allowed 65
BP Texas City Refinery Case Study in PSMBP Texas City Refinery Case Study in PSM
The third largest petroleum refinery in the The third largest petroleum refinery in the United States with a refining capacity of United States with a refining capacity of 475,000 barrels of crude per day.475,000 barrels of crude per day.
Located on a 1,200-acre facility in Texas City, Located on a 1,200-acre facility in Texas City, Texas southeast of Houston in Galveston Texas southeast of Houston in Galveston County.County.
1,200 permanent BP employees and 1,200 permanent BP employees and hundreds of additional contractors at the hundreds of additional contractors at the facilityfacility
The third largest petroleum refinery in the The third largest petroleum refinery in the United States with a refining capacity of United States with a refining capacity of 475,000 barrels of crude per day.475,000 barrels of crude per day.
Located on a 1,200-acre facility in Texas City, Located on a 1,200-acre facility in Texas City, Texas southeast of Houston in Galveston Texas southeast of Houston in Galveston County.County.
1,200 permanent BP employees and 1,200 permanent BP employees and hundreds of additional contractors at the hundreds of additional contractors at the facilityfacility
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Anatomy of a Disaster- BP Texas CityAnatomy of a Disaster- BP Texas City
Things to Think About:Things to Think About: What went wrong?What went wrong? What went right?What went right? What could/should have been done to What could/should have been done to
prevent this disaster?prevent this disaster?
Things to Think About:Things to Think About: What went wrong?What went wrong? What went right?What went right? What could/should have been done to What could/should have been done to
prevent this disaster?prevent this disaster?
67
BP Texas City Refinery Case Study in PSMBP Texas City Refinery Case Study in PSM
Fact Sheet on BP 2009 Monitoring I nspection The U.S. Department of Labor's Occupational Safety and Health Administration (OSHA) has proposed $87,430,000 in propose penalties against BP Products North America, Inc. for 709 alleged failures to comply with the 2005 settlement agreement and citations, and violations of safety and health standards identified during the agency's inspection of the corporation's refinery in Texas City, TX (BPTCR). The inspection of the refinery was conducted from May through October 2009. BP Texas City Refinery (BPTCR):
The third largest petroleum refinery in the United States with a refining capacity of 475,000 barrels of crude per day.
Located on a 1,200-acre facility in Texas City, Texas southeast of Houston in Galveston County.
1,200 permanent BP employees and hundreds of additional contractors at the facility
Prior History at BPTCR:
On March 23, 2005, an explosion and fire in the I somerization Unit of the BP Texas City Refinery (BPTCR) resulted in the death of 15 contractor employees and injury of at least 170 other BP employees and contractors.
OSHA initiated safety and health inspections into the March 2005 incident and issued citations and fines totaling over $21 million, the highest penalty that OSHA had ever issued.
The Report of the BP U.S. Refineries Independent Safety Review Panel (aka Baker Report) issued in J anuary 2007 identified a number of systemic process safety issues at BP refineries in the U.S.
March 2007, U.S. Chemical Safety and Hazard Investigation Board (CSB) released its report Refinery Explosion and Fire (15 Killed, 180 Injured). CSB found, "The Texas City disaster was caused by organizational and safety deficiencies at all levels of the BP Corporation".
OSHA has conducted 17 separate inspections at the refinery in the last 4 years.
Prior to the 2005 incident, two employees of BPTCR died due to a breakdown of the company’s lockout and tagout program.
Since the 2005 incident, four more fatal incidents have occurred at the facility, involving one BPTCR employee and 3 contractors.
2005 Settlement Agreement
As a result of the March 2005 explosion and subsequent inspection, BP entered into a settlement agreement with OSHA in September 2005
BP agreed to pay $21 million in penalties
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JORDAN BARABDeputy Assistant SecretaryJORDAN BARABDeputy Assistant SecretaryAfter BP-Texas City, Have We Learned Anything?After BP-Texas City, Have We Learned Anything? Now, in spite of your efforts, we have to acknowledge that Now, in spite of your efforts, we have to acknowledge that
something is desperately wrong. The status quo isn't working. something is desperately wrong. The status quo isn't working. In the past three months alone, In the past three months alone, 58 workers have died58 workers have died in in
explosions, fires and collapses at refineries, coal mines, an explosions, fires and collapses at refineries, coal mines, an oil drilling rig, and a natural-gas-fired power plant construction oil drilling rig, and a natural-gas-fired power plant construction site.site.
