Process Safety Management
_________________
(FACILITY NAME)
Introduction
This Program has been developed for the (TYPE IN THE PROCESS
THAT THIS PSM PROGRAM COVERS) at (NAME OF FACILITY) to meet the
requirements of OSHA Standard 29 CFR 1910.119 Process Safety
Management of Highly Hazardous Substances (PSM). Additional
program requirements have been taken from applicable ANSI &
(List Sources of Standards used in your Industry such as IIAR)
Standards.
Responsibilities
Facility Management
- assign sufficient resources and qualified operators to ensure
safe operating and material conditions are maintained
- assign a qualified supervisor to oversee and direct (Type in
the PROCESS COVERED IN THIS PROGRAM) operations, maintenance and
training
- involve (Type in the PROCESS COVERED IN THIS PROGRAM)
operators in the various elements of this program
- request, as necessary, assistance from Company Engineering to
execute the PSM Program and conduct effective audits
(Type in the PROCESS COVERED IN
THIS PROGRAM) Manager
- train all (Type in the PROCESS COVERED IN THIS PROGRAM)
operators in hazards of the (Type in the PROCESS COVERED IN THIS
PROGRAM) process, safe operating procedures, and good engineering
practices
- assign tasks based on operators level of knowledge
- monitor maintenance and operations activities to ensure they
comply with good engineering practice
- ensure contractors are provided the information required by
this program
- document the information, activities, inspections, etc
required by this program
(Type in the PROCESS COVERED IN
THIS PROGRAM) Operators
- actively participate in the PSM program
- exercise good engineering practices in the operation and
maintenance of the (Type in the PROCESS COVERED IN THIS PROGRAM)
systems
- comply with all safety procedures
Human Resource Manager
- Provide PSM overview indoctrination training for all new
employees as part of the New Hire Safety Orientation training.
PSM Elements
The PSM Standard contains 14 Elements that must be addressed
in this program.
- Employee Participation
- Process Safety Information (PSI)
- Process Hazard Analysis (PHA)
- Operating Procedures
- Training
- Contractor Safety
- Pre-Startup Safety Review
- Mechanical Integrity
- Hot Work Program
- Management of Change (MOC)
- Incident Investigation
- Emergency Planning and Response
- Compliance Audits
- Trade Secrets
Section 1: Employee
Participation
Requirements: The standard requires employers to:
- Develop a Plan of Action for implementation of Employee
Involvement
- Consult with employees on the conduct of the development of
PSM Elements
- Provide access to PSM information
Section 2: Process Safety
Information (PSI)
Requirements: the OSHA standard requires compiling of
technical information on the process and equipment in the (Type
in the PROCESS COVERED IN THIS PROGRAM) system. This requirement
is to allow for PHA and maintaining information on the system for
Operator training and reference.
- Hazards of (type in the Chemical covered in this program)
pertaining to the technology of the (Type in the PROCESS COVERED
IN THIS PROGRAM) system
- Information pertaining to the equipment in the process
- Documentation that equipment complies with recognized and
generally accepted good engineering practices.
Section 3: Process Hazard
Analysis
Requirements: An initial process hazard analysis must be
conducted by a team with expertise in engineering and process
operations, including at least one employee who has experience
and knowledge on the (Type in the PROCESS COVERED IN THIS
PROGRAM) system. Completion date for PHA was May 26, 1997.
- Establish a system to promptly address the team's findings
and recommendations
- Assure that the recommendations are resolved in a timely
manner
- Document resolutions
- Document what actions are to be taken
- Complete actions as soon as possible
- Develop a written schedule of when these actions are to be
completed; Communicate the actions to operating, maintenance
PHA review is required at least every five (5) to updated
and revalidate by a qualified to assure that the process hazard
analysis is consistent with the current process.
Identify previous incident which had a likely potential for
catastrophic consequences in the workplace
- Engineering and administrative controls
- Detection methods for providing early warning of releases
- Consequences of failure of engineering and administrative
controls
- Facility site
- Human factors
- Qualitative evaluation of a range of the possible safety and
health effects of failure of controls on employees
Section 4: Operating Procedures
Requirements: Develop and implement written operating
procedures that provide clear instructions for safely conducting
operations and maintenance. Operating procedures shall be readily
accessible to employees. The operating procedures shall be
reviewed as often as necessary to assure that they reflect
current operating practice. The employer shall certify annually
that these operating procedures are current and accurate.
Develop and implement safe work practices to provide for the
control of hazards during operations such as lockout/tagout;
confined space entry; opening process equipment or piping; and
control over entrance into a facility by maintenance, contractor,
laboratory, or other support personnel. These safe work practices
shall apply to employees and contractor employees.
- Initial startup
- Normal, temporary and emergency operations
- Normal shutdown
- Startup following a turnaround or after an emergency shutdown
- Operating limits
- Consequences of deviation & Steps required to correct or
avoid deviation.
- Safety and health considerations:
- Precautions necessary to prevent exposure, including
engineering controls
- Administrative controls, and personal protective equipment
- Control measures to be taken if physical contact or airborne
exposure occurs
- Quality control for raw materials and control of hazardous
chemical inventory levels
- Safety systems and their functions.
