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WEB 6: GLOBAL PSM REGULATION /

GOOD INDUSTRY PRACTICE


SUMMARY
Note:
1. Where we have obtained a copy of the referenced regulation or good
industry practice, the “Title” in this table is hyperlinked (i.e., blue
text and underlined) and the document can be viewed by clicking on
the link.
2 GUIDELINES FOR IMPLEMENTING PROCESS SAFETY MANAGEMENT

Country Title Type Summary Link Entry into Implementa Comparison Comments
(Region) REG force date tion/ to OSHA
or GIP Compliance PSM
Date
Global Risk Based Process GIP A 20-element Process http://www.aiche.org/ccps/reso 2007 --- Suggests a Center for Chemical
Safety Safety management urces/publications/books/guide broader and Process Safety
system lines-risk-based-process-safety deeper (CCPS) book
program than
OSHA PSM
and includes
“soft”
elements
such as PS
Culture
High level GIP Safety management https://www.energyinst.org/tec Dec 2010 Comparable Developed by UK
framework for framework capturing hnical/PSM/PSM-framework to CCPS. energy industry
process safety industry good practice. practitioners (incl.
management To provide a consistent BP, Chevron,
and effective approach ConocoPhillips,
for discussions with E.ON, Marsh, Total,
regulators, insurers and UK-HSE, UKPIA).
other stakeholders. Published by
Energy Institute.
Americas
Argentina There are Labor
Laws, but no
process safety
regulations.
GLOBAL PSM REGULATION / GOOD INDUSTRY PRACTICE SUMMARY 3

Country Title Type Summary Link Entry into Implementa Comparison Comments
(Region) REG force date tion/ to OSHA
or GIP Compliance PSM
Date
Brazil NR-20 (Flammable REG This NR sets minimum June 1978 July 2014 The latest There are no PSM
and Combustible requirements for the (latest NR-20 regulatory agencies
Liquids) management of Health revision) revision like the US. The
and Safety at Work made this regulatory body is
against the factors of standard the Brazilian
risks of accidents from similar to Ministry of Labor
activities of extraction, OSHA PSM that issues “Normas
production, storage, Regulamentadoras
transfer, handling, and – NRs.”
manipulation of
flammable and
combustible liquids
NR-13 (Pressure REG Pressurized vessels and June, 1978 April, 2014 N/A
vessels and piping) piping code (latest
revision)
NR-33 REG Confined space entry December, August 2012 N/A
2006 (latest
revision)
NR-19 REG Explosives handling June 1978 May 2011 N/A
(latest
revision)
NR-16 (Dangerous REG Hazardous operations June, 1978 July 2014 N/A This standard is
work and (latest used to define an
operations) revision) additional salary for
workers that are
exposed to safety
risks due to
explosives,
electricity,
flammables,
radioactivity and
security hazards
4 GUIDELINES FOR IMPLEMENTING PROCESS SAFETY MANAGEMENT

Country Title Type Summary Link Entry into Implementa Comparison Comments
(Region) REG force date tion/ to OSHA
or GIP Compliance PSM
Date
ANP Resolution REG Technical Regulation of http://www.anp.gov.br/? December N/A
43/2007 Operation Safety id=1606 2007
Management System on
Offshore Oil & Gas
Drilling and Production
Operations
ANP Resolution REG Technical Regulation of http://www.anp.gov.br/? April 2012 N/A
02/2010 Structural Integrity id=1606
Management System on
Onshore Oil & Gas
Drilling and Production
Operations
ANP Resolution REG Technical Regulation of http://nxt.anp.gov.br/NXT/gate January Very similar
05/2010 Operation Safety way.dll/leg/resolucoes_anp/201 2014 to OSHA
Management System on 4/janeiro/ranp%205%20- PSM
Oil & Gas Refineries %202014.xml
ANP Resolution REG Technical Regulation of http://www.unisolution.com.br/ February N/A
02/2011 Onshore Pipelines for Oil clientes/abtl/Download/RT_A 2011
& Gas NP_2_2011-Dutos
%20Terrestres.pdf
Atuação Resonsável GIP http://www.abiquim.org.br/pro 1992 N/A ABIQUIM –
(Responsible Care) grama/atuacao-responsavel/ Chemical
Companies
Brazilian
Association.
ABIQUIM requires
chemical companies
to comply with this
code in order to
keep membership
GLOBAL PSM REGULATION / GOOD INDUSTRY PRACTICE SUMMARY 5

