Last Updated on April 29, 2024 by Ossian Muscad
If you’re running a process-driven business, it’s important to be aware of OSHA’s Process Safety Management Standard. PSM is a critical process for any organization that works with hazardous materials. The OSHA Process Safety Management Standard (29 CFR 1910.119) outlines specific requirements for organizations to follow to protect their employees from potential process hazards. This guide will discuss process safety management (PSM), why it’s important, and how to implement a PSM program. It will also show you how to create a Process Safety Management Checklist.
What is Process Safety Management?
Process Safety Management is a regulation by the Occupational Safety and Health Administration (OSHA). PSM applies to any process that uses Highly Hazardous Chemicals (HHCs). The regulation is designed to prevent process-related accidents, like fires, explosions, and toxic releases.
The Center for Chemical Process Safety (CCPS) outlines the properties or characteristics of HHCs:
Toxic Materials:
- Asphyxiants
- Carcinogens
- Neurotoxins
- Reproductive toxins
Flammable Materials:
- Flammable solids
- Flammable liquids
- Flammable gasses
Explosives:
- Blasting agents
- Pyrotechnics
- Detonators
Reactive Chemicals:
- Oxidizers
- Organic peroxides
- Unstable (reactive) organics
- Pyrophoric
- Water-reactive chemicals
To comply with PSM, organizations must have systems and procedures in place to manage process hazards. These hazards can come from the materials used in the process, the process itself, or the equipment involved. PSM requires organizations to identify and assess process hazards and implement controls to mitigate those hazards.
In addition, PSM requires organizations to develop and implement procedures for managing process changes. Changes to process equipment, chemicals, or operating conditions can all create new hazards.
Why is PSM Important?
The main reason why OSHA created PSM is the Phillips Disaster of 1989. In this accident, a process hazard led to a series of explosions and fires that killed 23 people and injured 132 more. The disaster also caused over $100 million in damage.
After the Phillips Disaster, OSHA conducted an investigation and found that process safety management could have prevented the accident. As a result, they created the PSM regulation to prevent future process-related accidents.
Since then, process safety management has become an essential part of a process-driven business. PSM can help organizations to avoid accidents, injuries, and fatalities. It can also help to protect equipment and minimize process downtime.
Since the Phillips Disaster, process safety management has been vital to running a process-driven business. PSM can help organizations create a safer work environment, avoid process-related accidents, and protect equipment.
What Falls Under the PSM Standard—and What Doesn’t?
According to OSHA statements, the process safety management standard applies to any process involving chemicals in quantities at or above the specified threshold numbers.
The process must also meet one or more of the following:
- Be flammable or combustible liquids or gasses;
- Be flammable or combustible dust;
- Present an atmospheric hazard (oxygen deficiency or enrichment);
- Be an oxidizer;
- Be pyrophoric (catalytically active in the presence of oxygen);
- Be unstable (reactive) organics;
- Be water reactive; or
- Perform a process hazard analysis for it.
The 14 Process Safety Management Elements
An employer must develop and implement a process safety plan to meet the process safety management standard. The plan must address each of the 14 elements required by OSHA. These elements are as follows:
- Process Safety Information: Collect and record process safety information on three aspects of the process: process chemicals, equipment, and technology.
- Operating Procedures: Develop and document process-specific operating procedures.
- Process Hazard Analysis: Conduct a process hazard analysis (PHA) to identify and assess process hazards.
- Employee Participation: Before proceeding with other elements, safety managers must develop an action plan for implementing employee participation in the PSM program. In addition, safety managers should consult with employees on how to proceed with the process safety plan.
- Training: Provide process safety training to all employees who work with or around process chemicals.
- Contractor Safety: Manage contractor safety in accordance with the process safety plan. The PSM element applies to contractors performing maintenance repair, major renovations, turnaround, and other specialty work.
- Mechanical Integrity: To prevent process hazards, maintain the process equipment in good working condition and Record Inspections and maintenance activities in a mechanical integrity program.
- Incident Investigation: A safety management process could result in a catastrophic release of HHC. That’s why safety managers need to initiate an immediate investigation within 48 hours whenever this occurs.
- Management of Change (MOC): Before making any changes to chemicals, equipment, technology, or facilities, prepare and submit an MOC request. The process safety plan should detail how the organization will manage changes.
- Pre-Startup Safety Review (PSSR): Before startup, review new and modified processes to ensure that they meet process safety requirements.
- Emergency Planning and Response: Develop an emergency plan to prepare for process safety incidents. The plan should include procedures for notifying employees, contractors, and first responders.
- How Work Permit: A hot work permit is a document issued whenever hot work operations are going to be conducted. The permit establishes safety procedures that must be followed during the work.
- Compliance Audits: Safety managers must conduct process safety audits to ensure compliance with the process safety plan. The audit should be conducted by both the safety manager and an independent third party.
- Trade Secrets: Finally, process safety information can be considered a trade secret. To protect it, employers should have a process for handling it. That way, process safety information is not inadvertently released.
Steps to Implement Process Safety Management in Your Organization
Implementing Process Safety Management (PSM) within an organization is a systematic approach to managing hazards to prevent process-related accidents and injuries. Here is a detailed outline of steps to effectively implement PSM in your organization:
- Commitment and Leadership: Senior management must demonstrate unwavering commitment to PSM through policy development, resource allocation, and active participation in safety culture promotion.
