10.4 Process Safety Management (PSM) of Highly Hazardous Chemicals (1910.119 - 14 Elements)

OSHA promulgated 29 CFR 1910.119 (Process Safety Management of Highly Hazardous Chemicals) to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. PSM is a performance-based management standard designed to protect workers in chemical plants, refineries, industrial refrigeration facilities, and manufacturing sites by establishing comprehensive management systems across 14 mandatory elements.

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Scope & Threshold Quantities (TQ)

PSM applies to any facility managing a process that involves a chemical at or above specified Threshold Quantities (TQ) listed in Appendix A of 1910.119, or a process containing 10,000 pounds (4,535.9 kg) or more of flammable liquids or gases (Category 1 flammable liquids or flammable gases with a flash point below 73.4 °F / 23 °C and boiling point below 95 °F / 35 °C).

Key Chemical Threshold Examples (Appendix A)

• Anhydrous Ammonia: 10,000 lbs
• Chlorine: 1,500 lbs
• Hydrogen Fluoride (anhydrous): 1,000 lbs
• Ethylene Oxide: 5,000 lbs
• Hydrogen Sulfide: 1,500 lbs

Exemptions: Hydrocarbon fuels used solely for workplace consumption as fuel (e.g., heating or motor vehicle fuel) if not part of a covered process; retail facilities; normally unoccupied remote facilities.

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The 14 Elements of Process Safety Management

   +-------------------------------------------------------------------------+
   |                  THE 14 ELEMENTS OF PSM (1910.119)                      |
   +-------------------------------------------------------------------------+
   | 1. Employee Participation         8. Mechanical Integrity (RAGAGEP)     |
   | 2. Process Safety Information     9. Hot Work Permit                    |
   | 3. Process Hazard Analysis (5-Yr) 10. Management of Change (MOC)        |
   | 4. Operating Procedures          11. Incident Investigation (48-Hr)    |
   | 5. Training (3-Yr Refresher)     12. Emergency Planning & Response     |
   | 6. Contractor Oversight          13. Compliance Audits (3-Yr / 2 Reports)|
   | 7. Pre-Startup Safety Review     14. Trade Secret Access               |
   +-------------------------------------------------------------------------+

1. Employee Participation (1910.119(c))

Employers must construct a written plan of action ensuring employee participation. Employers must consult with employees and their representatives on the conduct and development of Process Hazard Analyses (PHAs) and all other PSM elements, providing access to all PSM documentation.

2. Process Safety Information (PSI) (1910.119(d))

Before conducting a PHA, the employer must compile complete written PSI enabling employees to identify and understand process hazards. PSI covers three areas:

• Chemical Hazards: Toxicity, PELs, physical data, reactivity, corrosive data, thermal stability.
• Process Technology: Block flow diagrams or simplified process flow diagrams, process chemistry, maximum intended inventory, safe operating limits (temperature, pressure, flow), and evaluation of consequences of deviations.
• Process Equipment: Materials of construction, Piping & Instrumentation Diagrams (P&IDs), electrical area classification, relief system design basis, ventilation system design, and applicable design codes (ASME, ANSI, API, NFPA).

3. Process Hazard Analysis (PHA) (1910.119(e))

A systematic evaluation to identify, evaluate, and control hazards associated with the process.

• Approved Methodologies: What-If, Checklist, What-If/Checklist, Hazard and Operability Study (HAZOP), Failure Mode and Effects Analysis (FMEA), Fault Tree Analysis (FTA).
• Team Composition: Must be performed by a multidisciplinary team including at least one person knowledgeable in process technology and one person experienced in the specific PHA methodology.
• Mandatory 5-Year Revalidation: PHAs must be updated and revalidated at least every five (5) years to ensure the analysis reflects current operating reality.

4. Operating Procedures (1910.119(f))

Employers must develop clear, written operating procedures for each operating phase: initial startup, normal operations, temporary operations, emergency shutdown (including assigning shutdown authority), emergency operations, normal shutdown, and startup following turnaround. Operating limits and consequences of process deviations must be documented. Procedures must be reviewed annually.

5. Training (1910.119(g))

Initial training is required for every employee operating a covered process before assignment. Refresher training must be provided at least every three (3) years (or more frequently as determined in consultation with operators). Training records must document employee identity, date of training, and verification of understanding.

6. Contractors (1910.119(h))

Applies to contractors performing maintenance, turnaround, major repair, or specialty work on or near covered processes.

• Employer Responsibilities: Evaluate contractor safety performance and programs prior to selection; inform contractors of process hazards and emergency action plans; maintain a contract employee injury/illness log.
• Contractor Responsibilities: Train workers in safe work practices; document training records; ensure workers follow plant safety rules; report hazards and injuries to the primary employer.

7. Pre-Startup Safety Review (PSSR) (1910.119(i))

Mandatory PSSR must be performed for new facilities and for modified facilities when the modification requires a change in PSI. The PSSR confirms prior to chemical introduction that:

• Construction and equipment meet design specifications.
• Safety, operating, maintenance, and emergency procedures are in place.
• PHA recommendations have been resolved or implemented.
• Operating employee training has been completed.

8. Mechanical Integrity (MI) (1910.119(j))

Employers must establish written procedures to maintain the ongoing integrity of critical process equipment (pressure vessels, storage tanks, piping, relief valves, emergency shutdown systems, controls, pumps, interlocks).

• RAGAGEP: Inspections and testing must follow Recognized and Generally Accepted Good Engineering Practices (e.g., API 510, API 570, ASME codes).
• Documentation: Inspections must record the date, inspector name, equipment serial/identifier, description of test, and inspection results.

9. Hot Work Permit (1910.119(k))

Employers must issue a written hot work permit for all hot work operations (welding, cutting, grinding, burning) conducted on or near a covered process. The permit must document fire prevention measures per 29 CFR 1910.252(a), specify authorized dates and equipment, and be retained until completion of work.

10. Management of Change (MOC) (1910.119(l))

Employers must establish written procedures to manage changes (except "replacements in kind") to process chemicals, technology, equipment, procedures, and facilities.

• Replacement in Kind Defined: An item that satisfies the exact design specification of the original equipment.
• MOC Evaluation Requirements: Must evaluate technical basis for change, safety and health impacts, modifications to operating procedures, required authorization signatures, and necessary updates to PSI and operator training prior to startup.

11. Incident Investigation (1910.119(m))

Employers must investigate each incident that resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical ("near-misses").

• Mandatory 48-Hour Deadline: The investigation must be initiated no later than 48 hours following the incident.
• Report & Retention: A multidisciplinary team prepares a written report detailing cause and corrective actions. Corrective action resolutions must be documented, reviewed with affected operating personnel, and report retained for five (5) years.

12. Emergency Planning and Response (1910.119(n))

Employers must establish and implement an emergency action plan for the entire plant in accordance with 29 CFR 1910.38 and 29 CFR 1910.120 (HAZWOPER).

13. Compliance Audits (1910.119(o))

Employers must evaluate and certify compliance with PSM provisions at least every three (3) years.

• Conducted by at least one person knowledgeable in the process.
• Audit findings must be documented, response actions tracked, and the two (2) most recent compliance audit reports retained on file.

14. Trade Secrets (1910.119(p))

Employers must make all information necessary to comply with PSM available to team members compiling PSI, conducting PHAs, writing operating procedures, conducting MOC, investigating incidents, and performing audits, regardless of trade secret status (confidentiality agreements may be required).