Country Title Type Summary Link Entry into Implementa Comparison Comments
(Region) REG force date tion/ to OSHA
or GIP Compliance PSM
Date
Canada No Compulsory, REG This Some provinces
varies by province, document is have or are
see Comments very similar developing
section to OSHA regulations
PSM covering various
Code of Practice – aspects of PSM
Process Safety
Management
(Newfoundland
draft document)
Canadian REG http://www.ec.gc.ca/lcpe- 1999 N/A
Environmental cepa/default.asp?
Protection Act – lang=En&n=26A03BFA-1
Environmental
Emergency
Regulation, Section
200, Part 8
Responsible Care GIP The Process Safety http://www.canadianchemistry. --- N/A Chemical Industry
Network (PSN) is a ca/ResponsibleCareHome.aspx Association of
CIAC committee. It is a Canada (CIAC)
volunteer (sweat equity)
group developing tools
and standards for process
safety to ensure it
maintains a high profile
within member
companies. The PSN
also shares process safety
incidents and learnings.
6 GUIDELINES FOR IMPLEMENTING PROCESS SAFETY MANAGEMENT

Country Title Type Summary Link Entry into Implementa Comparison Comments
(Region) REG force date tion/ to OSHA
or GIP Compliance PSM
Date
Canadian Society GIP The PSM division of the
for Chemical CSChE is a national
Engineering network of more than 300
(CSChE), “PSM volunteers. The division
Guide,” 4th edition connects individuals with
a common interest and
expertise in PSM to
create networking
opportunities and to share
ideas.
Colombia No process safety
regulations at
present
Mexico NOM -028-STPS- REG Requires 16 PSM http://trabajoseguro.stps.gob.m 30 August 28 February Very similar
2012 (unofficial elements x/trabajoseguro/boletines 2012 2014 regulation to
translation) %20anteriores/2012/bol044/vin OSHA PSM
culos/PROY-MOD-NOM-
028.pdf
Integral Security REG 1998 N/A
and Environmental
Management
System (SIASPA)
SSPA
United 29 CFR 1910.119 REG Requires 14 PSM http://www.ecfr.gov/cgi- 24 26 May 1992 -
States of (OSHA) elements for processes bin/text-idx? February
America with listed toxics above c=ecfr&SID=5df56ebb48b855 1992
listed TQs and/or with 42b53853863f60c639&rgn=di
flammables > 10,000 v8&view=text&node=29:5.1.1.
pounds 1.8.8.33.13&idno=29
GLOBAL PSM REGULATION / GOOD INDUSTRY PRACTICE SUMMARY 7

Country Title Type Summary Link Entry into Implementa Comparison Comments
(Region) REG force date tion/ to OSHA
or GIP Compliance PSM
Date
40 CFR 68 (EPA) REG Requires most of the http://www.ecfr.gov/cgi- 20 June 21 June 1999 See
same OSHA PSM bin/text-idx? 1996 Summary
(“Prevention”) elements c=ecfr&SID=5df56ebb48b855
+ registration, offsite 42b53853863f60c639&rgn=di
consequence assessment , v5&view=text&node=40:16.0.
and emergency response 1.1.5&idno=40
for listed toxics and
flammables above listed
TQs
Responsible Care – GIP Less specific, but most http://responsiblecare.american N/A American
Process Safety demanding in terms of chemistry.com/Responsible- Chemistry Council
Code expectations for Care-Program-
continuous improvement Elements/Process-Safety-
Code/Responsible-Care-
Process-Safety-Code-PDF.pdf
API RP 75 GIP http://www.techstreet.com/api/ Reaffirmed Includes This recommended
(Recommended products/1157045 May 2008 elements practice is currently
Practice for similar to under review by
Development of a OSHA PSM committee for
Safety and update
Environmental
Management
Program for
Offshore
Operations
and Facilities)
Safety and REG http://www.ecfr.gov/cgi- October, N/A
Environmental bin/text-idx? 2011
Management SID=73ecf0ca1763f93e3652e0
Systems (SEMS) 5e49894b7a&node=30:2.0.1.2.
[Title 30 CFR Part 3.19&rgn=div6
250 Subpart S]
8 GUIDELINES FOR IMPLEMENTING PROCESS SAFETY MANAGEMENT