- Employee Involvement: Engage employees at all levels in PSM activities, including decision-making processes, development of operating procedures, and participation in safety audits.
- Process Safety Information Compilation: Gather comprehensive data on the chemicals used, process technology, and equipment involved in processes. This includes material safety data sheets, process flow diagrams, and equipment specifications.
- Process Hazard Analysis (PHA): Carry out a systematic analysis to identify potential hazards associated with chemical processes. Select and apply appropriate methodologies such as What-If, Checklist, HAZOP, and FMEA to analyze the processes.
- Operating Procedures Development: Develop clear and concise procedures for safe startup, operation, and shutdown of process systems. This should include normal and emergency operating instructions, safety and health considerations, and equipment and chemical information.
- Training: Implement a comprehensive training program for all employees involved in operating processes. Training should cover operating procedures, hazard awareness, and emergency response actions.
- Pre-Startup Safety Review (PSSR): Before introducing new or modified processes, conduct a safety review to ensure that installations meet design specifications, adequate safety controls are in place, and employees are trained.
- Mechanical Integrity: Ensure the integrity of process equipment through regular inspections, testing, and maintenance. Develop procedures for maintaining equipment reliability and safe operation over its life span.
- Management of Change (MOC): Implement a formal system for managing changes in processes, equipment, technology, and personnel to prevent the introduction of new hazards.
- Incident Investigation: Establish procedures for promptly investigating incidents that resulted in, or could reasonably have resulted in, fires, explosions, toxic releases, or major injuries. Utilize findings to prevent recurrence.
- Emergency Planning and Response: Develop and implement plans for emergency response to process-related incidents. Plans should include evacuation procedures, emergency services coordination, and employee training.
- Compliance Audits: Periodically conduct internal and external audits to verify compliance with PSM requirements and the effectiveness of safety management systems. Address deficiencies identified during audits in a timely manner.
- Documentation and Record Keeping: Maintain thorough records of all elements of the PSM program, including process safety information, PHA reports, training records, audit reports, and incident investigation reports.
By following these steps, organizations can establish a robust Process Safety Management program that not only complies with regulatory requirements but also significantly reduces the risk of hazardous incidents, protecting employees, the environment, and assets.
Frequently Asked Questions (FAQs)
Q1: How often should we conduct Process Hazard Analysis (PHA)?
Process Hazard Analysis should be conducted every five years for each process as a best practice. However, the frequency can also be dictated by significant changes in the process, regulatory requirements, or following the occurrence of an incident.
Q2: What is the recommended approach for managing changes through the Management of Change (MOC) process?
The recommended approach involves a systematic review that includes risk assessment, documentation of the change, communication with affected personnel, and training if necessary. This ensures that all aspects of the change are considered, preventing unintended consequences.
Q3: Can you briefly explain the difference between Process Safety Management (PSM) and Occupational Health and Safety (OHS)?
Process Safety Management focuses specifically on preventing releases of any substance defined as a “highly hazardous chemical” by OSHA, aiming to prevent explosions, fires, and toxic releases. On the other hand, Occupational Health and Safety encompasses a broader range of workplace hazards that could affect an employee’s health and safety, not limited to chemical exposure.
Q4: How integral is employee involvement in the PSM framework, and what form should this involvement take?
Employee involvement is crucial in the PSM framework. It should include participation in the PHA process, development of operating procedures, emergency response planning, and safety audits. Engaging employees ensures that they understand the hazards and can contribute valuable practical insights.
Q5: What are the key components to include in a Pre-Startup Safety Review (PSSR)?
A comprehensive PSSR should include verification that the construction and equipment comply with design specifications, safety, health, and environmental standards are met, all necessary operating procedures and training have been completed, and the MOC process has been followed for any changes.
Q6: In case of non-compliance identified during a Compliance Audit, what steps should be taken?
Non-compliance issues identified during an audit must be addressed promptly. This involves developing a corrective action plan, setting timelines for completion, and re-auditing to ensure compliance. It is also important to analyze the root causes of non-compliance to prevent future instances.
Streamline Process Safety Management with DATAMYTE
DATAMYTE is a quality management platform with low-code capabilities. Our Digital Clipboard, in particular, is a low-code workflow automation software that features a workflow, checklist, and smart form builder. This tool lets you easily create custom digital forms to automate your PSM processes.
DATAMYTE also lets you conduct layered process audits (LPA), a high-frequency evaluation of critical process steps, focusing on areas with the highest failure risk or non-compliance. Conducting LPA with DATAMYTE lets you effectively identify and correct potential defects before they become major quality issues.
With DATAMYTE, you have an all-in-one solution for PSM compliance, from conducting PHAs and MOC processes to documenting and tracking corrective actions. Our platform helps you efficiently manage your PSM program, reducing the risk of hazardous incidents while improving overall quality and safety. Book a demo now to learn more.
Conclusion
Nowadays, process safety management is essential in any industry where process chemicals are handled. By understanding and implementing the 14 elements of PSM, employers can create a safe work environment and prevent process hazards. Implementing a strong PSM framework not only aids in compliance with regulatory standards but also significantly contributes to operational excellence and sustainability. It fosters a culture of safety, encourages proactive identification and mitigation of risks, and ensures the well-being of employees, the community, and the environment.
Process safety management is an investment in the future of the company, safeguarding against the unpredictable and often severe consequences of process-related incidents. Through continuous improvement and commitment to safety principles, organizations can achieve a high level of safety performance and reliability, setting a foundation for long-term success.
