Professional Documents
Culture Documents
Application
There are different categories of contract labor. This includes
those with specialized knowledge or skills who are hired to
operate the facility or perform a particular aspect of a job, those
who are hired for a short time period to perform turnaround
operations or maintenance, and those who provide incidental
service, such as janitorial, food, or laundry services. PSM provides
special provisions for contractors and all of their employees,
emphasizing the importance of protecting those employees who
may work for another employer. However, PSM standards need
not specifically apply to contractors providing incidental services
whose work does not influence process safety
Exemption
PSM does not apply to contractors providing minor services that
do not affect process safety, such as janitorial, food and drink,
laundry, delivery, or other supply services. It only applies to
contractors performing maintenance or repair, turnaround, major
renovation, or specialty work on or adjacent to a covered process
Employer Responsibilities
When selecting a contractor the employer operating the facility to
which PSM applies is required to obtain and evaluate information
regarding the prospective contract employer's safety
performance and programs. It is the operating employer's
responsibility to:
Inform the contract employers about potential fire, explosion,
or toxic release hazards related to the contractors work or
process.
Explain the provisions of the emergency action plan to the
contract employer.
Develop and implement safe work practices to control the
presence, entrance, and exit of contract employers and
contract employees in covered process areas.
Periodically evaluate the performance of contract employers
in fulfilling their obligations.
Maintain a contract employee injury and illness log related to
the contractor's work in the process areas.
Mechanical Integrity
OSHA believes that the mechanical integrity of the critical
process equipment is assured through proper installation,
design, and operation. PSM mechanical integrity requirements
apply to the following equipment:
Pressure vessels and storage tanks
Piping systems (including piping components such as
valves)
Relief and vent systems and devices
Emergency shutdown systems
Controls (including monitoring devices and sensors, alarms,
and interlocks)
Pumps
To maintain the ongoing integrity of the process equipment, the
operating employer must establish and implement written
procedures. Employees responsible for maintaining the integrity
of process equipment should be trained in an overview of the
Equipment Deficiencies
Equipment deficiencies outside the acceptable limits defined by
the process safety information must be corrected before further
Reasons
Warning signs/labels were not present on the tanks' storage area.
Workers did not know that tanks contained hazardous materials.
Other workers did not tell them (the victims) not to weld in the
hazardous chemical storage area, which is severe negligence.
The workers were new and had not received any safety training or
education
Management of Change
There is nothing permanent except change; therefore, written
procedures to manage changes, except for "replacements in
kind" (e.g., replacement of defective equipment with same
exact type which does not affect the operation or safety of the
process) to process chemicals, equipment, and technology, or
any other changes that could affect a covered process, must be
Incident Investigation
Incident investigation standards require the employer to
investigate as soon as possible (but no later than 48 hours
after) incidents that did result or could have resulted in
catastrophic releases of covered chemicals. The investigation
team must include at least one person who is knowledgeable in
the process (including a contract employee, if appropriate) to
investigate, analyze, and develop a written report on the
incident
Compliance Audit
In order to assess whether process safety management
standards are adequate and being followed, employers must
certify at least every three years that they have carefully
applied all the applicable provisions of the PSM standards. The
compliance audit must be conducted by at least one person
with knowledge of the process and standards requirement.
Furthermore, it is auditor's responsibility to prepare a report
based on the findings, noting any deficiencies, and the
employer's responsibility to determine and document any
responses to the findings and to document any deficiencies that
have been rectified. Remember! The last two compliance audit
reports must be kept on record
Trade Secrets
Summary
In order to assess whether process safety management
standards are adequate and being followed, employers must
certify at least every three years that they have carefully
applied all the applicable provisions of the PSM standards. The
compliance audit must be conducted by at least one person
with knowledge of the process and standards requirement.
Furthermore, it is the auditor's responsibility to prepare a report
based on the findings, noting any deficiencies, and the
employer's responsibility to determine and document any
responses to the findings and any deficiencies that have been
rectified. Bear in mind that PSM only applies to contractors
performing maintenance or repair, turnaround, major
renovation, or specialty work on or adjacent to a covered
process