Process Safety Management

This arch pictorially represents how the requirements of PSM work to protect employees. Each segment of the arch is briefly described below including how Safety Management Services, Inc. (SMS) can support the implementation of these requirements, and what is required of your company.

SMS offers training courses on Process Safety Management and Risk Management Programs.

Elements of Process Safety Management

Process Hazards Analysis (PHA)

  1. Determine the complexity of the Process Hazards Analysis (PHA) and the implementation schedule.
  2. Define the analysis tools that are acceptable for the complexity of the process.
  3. Minimally, the PHA should cover:
    • Process Hazards
    • Previous Incidents
    • Engineering & Administrative Controls
    • Consequences of Failure of Engineering & Administrative Controls
    • Facility Siting Issues
    • Human Factors.
  4. Outline team requirements.
  5. Report findings, recommendations, implementation, and documentation.
  6. Update/reevaluate process with PHA team every 5 years.
  7. Be sure to maintain all associated PHA documentation for process life.

SMS Will:

  • Perform preliminary facility and process assessment.
  • Assist customer in prioritization of evaluation for hazardous processes.
  • Serve as PHA team leader to implement hazards analysis techniques for identification of hazards consistent with process complexity.
  • Recommend in-process energies and material response testing.
  • Document the PHA findings/recommendations.
  • Assist in establishing a system to handle the tracking of recommendations.
  • Document the corrective action resulting from the PHA findings/recommendations.
  • Participate with PHA team to periodically update/reevaluate process.
  • Assist in the establishment of a PHA documentation access and control system.

Client Will:

  • Set priorities for process evaluations.
  • Be responsible for the actual implementation of PHA findings/recommendations.
  • Be responsible for maintaining associated PHA information for the life of the process.

Process Safety Information (PSI)

  1. Provide hazardous chemicals information (i.e., SDS information):
    • Toxicity
    • Thermal and chemical
    • Exposure limits
    • Reactivity and stability data
    • Incompatible materials
    • Physical data
    • Corrosivity data.
  2. Provide process technology information:
    • Process flow diagram
    • Applicable process chemistry
    • Maximum intended inventory
    • Safe operating parameters (e.g., temperature, pressure, flow, etc.)
    • Incompatible materials
    • Evaluation of consequences of deviations.
  3. Provide process equipment information:
    • Materials of construction
    • P&IDs
    • Relief system design & design basis
    • Ventilation system design
    • Design codes and standards employed
    • Material & energy balances (processes built after May 26, 1992)
    • Safety systems (e.g., interlocks, etc.)
    • Documentation of equipment compliance with acceptable engineering practices
    • Documentation for unused equipment maintenance, testing, operation, etc.

SMS Will:

  • Assist in development and compilation of highly hazardous materials information.
  • Conduct explosives characterization testing.
  • Review/evaluate process technology and equipment information for completeness as applicable to process hazards analysis.
  • Provide follow-on consulting services for changed or modified processes/equipment.
  • Work with existing databases to assist client in maintaining process safety information.
  • Review, organize, and publish process safety and SDS information.
  • Establish policies and procedures for the storage and retrieval of all applicable information.

Client Will:

  • Be responsible for maintenance of hazardous materials information, process technology information, or process equipment information.
  • Perform hazardous chemical testing – SMS can subcontract for this effort if necessary (e.g. toxicity, corrosivity, reactivity, sensitivity, etc.).
  • Write SDS for customers.
  • Commit to handle any material that could be called hazardous waste.

Operating Procedures

  1. Development and implementation of operating procedures:
    • Steps for each operating phase (e.g., startup, normal operation, shutdown, etc.)
    • Operating limits (e.g., consequences of deviation, steps for correction, etc.)
    • Exposure limits
    • Safety and health considerations
    • Incompatible materials
    • Safety systems.
  2. Procedure accessibility to employees.
  3. Annual certification of procedure accuracy.
  4. Implementation of safe work practices (e.g., lockout/tagout, confined entry).

SMS Will:

  • Assist in drafting new/revised operation procedures as required.
  • Assist in review/evaluation of procedure accuracy and incorporation of safety and health issues.
  • Assist the PSM Certification team in the annual review of procedures.
  • Assist in review/evaluation of “Safe Work Practices” system.

Client Will:

  • Write or maintain the procedures.
  • Maintain system for employee or contractor access to procedures.
  • Certify procedures.
  • Provide process engineering expertise/data/drawings as applicable.

