Process Safety Management

Process:
An activity which involves hazardous chemicals handling, usage, manufacturing, storage or
movement within facility.

Process Safety:
It is about identifying hazards and risk involving with the process, and its mitigation by
appropriate layers of protection to reduce severity and frequency of the incident that could
happen (i.e. fire, explosion and toxic release), also learning from previous incidents.

Process Safety Management:

It is an OSHA standard that helps to identify, evaluate and control the hazards and risk
associated with hazardous chemicals involved in process.

PSM Elements:
According to OSHA these are the elements of PSM:

1. Process safety information

2. Process hazard assessment
3. Employee participation during PHA
4. Establish a system to respond the findings of PHA
5. Periodic review of PHA
6. Written operating procedures
7. Employee training and maintaining their data
8. Contractors training
9. Emergency response plan
10. Establish a quality assurance program
11. Establish maintenance program for mechanical integrity and periodic inspection
12. Pre-startup safety reviews
13. Management of change, its communication and required training to relevant person.
14. Incident Investigation
15. Hot work permit
16. Compliance audits
1. Process safety information:
OSHA recommends that all information of hazardous chemical and process should be in written
form, compiled at one place and it is accessible in the case for identifying and evaluating hazard
analysis.
Following information should be available:

1. Information for hazardous chemicals:

 Toxicity
 Permissible exposure limits
 Physical data
 Reactivity data
 Corrosivity data
 Thermal and chemical stability data
 Hazardous effects
2. Information of technology of the process:
 Block flow diagram
 Process chemistry
 Maximum intended inventory
 Safe upper and lower limits for process variables such as temperatures,
pressures, flows or compositions.
 Evaluation of the consequences of deviations, which can affect health and safety
of employees.
3. Information of process equipment:
 Material of construction
 Piping and instrumentation diagram
 Material and energy balance
 Electrical classification
 Relief system design
 Ventilation system design
 Design codes and standards applied
 Safety systems (i.e. Interlocks, detection and suppression system)
2. Process hazard assessment:
Many developed process hazard techniques are used to identify and evaluate hazards and the
consequences in workplace. All process hazard assessments should revalidate at least every five
years. These are given as following:

 What-if
 Checklist
 What-if / Checklist
 Fault tree analysis
 Failure mode and effect analysis (FMEA)
 Hazard and operability (HAZOP) study

OSHA believes that the process hazard analysis is best performed by a team with expertise in
engineering and process operations, and that the team should include at least one employee
who has experience with and knowledge of the process being evaluated. Also, one member of
the team must be knowledgeable in the specific analysis methods being used.

3. Written Operating Procedures:

OSHA recommends to develop written operating procedures in accordance with process safety
information for the safely execution of activities. All tasks and procedures related to the
covered process must be appropriate, clear, consistent, and most importantly, well
communicated to employees.

These include:

 Startup procedure
 Normal shutdown procedure
 Emergency shutdown procedure
 Startup following turnaround
4. Employee participation:
Employer should ensure the participation of employees during process hazard analysis. All the
information related to process safety and process hazard analysis should be accessible to
employees.

5. Training:
PSM requires that each employee presently involved in operating a process or a newly assigned
process must be trained in an overview of the process and in its operating procedures. The
training must include 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.

Refresher training must be provided at least every three years, or more often if necessary, to
each employee. A training record must be kept and documented for future use.

6. Contractors:
PSM applies to contractors performing maintenance or repair, turnaround, major renovation,
or specialty work on or adjacent to a covered process. It does not apply to contractors
providing incidental services that do not influence process safety, such as janitorial, food and
drink, laundry, delivery, or other supply services.

Employer responsibilities:

 Potential fire, explosion, or toxic release hazards

 Applicable provisions of the emergency action plan
  Develop and implement safe work practices to control the presence, entrance, and exit
of contract employers and contract employees in covered process areas
 Evaluate periodically the performance of contract employers in fulfilling their obligations
 Maintain a contract employee injury and illness log related to the contractor’s work in
the process areas.
7. Pre-startup safety reviews:
PSM requires performing a pre-startup safety review for new facilities and for modified facilities
when the modification is significant enough to require a change in the process safety
information. Pre-startup safety reviews should confirm that:

 Construction and 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 for new facilities and recommendations
have been resolved or implemented before startup, and modified facilities meet the
management of change requirements
 Training of each employee involved in operating a process has been completed

ARL follows UOP operational safety guidelines / checklist for prestart up safety review for new
and modified facilities.

8. Mechanical Integrity:
PSM mechanical integrity requirements apply to the following equipment:

 Pressure vessels and storage tanks

 Piping systems (including valves)
 Relief and vent systems and devices
 Emergency shutdown systems
 Controls (including monitoring devices and sensors, alarms, and interlocks)
 Pumps

Written procedures should be established and implemented to maintain the ongoing integrity
of process equipment. Inspection and testing must be performed on process equipment using
procedures. The frequency of inspections and tests of process equipment must conform to
manufacturers’ recommendations and good engineering practices. Equipment deficiencies
outside the acceptable limits defined by the process safety information must be corrected
before further use.

9. Hot work permit:

A permit must be issued for hot work operations conducted on or near a covered process. The
permit must document that the fire prevention and protection requirements in OSHA
regulations (1910.252(a)) have been implemented prior to beginning the hot work operations.
The permit must be kept on file until completion of the hot work.

10. Management of change:

OSHA believes that contemplated changes to a process must be thoroughly evaluated to fully
assess their impact on employee safety and health and to determine needed changes to
operating procedures.

Written procedures to manage changes (except for “replacements in kind”) to process

chemicals, technology, equipment, and procedures, and change to facilities that affect a
covered process, must be established and implemented.

Employees who operate a process and maintenance and contract employees whose job tasks
will be affected by a change in the process must be informed of, and trained in, the change
prior to startup of the process or startup of the affected part of the process. If a change covered
by these procedures changes the required operating procedures or practices, they also must be
updated.

11. Incident Investigation:

A crucial part of the process safety management program is a thorough investigation of
incidents to identify the chain of events and causes so that corrective measures can be
developed and implemented.

PSM requires the investigation of each incident that resulted in, or could reasonably have
resulted in, a catastrophic release of a highly hazardous chemical in the workplace. Such an
incident investigation must be initiated as promptly as possible, but not later than 48 hours
following the incident.

An investigation report must be prepared including at least:

 Date of incident,
 Date investigation began,
 Description of the incident,
 Factors that contributed to the incident, and
 Recommendations resulting from the investigation.

A system must be established to promptly address and resolve the incident report findings and
recommendations.

12. Emergency response plan:

If, despite the best planning, an incident occurs, it is essential that emergency pre-planning and
training make employees aware of, and able to execute, proper actions. For this reason, an
emergency action plan for the entire plant must be developed and implemented in accordance
with the provisions of other OSHA rules (29 CFR 1910.38(a)). Like,

 Written emergency plan availability

 Emergency reporting
 Evacuation
 Fire Alarm System
 Training
13. Compliance audits:
Audits are an excellent way to check the credibility of PSM of an organization. To be certain
process safety management is effective, employers must certify that they have evaluated
compliance with the provisions of PSM at least every three years. The two most recent
compliance audit reports must be kept on file.