Country Title Type Summary Link Entry into Implementa Comparison Comments
(Region) REG force date tion/ to OSHA
or GIP Compliance PSM
Date
Chemical Facility REG This rule establishes risk- http://www.ecfr.gov/cgi- N/A
Anti-Terrorism based performance bin/text-idx?
Standards (CFATS), standards for the security tpl=/ecfrbrowse/Title06/6cfr27
Title 6, Chapter 1, of our nation’s chemical _main_02.tpl
Part 27 facilities. It requires
covered chemical
facilities to prepare
Security Vulnerability
Assessments, which
identify facility security
vulnerabilities, and to
develop and implement
Site Security Plans,
which include measures
that satisfy the identified
risk-based performance
standards.
GLOBAL PSM REGULATION / GOOD INDUSTRY PRACTICE SUMMARY 9

Country Title Type Summary Link Entry into Implementa Comparison Comments
(Region) REG force date tion/ to OSHA
or GIP Compliance PSM
Date
Maritime Security: REG The Coast Guard http://www.ecfr.gov/cgi- 2003 N/A
Facilities employs a three-tiered bin/text-idx?
(MARSEC), Title system of Maritime c=ecfr;sid=a485483870d82baf
33, Chapter 1, Security (MARSEC) b395c519af3d4219;rgn=div5;v
Subchapter H, Part Levels. MARSEC iew=text;node=33%3A1.0.1.8.
105 Levels are set to reflect 53;idno=33;cc=ecfr
the prevailing threat
environment to the
marine elements of the
national transportation
system, including ports,
vessels, facilities, and
critical assets and
infrastructure located on
or adjacent to waters
subject to the jurisdiction
of the U.S. MARSEC
Levels apply to vessels,
Coast Guard-regulated
facilities inside the U.S.,
and to the Coast Guard.
10 GUIDELINES FOR IMPLEMENTING PROCESS SAFETY MANAGEMENT

Country Title Type Summary Link Entry into Implementa Comparison Comments
(Region) REG force date tion/ to OSHA
or GIP Compliance PSM
Date
Europe –
EU
Europe SEVESO II REG Safety report to http://eur- N/A, as the
(EU)+UK demonstrate: lex.europa.eu/smartapi/cgi/sga Safety
a) major-accident _doc?smartapi!celexapi!prod! Report is a
prevention policy and CELEXnumdoc&lg=EN&num totally
safety management doc=31996L0082&model=guic different
systems hett approach
b) major-accident hazards
have been identified,
measures taken to
prevent such accidents
and to limit their
consequences for man
and the environment;
c) safety and reliability
have been incorporated
into operation [critical
activities] and
maintenance of
[critical] equipment
d)emergency response
plans exist
SEVESO II REG http://eur- See above
UPDATE lex.europa.eu/LexUriServ/Lex
UriServ.do?
uri=CELEX:32003L0105:EN:
NOT
SEVESO III REG Classification materials http://eur- 13 August 1 June 2015 See above
as per CLP and provision lex.europa.eu/LexUriServ/Lex 2012
of public information of UriServ.do?
MAHs and consequences uri=CELEX:32012L0018:EN:
on the web NOT
GLOBAL PSM REGULATION / GOOD INDUSTRY PRACTICE SUMMARY 11

Country Title Type Summary Link Entry into Implementa Comparison Comments
(Region) REG force date tion/ to OSHA
or GIP Compliance PSM
Date
EU Directive Countries to appoint http://ec.europa.eu/energy/oil/o 12 June 18 July 2015 See above Brings off-shore
2013/30/EU on “Competent Authorities”; ffshore/standards_en.htm 2013 closer to COMAH
safety of offshore CA’s to assess technical and
oil and gas and financial capability http://eur-lex.europa.eu/legal-
operations of licensees including content/EN/TXT/PDF/?
ability to cover potential uri=CELEX:32013L0030&fro
liabilities; m=EN
Operator must be
approved by licensing
authority;
Operators to submit a
Safety Report detailing:
 corporate major
accident prevention
policy,
 safety and
environmental
management system
 report on major hazards
 emergency response
plans
12 GUIDELINES FOR IMPLEMENTING PROCESS SAFETY MANAGEMENT

