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Process Safety Management

By Graphic Products Editorial Staff

Chemical Labeling and Process Safety Management

OSHA established a Process Safety Management (PSM) standard that applies to all companies that use any one of more than 130 dangerous chemicals. The OSHA Process Safety Management standard includes companies that use more than 10,000 pounds of flammable liquids and gases.

Overview of Requirements

Unexpected releases of toxic, reactive or flammable chemicals continue to be regularly reported. There is a potential for an accidental release any time these types of materials are not properly controlled. This creates the potential for a disaster. The purpose of the OSHA Process Safety Management standard is to prevent these types of releases.

Understanding OSHA's approach to process safety management requires an understanding of what OSHA means by the term “process.”  The OSHA definition of process is: “any activity involving a highly hazardous chemical including using, storing, manufacturing, handling, or moving such chemicals at the site, or any combination of these activities.”  In addition, OSHA defines any group of vessels that are interconnected, as well as separate individual vessels, that could result in the release of a highly hazardous chemical, as part of a single process.

Labels and Signs in Process Safety Management

Labels and signs play a critical role in all aspects of process safety management. They reliably provide hazard warnings, operating information, and safety reminders at the physical locations where this information is most needed.

Process Safety Management - OSHA Required Information

The starting point in process safety management is to compile written process safety information. OSHA requires that this be done before conducting a process hazard analysis. The compilation of written process safety information will help both the employer and employees identify and understand the hazards of processes involving highly hazardous chemicals.

Process safety information must include details about the hazards of the highly hazardous chemicals used or produced by the process. It must also describe the technology and equipment used in the process.  OSHA requires that, at a minimum, the following be included:

Information about Chemical Hazards:

  • Toxicity
  • Permissible exposure limits
  • Physical data
  • Reactivity data
  • Corrosivity data
  • Thermal and chemical stability data, and the hazardous effects of inadvertent mixing of different materials

In some cases the above information may already be available in Material Safety Data Sheets which, as of June 2015 will be found on the HazCom 2012 converted Safety Data Sheets.

The Process Technology:

  • A block flow diagram or a simplified process flow diagram
  • Description of the process chemistry
  • Maximum intended inventory
  • Safe upper and lower limits for such parameters as temperatures, pressures, flows and compositions.
  • An evaluation of the consequences of deviations, including those deviations affecting the safety and health of employees.

If the original technical information no longer exists, the needed technology information may be developed as a part of the process hazard analysis.

The information about the equipment in the process must include the following:

  • Materials of construction
  • Piping and instrument diagrams (P&IDs)
  • Electrical classification
  • Relief system design and design basis
  • Ventilation system design
  • Design codes and standards employed
  • Material and energy balances for any processes built after May 26, 1992
  • Safety systems (e.g., interlocks, detection, or suppression systems)

In addition, the OSHA Process Safety Management standard requires that the employer document that process equipment complies with recognized and generally accepted good engineering practices.

Process Safety Management - Process Hazard Analysis

The next step, the process hazard analysis, is a systematic approach for identifying, evaluating and controlling the hazards. The process hazard analysis methodology that is used must be appropriate for the complexity of the process and it must identify, evaluate and control all of the hazards involved in the process.

OSHA identifies following methods as appropriate for a process hazard analysis:

  • What-if
  • Checklist
  • What-if/checklist
  • Hazard and Operability Study (HAZOP)
  • Failure mode and effects analysis (FMEA)
  • Fault tree analysis
  • Or an appropriate equivalent methodology

The most commonly used method is the Hazard and Operability Study.

Process Safety Management - Operating Procedures

Clear, consistent written operating procedures need to be developed and implemented. The operating procedures must be consistent with the process safety information and provide clear instructions for safely operating and conducting activities associated with a process. OSHA requires that the procedures, at a minimum, address at least:

Clear, consistent written operating procedures need to be developed and implemented. The operating procedures must be consistent with the process safety information and provide clear instructions for safely operating and conducting activities associated with a process. OSHA requires that the procedures, at a minimum, address at least:

Steps for each operating phase:

  • Initial process startup
  • Normal operations
  • Temporary operations
  • Emergency shutdown (Includes defining the conditions under which an emergency shutdown is required. It should also include assigning qualified operators who can ensure the emergency shutdown is executed in a safe and timely manner.)
  • Emergency operations
  • Normal shutdown
  • Startup following a turnaround, or after an emergency shutdown.

