Intro To PSM at UI-WCP Oct 2019 (Workshop)

INTRODUCTION TO PROCESS
SAFETY MANAGEMENT
Special Lecture at Universitas Indonesia
under WCP Program
by
Prof. Dr Azmi Mohd Shariff
Universiti Teknologi PETRONAS
azmish@utp.edu.my
Oct 2019
© 2016 INSTITUTE OF TECHNOLOGY PETRONAS SDN BHD
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1
Learning Outcome
• Acknowledge why process safety need to be

implemented, managed, and regulated.
• Recognize US OSHA CFR1910.119 as one of the structured

regulations to manage and control major process safety
accidents.
2
Outline
• Introduction
• What is Management System
• Process Safety Management System
• 14 Elements of OSHA PSM
• PSM Summary
3
Major Accident
• Seriousness of consequences and

complex mechanisms of causation
• Many of the key decisions made by Bhopal 1984. Fatality 2,500++
people at another site, country or

organization
• Causes differ from those for

personnel safety
Piper Alpha, 1988. Fatality 167 and
about US3.4billion losses
• Need to look at the whole picture
• Management system approach for

control
BP Texas, 2005. USD1.5Billion losses

4
Motivation for the development of Process
Safety Management worldwide
OSHA CFR1910.119 PSM
1992, US
Major Hazard
Incidents Amended SEVESO II
worldwide Directive 2003, EUROPE
COMAH 2015, UK
Safety Case 2014,

Singapore
CIMAH 1996, Malaysia
Expanding Scale
of Operation &
New CIMAH
Technical
Complexity
Many authorities worldwide strengthen
the regulation on Process Safety
Management
5
What is Management System?
 Common management
 Formally
system operating model
established set of
activities designed
Policy/Goals
to:
- Produce specific
results
Review(Act) Identify need
- in a consistent (Plan)
manner
- on a sustainable Corrective
basis Action Activities
(Check) (Implement/Do)
6
What Is Process Safety Management
System?
Requirements for preventing

Requirements for
or minimizing the
managing hazards consequences of catastrophic
associated with releases of chemicals that
processes using highly are:
hazardous chemicals Toxic Reactive
Flammable Explosive
7
Differentiation with Occupational
Safety
In September 1998, Esso plant at Longford in Victoria,
Australia suffered a major fire. 2 men were killed and
the state’s gas supply was severed for 2 weeks.
1997 had passed without a single lost time injury and

Esso Australia had won an industry award for this
performance. It had completed around 5 million work
hours without a LTI to either an employee or
contractor.
8
Process Safety vs.
Occupational Safety
• If we’re in charge of • If we’re in charge of
safety and we think of safety and we think of
hazards like this… hazards like this…
Slips, Trips, & Falls

Unsafe Acts
Unsafe Conditions
On Site Hazard ID
Safety Meeting Asset Integrity HAZOP
JSA & PPE PHA LOPA
Major Accident Hazard
• We’re probably doing • We’re probably doing

“personal safety” “process safety”
9
Process Safety vs. Occupational
Safety – Risk Matrix Profile
Occupational
safety hazards -
“high likelihood
with low
consequence
incidents.”
Process safety
hazards - “low
likelihood
with (very)
high
consequence”
incidents.
10
What Is Process Safety Management?
CFR1910.119 PSM Standards 14 Elements
• Employee Participation • Mechanical Integrity
• Process Safety • Hot Work (Non-routine
Information Work Authorizations)
• Process Hazard Analysis • Management of Change
• Incident Investigation
• Operating Procedures
• Emergency Planning and
• Employee Training
Response
• Contractors
• Compliance Audits
• Pre-Start up Safety
• Trade Secret
Review
11
Covered Process
• Basis: Process which involves a highly hazardous chemical at or
above the specified threshold quantities
– 29 CFR 1910.119 PSM Standards Appendix A – listing of highly hazardous
chemicals which present a potential for a catastrophic event at or above
the threshold quantities.
• Mainly consists of
– proactive identification
– evaluation and
– mitigation or prevention of chemical release
that could occur as a result of failure in processes, procedures or
equipment
12
PSM Rule Provisions
Employee Pre-Startup Hot Work

