Process Safety Management (PSM) is a critical framework designed to prevent catastrophic incidents involving hazardous chemicals. More than just compliance, it’s about protecting workers, the community, and the environment by identifying, evaluating, and controlling risks.

Hazards

When it comes to highly flammable chemicals, it’s essential to understand the risks. At a minimum, information about these hazards should include:

• Toxicity
• Permissible Exposure Limits (PELs)
• Physical data
• Reactivity data
• Corrosivity data
• And, thermal and chemical stability data

Understanding the Hazards

OSHA’s 29 CFR 1910.119 outlines the specific chemicals that fall under PSM requirements, with Appendix A providing a detailed list by name. There are a few tips on how to know your hazards, including:

• Which chemicals are reactive or able to cause a runaway reaction
• Toxic, fire, or explosive hazards associated with your process chemicals
• What to do during an incident or unusual process condition
• And, read and understand the hazards listed on the Safety Data Sheets (SDS)

Elements of Process Safety Management

To ensure your company’s compliance, keep in mind the 14 PSM elements, which include:

• Employee Participation: Employees must be involved in every aspect at their worksites
• Process Safety Information: Compilation of written process safety information prior to conducting any process safety hazard analysis
• Process Hazard Analysis: Analyze the consequences of safety failures
• Operating Procedures: Employers should have a plan for keeping workers safe when work starts
• Training: Workers involved with highly hazardous chemicals must be well trained
• Contractors: Contractors must be well informed on the hazards they face
• Pre-Startup Safety Review: Review safety procedures prior to starting work
• Mechanical Integrity: Periodic documented inspections are required
• Hot Work Permit: Issue permits to anyone who welds or performs at high temperatures
• Management of Change: Standard procedures for managing changes to process chemicals
• Incident Investigation: Investigate all incidents resulting in catastrophic chemical releases
• Emergency Planning and Response: Create emergency plans for smaller releases
• Compliance Audits: Employers certify that they have evaluated compliance with provisions
• And, Trade Secrets: Employees have the right to know processes

Operating Procedures

The employer must develop and implement written operating procedures, consistent with the process safety information, which provides clear instructions for safely conducting activities involved in each covered process. OSHA believes tasks and procedures related to the covered process must be appropriate, clear, consistent, and most importantly, well communicated to employees.

Hot Work Permit

Issue a permit for any hot work operations on or near a covered process. Document in the permit that the fire prevention and protection requirements in CFR 1910.252(a) are in place before work begins. The permit must show the authorized date(s) for the hot work and remain on file until the work is complete.

Incident Investigation

A crucial part of PSM is thoroughly investigating incidents to identify the chain of events and root causes, then developing and implementing corrective measures. Begin the investigation as soon as possible, and no later than 48 hours after the incident. PSM requires the investigation of each incident resulting in, or could have resulted in, a catastrophic release of a highly hazardous chemical in the workplace.

The investigation must be a team consisting of at least one person knowledgeable in the process, including a contract employee, if the incident involved the work of a contractor, and other people with appropriate knowledge and experience to investigate and analyze the incident thoroughly. Document resolutions and corrective actions, and ensure all affected personnel whose job tasks relate to the incident findings review the report. The employer must keep incident investigation reports for at least 5 years.

Training

PSM requires employers to train every employee who operates a process, whether current or newly assigned. Training must cover an overview of the process, operating procedures, safety and health hazards, emergency operations (including shutdown), and safe work practices specific to the job. Employers must also certify in writing that each worker has the knowledge, skills, and abilities to perform their duties safely.

Conclusion

In any industry that handles highly hazardous chemicals, improper control can lead to accidental releases, and even disaster. Process safety is a team effort, and everyone has a role to play. Stay aware, know your responsibilities, and work with your team to keep yourself and others safe.