Section 5: Training
Initial training:Each operator must be trained in an
overview of the process and in the operating procedures. The
training shall include emphasis on the specific safety and health
hazards, emergency operations including shutdown, and safe work
practices applicable to the employee's job tasks.
For those employees already involved in operating a process on
May 26, 1992, an employer may certify in writing that the
employee has the required knowledge, skills, and abilities to
safely carry out the duties and responsibilities as specified in
the operating procedures.
Refresher training shall be provided at least every three
years, and more often if necessary, to each employee involved in
operating a process to assure that the employee understands and
adheres to the current operating procedures of the process. The
employer, in consultation with the employees involved in
operating the process, shall determine the appropriate frequency
of refresher training.
Training documentation. The employer shall ascertain that
each employee involved in operating a process has received and
understood the training required by this paragraph. The employer
shall prepare a record that contains the identity of the
employee, the date of training, and the means used to verify that
the employee understood the training.
Section 6: Contractors
- Obtain and evaluate information regarding the contract
employer's safety performance and programs
- contract employers of the known potential fire, explosion, or
toxic release hazards related to the contractor's work and the
process to contract employers the applicable provisions of the
emergency action plan
- Develop and implement safe work practices to control the
entrance, presence and exit of contract personnel
- evaluate the performance of contract employers in fulfilling
their obligations
- a contract employee injury and illness log related to the
contractor's work in process areas
Section 7: Pre-Startup Safety
Review
Requirements: Perform a pre-startup safety review for new
facilities and for modified facilities when the modification is
significant enough to require a change in the process safety
information. The purpose of the Pre-Startup Review is to confirm
that, prior to the introduction of highly hazardous chemicals to
a process:
- Construction and equipment is in accordance with design
specifications;
- Safety, operating, maintenance, and emergency procedures are
in place and are adequate
- Modified facilities meet the requirements contained in
Management of Change
- Training of each employee involved in operating a process has
been completed.
Section 8: Mechanical Integrity
Requirements: Establish and implement written procedures
to maintain the on-going integrity of (Type in the PROCESS
COVERED IN THIS PROGRAM) equipment. This includes:
- date
- name of the person performing T&I
- serial number or other identifier of the
- description of the inspection or test performed
- results
New Equipment. Assure that equipment as it is fabricated
is suitable for the process application for which they will be
used. Additionally, conduct appropriate checks and inspections to
assure that equipment is installed properly and consistent with
design specifications and the manufacturer's instructions.
Section 9: Hot Work
Requirements: The employer shall issue a hot work permit
for hot work operations conducted on or near a covered process.
The permit shall document that the fire prevention and protection
requirements in 29 CFR 1910.252(a) have been implemented prior to
beginning the hot work operations; it shall indicate the date(s)
authorized for hot work; and identify the object on which hot
work is to be performed. The permit shall be kept on file until
completion of the hot work operations.
Section 10: Management of
Change (MOC)
Requirements: Establish and implement written procedures
to manage changes (except for "replacements in kind")
to process chemicals, technology, equipment, and procedures; and,
changes to facilities that affect a covered process.
- The technical basis for the proposed change;
- Impact of change on safety and health;
- Modifications to operating procedures;
- Necessary time period for the change; and,
- Authorization requirements for the proposed change.
Section 11: Incident
Investigation
Investigate each incident that resulted in, or could
reasonably have resulted in a catastrophic release of highly
hazardous chemical in the workplace. An incident investigation
shall be initiated as promptly as possible, but not later than 48
hours following the incident.
Establish an incident investigation team which consists of
at least one person knowledgeable in the process involved,
including a contract employee if the incident involved work of
the contractor, and other persons with appropriate knowledge and
experience to thoroughly investigate and analyze the incident
Incident Reports: A report shall be prepared at the
conclusion of the investigation that includes at a minimum:
- Date of incident
- Date investigation began
- Description of the incident
- Factors that contributed to the incident
- Recommendations resulting from the investigation
Corrective Actions: Establish a system to promptly address
and resolve the incident report findings and recommendations.
Resolutions and corrective actions shall be documented
Report Review: The report shall be reviewed with all
affected personnel whose job tasks are relevant to the incident
findings including contract employees where applicable. Incident
investigation reports shall be retained for five years
Section 12: Emergency Planning
& Response
Establish and implement an emergency action plan for the
entire plant in accordance with the provisions of 29 CFR
1910.38(a). and 29 CFR 1910.120(a), (p) and (q). In addition, the
emergency action plan shall include procedures for handling small
releases.
Section 13: Compliance Audits
Requirements: Certify compliance with the provisions of
the PSM Standard at least every three years to verify that the
procedures and practices developed under the standard are
adequate and are being followed.
- The compliance audit shall be conducted by at least one
person knowledgeable in the process.
- A report of the findings of the audit shall be developed.
- Promptly determine and document an appropriate response to
each of the findings of the compliance audit, and document that
deficiencies have been corrected.
- Retain the two (2) most recent compliance audit reports.
Section 14: Trade Secrets