OSHA is particularly concerned about the recent number of OSHA is particularly concerned about the recent number of serious incidents at refineries that have scalded, burned or serious incidents at refineries that have scalded, burned or struck down your fellow workers. We are tracking these struck down your fellow workers. We are tracking these catastrophes and looking for trends -- including problems catastrophes and looking for trends -- including problems resulting from aging facilities. Since the BP Texas City resulting from aging facilities. Since the BP Texas City explosion in 2005, OSHA has counted over explosion in 2005, OSHA has counted over 20 serious 20 serious incidents in refineriesincidents in refineries across the country. across the country.
After BP-Texas City, Have We Learned Anything?After BP-Texas City, Have We Learned Anything? Now, in spite of your efforts, we have to acknowledge that Now, in spite of your efforts, we have to acknowledge that
something is desperately wrong. The status quo isn't working. something is desperately wrong. The status quo isn't working. In the past three months alone, In the past three months alone, 58 workers have died58 workers have died in in
explosions, fires and collapses at refineries, coal mines, an explosions, fires and collapses at refineries, coal mines, an oil drilling rig, and a natural-gas-fired power plant construction oil drilling rig, and a natural-gas-fired power plant construction site.site.
OSHA is particularly concerned about the recent number of OSHA is particularly concerned about the recent number of serious incidents at refineries that have scalded, burned or serious incidents at refineries that have scalded, burned or struck down your fellow workers. We are tracking these struck down your fellow workers. We are tracking these catastrophes and looking for trends -- including problems catastrophes and looking for trends -- including problems resulting from aging facilities. Since the BP Texas City resulting from aging facilities. Since the BP Texas City explosion in 2005, OSHA has counted over explosion in 2005, OSHA has counted over 20 serious 20 serious incidents in refineriesincidents in refineries across the country. across the country.
69
There is Much More to PSMThere is Much More to PSM
Now, The OSHA PSM National Emphasis Now, The OSHA PSM National Emphasis Program for Refineries & Chemical Program for Refineries & Chemical
Facilities & Facilities & Severe Violator Severe Violator Enforcement Program (SVEP)Enforcement Program (SVEP)
Now, The OSHA PSM National Emphasis Now, The OSHA PSM National Emphasis Program for Refineries & Chemical Program for Refineries & Chemical
Facilities & Facilities & Severe Violator Severe Violator Enforcement Program (SVEP)Enforcement Program (SVEP)
70
OSHA National Emphasis Program (NEP) for Refineries & Chemical Facilities
OSHA National Emphasis Program (NEP) for Refineries & Chemical Facilities
Petroleum Petroleum Refineries NEPRefineries NEP Issued August Issued August
20092009Chemical Facilities Chemical Facilities
NEPNEP Issued July 2010Issued July 2010
Petroleum Petroleum Refineries NEPRefineries NEP Issued August Issued August
20092009Chemical Facilities Chemical Facilities
NEPNEP Issued July 2010Issued July 2010
71
Typical Standards CitedTypical Standards Cited
1910.119 1910.119 PSM – 249 violationsPSM – 249 violations 1910.147 1910.147 Lock and Tag - 20Lock and Tag - 20 1910.120 1910.120 Hazwoper - 19Hazwoper - 19 1910.1200 1910.1200 Hazcom - 12Hazcom - 12 1910.146 1910.146 Confined Space - 11Confined Space - 11 5A.001 5A.001 General Duty - 9General Duty - 9 1910.307 1910.307 Hazardous Locations - 7Hazardous Locations - 7
1910.119 1910.119 PSM – 249 violationsPSM – 249 violations 1910.147 1910.147 Lock and Tag - 20Lock and Tag - 20 1910.120 1910.120 Hazwoper - 19Hazwoper - 19 1910.1200 1910.1200 Hazcom - 12Hazcom - 12 1910.146 1910.146 Confined Space - 11Confined Space - 11 5A.001 5A.001 General Duty - 9General Duty - 9 1910.307 1910.307 Hazardous Locations - 7Hazardous Locations - 7
72
Most Frequent NEP PSM CitationsMost Frequent NEP PSM Citations
(f)(1) Operating procedures…………..38(f)(1) Operating procedures…………..38
(d)(3) PSI pertaining to equipment ….28(d)(3) PSI pertaining to equipment ….28
(e)(3) PHA specific criteria……………26(e)(3) PHA specific criteria……………26
(j)(4) MI Inspection & Testing ………..21(j)(4) MI Inspection & Testing ………..21
(e)(5) PHA recommendation ...………12(e)(5) PHA recommendation ...………12
