There are certain industries and businesses that cannot avoid the use of hazardous chemicals. However, effectively mitigating the hazards of working with these chemicals while maintaining relevant equipment is imperative for the safety and health of employees, the public, and the environment.
Many industries continue to struggle to prevent unexpected releases of toxic, flammable, or reactive gasses and liquids, resulting in unsafe working environments. In January of 2020, a propylene gas explosion caused by a leak at a Houston manufacturing facility killed two employees on site, and had the leak been worse, the consequences could have been even more catastrophic.
To protect our environment and the health and wellness of employees and the general public, OSHA has a standard that must be followed by industries that deal with hazardous materials.
What is Process Safety Management (PSM)?
Process safety management (PSM) is a regulation put in place by OSHA to help companies prevent highly hazardous chemicals (HHCs) from being mishandled or released. This standard details several requirements involving the handling, moving, storing, or manufacturing of harmful HHCs, and is a legal requirement according to the Clean Air Act Amendments (CAAA) of 1990.
OSHA created the Process Safety Management of Highly Hazardous Chemicals standard to help prevent or minimize catastrophic releases of toxic, flammable, reactive, or explosive chemicals that can cause fires or explosions. Since these HHCs can be so destructive and put public safety at risk, the requirements within the standard are strict and non-negotiable.
Who Should Follow the PSM Standard?
The PSM program standard applies to all industries that use highly hazardous chemicals. This includes, but is not limited to:
- Manufacturing industries
- Construction industries
- Electric, gas, and sanitary services
- Farm product warehousing
- Natural gas liquids
- Pyrotechnics and explosives manufacturing
- Wholesale trade
Any company that deals with more than 130 specific reactive and toxic chemicals in listed threshhold quantities, as well as flammable gases and liquids in quantities of 10,000 pounds or more, will be expected to follow the requirements of the PSM standard.
However, there are a few industry exceptions to the PSM standard, including:
- Grain and field bean merchant wholesalers
- Other farm product raw material merchant wholesalers
- Farm supplies merchant wholesalers
- Retail flammable liquid vendors (gas stations)
How to Comply with the PSM Standard
OSHA’s PSM standard requires employers to have a process safety management system in place that follows 14 specific rules and practices.
1. Process Safety Information
Before starting with a hazard analysis, employers are required to develop a written list of PSM safety information relevant to the hazardous chemicals used on site. This is essential in helping both employers and employees understand the potential hazards of working with HHCs and how to prevent accidents and injuries.
Information about the HHCs involved in a business’s process must be shared with all employees and include:
- Permissible exposure limits
- Reactivity data
- Corrosivity data
- Physical data
- Thermal and chemical stability data
- Hazardous effects of inadvertently mixing different materials
Additionally, information about any technology involved in a business’s process must also be shared with all employees and include:
- Process chemistry
- Maximum intended inventory
- Block flow or simplified process flow diagram
- Safe upper and lower limits for items such as flows, pressures, temperatures, and compositions
- An evaluation of the consequences of deviations, especially for those affecting employees’ health and safety
- Equipment of the process including minimum and maximum safe working pressures, temperatures, and flows
2. Process Hazard Analysis
Process hazard analyses (PHAs) are designed to identify, evaluate, and control the hazards of processes involving HHCs. There are several recommended methods, including what-if checklists and hazard and operability studies (HAZOPs) that employers can use to determine and evaluate these hazards.
PHAs must be updated every five years and the documentation of PHAs must be kept for the entire life of the process itself.
3. Operating Procedures
Employers must establish and execute written operating procedures with clear instructions. These instructions should emphasize hazards, health considerations, operating limitations, safety practices, and any relevant special circumstances.
4. Employee Involvement
OSHA requires employers to consult with employees and employee representatives in all 14 PSM elements and when developing the process hazard analysis. Employees must be given access to any process hazard analyses, past or present. Temporary workers and contractors are included in this standard.
5. Process Safety Management Training
Training is required for any employee involved in the operation and maintenance of the process. The process safety management training should include health hazards, emergency operations, and best work practices, and refresher training should be conducted every three years. Thankfully, many third-party safety consulting firms offer on-site safety training.
6. Contractor Training
It is the employer’s responsibility to ensure contracted employees are trained on how to safely perform their jobs. This includes making contractors involved in maintenance, repair, renovation, or specialty work aware of potential process hazards, emergency action plans, facility safety rules, and how to inform their superior of a hazard.
7. Pre-Startup Safety Review
Modified work sites and new facilities are required to undergo a pre-startup safety review. This will verify that all equipment is in accordance with design specifications, confirm proper safety and emergency procedures are in place, and make sure that the process operators are well and fully trained.
8. Mechanical Integrity
On-site employers must have written procedures regarding the ongoing integrity of any process equipment on site. This will ensure all equipment is properly designed, installed, and maintained.
9. Hot Work Permits
Permits must be kept on file to prove that fire prevention requirements were met prior to the start of hot-work operations. This permit should specify authorized work dates and location details.
10. Management of Change Process
Written procedures need to be put in place to manage any changes to process chemicals, equipment, technology, or procedures. Employers must train and inform employees and contractors of these changes prior to start-up, and these procedures must be updated regularly as needed.
11. Accident Investigation
OSHA requires employers to investigate every incident on site that resulted in, or may have resulted in, a catastrophic accident. Incident investigation should begin within 48 hours after the accident. It’s imperative that a knowledgeable and experienced investigation team analyze the results and write a report detailing any needed changes in procedures. All incident reports must be kept on file for at least five years.
12. Emergency Planning and Response
In the event of an emergency, employers will need an emergency action plan and employees should be trained on the necessary emergency response.
13. Safety Compliance Audits
Once every three years, employers must conduct a process safety management audit. This should confirm that practices and procedures are satisfactory and are being followed. Any deficiencies or corrections must be included in the report. Additionally, employers need to keep their two most recent OSHA PSM audit reports on file.
14. Trade Secret Protection
Due to the nature of work that many industries involved in HHCs conduct, OSHA’s PSM does not prevent employers from requiring employees to sign confidentiality agreements to prevent the disclosure of trade secrets. However, there is a list of employees and representatives that must have access to all necessary information, including:
- Those performing compliance audits
- Those performing incident investigations
- Those developing process hazard analysis
- Those responsible for emergency planning and response
- Those compiling the process safety information
- Those developing operating procedures
Emergency Action Planning: Are You Prepared?
Get Help with Process Safety Compliance
Following OSHA’s PSM standard is essential for workplace and public safety, but also for protecting your business from OSHA violations. Following and maintaining all 14 requirements for the PSM standard can be overwhelming, especially for site managers with many other projects to focus on.
Third-party safety consultants bring immense industry expertise and professional diligence to help keep your business compliant and your team safe.
Schedule a consultation and discover how SafetyPro can help you achieve process safety compliance.