Participation Safety Review Permits
Process Safety Mechanical Management

Information Integrity of Change
Process Hazard Incident

Contractors Trade Secrets
Analyses Investigations
Emergency
Operating Compliance
Training Planning and
Procedures Audits
Response
13
Employee Participation
Requirement:
• Written plan of action to implement &
ensure employee participation
– Roles of employees in the PSM programs
development
• Employer must consult with employees and

representatives:
– Development of all elements of PSM system
especially in process hazard analyses
14
Employee Participation cont.
• Consultation / participation:
• determine frequency of training
and content of initial and
refresher training.
• develop and review operating

and maintenance procedures.
• Involve in incident
Image from: http://www.flsmidth.com/en-
investigations for the covered us/eHighlights/Archive/Cement/2013/April/Proactive+maintenance+to+secure+
availability
process.
15
Employee Participation cont.
Communicate PSM program information to employees
Inform affected employees of the findings from incident

investigation, audits and Process Hazard Analysis (PHA)
Easy access to important PSM information:

 Process Safety information (PSI), PHAs, etc.)
 Incident and near miss review information
 Emergency response plans and procedures.
16
PSM Rule Provisions



Emergency
Procedures Audits
Response
17
Comprehensive Process Safety
Information
Compile,
develop and Technology &
Process
Hazards &
maintain Chemicals
written
process safety
Process
information: Equipment
Comprehensive Process
Safety Information
18
Information (PSI) - Chemical
 Hazards of the chemical include:
• Toxicity information
• Permissible exposure limits
• Physical data
• Reactivity data
• Corrosivity data
• Thermal and chemical stability
data
• Hazard effects of inadvertent
mixing of different materials
19
Information (PSI) - Technology
 Information Pertaining to
the Technology of the
Chemical Process
• Block Flow Diagram
• Process Chemistry
• Maximum Intended
Inventory
• Safe Upper/Lower Limits
• Evaluation of
consequences of
deviations, including
those affecting safety and
health of employees.
20
Information (PSI) - Equipment
 Equipment of the chemical process includes:
• Materials of Construction
• Piping and Instrument Diagrams (P&IDs)
• Electrical Classifications
• Relief System Design and Design Basis
• Ventilation System Design and Design Basis
• Design Codes and Standards
• Material and Energy Balances for Processes
• Safety Systems
• Equipment complies with recognized and generally good
engineering practices.
• Equipment designed/constructed to codes/standards no
longer in general use.
21
Information
Safety Information Must Be Accessible To All
Will be used by:

• Team performing process hazard analyses
• Contractors who will be working within the
process
• Those developing training programs &
operating procedures
• Pre-startup reviews team
• Local emergency preparedness planners &
enforcement officials
22
PSM Rule Provisions


Process
Incident
Hazard Contractors Trade Secrets
Investigations
Analyses
Emergency
Procedures Audits
Response
23
Process Hazard Analysis
• PHA Identifies:
 Hazards of the process
 Previous incident
 Engineering &
administrative controls
 Consequences of failures
 Facility sitting
 Human factors
 Possible health & safety
effects on associates should
there be a release.
24
Image from: http://www.toyo-eng.com/jp/en/products/analysis/hazard/
PSM Rule Provisions



Emergency
Procedures Audits
Response
25
Operating Procedures
Operating procedures to at least address the followings:
Steps of each phase
-initial start-up Safety & health considerations
-normal shutdown -properties and hazards of the
-normal & temporary chemicals
operations -precautions & control
-emergency operations & requirements
shutdown -safety system
Operating limits
-consequences of deviation
-steps required to correct or
avoid deviation
26
Operating Procedures
• Standard Operating Procedures • Procedures Should
– Documents the steps to – State the operating limits
operate the process safely – Discuss the consequences
– Include Job Hazard Analysis of deviation
(JHA) – Address safety and health
issues
• Procedures Must Be • Align with training program

