Elements of Process Safety Management

A Review of the 14 Elements

A Way of Looking at the 14 Elements of PSM

Elements Concerned with Evaluation of Progress Towards Goals Process Hazards

Analysis Pre-startup Safety

Review Management of Change Incident Investigation Compliance Audits Trade Secrets

Elements Concerned with Achieving Safety Goals Employee Participation Process Safety

Information Operating Procedures Training Contractors Mechanical Integrity Hot Work Emergency Planning

Employee Participation

Purpose One of the Most Essential Elements for a Successful

Program People at Working Level Know Most about Operations Serves as a Sanity Check re: Common Sense Problems Couples with All Other Elements and Ensures

Successful Implementation What is Required, Employers Must

Have a Written Plan to Ensure Employee Participation Involve Employees in Conduct and Implementation of

PHAs & Other Elements of PSM Provide Access to PHAs and all other Information

Required to Be Developed by PSM Rule

Process Safety Information

Purpose - Ensure Personnel Have Access to Information Needed Work Safely and Efficiently

What is Required HHC Hazard Information – MSDS + other Data Needed to

Comply Info on Technology (PFDs, Process Chemistry, Max

Inventory, Safe Upper and Lower Limits, Evaluation of Consequences of Deviations)

Info on Equipment (Materials, P&IDs, Electrical Class, Relief System Design and, Design Codes and Standards, Material and Energy Balances, Safety Systems, e.g. Interlocks, etc.)

Documentation Equipment Complies with RAGAGEP For Equipment Designed in Accordance with Codes and

Standards no Longer in Use, Must Document Is Designed, Maintained, Inspected, Tested, and Operating in Safe Manner

Process Hazards Analysis

Purpose Identify Hazards and Provide a Preliminary Estimate as to Seriousness Correct Problems (Design Changes or Modifications, Adding Safety

Features, Improving Procedures and Training) What is Required

Process Hazard Analysis be Done Using – What If, Checklist, What-If/Checklist, HAZOP, FMEA, Fault Tree Analysis, etc.

PHA will Address – Hazards & Identification of Previous Potentially Catastrophic Incidents Engr. and Admin. Controls Applicable, Consequences fo Failure of

Engr. and Admin. Controls Facility Siting, Human Factors Qualitative Evaluation Of Potential Safety and Health Effects if

Controls Fail Team – Engr. and Process Operations, One Member Specific to

Process Evaluated, One Member Knowledgeable in PHA Process Employer Must

Establish System to Address Findings Update and Revalidate Every Five Years

Operating Procedures

Purpose is to Assure Safe and Reliable Operations What is Required – Employer Must:

Address Safe Actions During Initial Startup, Normal Operations, Temporary Operations, Emergency Shutdown, Emergency Operations, Normal Shutdown, Startup Following Turnaround or Emergency Shutdown

Identify Operating Limits – Consequences of Deviation and Corrective Action

Identify Safety and Health Considerations (properties and hazards and precautions to prevent or correct problems)

Identify Safety Systems and Functions Safe Work Practices Must be Addressed (e.g. lockout/tag-out,

confined space entry, etc. Procedures Shall be Reviewed as Required to Accurately Reflect

Current Operations. Employer Must Certify to this Annually

Training

Purpose is to Assure Personnel Can Accomplish Duties Safely

What is Required Initial Training with Emphasis on Safety and

Health Hazards, Emergency Operations Including Shutdown, Safe Work Practices

Refresher Training at Least Every Three Years

Training Shall be Documented

Contractors

Purpose is to Ensure Contract Employees Observe Same Safety Rules and Standards as Permanent Employees

What is Required Applies to Contractors Performing Maintenance, Repair, T/A, Renovation

or Specialty Work In or Around a Covered Process Employer Shall:

When Selecting, Evaluate Contractors Safety Performance and Programs Inform Contract Employees of Known Hazards Related to Work to be Done Explain Applicable Emergency Action Plan Provisions Expain Application of Safe Work Practices to Control Contractor Evaluate Performance Maintain a Log of Injuries and Illness