Country Title Type Summary Link Entry into Implementa Comparison Comments
(Region) REG force date tion/ to OSHA
or GIP Compliance PSM
Date
ATEX REG The Equipment and https://ec.europa.eu/growth/sec 23 March 1st July 2003 N/A The Directive is
Protective systems tors/mechanical- 1994 implemented in
intended for use in engineering/atex_en Europe by means of
Potentially Explosive each national
Atmospheres (ATEX) authority
Directive 94/9/EC transposing its
provides the technical provisions into their
requirements to be legislation (e.g.
applied and the relevant DSEAR in the UK).
conformity assessment
procedures before placing
this equipment on the
European market.
PED (Pressure REG Pressurised vessels, as http://ec.europa.eu/growth/sect May 1997 30th May N/A The Directive is
Equipment used in the process ors/pressure-gas/pressure- 2002 implemented in
Directive) industries must: equipment/directive_en Europe by means of
 be safe; each national
 meet essential authority
safety requirements transposing its
covering design, provisions into their
manufacture and legislation (e.g.
testing; PSSR in the UK).
 satisfy
appropriate conformity
assessment procedures;
and
 carry the CE
marking and other
information.
GLOBAL PSM REGULATION / GOOD INDUSTRY PRACTICE SUMMARY 13

Country Title Type Summary Link Entry into Implementa Comparison Comments
(Region) REG force date tion/ to OSHA
or GIP Compliance PSM
Date
Registration, REG Manufacturers or http://www.hse.gov.uk/reach/in 1st June 2007 N/A The Directive is
Evaluation, importers of >1 T/yr. of dex.htm and implemented in
Authorisation & substances must register http://echa.europa.eu/web/gues Europe by means of
restriction of them with European t each national
Chemicals Chemicals Agency authority
(REACH) (ECHA). The registration transposing its
package must be provisions into their
supported by an legislation (e.g.
[extensive] standard set REACH in the UK).
of data on that substance.
No data, no market!
CLP/GHS - REG Aligns EU to the GHS http://eur-lex.europa.eu/legal- 31 May 2015 N/A The Directive is
Classification, (Globally Harmonised content/EN/TXT/? implemented in
labelling and System of Classification uri=URISERV:ev0013 Europe by means of
packaging of and Labelling of each national
substances and Chemicals), a United authority
mixtures Nations system to transposing its
identify hazardous provisions into their
chemicals and to inform legislation (e.g.
users about these hazards COSHH and
through standard symbols REACH in the UK).
and phrases on the
packaging labels and
through safety data sheets
(SDS).
All of the above EU Directives are separately implemented, in each of the 28 countries of the EU.
All national implementation texts are scrutinized, by the EU Commission, to ensure they will actually implement all the measures required in the directive.
Belgium GIP Guidance document for https://www.lne.be/veiligheidsr See And all EU
SEVESO apportage/ SEVESO regulations
above
14 GUIDELINES FOR IMPLEMENTING PROCESS SAFETY MANAGEMENT

Country Title Type Summary Link Entry into Implementa Comparison Comments
(Region) REG force date tion/ to OSHA
or GIP Compliance PSM
Date
Netherlands ??? REG Risk assessment tool: See And all EU
http://www.rivm.nl/Onderwerp SEVESO regulations
en/R/Regionale_infectieziekteb above
estrijding/Regionale_Arts_Con
sulenten_RAC/Projecten_RAC
/Afgeronde_projecten_RAC/P_
t_m_T/Risicoinventarisatie/Ris
k_Assessment_Tool
Norway
Sweden
Switzerland
UK COMAH REG Seveso II based 1999 COMAH: See
regulation http://www.legislation.gov.uk/u SEVESO
ksi/1999/743/contents/made above
2005 Amendments:
http://www.hse.gov.uk/comah/
background/summary.pdf
DSEAR REG UK implementation of http://www.hse.gov.uk/fireande 2005 N/A Defines Area
EU’s ATEX regulations xplosion/dsear.htm Classification &
equipment
specifications.
Also covers
Hierarchy of
Control.
R2P2 (Reducing GIP Definitive basis for risk http://www.hse.gov.uk/risk/the 2001 N/A Basis of UK’s risk
Risks and regulations ory/r2p2.htm approaches,
Protecting People) defining
“Tolerability”,
ALARP, Cost-
Benefit approach,
etc.
GLOBAL PSM REGULATION / GOOD INDUSTRY PRACTICE SUMMARY 15