– Written – Partner with Quality Team
– Consistent with the Process (ISO 9001) to create
Safety Information (PSI) training matrix and
– Well communicated to the documents management
employees
27
Operating Procedure for Non-routine Work
Develop and implement safe work practices* to

control the process hazards during:
– Lockout/tagout;
– Confined space entry;
– Opening process equipment or
piping; and
– Control over entrance into a facility by maintenance,
contractor, laboratory, or other support personnel
* These safe work practices also apply to contractor’s

employees 28
PSM Rule Provisions



Emergency
Procedures Audits
Response
29
Training Primary Requirements
1st – initial training that include “an overview of process and

operating procedures”
2nd – refresher training for employees who are involved in

operating a process. To ensure affected employees continue to
understand the operating requirements e.g. operating procedures
3rd – training to be recorded & documented.
• These explicit requirement though are able to be applied &

implemented in a wide variety of ways
30
PSM Rule Provisions



Emergency
Procedures Audits
Response
31
Contractors Management
• Contractor Provisions:
 Apply to contractors performing maintenance, repair,
turnaround, major renovation or specialty work on or
adjacent to a covered process
 Require that process owners screen and hire
contractors that perform work safely
 Contractors should implement their own safety
programs
 All must work to ensure good communication.
 Not applicable to contractors providing
incidental services such as janitorial work,
food and drink services, laundry, etc
32
Contractors Management cont.
• Ensure that Contractors Work Safely and Understand the
Potential Process Hazards
• Provision of Contractor Safety Orientation Must Be Included
As a Requirement of Every Contract
• Important to:
– Inform Contractor and their Employees of Known
Potential Process Hazards
– Review Contractor’s Safety Performance and Safety
Training Program
– Inform Contractors of Emergency Action Procedures
– Maintain an Injury and Illness Log
33
Contractors Management cont.
Absolute Requirements
• Contract employee injury and illness logs related to work in covered process areas.
• 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.
34
PSM Rule Provisions



Emergency
Procedures Audits
Response
35
Mechanical Integrity
• Applicable to the following items :

– Pressure vessels and storage tanks,
– Piping systems
– Relief and vent systems and devices,
– Emergency shutdown systems,
– Controls system
– Pumps
36
Mechanical Integrity cont.
• Industry may also include other items such as (though

not listed):
– Rotating equipment.
– Heat exchange equipment.
– Electrical generation and distribution equipment.
– Un-interruptable power supplies.
– Emergency power supply equipment.
– Fire protection equipment.
– etc
37
Mechanical Integrity –
Inspection & Testing
• Inspections and tests must be performed on process
equipment according to - Recognized and Generally
Accepted Good Engineering Practices (RAGAGEP)
such as MS, ASTM, ASME, ANSI and PTS
• Frequency of inspections and tests must be consistent with

applicable manufacturers' recommendations and good
engineering practices.
• Prior operating experience may indicate more frequent

testing and inspection than manufacturers’
recommendations.
• Each performed inspection and test on process related

equipment must be documented.
38
Mechanical Integrity –
Quality Assurance
• Employer must assure that
– all new plants and equipment are suitable for
the intended process application.
– appropriate checks are performed to assure

that equipment is installed properly and
consistent with design specifications and the
manufacturer's instructions.
– maintenance materials, spare parts and

equipment are suitable for the intended
process application.
39
PSM Rule Provisions



Emergency
Procedures Audits
Response
40
Pre-Start up Safety Review (PSSR)
• Ensures that New and Modified Processes are safe to operate
• PSSR’s must be conducted prior to the induction of feed
• Confirm that;
 Construction and equipment • New Process Safety
are in accordance with design Information have been
specs recorded during PSSR
 Safety, operating, maintenance
• Procedures, training and
and emergency procedures are
equipment records are
in placed
available and updated
 A PHA has been performed and
recommendations have been • any changes, modifications,
resolved or implemented and additions made are
before start-up. thoroughly checked and
reviewed before flip on the
switch.
41
PSM Rule Provisions



Emergency
Procedures Audits
Response
42
Hot Work
What are Hot work?