Contract Employer Shall Assure Employees Trained Assure Employees Instructed in Known Hazards and Emergency Plan Document Employees Receive and Understand Training Assure Employees Follow Safety Rules of Plant Advise Employees of any Unique Hazards Presented by Contractors Work

Pre-Startup Safety Review

Purpose is to Assure Initial Startups or Startups Following Turnarounds or Abnormal Shutdowns are Carried Out Safely

What is Required Review for New Facilities or Modified Facilities when The

Modification Requires a Change in the Process Safety Information

Must Be done Prior to Introduction of HHCs Must Confirm

Construction and Equipment Meets Design Specifications Safety, Operating, Maintenance, and Emergency Procedures

are Adequate For New Facilities a PHA has Been Done and Issues Resolved For Modified Facilities, Management of Change Procedures

Have Been Completed

Hot Work

Purpose is to Assure Workers are Not Exposed to Sources of High Energy, e.g. Explosive Substances, Toxic Chemicals, Heat, Electricity, Moving Machinery, etc.

What is Required Employer Issue Hot Work Permit for Work on or

Near Covered Process Permit Must Document Fire Prevention and

Protection in Place Principles Apply to Energy Control Procedures or

Permits to Work As Well, e.g. digging near buried cable or pipelines

Management of Change

Purpose All Accidents are a Result of Uncontrolled Changes Make Sure Changes are Properly Identified and Controlled

Before Implemented What is Required – Employers Must

Write Procedures to Manage Changes (Except for Replacement in Kind) that Address Technical Basis for the Change Impact of Change on Safety and Health Modifications to Operating Procedures Necessary Time Period for the Change Authorization Requirements for the Change

Inform and Train Operations, Maintenance, and Contract Employees Affected by the Change Prior to Start-up

Update Applicable Process Safety Information Update Operating Procedures or Practices

Incident Investigation

Purpose Provide Feedback for Prevention of Future Problems Incidents are Analogous to Hazards ( Potential Problem), Become

Accidents When Someone is Harmed After the Fact vs. Other Elements Aimed at Anticipation and

Prevention What is Required

Investigation of any Incident that Resulted or Could Have Resulted in Catastrophic Release of a HHC

Prompt Initiation, Within 48 Hours Investigation Team Formed Consisting of Knowledge of Process

Affected, Contractor if Involved, Others with Appropriate Knowledge

Report Prepared Employer has a System to Promptly and Effectively Address

Findings and Recommendations; and Document this Resolution Report is Reviewed with Affected Personnel Reports are Retained for Five Years

Emergency Planning and Response

Purpose is to Minimize Injuries and Damage in Event of an Incident or Accident

What is Required Establishment and Implementation of an

Emergency Action Plan Procedures for Handling Small Releases Training

Compliance Audits

Purpose is to Compare Performance Against the Written Standards and Procedures

What is Required Employer Certify Every Three Years He Has Verified

Procedures and Practices Required by The Rule are Adequate and Being Followed

Audit Team Include One Person Knowledgeable in Process and Other Knowledgeable Personnel

Audit Report Developed Employer Respond to Findings and Document

Deficiencies Have Been Resolved Two Most Recent Audit Reports Be Retained

Trade Secrets – Only Non-Technical Element in the Rule

Purpose To Insure Employees Have Access to Information

Needed to Perform Job Safely, Regardless of Trade Secrets

A Trade Secret is Knowledge not Patented but Gives a Co. a Competitive Advantage

What is Required Information (Regardless of Status) be Made Available to

Persons Responsible for Compiling Process Safety Information Development of Process Hazard Analysis Development of Operating Procedures Involved in Incident Investigations, Emergency

Planning and Response, and Compliance Audits Allows Employer’s to Require Confidentiality

Agreements of Employees

Summary

Consistent Roadmap Through the PSM Program

The Elements Make Good Business Sense to Assure Safe and Reliable Operations