A Guide to OSHA’s Process Safety Management Standard

What is Process Safety Management?

Process Safety Management (PSM) is an Occupational Safety and Health Administration (OSHA) regulatory standard designed for processes involving Highly Hazardous Chemicals (HHCs). This standard includes requirements for preventing catastrophic releases of toxic, reactive, flammable, or explosive chemicals. PSM serves as a comprehensive framework designed to ensure the safe management of highly hazardous substances.

What Falls Under the Process Safety Management Standard?

OSHA states that the process safety management standard applies to any process that involves a chemical with quantities at or above the specified threshold listed inAppendix A. These highly hazardous chemicals often have the following properties, defined by the Center for Chemical Process Safety (CCPS) as follows:

• Toxic Material: an airborne agent that could result in acute adverse human health effects

• Reactive Material: a substance that enters into a chemical reaction with other stable or unstable materials

• Flammable: a gas that can burn with a flame if mixed with a gaseous oxidizer, such as air, and then ignited

• Explosive: a chemical that causes a sudden release of pressure, gas, and heat when subjected to sudden shock, pressure, or high temperature

The PSM standard also covers any process that involves a Category 1 flammable gas or a flammable liquid with a flashpoint below 100 °F (37.8 °C) and in a quantity of 10,000 pounds (4535.9 kg) or more.

Compliance with PSM is not required when hydrocarbon fuels are used solely for workplace consumption and when flammable liquids are kept below their normal boiling point. PSM also does not apply to retail facilities, oil or gas well drilling or servicing operations, and normally unoccupied remote facilities.

Why is Process Safety Management Important?

In workplaces where handling chemicals is a common occurrence, protecting employees should be the number one priority. Mandated by OSHA, PSM provides a systematic approach to handling, storing, transporting, and using dangerous chemicals to prevent accidents and minimize risks.

For organizations with processes that involve the use of HHCs, complying with process safety management is crucial, not only because it’s a legal requirement, but also because the consequences of unsafe handling of hazardous chemicals can be devastating and can lead to incidents such as the 1989 Phillips 66 explosion in Houston, which killed 23 workers and injured 132 which ultimately lead to OSHA creating the PSM Standard.

Despite its introduction in 1992, another major incident occurred in 2005 at BP’s Texas City refinery, killing 15 workers, injuring 180, and costing BP over $3 billion in compensation, repairs, and lost profits.

In response, OSHA began enforcing the PSM standard more strictly and issued several revisions to reinforce compliance, promoting proactive hazard identification and a safer culture across any industry handling hazardous chemicals.

The 14 PSM Elements

To prevent incidents associated with handling hazardous chemicals, chemical safety managers need to ensure that each site has a process safety management program with all of the 14 elements:

1. Employee Participation

To begin, chemical safety managers will need to develop a plan of action for implementing employee participation in the PSM program. Additionally, managers must consult with employees on how to proceed with each element and provide access to information relevant to the program.

2. Process Safety Information

Collect and document process safety information (PSI) regarding hazards, technology, and equipment that should cover toxicity, exposure limits, physical and chemical properties, and risks with mixing materials. If safety data sheets comply with OSHA standards, hazard information is considered met.

3. Process Hazard Analysis

A process hazard analysis (PHA) evaluates process hazards, considering past incidents, control measures, and potential consequences of failures. It requires a specialized team comprising experts in engineering, process operations, and PHA methodologies. Such methodologies include PHA checklists, which should be updated and revalidated every five years, as well as other analysis tools like HAZOP, FMEA, and fault tree analysis.

4. Operating Procedures

Operating procedures should be aligned with PSI and outline the steps for each operating phase, operating limits, safety and health considerations, and safety systems and their functions. Aside from PSI on hazards, other safety and health considerations are needed as precautions to prevent exposure, control measures in case of exposure, quality control for raw materials, and control of hazardous chemical inventory levels.

5. Employee Training

Employees must receive adequate training on the process, operating procedures, emergency operations, specific safety and health hazards, and safe work practices in addition to participating in the PSM program. Chemical safety managers must conduct refresher training at least every three years, ensuring all training is documented with the employee’s identity, training date, and verification of their understanding.

6. Contractor Training

This PSM element applies to contractors performing maintenance, repair, turnaround, major renovation, and specialty work, and where their safety performance and programs are reviewed before selection. After selection, managers must periodically evaluate the contractor’s performance and provide site inductions to inform their employees of potential hazards related to the work, process, or site.

7. Pre-Startup Safety Review

A Pre-Startup Safety Review (PSSR) should be performed for new and modified facilities. It’s also used to confirm that construction and equipment are in accordance with design specifications, operating procedures have been established, and all employee training is complete.

8. Mechanical Integrity

Ensure the mechanical integrity of process equipment, including pressure vessels, storage tanks, piping systems, pumps, and monitoring systems. Document the inspections and tests conducted to rectify any deficiencies beyond acceptable limits before further use. Utilize tracking tools or software to monitor equipment status, promptly addressing any issues to prevent accidents.

9. Hot Work Permit

A hot work permit must be issued whenever hot work operations occur on or near a process. Before giving the go signal, chemical safety managers must first ensure that all fire prevention and protection requirements under the Welding, Cutting, and Brazing OSHA standard are met. The permit will confirm compliance and specify the authorized dates and the objects on which the hot work is to be performed.

10. Management of Change

Before making any changes to chemicals, technology, equipment, or facilities, prepare a management of change (MOC) procedure. It should address the technical basis for the proposed change, its impact on safety and health, modifications to operating procedures, and the authorization requirements and time period needed for the proposed change.

11. Incident Investigation

A PSM incident involves or could potentially lead to a catastrophic release of a hazardous chemical, requiring chemical safety managers to initiate an investigation within 48 hours to identify causes, contributing factors, and preventive recommendations. Prompt corrective actions must be implemented, and all affected parties should review the completed report to assess the need for further investigation.

12. Emergency Planning and Response

An emergency action plan (EAP) should be developed for the entire site in compliance with the OSHA EAP standard, including detailed procedures for managing small releases of highly hazardous chemicals (HHCs). If the site falls under the Hazardous Waste Operations and Emergency Response (HAZWOPER) OSHA standard, the EAP must also meet all applicable HAZWOPER requirements.

13. Compliance Audits

Chemical safety managers must conduct compliance audits at least every three years to verify that the site’s PSM program meets all required elements. They must document appropriate responses to each audit finding, and organizations are required by the PSM standard to retain the two most recent compliance audit reports.

14. Trade Secrets

Without regard to possible trade secret status, all information necessary to comply with the PSM standard should be made available to those involved in the PSM program. However, organizations are allowed to require such persons to enter into confidentiality agreements not to disclose any trade secret information.