Operating limits:

  • Consequences of operating deviations
  • Steps required to correct or avoid deviations

Safety and health considerations:

  • The properties and hazards of the chemicals used in the process.
  • Precautions necessary to prevent exposure.
  • Control measures to be taken if there is a physical or airborne contact, or exposure.
  • Quality control for raw materials and control of hazardous chemical inventory levels.
  • Any special or unique hazards.

Safety systems (interlocks, detection systems, suppression systems) and their functions.

There must be appropriate safe work practices in place for the control of hazards during work activities such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. These safe work practices apply to both employees and contract employees.

Process Safety Management - Employee Participation

Employee participation is required by the OSHA Process Safety Management standard. It requires that employers consult with employees and their representatives on the conduct and development of process hazard analyses and on the development of the other elements of process management.  In addition, employers must provide access to process hazard analyses and all other information that is required by the OSHA PSM standard.

Process Safety Management - Training

Process Operator Initial Training

The OSHA PSM requires each employee who is involved in operating a process, or who has been newly assigned to operate a process, be trained in an overview of the process and in its operating procedures. The training must have an emphasis on the specific safety and health hazards of the process; emergency operations including shutdown; and other safe work practices that apply to the employee’s job tasks.

Process Operator Refresher Training

To ensure that the employee understands and adheres to the operating procedures, refresher training must be provided at least every three years, or more often if necessary.

As an employer you must determine that each operator has received and understood the initial and refresher training required by OSHA.  A written record must be kept identifying the employees who were trained, the date of training, and how the employee's understanding of the training was verified.

Process Safety Management - Pre-Startup Safety Review

Before a new highly hazardous chemical is introduced into a process a safety review must be conducted.  The review must confirm that the following:

  • Construction of the process and the process equipment are in accordance with design specifications.
  • Safety, operating, maintenance and emergency procedures are in place and are adequate.
  • A process hazard analysis has been performed and the recommendations have been resolved or implemented.
  • Training of each operator involved with the process using the new chemical has been completed.

Process Safety Management - Mechanical Integrity

OSHA requires that employers have written maintenance procedures for process equipment and that the procedures are followed.

Employees involved with maintaining process equipment must be trained in an overview of that process and its hazards. They must also be trained in the procedures that are applicable to the tasks they need to perform.

Process equipment must be inspected and tested using procedures that follow recognized and generally accepted good engineering practices. Each inspection and test must be documented, identifying the date and the name of the person who performed the inspection or test; the serial number or other methods of identifying the equipment; a description of the inspection or test performed; and documentation of the results.

Any equipment deficiencies must be corrected.

The OSHA mechanical integrity requirements apply to the following types of equipment:

  • Pressure vessels and storage tanks
  • Piping systems (including piping components such as valves and flanges)
  • Relief and vent systems and devices
  • Pumps
  • Emergency shutdown systems
  • Controls (including monitoring devices and sensors, alarms, and interlocks)

Process Safety Management - Incident Investigation

A crucial part of a Process Safety Management program is a thorough investigation of any incidents. The purpose is to identify the cause, and the chain of events that lead to the incident, so that corrective measures can be implemented.

An incident investigation must be initiated promptly, and no later than 48 hours following the incident. The investigation must be conducted by a team with at least one person who is knowledgeable about the process. If a contractor employee was involved, then the team must include an employee of the contractor.  The team should also include other people who have the appropriate knowledge and experience to investigate and analyze the incident thoroughly.

An investigation report must be prepared and include at least:

  • Date of incident
  • Date investigation began
  • Description of the incident
  • Factors that contributed to the incident
  • The recommendations resulting from the investigation

The report must be reviewed by all affected personnel whose jobs are relevant to the incident findings. The report findings must be promptly addressed, resolved, and the corrective actions documented.

Process Safety Management - Emergency Planning and Response

An emergency action plan for the entire plant must be developed and implemented. This allows employees to be prepared for and able to carry out the proper actions. In addition, the emergency action plan must include procedures for handling small releases of hazardous chemicals.

Process Safety Management - Compliance Audits

Compliance with the provisions of the Process Safety Management system must be evaluated at least every three years. This will verify that the procedures and practices are adequate and are being followed. The above provides just an overview of the OSHA required Process Safety Management standard. You should be thoroughly familiar OSHA 29 CFR 1910.119 to ensure full compliance with the OSHA Process Safety Management standard.