No matter how standardized it has become, processing chemicals has always entailed hazards. Recognizing lapses that can exist in the safety management of some chemical facilities, the Occupational Safety and Health Administration (OSHA) has created the Process Safety Management (PSM), highlighting the importance of a management-level safety approach to prevent accidents. This article will detail the kinds of facilities required to comply with the PSM standard, explore all the criteria that covered facilities need to address, and offer some tips to implement the PSM successfully.
What kinds of facilities are covered by the OSHA PSM regulation?
The OSHA PSM standards apply to facilities with a process involving a regulated substance at or above its threshold quantity (TQ). These regulated substances, listed in 29 CFR 1910.119 Appendix A along with their corresponding TQ, have been determined to be highly hazardous, toxic, or reactive. Facilities that process flammable liquids and gases, such as gasoline and hydrogen, in quantities at or above 10,000 lbs are also subject to the PSM standards. The PSM standards usually apply to the following types of processes and industries:
- Refrigeration systems that use ammonia
- Chemical manufacturing facilities
- Paints, coatings, and adhesives manufacturing
- Pulp and paper manufacturing
- Water and wastewater treatment facilities, including those facilities that have on-site water treatment
- Pyrotechnics and explosives manufacturing
- Semiconductor manufacturing
- Electric, gas, and sanitary services provider
The PSM standards, however, do not apply to retail facilities that derive most of their income from the sale of chemicals. Processes that handle hydrocarbon fuels used solely for heating and refueling are also exempt. By extension, storing flammable liquids whose flashpoint is below 100 F in atmospheric storage tanks is not a covered process. Lastly, oil and gas drilling and servicing operations and other processes in normally unoccupied remote facilities are exempt from the PSM standards.
What are the elements of a complete PSM?
The PSM regulation gives covered facilities a framework to:
- assess the potential dangers of their processes,
- prevent the possible release of hazardous substances from mechanical, procedural, and human error, and
- act accordingly in cases of chemical accidents.
Additionally, the framework incorporates a robust feedback mechanism to monitor incidents and extract teachings to create a safer work environment. OSHA requires employers to address the following 14 elements of the PSM regulation to control process hazards effectively.
1. Employee Participation
Facilities must ensure that employees buy into the purpose and importance of proper PSM implementation by involving them in the PSM development process.
2. Process Safety Information
Employers must compile written copies of process safety information on:
- The hazardous chemicals involved in the process.
- The technology implemented.
- The specific equipment used.
Data on chemical safety, process chemistry, and piping and instrumentation diagrams are examples of information that must be compiled for each covered process.
3. Process Hazard Analysis
Using the compiled process safety information, employers must then comprehensively assess the process hazards, take action to manage risks, and communicate these actions to employees involved with the process.
4. Operating Procedures
Employers must develop a written operating procedure for the safe startup, operation, and shutdown of equipment. The document must be regularly updated and certified as current and accurate at least once a year.
5. Training
Employers must provide employees with adequate safety training (initial and refresher), emphasizing safety and health hazards of their assigned work, emergency operations, and other safe work practices. Furthermore, employers must also monitor and document employees’ learning progress and benchmark performance to assess the effectiveness of and identify gaps in the training program.
6. Contractors
Facilities must inform all on-site contractors of the process hazards and associated safety protocols and follow the facilities’ safety procedures.
7. Pre-startup Safety Review
Facilities should conduct a pre-startup safety review on new or modified processes before operations commence to properly document process safety information and develop the corresponding process hazard analysis, operating procedure, and training program.
8. Mechanical Integrity
Employers must conduct regular inspections and preventive maintenance of equipment to ensure the mechanical integrity of the process.
9. Hot Work permit
Employers must enforce a hot work permit system (e.g., for welding and cutting work) that documents the dates of authorized hot work and the identity of the process that needs hot work. This part also extends to any non-routine work undertaken on or near a covered process.
10. Management of Change
Employers must create and implement a system to manage chemical, technological, and equipment changes in covered processes. An update must accompany any change in the process safety information on the hazard analysis and operating procedure.
11. Incident Investigation
Employers must establish a procedure to document and investigate incidents that resulted in or would have resulted in the release of hazardous chemicals. The investigation should highlight the chain of events and their causes to allow for corrective actions to be undertaken.
12. Emergency Planning and Response
Employers must develop an emergency plan (e.g., reporting of fire and other emergencies, evacuation plan, etc.) that covers the entire plant. This part should also include procedures for small hazardous chemical releases.
13. Compliance Audits
Employers must conduct compliance audits on all elements of the PSM every three years to identify opportunities for improvement. This must be accompanied by a documentation of recommendations and corrective actions that were successfully undertaken.
14. Trade Secrets
All information necessary for a proper PSM implementation must be available to employees tasked with specific PSM compliance-related functions. Employers, however, may use confidentiality or nondisclosure agreements to protect their trade secrets.
What are some tips for a successful PSM implementation?
A successful PSM implementation program must start with an accurate accounting of any hazardous chemicals present in your facility. A regularly updated inventory helps in doing this, especially when determining whether a covered chemical has reached a specific TQ.
Use existing facility knowledge databases (equipment and process manuals, safety data sheets, etc.) as reference for identifying covered processes and conducting necessary process hazard analysis. The key here is to integrate any resources or plans (e.g., EPA Risk Management Plan) available to efficiently overcome resource-draining activities in fulfilling PSM requirements. Using an integrated safety platform to manage and accurately report all chemical inventory and asset data, safety and training programs, incidents, inspections, and permitting processes empowers and expedites the proper documentation of all PSM-related actions. Integrating all relevant safety systems into a secure platform also ensures issues relating to the 14 PSM elements are routinely addressed, effectively creating a more robust safety program.
The PSM standards monitor facilities as they proactively address any hazard arising from operations and prevent chemical accidents from happening. The guidance from the comprehensive PSM reporting criteria creates a robust system for process hazard identification, safe operating procedure implementation, accident planning and investigations, and corrective actions. Implementing a software solution to integrate all these various aspects of the PSM lightens the load of compliance and ensures that facilities operate at their maximum potential, with regard to both productivity and safety.
Sources
Process safety management of highly hazardous chemicals, 29 C.F.R. §1910.119 (2023).
https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XVII/part-1910/subpart-H/section-1910.119
Taylor, A. (2014, December 2). Bhopal: The world’s worst industrial disaster, 30 years later.
The Atlantic. https://www.theatlantic.com/photo/2014/12/bhopal-the-worlds-worst-industrial-disaster-30-years-later/100864/
U.S. Department of Labor. (2000). Process safety management. Occupational Safety and Health Administration. https://www.osha.gov/sites/default/files/publications/osha3132.pdf U.S. Department of Labor. (n.d.). Process safety management. Occupational Safety and Health Administration. https://www.osha.gov/process-safety-management/sbrefa
