Process Safety Management Awareness

Covered processes and catastrophic releases

PSM applies to a process that involves a highly hazardous chemical: a substance with toxic, reactive, flammable or explosive properties that meets one of the two tests below.

• A process with a chemical at or above its threshold quantity in Appendix A of the standard.
• A process with a Category 1 flammable gas or a flammable liquid with a flashpoint below 100 °F (37.8 °C), on site in one location, in a quantity of 10,000 pounds or more. There are exceptions, for example hydrocarbon fuels used solely for workplace consumption as a fuel (such as propane for comfort heating or gasoline for vehicle refueling), as long as those fuels are not part of a process containing another highly hazardous chemical covered by the standard.

The standard does not apply to retail facilities, oil or gas well drilling or servicing operations, or normally unoccupied remote facilities.

A process means any use, storage, manufacturing, handling or on-site movement of the chemical.

Reference: 29 CFR 1910.119(a)(1)(i) · 29 CFR 1910.119(a)(1)(ii) · 29 CFR 1910.119(b) "Process" · 29 CFR 1910.119(b) "Highly hazardous chemical" · 29 CFR 1910.119(b) "Catastrophic release" · 29 CFR 1910.119(a)(2)

Your right to take part

PSM involves the people who run and maintain the process. Your employer must consult with employees and their representatives on process hazard analyses and on the other elements of process safety management.

You and your representatives must also be given access to the process hazard analyses and to all other information the standard requires.

Reference: 29 CFR 1910.119(c)(2) · 29 CFR 1910.119(c)(3)

Written operating procedures

The employer develops and implements written operating procedures that give clear instructions for safely conducting the activities in each covered process. They include steps for each operating phase: initial startup; normal operations; temporary operations; emergency shutdown, including the conditions under which emergency shutdown is required and the assignment of shutdown responsibility to qualified operators; emergency operations; normal shutdown; and startup following a turnaround or after an emergency shutdown.

Operating limits

For operating limits, the procedures cover the consequences of deviation and the steps required to correct or avoid deviation. If a temperature or pressure goes outside its limit, the procedure tells you what that means and what to do.

• Procedures must be readily accessible to employees who work in or maintain the process.
• The employer certifies annually that they are current and accurate.

Reference: 29 CFR 1910.119(f)(1) · 29 CFR 1910.119(f)(1)(i) · 29 CFR 1910.119(f)(1)(ii)(A) · 29 CFR 1910.119(f)(1)(ii)(B) · 29 CFR 1910.119(f)(2) · 29 CFR 1910.119(f)(3)

The training you must receive

Before you operate a process

Each employee involved in operating a process, and each employee before operating a newly assigned process, is trained in an overview of the process and its operating procedures, with emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices for the job.

Refresher

Refresher training is provided at least every three years, and more often if necessary.

Records

The employer keeps a record with your identity, the date of training, and how it was verified that you understood the training.

If you maintain process equipment

The employer trains each employee involved in maintaining the on-going integrity of process equipment in an overview of that process and its hazards and in the procedures for their job tasks, so the tasks can be done safely.

Reference: 29 CFR 1910.119(g)(1)(i) · 29 CFR 1910.119(g)(2) · 29 CFR 1910.119(g)(3) · 29 CFR 1910.119(j)(3)

Safe work practices and hot work permits

Safe work practices

The employer has safe work practices to control hazards during operations such as lockout/tagout, confined space entry, opening process equipment or piping, and control over who enters the facility. They apply to employees and contractor employees alike.

Hot work

Hot work is electric or gas welding, cutting, brazing, or similar flame- or spark-producing work. The employer issues a hot work permit for hot work on or near a covered process. The permit:

• documents that the fire prevention and protection requirements in 29 CFR 1910.252(a) were put in place before the work begins
• shows the date(s) authorized and the object to be worked on
• is kept on file until the hot work is completed

Reference: 29 CFR 1910.119(f)(4) · 29 CFR 1910.119(b) "Hot work" · 29 CFR 1910.119(k)(1) · 29 CFR 1910.119(k)(2)

Management of change

Many process disasters started with a "small" change nobody reviewed. The employer has written procedures to manage changes to process chemicals, technology, equipment and procedures, and to facilities that affect a covered process.

• A replacement in kind, one that satisfies the design specification, is not a change under these procedures.
• Other changes to process chemicals, technology, equipment or procedures, such as a different gasket material, a new valve type, or a new step in a procedure, go through management of change before they are made.
• If a change affects the operating procedures, those procedures are updated.

Reference: 29 CFR 1910.119(l)(1) · 29 CFR 1910.119(b) "Replacement in kind" · 29 CFR 1910.119(l)(5) · 29 CFR 1910.119(l)(2)

If you are a contract employee

These rules apply to contractors doing maintenance or repair, turnaround, major renovation or specialty work on or next to a covered process. They do not apply to incidental services such as janitorial, food, laundry or delivery.

Who does what

• The host employer informs your contract employer of the known fire, explosion or toxic release hazards of your work and the process.
• Your contract employer makes sure you are trained in the work practices necessary to safely perform your job, and documents that you received and understood the training.
• Your contract employer makes sure you are instructed in those hazards and in the emergency action plan.
• Your contract employer makes sure you follow the facility's safety rules, including its safe work practices.
• Your contract employer tells the host about any unique hazards your work presents, or hazards your work finds.

Reference: 29 CFR 1910.119(h)(1) · 29 CFR 1910.119(h)(2)(ii) · 29 CFR 1910.119(h)(3)(ii) · 29 CFR 1910.119(h)(3)(iv) · 29 CFR 1910.119(h)(3)(v) · 29 CFR 1910.119(h)(3)(i) · 29 CFR 1910.119(h)(3)(iii)

Incidents and emergencies

Near misses count

The employer investigates each incident that resulted in, or could reasonably have resulted in, a catastrophic release. So a near miss that could reasonably have become a catastrophic release is investigated too. Report it.

• The investigation starts as promptly as possible, and not later than 48 hours after the incident.
• The report is reviewed with all affected personnel whose jobs relate to the findings, including contract employees where applicable.

Emergency action plan

The employer has an emergency action plan for the entire plant that also includes procedures for handling small releases. Know your alarm, your escape route and your assembly point.

Reference: 29 CFR 1910.119(m)(1) · 29 CFR 1910.119(m)(2) · 29 CFR 1910.119(m)(6) · 29 CFR 1910.119(n)