• Bryan Evans

Process Safety Management (PSM) Video Series Recap

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INTRODUCTION:

HSE Technology has assembled a series of video blogs on managing Process Safety Management (PSM) requirements. We have explored the different PSM elements from a compliance perspective and provided some best practices along the way. Here is the link to the YouTube channel with our PSM video series.

This document is a recap summary of the video series and will serve to tie the content together.


BACKGROUND:

The Occupational Safety and Health Administration (OSHA) created the first PSM requirements in 1992 as a response to a series of catastrophic incidents related to highly hazardous chemicals (HHC).

These requirements have changed and expanded several times in the last few decades, and all HHC-related companies need to keep up to date as they change and expand. To make sure your company is PSM compliant, keep in mind the following 14 elements that OSHA inspectors will audit when they review your PSM compliance program.


1. EMPLOYEE PARTICIPATION

Perhaps one of the most important mandates, the employee participation clause requires that employees—including production and maintenance staff—be involved in every aspect of the PSM programs at their respective worksites. They must also be represented (through documentation) at the meetings where PSM-related issues are discussed. OSHA requires employee participation to be followed as written, so employers should create formal plans. Having an electronic record of all employee activities makes it easier to demonstrate employee participation.


2. PROCESS SAFETY INFORMATION

Based upon OSHA’s PSM mandates, “The employer shall complete a compilation of written process safety information before conducting any process safety hazard analysis required by the standard.” In other words, all workers should be able to access and understand the technical data regarding the HHC-related risks they face on the job in which they are participating.


3. PROCESS HAZARD ANALYSIS (PHA)

One of the more technical elements of PSM, Process Hazard Analysis (PHA) requires that engineers and maintenance leaders analyze the potential consequences of safety and process failures. These analyses are conducted in teams, and the team includes one person who is “knowledgeable in the specific process hazard methodology being used.” Best practices include developing a library of electronic PHA’s and then tailor these for the particular process, project, or customer requirements. Often these PHA’s are linked into the company’s Risk Register for monitoring and control.


4. OPERATING PROCEDURES

The potential chemical hazards following turnarounds and emergency shutdowns are numerous and dangerous. These must be well-documented and auditable. OSHA inspectors want to see that companies have plans for managing process safety when starting back up.


5. TRAINING

Employees and contractors who carry out activities involving highly hazardous chemicals need to be well-trained, and their training must be delivered through a competent source. Their training also needs to be well-documented and easily audited. Training management software makes it much easier to track and report the training activities to auditors, to include ad-hoc training such as Safety Meetings.


6. CONTRACTORS

Employees and contractors must be well-informed of the hazards they face during their activities. Under the PSM National Emphasis Program, “The employer shall inform contract employers of the known potential fire, explosion or toxic release hazards related to the contractor’s work and the process.” Again, electronic records can provide an audit trail of acknowledgements of this training.


7. PRE-STARTUP SAFETY REVIEW (PSSR)

It is required to review your safety procedures every time a worksite starts back up. This also needs to be documented, with signatures or electronic acknowledgements. OSHA expects employers to perform pre-startup safety reviews (PSSR) for both new and modified facilities. This rule applies even if the procedural changes only affect a single component or process.


8. MECHANICAL INTEGRITY

Periodic, documented inspections are required for several systems, including:

Pressure vessels,Storage tanks,Relief and vent systems,Emergency shutdown systems,Controls,Pumps,Piping systems,Ventilation systems.

The employers or contractors conducting these inspections must not only be officially trained, their testing procedures must follow “recognized and generally accepted good engineering practices,” according to OSHA. In other words, your company must be able to explain WHY your inspectors made their decisions. Further, having very good records of maintenance activities for these critical systems is a very important part of demonstrating PSM compliance.


9. HOT WORK PERMIT

Every employer is required to issue permits to employees and contractors who weld or perform other high-temperature work near covered processes. They also need to train their personnel to post and file these permits when necessary. Another example of electronic records providing an audit trail.


10. MANAGEMENT OF CHANGE (MoC)

Companies are required to have standard procedures for managing changes to process chemicals, technology, equipment and procedures. Each change also requires the following considerations:

The technical basis for the change,The impact of the change on worker safety and health,Necessary modifications to operating procedures,The necessary time period for the change,Authorization requirements for the proposed change.

Good records for MoC, including approvals, is essential for demonstrating compliance.


11. INCIDENT INVESTIGATION

OSHA’s state standard calls for investigations for all incidents that result in—or could have resulted in—a catastrophic, highly hazardous chemical release. Because of that ambiguous wording, cautious companies must keep every potential HHC-related scenario in mind.

Having good records for incidents, near misses, investigations, and corrective actions leads to good performance and keeps the whole team on the same page by sharing information about relevant incidents.


12. EMERGENCY PLANNING AND RESPONSE

Even minor chemical releases can lead to major incidents. This element mandates employers to create emergency plans for handling smaller HHC releases.


13. COMPLIANCE AUDITS

According to the PSM-NEP, “Employers shall certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed.” This element also requires employers to retain at least their two most recent audit reports.

Good documentation of audits, easily demonstrated to auditors, is crucial to maintaining compliance.


14. TRADE SECRETS

Until recently, some companies attempted to protect proprietary information by keeping process details from their employees. To prevent this scenario and enhance worker safety, the “trade secrets” PSM element gives employees and contractors the right to know processes that may affect their health and safety.

Having trouble managing all these PSM requirements? HSE Technology can help you with PSM software in the Cloud that provides one centralized location for all of your PSM documents, training, maintenance, audits, incidents, improvements, and more. For more information about these easy-to-use applications, contact us today at hsetechnology.com.


SUMMARY:

Process Safety Management (PSM) Compliance can be challenging to administer, especially for smaller organizations. There are many mandated activities and documentation requirements. It is easy to let things fall through the cracks. Those oversights tend to be revealed during audits.

The fact that PSM requirements crosses many organizational responsibilities makes it difficult to keep everyone on the same page. Highlighting that fact is the first element: Employee Participation. Compliance requires rigorous record-keeping which often results in many different organizational elements working together to provide a complete accounting of PSM activities. Accurate reporting begs for a system!


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