Process Safety Management

Employee Involvement

29 CFR 1910.1195189 Title 8

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What is PSM?

The regulations contain requirements for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable or explosive chemicals.

The establishment of process safety management regulations are intended to eliminate to a substantial degree, the risks to which employees are exposed in petroleum refineries, chemical plants and other similar facilities.

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What is the purpose of PSM?

To protect our employees and the communityTo protect the environmentThe right way to do businessIt increases employee involvement and awarenessProvides sustainable systems through on-going requirementsAnd it’s the Law!

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History Behind PSM

1980s and early 1990s witnessed an alarming number of industrial accidentsOSHA/EPA driven to prevent the unexpected releases of toxic, reactive, or flammable liquids and gasesTrade unions seeking greater protection for represented employeesCommunities demanding protection for themselves and the environmentIndustry is supportive of OSHA/EPA’s movement to protect communities, employees, and surrounding environment

Year Location Deaths Injuries

1984 Bhopal 2000+

1988 PEPCON 2 350

1989 Phillips 23 350

1990 ARCO Chemical 17

1990 BASF 2

1991 IMC 8 128

1991 Union Carbide 1

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14-PSM ElementsBuilding Blocks for Reducing Risks

Employee Participation

Operating Procedures

Process Safety Information

Process Hazard Analysis

Training Mechanical Integrity

Management of Change

Pre-Startup Safety Review

Contractor Program

Hot Work Permit

Incident Investigation

Trade Secrets

Compliance Audits

Emergency Planning

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What is PSM?

Will not be covering the following PSM Elements:

Element 6: ContractorsElement 8: Mechanical IntegrityElement 12: Emergency Planning & ResponseElement 13: Compliance AuditsElement 14: Trade Secrets

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Element 1Employee Participation

Operating ProceduresProcedure ReviewDevelopment of procedures

Incident Investigation team membersHazardous Energy Control (LOTO)

Maintaining LOTO Logs (documentation)

Employees participate in Hazops

Employee Participation is not limited to the items above.A pro-active facility will involve their employees in the other PSM elements as well.

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Element 2Process Safety Information

Hazards of the chemicalsProcess TechnologyProcess EquipmentMSDSPressure Safety Valve Design

P&ID’sDesign StandardsElectrical ClassificationEquipment RecordsSafe Operating Limits

Written information is compiled and available to allow employees to understand the hazards posed by the process which shall include, but is not limited to the following:

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Element 3Process Hazard Analysis (PHA or Hazop)

A detailed study of each process unit to ensure the fundamental design adequately addresses the process hazards and identifies the safeguards to prevent accidental releases.

The study is conducted by a team including engineering and operations expertise and trained PHA facilitator.

Hazards of the processPrevious incidentsEngineering controls for hazardsAdministrative controls for hazards

Consequences of control failuresFacility sitingHuman factorsEffect of failure on employees

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Element 4Operating Procedures

ObjectiveDevelop, implement, and maintain clearly written detailed procedures for safely operating and maintaining a process during all operating modes.

Required content in operating procedures:Operating LimitsConsequence of deviationSteps to correct or avoid deviations (Trouble Shooting)

Safety and Health MeasuresPrecautions to prevent over exposureAction to take if exposure occursHazards

Safety SystemsLockout / tagoutConfined space entryOpening process equip

Annual CertificationCurrent and accurate

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Element 5Training

Initial training Each employee presently involved in operating or maintaining a process, and each employee before working in a newly assigned process, shall be trained in an overview of the process and in the operating procedures.The training shall include emphasis on the specific safety and health hazards, procedures, and safe practices applicable to the employee's job tasks.

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Element 5Training

Refresher and supplemental trainingAt least every three years, and more often if necessary, refresher and supplemental training shall be provided to each maintenance or operating employee and other workers necessary to ensure safe operation of the facility.

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Element 7Pre-Startup Safety Review (PSSR)

The pre-start up safety review shall confirm that prior to the introduction of acutely hazardous, flammable and explosive materials to a process:

Construction and/or equipment are in accordance with design specifications;Safety, operating, maintenance, and emergency procedures are in place and are adequate;For new facilities, a process hazard analysis has been performed and recommendations have been resolved or implemented before start-up; and modified facilities

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Element 7Pre-Startup Safety Review (PSSR)

Training of each operating employee and maintenance worker has been completed.

The Pre-Start Up Safety Review shall involve employees with expertise in process operations and engineering.

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Element 9Hot Work Permit

Hot Work PermitShall develop and implement a written procedure for the issuance of "hot work" permits.The permit shall certify that the applicable portions of the fire prevention and protection requirements have been implemented prior to beginning the hot work operations;

Indicate the date(s) authorized for hot workIdentify the equipment or facility on which hot work is to be done.The permit shall be kept on file until completion of the hot work operations.

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Element 10Management of Change (MOC)

Management Of ChangeShall establish and implement written procedures to manage changes (except for "replacement in kind") to process chemicals, technology, and equipment, and changes to facilities.Employees involved in the process shall be informed of, and trained in, the change in the process as early as practicable prior to its start up.

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Element 11Incident Investigation

Incident InvestigationShall establish a written procedure for prompt reporting and investigating every incident which results in or could reasonably have resulted in a major accident.Incident investigations shall be initiated no later than 48 hours following the incident.An incident investigation team shall be established and consist of persons knowledgeable in the process involved including a contract employee if the incident involved work of the contractor, and other persons who are qualified to thoroughly investigate and analyze the incident.Shall prepare a report and either provide a copy of the report or communicate the contents of the report to all employees and other personnel whose work assignments are within the facility, where the incident occurred at the time the incident occurred