OSHA: Process Safety Management

On February 24, 1992, OSHA published the final rule "Process Safety Management of Highly Hazardous Chemicals." This standard is performance oriented; that is, it sets general requirements for the management of hazardous chemicals. Process safety management (PSM) was developed after the Bhopal accident (1985), to prevent similar accidents. It is recognized by industry and the government as an excellent regulation that will reduce the number and magnitude of accidents -if it is understood and practiced as intended. The PSM standard has 14 major sections: 1. Employee Participation, 2. Process Safety Information, 3. Process Hazard Analysis, 4. Operating Procedures, 5. Training, 6. Contractors, 7. Pre-Startup Safety Review, 8. Mechanical Integrity, 9. Hot Work Permits, 10. Management Of Change, 11. Incident Investigations, 12. Emergency Planning And Response, 13. Audits, And 14. Trade Secrets. A brief description of each section is given in what follows. Employee participation requires active employee participation in all the major elements of PSM. Employers must develop and document a plan of action to specify this participation. Process safety information is compiled and made available to all employees to facilitate the understanding and identification of hazards. This information includes block flow diagrams or process flow diagrams, process chemistry, and process limitations, such as temperatures, pressures, flows, and compositions. Consequences of process deviations are also required. This process safety information is needed before training, process hazards analysis, management ofchange, and accident investigations Process hazard analysis (PHA) must be performed by a team of experts, including engineers, chemists, operators, industrial hygienists, and other appropriate and experienced specialists. The PHA needs to include a method that fits the complexity of the process, a hazards and operability (HAZOP) study for a complex process, and for less complex processes a less rigorous process, such as what-if scenarios, checklists, failure mode and effects analysis, or fault trees. Employers must ensure that the recommendations from the PHA are acted on in a timely manner. Every PSM process needs an updated PHA at least every five years after the initial analysis is completed.

Operating procedures that facilitate the safe operation of the plant must be documented. These instructions need to be clearly written and consistent with the process safety information. They need to cover, at a minimum, initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, startup after normal and emergency shutdowns, operating limits and consequences of deviations, safety and health considerations, hazardous properties of the chemicals, exposure precautions, engineering and administrative controls, quality control specifications for all chemicals, special or unique hazards, and safety control systems and functions. Safe work practices also need to be documented, such as hot work, lockout/tagout, and confined space. These operating procedures are updated frequently, with the frequency being set by the operating personnel. An effective training program helps employees understand the hazards associated with the tasks they perform. Maintenance and operations personnel receive initial training and refresher training. Operators need to understand the hazards associated with every task, including emergency shutdowns, startups, and normal operations. Refresher training is given every three years and more often if necessary; the operators decide on the frequency of the refresher training. Contractors are trained to perform their tasks safely to the same extent as employees. Even when selecting contractors, the employees need to consider the contractors' safety performance in addition to their skills. A pre-startup safety review is a special safety review that is conducted after a modification to the process or operating conditions has been made and before the startup. In this review a team of reviewers ensures that (1) the system is constructed in accordance with the design specifications, (2) the safety, maintenance, operating, and emergency procedures are in place, (3) the appropriate training is completed, and (4) the recommendations from the PHA are implemented or resolved. The mechanical integrity section of the PSM standard ensures that the equipment, piping, relief systems, controls, and alarms are mechanically sound and operational. The requirements include (1) written procedures to maintain functioning systems, (2) training regarding preventive maintenance, (3) periodic inspections and testing based on vendor recommendations, (4) a process to correct deficiencies, and (5) a process to ensure that all equipment and spare parts are suitable. The PSM standard ascertains that a system is in place to prepare and issue hot work permits before conducting hot work activities (welding, grinding, or using spark-producing equipment). The permit requires dates authorized for hot work, the equipment involved in the work, a system to maintain and document certification, identification of openings where sparks may drop, the types and numbers of fire extinguishers, identification of fire watches, an inspection before the work, authorization signatures, identification of flammable materials in the area verification that the surrounding area is not explosive, verification that

combustible materials are removed or covered appropriately, identification and closure of open vessels or ducts, and veritication that welded walls are not flammable. Under the management of change section of the PSM standard employees are required to develop and implement documented procedures to manage changes in the process chemistry, process equipment, and operating procedures. Before a change occurs (except for replacementin- kind), it must be reviewed to ascertain that it will not affect the safety of the operation. After the change has been made, all the affected employees are trained, and a prestartup review is conducted. The PSM standard mandates incident investigation. Employers must investigate all incidents that have or could have resulted in a major release or accident within 48 hours of the event. The regulation requires an investigation team composed of people, including operators, who are knowledgeable about the system. After the investigation, the employers are required to appropriately use the investigation recommendations The intent of the PSM element for emergency planning and response is to require employers to respond effectively to the release of highly hazardous chemicals. Although the regulation requires this activity for companies with more than 10 employees, this element should be part of a program for even the smallest organizations that handle hazardous chemicals. Under the audits section of the PSM standard employers are required to certify that they have evaluated their compliance with the standard at least every three years. The recommendations from the audit must be followed. The audit reports need to be retained as long as the process exists. The trade secrets section of the PSM standard ensures that all contractors are given all the information relevant to operating in the plant safely. Some personnel may need to sign secrecy agreements before they receive this information.