• cutting, welding, soldering and brazing
operations for construction/
demolition/maintenance/repair
activities that involve the use of
portable gas or arc welding equipment
• Hot work shall cover the following

processes:
 Welding and allied processes
 Heat treating
 Grinding
 Thawing pipe
 Power-driven fasteners
 Hot riveting
 Any other spark, flame or heat
43
Hot Work Permit
• The employer must issue a hot work

permit for hot work operations
conducted on or near a covered
process.
• The permit must document:
– fire prevention requirements have been
implemented before starting the hot work
operations;
– date(s) authorized for hot work; and,
– object on which hot work is to be
performed.
• The permit must be kept on file until
completion of the hot work
operations.
44
PSM Rule Provisions



Emergency
Procedures Audits
Response
45
1910.119 Process Safety Management of
Highly Hazardous Chemicals
All staff must follow a written MOC procedure to assure that all
of the following considerations are addressed prior to making
any change:
I. Technical basis for the proposed change

II. Impact of change on safety and health
III. Modifications to operating procedures
IV. Necessary time period for the change
V. Authorization requirements
MOC
CFR 1910.119 (l)(2)
46
Management of Change cont.
• Create formalized system to review and

manage all changes:
 Process chemicals
 Process technology
 Equipment
 Procedures
 Facilities that affect a covered process.
• Does not apply to “replacements in kind”

 Replacements of similar function with existing
design specifications.
47
PSM Rule Provisions



Emergency
Procedures Audits
Response
48
Incident Investigation
Investigate each
incident, which
resulted in, or could Investigate
reasonably have Incidents
&
Begin within
48-hours
resulted in a Near-Misses
catastrophic release
of highly hazardous
chemical. Reatain Incident Team
with Process
Reports 5-years
Investigation Knowledge
Follow-up Report with

System for Conclusions &
Recommendations Recommendatons
49
Incident Investigation
Investigation report
Investigation team Report
• An incident investigation team • A report shall be prepared
shall be established and at the conclusion of the
investigation which includes
consist of: at a minimum:
i. At least one person i. Date of incident;
knowledgeable in the ii. Date investigation
began;
process involved iii. A description of the
ii. a contract employee if the incident;
incident involved work of iv. The factors that
contributed to the
the contractor incident
iii. other persons with v. Any recommendations
resulting from the
appropriate knowledge and investigation.
experience to thoroughly
investigate and analyze the
incident.
50
PSM Rule Provisions



Emergency
Procedures Audits
Response
51
Minimum Requirements of an
Emergency Action Plan
Establish and implement an emergency action plan for entire plant including
handling small releases.
May also be subjected to the hazardous waste and emergency response provisions
1. Procedures for reporting a 6. The name or job title of

fire or other emergency every employee who
2. Procedures for emergency has duties under the
evacuation plan
3. Emergency shutdown 7. An employee alarm
procedures system
4. Procedures to account for 8. Training
all workers 9. Review with each
5. Procedures to be followed employees
by employees performing 10. Practice drills
rescue or medical duties
52
Hazardous Waste Operations and
Emergency Response
The following operations are covered by 1910.120:

1. Clean-up operations required by a governmental body.
2. Corrective actions involving clean-up operations at sites
covered by the Resource Conservation and Recovery Act of
1976 (RCRA).
3. Voluntary clean-up at uncontrolled hazardous waste sites.
53
PSM Rule Provisions



