Elements of PSM
Dr. Shirazeh Arghami
Why Did OSHA Develop PSM?
• Process Safety Management is a regulation, promulgated
by OSHA, intended to prevent an incident like the 1984
Bhopal Disaster
• And to Prevent Release of:
• Toxic
• Reactive
• Flammable
• Explosive chemicals
2
OSHA
3
Process safety management of highly
hazardous chemicals
Application
Definitions
Employee
participation
Process
safety
information
Process
hazard
analysis
Operating
procedures
Training
Contractors
29 CFR 1910.119:
Process safety management of highly hazardous chemicals
Pre-startup
safety review
Mechanical
integrity
Hot work
permit
Management
of change
Incident
investigation
Emergency
planning and
response
Compliance
Audits
Trade secrets
A Way of Looking at the 14 Elements of PSM
• Elements Concerned with
Evaluation of Progress Towards
Goals
•
•
•
•
•
•
Process Hazards Analysis
Pre-startup Safety Review
Management of Change
Incident Investigation
Compliance Audits
Trade Secrets
• Elements Concerned with
Achieving Safety Goals
•
•
•
•
•
•
•
•
Employee Participation
Process Safety Information
Operating Procedures
Training
Contractors
Mechanical Integrity
Hot Work
Emergency Planning
5
Process Hazards Analysis
• Purpose
• Identify Hazards and Provide a Preliminary Estimate as to Seriousness
• Correct Problems (Design Changes or Modifications, Adding Safety Features, Improving
Procedures and Training)
• What is Required
• Process Hazard Analysis be Done Using – Checklist, What-If, HAZOP, FMEA, Fault Tree
Analysis, Layer of Protection Analysis (LOPA), etc.
• PHA will Address –
• Hazards & Identification of Previous Potentially Catastrophic Incidents
• Engr. and Admin. Controls Applicable, Consequences for Failure of Engr. and Admin.
Controls
• Facility Siting, Human Factors
• Qualitative Evaluation of Potential Safety and Health Effects if Controls Fail
• Team – Engr. and Process Operations, One Member Specific to Process Evaluated, One
Member Knowledgeable in PHA Process
• Employer Must
• Establish System to Address Findings
• Update and Revalidate Every Five Years
6
… Process Hazards Analysis
• Real World Advice
• Choose the right method, not every process needs a HAZOP.
• Chose the right team – experience is the key.
• PHA doesn’t end with a report - develop a system to review and manage
PHA recommendations
7
Pre-Startup Safety Review (PSSR)
• Purpose is to Assure Initial Startups or Startups Following Turnarounds or
Abnormal Shutdowns are Carried Out Safely
• What is Required
• Review for New Facilities or Modified Facilities when The Modification Requires a Change
in the Process Safety Information
• Must Be done Prior to Introduction of HHCs (Highly Hazardous Chemicals)
• Must Confirm
• Construction and Equipment Meets Design Specifications
• Safety, Operating, Maintenance, and Emergency Procedures are Adequate
• For New Facilities a PHA has Been Done and Issues Resolved
• For Modified Facilities, Management of Change Procedures Have Been Completed
• Training employees involved in operating a process completed
8
… Pre-Startup Safety Review (PSSR)
• Real World Advice
• Involve the right people – experience counts
• Don’t rely on memory - use checklists
• Develop a system for managing post-startup actions from PSSR
• Use the PSSR as opportunity to prove that process is safe to start –
Document everything!
