Process Safety Management Tips for the Little Guy

What Is Process Safety Management

Process

Safety Management is the

application of management principles
and systems to the identification,
understanding, and control of process
hazards to protect employees, facility
assets and the environment.

What Is Process Safety Management

14 Elements

Application
Employee
Participation
Process Safety
Information
Process Hazard
Analysis
Operating Procedures
Employee Training

Contractors

Pre-Start up Safety
Review
Mechanical Integrity
Hot Work (Non-routine
Work Authorizations)
Management of
Change
Incident Investigation
Emergency Planning
and Response
Compliance Audits

1910.119 (a) Application

Appendix A of 29 CFR 1910.119 contains a
listing of toxic and reactive highly hazardous
chemicals which present a potential for a
catastrophic event at or above the threshold
quantities listed.
To adequately address this section, identify
what brings you into coverage by the
standard, specifying which processes at the
facility are covered and why.

1910.119 (a) Application

cont.
Consider what you can do to get out of the situation
Reduce inventories of highly hazardous
chemicals
Receive smaller shipments
Enhance inventory control
Break up storage locations within the plant to
reduce the amounts on hand to below the
threshold quantity (TQ)
Substitute listed with non-listed

May 25, 2004 Conyers GA

1910.119 (c) Employee

Participation
Employees are required to be an active part
of the process and your written programs
need to document what roles employees play,
their involvement in the development of the
programs, and continuing participation in the
process.
An OSHA inspector (CSHO) will attempt to
verify participation by interviewing employees
at random.

1910.119 (c) Employee

Participation cont.
Consultation

/ participation with training

and supervision to determine the
frequency and content of initial and
refresher training.
Consultation / participation to develop
and review operating and maintenance
procedures.
Consultation / participation in incident
investigations regarding the covered
process.

1910.119 (d) Process Safety

Information
Material Safety Data
Sheets (MSDS)
Piping and
instrumentation
diagrams (PINDs)
Block flow diagrams

Material and energy

balance calculations
Relevant consensus
standards
Materials of
construction

1910.119 (d) Process Safety

Information cont.

Available to all affected employees [requirement of

1910.119 (c) Employee Participation]

Available for Process Hazard Analysis and

revalidations [requirement of 1910.119 (e) Process
Hazard Analysis]

So auditors and CSHOs can find everything!

1910.119 (e) Process Hazard

Analysis

1910.119 (e) Process Hazard

Analysis
OSHA has

suggested formats
Dont start until all information is
gathered
Use a software tool to guide, record,
manage process

1910.119 (e) Process Hazard

Analysis
Catastrophic release means a major
uncontrolled emission, fire, or
explosion involving one or more
highly hazardous chemicals, that
presents serious danger to
employees in the workplace.
1910.119(b)

1910.119 (f) Operating

Procedures
Standard

Operating Procedures
Do in tandem with Job Hazard Analysis
(JHAs)
Mesh with training program
Partner with Quality Team (ISO 9001) to
create training matrix and managed
documents

1910.119 (g) Employee

Training
The

employer shall prepare a record:

Identity

of employee.
Date of training.
Means to verify that employee
understood training
At a minimum, refresher training shall be
provided at least every three years and more
often if necessary to each employee involved
in operating a process.

1910.119 (h) Contractors

Absolute

Requirements

Employer

Contract employee injury and illness logs

related to work in covered process areas.

Contract

Documentation:

Employer Documentation:

Records showing employees received

training in and understands safe work
practices related to the process on or near
where they will be working so they perform
their jobs safely.

1910.119 (i) Pre-Start up

Safety Review
Check,

double check, and review any

changes, modifications, additions made
in a PSM covered area before you flip
the switch.

1910.119 (j) Mechanical

Integrity

The employer shall develop and maintain a master

list of all equipment specifically covered by the
standard, and equipment that is important to safety of
the process.

Pressure vessels and storage tanks.

Piping systems including valves and other piping
components.
Relief and vent systems and devices.
Emergency shutdown systems.
Controls (including monitoring devices and sensors,
alarms, and interlocks).

1910.119 (j) Mechanical

Integrity cont.

Pumps.
Rotating equipment.
Heat exchange equipment.
Electrical generation and distribution
equipment.
Un-interruptable power supplies.
Emergency power supply equipment.
Fire protection equipment.

1910.119 (k) Hot Work (a.k.a. Nonroutine Work Authorizations)

Welding,

cutting, braising make sure

only trained personnel perform these
functions
Have trained fire watchers (align with
fire extinguisher / fire response training)

1910.119 (l) Management of

Change
Create

formalized system to review all

changes to process areas including:
Raw

material changes / substitutions

Personnel changes
Process parameters
Facility changes (HVAC / roof / fire
protection / ..)

1910.119 (l) Management of

Change cont.

PSI
Mechanical Integrity
PINDs
Hot Work
Contractor Safety
Employee Training
PSSR
Operating Procedures

1910.119 (m) Incident

Investigation
Investigate
Incidents
&
Near-Misses

Reatain
Reports 5-years

Begin within
48-hours

Incident
Investigation

Follow-up
System for
Recommendations

Report with
Conclusions &
Recommendatons

Team
with Process
Knowledge

1910.119 (n) Emergency

Planning and Response
Call

in all resources and make plan

comprehensive:
Information

Technology (IT) Disaster

Recovery Plan
Business Continuity Plan (session #554 @ 4:30)
Security
Communications / Public Relations
Employee Assistance

1910.119 (o) Compliance

Audits
Ask

for the audit protocol ahead of time

Have a system in place to identify the
location of all PSM documentation
Identify what's in or out of audit scope
Ask for money to correct audit items
before the audit is conducted
Prepare management for report

Resources

OSHA web site (www.OSHA.gov):

OSHA training institute

CPL 2-2.45 Process Safety Management of Highly

Hazardous Chemicals Compliance Guidelines and
Enforcement Procedures 78 pages of gold!
Appendix C to 1910.119 Compliance Guidelines and
Recommendations for Process Safety Management
(Nonmandatory)
Safety and Health Chemical Process Industry course
#330A. PSM boot camp five days of fun and a three
ring binder!

AIChE / CCPs

Please Visit!
Booth # 1312

Booth # 1310