Emergency
Procedures Audits
Response
54
Compliance Audits
• Audit the compliance of your PSM program every 3

years to verify PSM system and procedures are
adequate and being followed.
• The audit must be conducted by at least one person
knowledgeable in the process.
• Develop a report of the audit findings and document
appropriate response to each finding.
• Document when deficiencies have been corrected.
• Retain two most recent compliance audit reports.
55
PSM Rule Provisions



Emergency
Procedures Audits
Response
56
Trade Secrets
• A trade secret could be a formula, device, pattern or compilation of
information used in one’s business and provides them the opportunity for
advantage over competitors.
• Employers must make trade secret information available to persons

responsible for:
– Compiling the process safety information
– Developing of the process hazard analysis and operating procedures;
– Incident investigations, emergency planning and response, and
compliance audits.
• Confidentiality agreements are permitted.
57
Concern
Post CFR 1910.119 Standard 1992, major process accidents still
happen due to the following key reasons:
1. Process Safety Culture
2. Process Safety Competency
3. Stakeholder engagement
4. Conduct of Operations
5. Measurement and Metrics
6. Management Review and Continuous Improvement
Address by
RISK BASED PROCESS SAFETY (RBPS) BY CCPS

58
PSM Summary
• Facilities with a process using a highly hazardous chemical in an amount
exceeding the TQ must develop, document and implement:
– Written hazard information, process analysis, operating procedures,
emergency procedures and employee/contractor training.
– Maintenance procedures, inspections, incident evaluations.
– Re-evaluation of PSM information, procedures, compliance audits of
processes and related equipment, and refresher training every three
years.
– PHA must be updated & revalidated every 5 years.
– Audit on the quality of the efforts that go into each PSM program
element.
• Importantly, two key elements that can insured the highest quality PSM
program: management commitment and skill of implementation.
59
The End
Thank You!
60

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INTRODUCTION TO PROCESS

• Acknowledge why process safety need to be

• Recognize US OSHA CFR1910.119 as one of the structured

• Seriousness of consequences and

• Many of the key decisions made by Bhopal 1984. Fatality 2,500++

people at another site, country or

• Causes differ from those for

• Management system approach for

BP Texas, 2005. USD1.5Billion losses

Safety Case 2014,

CIMAH 1996, Malaysia

Requirements for preventing

1997 had passed without a single lost time injury and

Slips, Trips, & Falls

• We’re probably doing • We’re probably doing

• Employee Participation • Mechanical Integrity

• Process Safety • Hot Work (Non-routine

Information Work Authorizations)

• Process Hazard Analysis • Management of Change

Employee Pre-Startup Hot Work

Process Safety Mechanical Management

Process Hazard Incident

• Employer must consult with employees and

• develop and review operating

Communicate PSM program information to employees

Inform affected employees of the findings from incident

Easy access to important PSM information:

Employee Pre-Startup Hot Work

Process Safety Mechanical Management

Process Hazard Incident

Will be used by:

Employee Pre-Startup Hot Work

Process Safety Mechanical Management

Employee Pre-Startup Hot Work

Process Safety Mechanical Management

Process Hazard Incident

• Procedures Must Be • Align with training program

Develop and implement safe work practices* to

* These safe work practices also apply to contractor’s

Employee Pre-Startup Hot Work

Process Safety Mechanical Management

Process Hazard Incident

1st – initial training that include “an overview of process and

2nd – refresher training for employees who are involved in

3rd – training to be recorded & documented.

• These explicit requirement though are able to be applied &

Employee Pre-Startup Hot Work

Process Safety Mechanical Management

Process Hazard Incident

Employee Pre-Startup Hot Work

Process Safety Mechanical Management

Process Hazard Incident

• Applicable to the following items :

• Industry may also include other items such as (though

• Frequency of inspections and tests must be consistent with

• Prior operating experience may indicate more frequent

• Each performed inspection and test on process related

– appropriate checks are performed to assure

– maintenance materials, spare parts and

Employee Pre-Startup Hot Work

Process Safety Mechanical Management

Process Hazard Incident

Employee Pre-Startup Hot Work