Process Safety Management

           Process Safety Management came about in 1992 due to horrific and catastrophic incidents that were occurring around the world that came about as a result of unintended releases of highly hazardous chemicals, or HHCs.  For Process Safety Management, you have fourteen important parts for it to work correctly. 

            Process Safety Information, Process Hazard Analysis, Operating Procedures, Training, Contractors, Mechanical Integrity, Hot Work, Management of Change, Incident Investigation, Compliance Audits, Trade Secrets, Employee Participation, Pre-startup Safety Review, and finally Emergency Planning and Response. Employee Participation is probably the shortest of all the elements, but has the biggest impact. According to CFR 1910.119, employers need to develop a written plan of action regarding the implementation of employee participation. Essentially employees, production, maintenance, and any other staff are to be involved in all aspects of the PSM program. 

            Process Safety Information is considered one of the most concentrated, maintenance-specific listings of all the elements. In CFR 1910.119, it is stated that the employer shall complete a compilation of written process safety information before conducting any process safety hazard analysis. Process Hazard Analysis is one of the more technical elements, and even includes a what-if evaluation. In the CFR, it states that the process hazard analysis needs to be appropriate to the complexity of the process and needs to identify, evaluate, and control the hazards involved in the process. 

            Operating procedures seem like an oversight by many people, but the element itself has a few items to take note of. In cases of physical contact or airborne exposure, control measures are to be taken after startups following a turnaround or an emergency shutdown. The Training element specifically addresses the needs for those during a process operation. Maintenance technicians need to be fully trained for all the functions they are performing, and the training needs to be accomplished through a competent source and very well documented. Contractors can provide a plethora of opportunities to trip an otherwise healthy and well-executed maintenance strategy.

            Pre-Startup Safety Reviews are important reviews that need to take place before any highly hazardous chemical is introduced into a process. With the PSM, it requires the employer to perform 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. Mechanical Integrity is something that OSHA believes is important to maintain. The integrity of critical process equipment is important to ensure it is designed and installed correctly and operates properly. Hot Work Permits are issued for hot work operations conducted near or on a covered process. The permit must document that the fire prevention and protection regulations have been implemented prior to beginning the hot work operations, the date or dates authorized for the hot work, and the identity of the object on which the hot work is to be performed. 

            

            One of the other most crucial elements of PSM is Incident Investigation. Incident Investigation is a thorough investigation of any incident 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 into the workplace. 

https://www.safetyinfo.com/guest-library/materials/process-safety-management-elements-psm

http://www.plantengineering.com/single-article/the-14-elements-of-osha-inspections-how-they-affect-maintenance-processes/124d9efb4bf664edbf59804775c72cc1.html

https://www.osha.gov/Publications/osha3132.html#psi