(l)(1) MOC implementation …………..12(l)(1) MOC implementation …………..12
(f)(1) Operating procedures…………..38(f)(1) Operating procedures…………..38
(d)(3) PSI pertaining to equipment ….28(d)(3) PSI pertaining to equipment ….28
(e)(3) PHA specific criteria……………26(e)(3) PHA specific criteria……………26
(j)(4) MI Inspection & Testing ………..21(j)(4) MI Inspection & Testing ………..21
(e)(5) PHA recommendation ...………12(e)(5) PHA recommendation ...………12
(l)(1) MOC implementation …………..12(l)(1) MOC implementation …………..12
1910.119
73
Severe Violator Enforcement Program (SVEP)Severe Violator Enforcement Program (SVEP)
This Instruction establishes enforcement This Instruction establishes enforcement policies and procedures for OSHA's Severe policies and procedures for OSHA's Severe Violator Enforcement Program (SVEP), which Violator Enforcement Program (SVEP), which concentrates resources on inspecting concentrates resources on inspecting employers who have demonstrated employers who have demonstrated indifference to their OSH Actindifference to their OSH Act obligations by obligations by willful, repeated, or failure-to-abate violations. willful, repeated, or failure-to-abate violations. This Instruction replaces OSHA's Enhanced This Instruction replaces OSHA's Enhanced Enforcement Program (EEP).Enforcement Program (EEP).
This Instruction establishes enforcement This Instruction establishes enforcement policies and procedures for OSHA's Severe policies and procedures for OSHA's Severe Violator Enforcement Program (SVEP), which Violator Enforcement Program (SVEP), which concentrates resources on inspecting concentrates resources on inspecting employers who have demonstrated employers who have demonstrated indifference to their OSH Actindifference to their OSH Act obligations by obligations by willful, repeated, or failure-to-abate violations. willful, repeated, or failure-to-abate violations. This Instruction replaces OSHA's Enhanced This Instruction replaces OSHA's Enhanced Enforcement Program (EEP).Enforcement Program (EEP).
74
Severe Violator Enforcement Program (SVEP)Severe Violator Enforcement Program (SVEP)
References:References:
OSHA Instruction CPL 03-00-010, Petroleum OSHA Instruction CPL 03-00-010, Petroleum Refinery Process Safety Management Refinery Process Safety Management National Emphasis Program, August 18, 2009National Emphasis Program, August 18, 2009
References:References:
OSHA Instruction CPL 03-00-010, Petroleum OSHA Instruction CPL 03-00-010, Petroleum Refinery Process Safety Management Refinery Process Safety Management National Emphasis Program, August 18, 2009National Emphasis Program, August 18, 2009
75
Severe Violator Enforcement Program (SVEP)Severe Violator Enforcement Program (SVEP) Enhanced Follow-up InspectionsEnhanced Follow-up Inspections Nationwide Inspections of Related Nationwide Inspections of Related
Workplaces/WorksitesWorkplaces/Worksites Increased Company Awareness of OSHA Increased Company Awareness of OSHA
EnforcementEnforcement Enhanced Settlement ProvisionsEnhanced Settlement Provisions Federal Court Enforcement under Section 11(b) Federal Court Enforcement under Section 11(b)
of the OSH Actof the OSH Act
Bottom Line: OSHA is Serious Bottom Line: OSHA is Serious AboutAbout
Compliance and Enforcement of Compliance and Enforcement of PSMPSM
Enhanced Follow-up InspectionsEnhanced Follow-up Inspections Nationwide Inspections of Related Nationwide Inspections of Related
Workplaces/WorksitesWorkplaces/Worksites Increased Company Awareness of OSHA Increased Company Awareness of OSHA
EnforcementEnforcement Enhanced Settlement ProvisionsEnhanced Settlement Provisions Federal Court Enforcement under Section 11(b) Federal Court Enforcement under Section 11(b)
of the OSH Actof the OSH Act
Bottom Line: OSHA is Serious Bottom Line: OSHA is Serious AboutAbout
Compliance and Enforcement of Compliance and Enforcement of PSMPSM 76
EPA Risk Management Plans (RMP) Basics
EPA Risk Management Plans (RMP) Basics
CAA 112(r)CAA 112(r)CAA 112(r)CAA 112(r)
77
One More Thing to Discuss…EPA Risk Management Plans(RMP)
One More Thing to Discuss…EPA Risk Management Plans(RMP)
Many Times Companies Who Must Comply Many Times Companies Who Must Comply with PSM, must also Comply with the with PSM, must also Comply with the Requirements of EPA Risk Management Requirements of EPA Risk Management Plans (RMP)Plans (RMP)
The RMP Standard was to be a Mirror of the The RMP Standard was to be a Mirror of the PSM Standard…Didn’t happen!PSM Standard…Didn’t happen!