Country Title Type Summary Link Entry into Implementa Comparison Comments
(Region) REG force date tion/ to OSHA
or GIP Compliance PSM
Date
Environmental Risk GIP Quantitative definition of http://www.hse.gov.uk/aboutus/ 2014 2015 First global Mandatory
Tolerability for a Major Accident to the meetings/committees/cif/enviro quantitative approach to be
COMAH Environment (MATTE); nmental-risk-assessment.pdf approach for included in
Establishments definition of Tolerability environment COMAH Safety
thresholds for different al risk Reports from 2015
receptors and risk-based assessments, for all UK sites.
approach for ALARP to bring
demonstration for environment
environmental risks. to same level
as people
risks.
ALARP suite of GIP Extensive HSE guidance http://www.hse.gov.uk/risk/exp N/A Good training
Guidance on how to demonstrate ert.htm material
ALARP has been
achieved (including
guidance on cost-benefit
analyses)
Guidance on GIP Further guidance on http://www.hse.gov.uk/foi/inter N/A
ALARP Decisions ALARP demonstration nalops/hid_circs/permissioning
in COMAH and /spc_perm_37/ and
HID's approach to http://www.hse.gov.uk/foi/inter
ALARP decisions nalops/hid_circs/permissioning
/spc_perm_39.htm
COSHH, CLP and REG Implementation of EU http://www.hse.gov.uk/coshh/d N/A Fist link for
REACH regulations in the UK etail/coshh-clp-reach.htm REACH
concerning Control of
Substances hazardous to
Human Health,
Classification Labelling
and Packaging and
REACH.
16 GUIDELINES FOR IMPLEMENTING PROCESS SAFETY MANAGEMENT

Country Title Type Summary Link Entry into Implementa Comparison Comments
(Region) REG force date tion/ to OSHA
or GIP Compliance PSM
Date
Europe –
Non-EU
Russia PB- 03-517-02 REG N/A This is a general
(General Industrial industrial safety
Safety for regulation
Organizations
Engaged in
Activities in the
Field of Industrial
Safety of
Dangerous
Production
Facilities)
(unofficial
translation)
Asia and
Middle
East
Abu Dhabi ADNOC-CoP-V5- REG https://www.adnoc.ae/
06
GLOBAL PSM REGULATION / GOOD INDUSTRY PRACTICE SUMMARY 17

Country Title Type Summary Link Entry into Implementa Comparison Comments
(Region) REG force date tion/ to OSHA
or GIP Compliance PSM
Date
Australia NOHSC:1014 REG 2002 Similar to
(National Standard the UK, this
for Control of is a Safety
Major Hazard Case
Facilities) approach
WHS (Work Health REG New work health and http://www.safeworkaustralia.g 2011 N/A WHS is not really a
and Safety) safety (WHS) laws ov.au/sites/swa/about/publicati PSM reg. No direct
commenced on 1 January ons/pages/publication reference to process
2012 in many states and systems or
territories to harmonise handling/storage of
occupational health and hazardous
safety (OH&S) laws materials.
across Australia.
WHS legislation includes
a model WHS Act,
regulations, Codes of
Practice, and a national
compliance and
enforcement policy.
18 GUIDELINES FOR IMPLEMENTING PROCESS SAFETY MANAGEMENT

