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 Pre-Start up Safety

Employee Review
Participation Mechanical Integrity
Process Safety Hot Work (Non-routine
Information Work Authorizations)
Process Hazard Management of
Analysis Change
Operating Procedures Incident Investigation
Employee Training Emergency Planning
and Response
Contractors 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 Material and energy
Sheets (MSDS) balance calculations
Piping and Relevant consensus
instrumentation standards
diagrams (PINDs) Materials of
Block flow diagrams 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 Documentation:
Contract employee injury and illness logs
related to work in covered process areas.
Contract 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. Non-
routine 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 Begin within
& 48-hours
Near-Misses

Reatain Incident Team

with Process
Reports 5-years
Investigation Knowledge

Follow-up Report with

System for Conclusions &
Recommendations Recommendatons
1910.119 (n) Emergency
Planning and Response
Call
in all resources and make plan
comprehensive:
InformationTechnology (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):
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)
OSHA training institute
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