Training

  1. Initial training:
    • Process overview
    • Procedures
    • PHA issues
    • Safety and health hazards
    • Emergency shutdown
    • Applicable safe work practices.
  2. Refresher training:
    • Minimum every 3 years
    • Frequency to be determined with employees.
  3. Training documentation:
    • Employee identity
    • Date of training
    • Test employee understanding.

SMS Will:

  • Assist with the development and evaluation of the training system including: Curriculum, Employee Training Matrix, Refresher Training, and Documentation.
  • Assist in the development of an employee training database system for maintaining employee training documentation (e.g., curriculum, test results).
  • Assist in training related to the Process Hazards Analysis for initial and refresher training.

Client Will:

  • Implement the training system.
  • Maintain employee training documentation.

Mechanical Integrity

  1. Defines applicable equipment types.
  2. Development of procedures for maintaining equipment integrity.
  3. Maintenance personnel training.
  4. Inspection and testing of equipment:
    • Process equipment
    • Inspection and testing procedures
    • Inspection and testing frequency
    • Documentation of inspections and tests
  5. Equipment deficiencies correction.
  6. Quality assurance:
    • Verification of suitable fabrication
    • Inspection of equipment installation
    • Appropriate maintenance materials, spare parts, and equipment

SMS Will:

  • Assist the PSM team in the preparation/review of existing maintenance procedures and training programs for process maintenance.
  • Assist in developing a mechanical integrity employee training program and training maintenance personnel regarding potential hazards associated with process maintenance.
  • Review and consult on the existing inspection and testing of process equipment.
  • Assist in the development and review of inspection and testing procedures, plans, methods, and frequency.
  • Assist in the development of a system to document inspection and test data and equipment deficiencies and corrective action.
  • Consult on adequacy of QA Program.

Client Will:

  • Be responsible for updating or maintaining procedures, training records, reporting of deficiency findings, or QA program.
  • Be responsible for equipment selection, installation, or actual maintenance of process.

Incident Investigation

  1. Defines when incident investigation is required.
  2. Initiation of investigation to occur ASAP but within 48 hours.
  3. Investigation team definition.
  4. Investigation report items defined:
    • Incident date
    • Investigation start date
    • Description of incident
    • Factors contributing to incident
    • Resulting recommendations
  5. Investigation recommendations/findings resolution and documentation.
  6. Affected personnel provided access to incident report.

SMS Will:

  • Assist in development of the incident investigation procedure and documentation system.
  • Participate with the incident investigation team.
  • Perform special studies and testing to assist in incident investigations on an as needed basis.
  • Provide alternative methodologies for incident investigation.
  • Develop approach of analysis of trend incidents, including near misses.
  • Establish reporting requirements and processes for corrective action.

Client Will:

  • Initiate an incident investigation.
  • Maintain documentation associated with an incident investigation.
  • Select the incident investigation procedure/approach.

Emergency Planning and Reponse

  1. Establishment of Emergency Action Plan:
    • In accordance with 29 CFR 1910.38(a)
    • Procedure for handling small releases
    • Compliance with 29 CFR 1910.120 (Hazardous Waste)

SMS Will:

  • Provide consulting and assistance in developing an Emergency Action Plan consistent with applicable PSM regulations.
  • Assist in identifying and evaluating risks requiring emergency planning and response.
  • Provide subcontractor services for training employees and subcontractors in specific 29 CFR 1910 regulations.
  • Be available to provide consultation in an emergency situation.
  • Establish administrative procedures for emergency planning and response.
  • Provide ongoing services to periodically review plan for updates/revisions.

Client Will:

  • Provide personnel for hands-on participation in an emergency response.
  • Be responsible for or provide Emergency Action Plan documentation or implementation.
  • Be responsible for consulting and assistance to comply with requirements other than OSHA 1910.119. (EPA, Coast Guard, etc.)

Trade Secrets

  1. Information required for compliance available to responsible personnel.
  2. Confidential agreements authorized.
  3. Employee and employee representatives access to 29 CFR 1910.119 documentation in a timely and cost-effective manner.
  4. SMS has the disciplines and tools in place to lead industry into compliance with 29 CFR 1910.119 and access to standardized internal SMS compliance activities that include trade secret information.

SMS Will:

  • Provide guidance to customer regarding access and dissemination of proprietary or trade secret information.
  • Ensure that trade secret information is evaluated and protected in the PHA and other relevant elements.

Client Will:

  • Provide legal recommendations or review of employer’s system for protecting trade secret information proprietary non-disclosure agreements)
  • Maintain records or files regarding trade secret data.

