9.2 Process Safety Management (PSM) (29 CFR 1910.119)

Process Safety Management (PSM) (29 CFR 1910.119)

Introduction & Applicability of PSM

The Process Safety Management of Highly Hazardous Chemicals standard (29 CFR 1910.119) contains requirements for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. A release of these chemicals can cause toxic exposure, fires, or explosions, resulting in catastrophic injuries and fatalities.

PSM applies to processes involving highly hazardous chemicals (HHCs) that exceed specified Threshold Quantities (TQs). A "process" is defined as any activity involving an HHC, including use, storage, manufacturing, handling, or on-site movement. The standard lists over 130 HHCs in Appendix A with specific TQs:

• Anhydrous Ammonia: TQ of 10,000 pounds.
• Chlorine: TQ of 1,500 pounds.
• Flammable Liquids or Gases: TQ of 10,000 pounds, unless stored in atmospheric tanks below their normal boiling point without refrigeration, or used solely for fuel.
• Hydrogen Fluoride (Anhydrous): TQ of 1,000 pounds.

The 14 Elements of PSM

The standard outlines 14 interdependent elements forming a comprehensive safety management system.

1. Employee Participation

Employers must develop a written plan of action for employee participation, consulting employees on the development of PHAs and other elements, and providing access to all process safety information.

2. Process Safety Information (PSI)

Before performing a PHA, employers must compile written Process Safety Information (PSI) regarding:

• Chemical Hazards: Toxicity, PELs, physical data, reactivity, corrosivity, and thermal stability.
• Process Technology: Flow diagrams, process chemistry, maximum inventory, and operating limits.
• Process Equipment: Materials of construction, P&IDs, electrical classification, relief and ventilation system designs, and adherence to Recognized and Generally Accepted Good Engineering Practices (RAGAGEP).

3. Process Hazard Analysis (PHA)

A PHA is a systematic effort to identify, evaluate, and control process hazards. It must be performed by a multidisciplinary team including at least one employee with experience and knowledge of the specific process.

• Methodologies: Acceptable methods include What-If, Checklist, Hazard and Operability Study (HAZOP), Failure Mode and Effects Analysis (FMEA), or Fault Tree Analysis.
• Frequency: PHAs must be updated and revalidated at least every five (5) years to ensure they reflect current conditions.
• Action Tracking: Employers must establish a system to address team findings, document resolutions, and communicate actions to operating and maintenance staff.

4. Operating Procedures

Employers must implement written operating procedures providing instructions for safe operations, addressing:

• Steps for each operating phase (startup, normal, emergency shutdown, and shutdown).
• Operating limits and consequences of deviations.
• Safety and health considerations (chemical hazards, controls).
• Safety systems and their functions.

Operating procedures must be reviewed and certified annually (every 12 months) to ensure they reflect current practices.

5. Training

Employees operating a covered process must receive initial training in an overview of the process and operating procedures. Refresher training must be provided at least every three (3) years to maintain competency.

6. Contractors

Employers must evaluate the safety performance and programs of contract employers before selection. They must inform contract employers of the potential fire, explosion, or toxic release hazards related to the contractor's work and the process.

7. Pre-Startup Safety Review (PSSR)

A PSSR is required for new and modified facilities when changes require updating PSI. Prior to introducing chemicals, the review must confirm:

• Construction and equipment meet design specifications.
• Safety, operating, maintenance, and emergency procedures are in place.
• New facility PHAs are performed and recommendations resolved.
• Modified facilities comply with Management of Change rules.

8. Mechanical Integrity (MI)

Employers must implement written procedures to maintain the ongoing integrity of process equipment (pressure vessels, tanks, piping, relief systems, shutdown systems). Inspection and testing must follow RAGAGEP.

9. Hot Work Permit

The employer must issue a hot work permit for operations conducted on or near a covered process, documenting that fire prevention requirements were met.

10. Management of Change (MOC)

Employers must implement written procedures to manage changes (except 'replacements in kind') affecting process chemicals, technology, equipment, and procedures. The MOC must address:

• Technical basis for change.
• Safety and health impacts.
• Modifications to operating procedures.
• Necessary time period and authorizations.

Employees and contractors affected must be trained in the change prior to startup.

11. Incident Investigation

Employers must investigate each incident that resulted in, or could reasonably have resulted in (a 'near miss'), a catastrophic release.

• Timeline: Must be initiated within 48 hours.
• Team: Includes at least one person knowledgeable in the process, plus any relevant contractors.
• Report: Identifies the date, description, contributing factors, and recommendations. Findings must be resolved and reviewed with affected staff. Reports must be kept for five years.

12. Emergency Planning and Response

Employers must implement an emergency action plan in accordance with 29 CFR 1910.38 and 29 CFR 1910.120.

13. Compliance Audits

Employers must evaluate compliance with PSM at least every three (3) years. The audit requires at least one person knowledgeable in the process. Employers must document findings, correct deficiencies, and retain the two (2) most recent audit reports.

14. Trade Secrets

Employers must make all information necessary to comply with the standard available to those compiling PSI, performing PHAs, developing operating procedures, investigating incidents, or auditing, without regard to trade secret status.