Country Title Type Summary Link Entry into Implementa Comparison Comments
(Region) REG force date tion/ to OSHA
or GIP Compliance PSM
Date
China AQ/T3034-2010 REG* This China Process May 1, Most items * It is our
(Guidelines for Safety guide or rule is 2011 are copied understanding that
Process Safety for issued by State from OSHA although this is
Petrochemical Administration of Work PSM, with titled as a
Corporations) Safety (SAWS) of China. very few “Guideline,” it
(unofficial SAWS is more like items added would be enforced
translation) OSHA of US. Beside this as a regulation if a
rule, SAWS now foreign company
recommends HAZOP to has an event.
be used for new built
facilities, especially in
government owned
company. It seems
someday in short future
SAWS will issue a
dedicated rule for
HAZOP.
Hong Kong
India Oil India Safety N/A Similar to UK HSE
Regulations regulation
(Production and N/A
Natural Gas –
Offshore
Regulation)
Indian Chemical N/A This council is
Council working on
adopting guidelines
similar to OSHA
PSM
Indonesia N/A No regulations, but
PSM
implementation by
some companies
GLOBAL PSM REGULATION / GOOD INDUSTRY PRACTICE SUMMARY 19

Country Title Type Summary Link Entry into Implementa Comparison Comments
(Region) REG force date tion/ to OSHA
or GIP Compliance PSM
Date
Iraq N/A No regulations, but
“Safety Case” type
studies performed
by major joint
ventures
Japan High Pressure Gas The High Pressure Gas e-gov link: http://law.e- N/A
Safety Act Safety Act, the Fire gov.go.jp/cgi-bin/idxsearch.cgi
Services Act, the
Industrial Safety and 2006
Health Law, and the Act
on the Prevention of
Disasters in Petroleum
Industrial Complexes and
Other Petroleum
Facilities are collectively
referred to as the 'four
safety acts.'
Kuwait N/A No overarching
regulation, but a
number of “safety
study” requirements
Malaysia Occupational Safety REG http://www.dosh.gov.my/index. 2006 N/A
and Health Act php?lang=en
New Health and Safety REG Similar to Australia, a 2013 N/A Similar to Australia,
Zealand in Employment “Safety Case” approach a “Safety Case”
(Petroleum is used approach is used
Exploration and
Extraction)
Regulations 2013
20 GUIDELINES FOR IMPLEMENTING PROCESS SAFETY MANAGEMENT

Country Title Type Summary Link Entry into Implementa Comparison Comments
(Region) REG force date tion/ to OSHA
or GIP Compliance PSM
Date
Oman REG N/A Petrochemical
Oman follows
requirements
similar to major oil
companies
Saudi N/A Government-owned
Arabia companies have
extensive PSM
procedures
Singapore Singapore Standard REG PREVIEW ONLY 2013 Some The Ministry of
SS506 Part 3: 2013, http://www.singaporestandards management Manpower expects
Occupational Safety eshop.sg/data/EcopyFileStore/ system a Safety and Health
and Health (OSH) 061114131101Preview%20- requirements management system
Management %20SS%20506-3-2006.pdf , along with approach:
System - a Safety http://www.mom.go
Requirements for http://rpsonline.com.sg/proceed Case v.sg/workplace-
the Chemical ings/9789810714451/html/Go safety-health/safety-
Industry HengHuat.pdf health-
management-
systems/Pages/defa
ult.aspx
National REG One-time QRA report for http://www.nea.gov.sg/ N/A
Environment new chemical plants
Agency
South Occupational Safety REG In particular, Article 49-2 http://english.kosha.or.kr/englis January N/A
Korea and Health Act (Submission etc. of h/main.do 2012
Process Safety Report)
lays out requirements for
submission,
review/approval, and
updating of such reports
GLOBAL PSM REGULATION / GOOD INDUSTRY PRACTICE SUMMARY 21

Country Title Type Summary Link Entry into Implementa Comparison Comments
(Region) REG force date tion/ to OSHA
or GIP Compliance PSM
Date
Framework Plan on REG http://eng.me.go.kr/eng/web/m 2005 N/A
Hazardous ain.do
Chemical
Management
Taiwan
United Arab Federal Law No. 8 REG 1980 N/A
Emirates (Regulations of
Labour Relations
Federal Law No. 24 REG https://www.ead.ae/sitepages/h 1999 N/A
(Protection and ome.aspx
Development of the
Environment
Other
Regulations
/ GIP
Documents

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