Remember…PSM Protects the Workforce, Remember…PSM Protects the Workforce, RMP Protects the CommunityRMP Protects the Community
Many Times Companies Who Must Comply Many Times Companies Who Must Comply with PSM, must also Comply with the with PSM, must also Comply with the Requirements of EPA Risk Management Requirements of EPA Risk Management Plans (RMP)Plans (RMP)
The RMP Standard was to be a Mirror of the The RMP Standard was to be a Mirror of the PSM Standard…Didn’t happen!PSM Standard…Didn’t happen!
Remember…PSM Protects the Workforce, Remember…PSM Protects the Workforce, RMP Protects the CommunityRMP Protects the Community
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EPA RMPEPA RMP
Basic RequirementsBasic Requirements Executive summaryExecutive summary RegistrationRegistration Off-site consequence analysisOff-site consequence analysis Five-year accident historyFive-year accident history Emergency response planEmergency response plan Prevention program summary informationPrevention program summary information CertificationCertification
Basic RequirementsBasic Requirements Executive summaryExecutive summary RegistrationRegistration Off-site consequence analysisOff-site consequence analysis Five-year accident historyFive-year accident history Emergency response planEmergency response plan Prevention program summary informationPrevention program summary information CertificationCertification
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All Public Facilities in this Release Plume Must be Identified & Surveyed
Release Plume
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OSHA PSM SummaryOSHA PSM Summary
PSM is a Comprehensive, Difficult StandardPSM is a Comprehensive, Difficult Standard Although it was Promulgated in 1991, Although it was Promulgated in 1991,
Catastrophes Continue to OccurCatastrophes Continue to Occur Recognizing these Facts, OSHA has Recognizing these Facts, OSHA has
Developed a National Emphasis Program for Developed a National Emphasis Program for Refineries and Chemical ManufacturersRefineries and Chemical Manufacturers
More Emphasis Planned for all PSM SitesMore Emphasis Planned for all PSM Sites There is Much More Work to be Done…There is Much More Work to be Done… RMP Must Also be Considered for Many RMP Must Also be Considered for Many
FacilitiesFacilities
PSM is a Comprehensive, Difficult StandardPSM is a Comprehensive, Difficult Standard Although it was Promulgated in 1991, Although it was Promulgated in 1991,
Catastrophes Continue to OccurCatastrophes Continue to Occur Recognizing these Facts, OSHA has Recognizing these Facts, OSHA has
Developed a National Emphasis Program for Developed a National Emphasis Program for Refineries and Chemical ManufacturersRefineries and Chemical Manufacturers
More Emphasis Planned for all PSM SitesMore Emphasis Planned for all PSM Sites There is Much More Work to be Done…There is Much More Work to be Done… RMP Must Also be Considered for Many RMP Must Also be Considered for Many
FacilitiesFacilities
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Tools for Additional PSM AssistanceTools for Additional PSM Assistance
PSM ChecklistPSM Checklist www.oshainfo.gatech.eduwww.oshainfo.gatech.edu
OSHA WebsiteOSHA Website www.osha.govwww.osha.gov
Chemical Safety Board WebsiteChemical Safety Board Website www.csb.govwww.csb.gov
PSM ChecklistPSM Checklist www.oshainfo.gatech.eduwww.oshainfo.gatech.edu
OSHA WebsiteOSHA Website www.osha.govwww.osha.gov
Chemical Safety Board WebsiteChemical Safety Board Website www.csb.govwww.csb.gov
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PSM Checklist
Use this checklist to help determine employer compliance with the Process Safety Management Standard issued by the Occupational Safety and Health Administration. Please note that the checklist does not include all of the standard’s requirements and does not reflect all OSHA letters of interpretation or compliance directives in particular situations. There are 3 elements to a review of a PSM program:
1. Documentation review – examination of the documentation of the programs required by the standard. 2. Field Inspection & Verification – examination of the physical covered process; its equipment, piping,
instrumentation, procedures, and operation. 3. Interviews – discussions with employees and contractors to determine if the implemented program matches the
program outlined in the documentation. In order to gather the information needed to audit a PSM program the following questions need to be asked for each PSM program element
Who What When Where Why How
Who – Who is responsible for developing and implementing each of the program elements? What – What are the requirements and contents of each program element? When – When are the required actions for each element completed and when were they required to be
completed? Where – Where have actions been implemented or changed? Why – Why have the implementation decisions and priorities been made as recorded in the documentation? How – How is the program implemented and how is the program’s effectiveness evaluated and improved?
