INFORMATION DATE 19920805
DESCRIPTION USDOL Program Highlights on Process Safety Management
TOPIC Highly hazardous chemical
SUBJECT Process safety management of highly hazardous chemicals
ABSTRACT Process Safety Management of Highly Hazardous chemicals covers application, process safety information, employee involvement, and process hazard analysis. The employer must consider safety records in selecting contractors and informing contractors of potential process hazards etc.
U.S. Department of Labor
Program Highlight
Fact Sheet No. OSHA 92-45
Application-covers processes involving listed (highly hazardous) chemicals at specified quantities and flammable liquids or gases in quantities of 10,000 pounds or more (except products used solely for heating or fuel). Rules covering pyrotechnic and explosives manufacture incorporate the PSM provisions by reference.
Process Safety Information-requires compilation of written process safety information including hazard information, process technology and information on equipment in the process.
Employee Involvement-requires developing a written plan of action regarding employee participation; consulting with employees and their representatives on the conduct and development of process hazard analyses and on the development of other elements of process safety management required under the rule; providing to employees and their representatives access to process hazard analyses and to all other information required to be developed under the rule.
Process Hazard Analysis-specifies that hazard analyses must be conducted for each covered process using compiled process safety information in an order to be determined by the employer. Process hazard analyses must be updated and revalidated at least every five years. Records must be maintained of the most recent analyses.
Process Hazards Analysis Methods-The employer must choose an appropriate method. The standard mandates what-if; checklist; what-if/checklist; hazard and operability study (HAZOP); failure mode and effects analysis (FMEA); fault tree analysis; or an equivalent method.
Contents-must address: hazards of the process; previous hazardous incidents; engineering and administrative controls; consequences of failure of engineering and administrative controls; facility siting; human factors; and evaluation of effects of failure of controls on employees.
Procedure-team performing analysis must have expertise in engineering and process operations and must include one employee with experience and knowledge specific to the process and someone knowledgeable in the specific process hazard analysis methodology used by the team.
Follow-up-must establish a system to address hazard analysis findings and recommendations; ensure timely resolution; document actions planned; complete actions as soon as possible, in accordance with a written schedule; notify affected operating, maintenance and other employees of planned actions.
Operating Procedures-must be in writing and provide clear instructions for safely operating processes; must include steps for each operating phase, operating limits, safety and health considerations and safety systems. Procedures must be readily accessible to employees, must be reviewed as often as necessary to ensure they are up to date and must cover special circumstances such as lockout/tagout and confined space entry.
Training-mandates training covering specific safety and health hazards, emergency operations and safe work practices. Initial training must occur before assignment or employers may certify that employees involved in the process have the required knowledge, skills and abilities to safely perform duties and responsibilities specified in the operating procedures. PSM calls for refresher training at least every three years and requires written documentation of training.
Contractors-identifies responsibilities of employer regarding contractors involved in maintenance, repair, turnaround, major renovation or specialty work, on or near covered processes. The employer must: consider safety records in selecting contractors; inform contractors of potential process hazards; explain the facility's emergency action plan; develop safe work practices for contractors in process areas; evaluate contractor safety performance; and maintain an injury/illness log for contractors working in process areas. PSM requires contractors to train their employees in safe work practices and document that training, ensure that employees know about potential process hazards and the employer's emergency action plan, ensure that employees follow safety rules of facility, advise employer of hazards contract work itself poses or hazards identified by contract employees.
Pre-Startup Safety Review-mandates a safety review for new facilities and modified sites to confirm integrity of equipment; to ensure that appropriate safety, operating, maintenance and emergency procedures are in place; and to verify that a process hazard analysis has been performed.
Mechanical Integrity-requires written procedures, training for process maintenance employees and inspection and testing for process equipment including pressure vessels and storage tanks; piping systems; relief and vent systems and devices; emergency shutdown systems; pumps; and controls such as monitoring devices, sensors, alarms and interlocks. PSM calls for correction of equipment deficiencies and assurance that new equipment and maintenance materials and spare parts are suitable for the process and properly installed.
Hot Work-mandates a permit system for hot work operations conducted on or near a covered process.
Management of Change-specifies a written program to manage changes in chemicals, technology, equipment and procedures which addresses the technical basis for the change, impact of the change on safety and health, modifications to operating procedures, time period for the change and authorization requirements for the change. The standard requires employers to notify and train affected employees and update process safety information and operating procedures as necessary.
Incident Investigation-requires employer to investigate as soon as possible (but no later than 48 hours) incidents that did result or could have resulted in catastrophic releases of covered chemicals. The standard calls for an investigation team, including at least one person knowledgeable in the process (a contractor employee, if appropriate), to develop a written report on the incident. Employers must address and document their response to report findings and recommendations and review findings with affected employees and contractor employees. Reports must be retained for five years.
Emergency Planning and Response-requires employers to develop and implement an emergency action plan.
Compliance Audits-calls for employers to certify that they have evaluated compliance with process safety requirements at least every three years and specifies retention of the audit report findings and the employer's response. Employers must retain the two most recent audit reports.
Trade Secrets-sets requirements similar to trade secret provisions of the hazard communication standard requiring information to be available to employees from the process hazard analyses and other documents required by the Standard. PSM permits employers to enter into confidentiality agreement to prevent disclosure of trade secrets.
This is one of a series of fact sheets highlighting U.S. Department of Labor programs. It is intended as a general description only and does not carry the force of legal opinion.