Employee Participation

  1. Written action plan for implementation of employee participation.
  2. Consultation with employees/representatives regarding PHA & PSM development.
  3. Employee access to all PHA & PSM information.

SMS Will:

  • Provide in-plant consulting to the management/employee team to develop a written implementation plan.
  • Assist in developing a system for employee access to existing systems (PHA and PSM information).
  • Provide follow-on consulting service for plan/information system updates/upgrades.

Client Will:

  • Be responsible for the actual writing, implementation or distribution of the plan.
  • Maintain the system.
  • Involve employees in the PHA and PSM process.

Contractors

  1. Defines applicable contractors.
  2. Employer responsibilities:
    • Evaluate contract employers safety performance
    • Inform contract employers of potential hazards
    • Explain applicable provisions of emergency action plan
    • Implement “Safe Work Practices” for working with contract employees
    • Evaluate fulfillment of contract employer’s responsibilities
    • Maintain a contractor’s injury and illness log
  3. Contract employer responsibilities:
    • Employee training
    • Employee understands potential hazards
    • Documentation of employee training
    • Assures employees follow “Safe Work Practices”
    • Advises employer of any additional hazards

SMS Will:

  • Assist in establishing criteria/procedures for (a) evaluating contractor safety records and procedures, (b) informing contractors of potential hazards, (c) explaining Emergency Action Plan, (d) evaluating contractor performance, and (e) maintaining contractor injury/illness log.
  • Provide independent contractor evaluation.
  • Assist in establishing contract employee training and documentation program (OR) Review contractor training program and recommend changes/additions where necessary.
  • Consult/assist in the development of a hazards awareness program/procedures based on hazards analysis.

Client Will:

  • Be responsible for the implementation or maintenance of employer’s safety plans, procedures, training records, or injury/illness logs.
  • Be responsible for actual training of contract employees (subcontract services may be offered to provide OSHA training).
  • Be responsible for contracting practices or legal execution of contracts between employer and contractor(s).

Pre-Startup Safety Review (PSSR)

  1. Required for:
    • New facilities
    • Modified facilities
  2. Prestartup safety review items:
    • Construction/equipment complies with design specifications
    • Safety, operations, maintenance, and emergency procedures completed
    • PHA is complete and recommendations have been addressed and findings documented

SMS Will:

  • Assist in establishing a formalized procedure for conducting pre-startup safety reviews.
  • Provide documentation to the team on pre-startup PHA issues and resolutions.

Client Will:

  • Conduct pre-startup safety reviews
  • Maintain documentation related to the reviews

Hot Work Permits

  1. Defines when Hot Work permits are required.
  2. Documentation of Hot Work permits.

SMS Will:

  • Provide consulting services to develop/review procedures and forms for conducting hot work.
  • Provide process hazards consultation for unique situations.

Client Will:

  • Implement and enforce Hot Work permitting system.
  • Maintain Hot Work permit documentation.

Management of Change

  1. Documented procedure items:
    • Technical basis for change
    • Safety and health impacts
    • Operating procedure modifications
    • Time period for change
    • Authorization requirements for change
  2. Employee notification and training.
  3. Updating process safety information.
  4. Updating all affected procedures.

SMS Will:

  • Work with client’s existing systems to develop an MOC system which meets PSM requirements.
  • Assist the PSM team in the development/review of MOC procedures affecting covered processes.
  • Evaluate any potential process changes and review potential impacts to employee safety and health..
  • Recommend and review updates to process and maintenance procedures and training requirements.
  • Assist by drafting MOC procedures.
  • Provide on-going consulting services for hazards analysis for proposed changes.

Client Will:

  • Be responsible for the actual writing, approval, and maintenance of management of change procedures, documentation and training records.

Compliance Audits

  1. Verification of compliance with 29 CFR 1910.119.
  2. Performed every 3 years.
  3. Compliance audit team defined.
  4. Documentation of audit report findings.
  5. Corrective action documentation for audit findings.
  6. Retention of two current compliance audit reports.

SMS Will:

  • Participate with and/or lead the compliance audit team.
  • Utilize SMS-developed forms for conducting audit.
  • Assist in updating policies and procedures for 29 CFR 1910.119 compliance.
  • Issue an audit report.

Client Will:

  • Request compliance audits.
  • Maintain documentation related to the audits.
  • Certify 29 CFR 1910.119 compliance by following recommendations in the audit report.