An essential part of verifying program implementation is to audit the flow of information and activities among the elements. When information in one element is changed or when action takes place in one element that affects other elements, an auditor/reviewer should examine a sample of the related elements to see if the appropriate changes and followup actions have taken place. The following example demonstrates the interrelationship among the elements: During a routine inspection of equipment (Mechanical Integrity), the maintenance worker discovers a valve that no longer meets the applicable code and must be changed. Because the type of valve is no longer made, a different type of valve must be selected and installed (Management of Change). The type of valve selected may mandate different steps for the operators (Operating Procedures) who will require training and verification in the new procedures (Training). The rationale for selecting the type of valve must be made available for review by employees and their representatives (Employee Participation). When the new valve is installed by the supplier (Contractors), a qualified and safe contractor must be selected to perform the work (Contractor Management). The work will involve shutting down part of the process (Pre-startup Safety Review) as well as brazing some of the lines (Safe Work Practices - Hot Work Permit). The employer must review the response plan (Emergency Planning) to ensure that procedures are adequate for the installation hazards. Although Management of Change provisions cover interim changes, after the new valve is in place the Process Safety Information will have to be updated before the (Process Hazard Analysis) is updated or revalidated, to account for potential hazards associated with the new equipment. Also, inspection and maintenance procedures and training will need to be updated (Mechanical Integrity). In summary, 12 PSM elements can be affected by changing one valve. A reviewer/inspector/auditor/compliance officer would check a representative number of these 11 elements to confirm that the required follow-up activities have been implemented for the new valve.
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For More InformationFor More Information
www.psmtraining.comwww.psmtraining.com
www.oshainfo.gatech.eduwww.oshainfo.gatech.edu
www.pe.gatech.edu/safetywww.pe.gatech.edu/safety
www.psmtraining.comwww.psmtraining.com
www.oshainfo.gatech.eduwww.oshainfo.gatech.edu
www.pe.gatech.edu/safetywww.pe.gatech.edu/safety
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Contact InformationContact InformationMichelle Dunham, MSPH, MSMMichelle Dunham, MSPH, MSM
[email protected]@gtri.gatech.edu 404-407-8284404-407-8284
Bob HendryBob Hendry [email protected]@gtri.gatech.edu
Art Wickman, CIHArt Wickman, CIH [email protected]@gtri.gatech.edu
Georgia Tech Occupational Safety & Health ProgramGeorgia Tech Occupational Safety & Health Program www.oshainfo.gatech.eduwww.oshainfo.gatech.edu
Michelle Dunham, MSPH, MSMMichelle Dunham, MSPH, MSM [email protected]@gtri.gatech.edu 404-407-8284404-407-8284
Bob HendryBob Hendry [email protected]@gtri.gatech.edu
Art Wickman, CIHArt Wickman, CIH [email protected]@gtri.gatech.edu
Georgia Tech Occupational Safety & Health ProgramGeorgia Tech Occupational Safety & Health Program www.oshainfo.gatech.eduwww.oshainfo.gatech.edu
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FundingFundingFunding for:Funding for:
Process Safety Management of Highly Process Safety Management of Highly Hazardous and Explosive Chemicals: Hazardous and Explosive Chemicals: Simple Keys to ComplianceSimple Keys to Compliance
By special funding from the Occupational By special funding from the Occupational Safety and Health AdministrationSafety and Health Administration
Funding for:Funding for:
Process Safety Management of Highly Process Safety Management of Highly Hazardous and Explosive Chemicals: Hazardous and Explosive Chemicals: Simple Keys to ComplianceSimple Keys to Compliance
By special funding from the Occupational By special funding from the Occupational Safety and Health AdministrationSafety and Health Administration
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