9
Management of Change (MOC)
• Purpose
• All Accidents are a Result of Uncontrolled Changes
• Make Sure Changes are Properly Identified and Controlled Before Implemented
• What is Required – Employers Must
• Write Procedures to Manage Changes (Except for Replacement in Kind) that Address
• Technical Basis for the Change
• Impact of Change on Safety and Health
• Modifications to Operating Procedures
• Necessary Time Period for the Change
• Authorization Requirements for the Change
• Inform and Train Operations, Maintenance, and Contract Employees Affected by the
Change Prior to Start-up
• Update Applicable Process Safety Information
• Update Operating Procedures or Practices
10
… Management of Change (MOC)
• Real World Advice
• There are very few ‘Replacement in Kind’
• Be sure complete all pre- and post-change actions
• Include personnel changes
• Paper is ok, but electronic is far superior
11
Incident Investigation
• Purpose
• Provide Feedback for Prevention of Future Problems
• Incidents are Analogous to Hazards (Potential Problem), Become Accidents When Someone
is Harmed
• After the Fact vs. Other Elements Aimed at Anticipation and Prevention
• What is Required
• Investigation of any Incident that Resulted or Could Have Resulted in Catastrophic Release
of a HHC
• Prompt Initiation, Within 48 Hours
• Investigation Team Formed Consisting of Knowledge of Process Affected, Contractor if
Involved, Others with Appropriate Knowledge
• Report Prepared
• Employer has a System to Promptly and Effectively Address Findings and
Recommendations; and Document this Resolution
• Report is Reviewed with Affected Personnel
• Reports are Retained for Five Years
12
Compliance Audits
• Purpose is to Compare Performance Against the Written Standards
and Procedures
• What is Required
• Employer Certify Every Three Years He Has Verified Procedures
and Practices Required by The Rule are Adequate and Being
Followed
• Audit Team Include One Person Knowledgeable in Process and
Other Knowledgeable Personnel
• Audit Report Developed
• Employer Respond to Findings and Document Deficiencies Have
Been Resolved
• Two Most Recent Audit Reports Be Retained
13
Trade Secrets – Only Non-Technical Element in the Rule
• Purpose
• To Insure Employees Have Access to Information Needed to Perform Job
Safely, Regardless of Trade Secrets
• A Trade Secret is Knowledge not Patented but Gives a Co. a Competitive
Advantage
• What is Required
• Information (Regardless of Status) be Made Available to Persons
Responsible for
• Compiling Process Safety Information
• Development of Process Hazard Analysis
• Development of Operating Procedures
• Involved in Incident Investigations, Emergency Planning and Response,
and Compliance Audits
• Allows Employer’s to Require Confidentiality Agreements of Employees
14
A Way of Looking at the 14 Elements of PSM
• Elements Concerned with
Evaluation of Progress Towards
Goals
•
•
•
•
•
•
Process Hazards Analysis
Pre-startup Safety Review
Management of Change
Incident Investigation
Compliance Audits
Trade Secrets
• Elements Concerned with
Achieving Safety Goals
•
•
•
•
•
•
•
•
Employee Participation
Process Safety Information
Operating Procedures
Training
Contractors
Mechanical Integrity
Hot Work
Emergency Planning
15
Employee Participation
• Purpose
•
•
•
•
One of the Most Essential Elements for a Successful Program
People at Working Level Know Most about Operations
Serves as a Sanity Check re: Common Sense Problems
Couples with All Other Elements and Ensures Successful Implementation
• What is Required, Employers Must
• Have a Written Plan to Ensure Employee Participation
• Involve Employees in Conduct and Implementation of PHAs & Other
Elements of PSM
• Provide Access to PHAs and all other Information Required to Be Developed
by PSM Rule
16
Process Safety Information (PSI)
• Purpose - Ensure Personnel Have Access to Information Needed Work Safely
and Efficiently
• What is Required
• HHC Hazard Information – MSDS + other Data Needed to Comply:
•
•
•
•
•
Toxicity information
Permissible exposure limits
Reactivity data
Corrosivity data
Information pertaining to the technology of the process
• Info on Technology (PFDs, Process Chemistry, Max Inventory, Safe Upper and Lower Limits,
Evaluation of Consequences of Deviations)
• Info on Equipment (Materials, P&IDs, Electrical Class, Relief System Design and, Design
Codes and Standards, Material and Energy Balances, Safety Systems, e.g. Interlocks, etc.)
• Documentation Equipment Complies with RAGAGEP
• For Equipment Designed in Accordance with Codes and Standards no Longer in Use, Must
Document Is Designed, Maintained, Inspected, Tested, and Operating in Safe Manner
17
… Process Safety Information (PSI)
• Real World Advice
• Most information exists in SDSs, literature, & plant and process
documentation
• Gather all PSI in one place – either electronic or paper
• Be sure that PSI is updated as changes are made
• Create an Action Item for annual review of the PSI
18
Operating Procedures
• Purpose is to Assure Safe and Reliable Operations
• What is Required: Employer must develop and implement written
operating procedures that provide clear instructions for safety
conducting activities involved in each covered process:
• Address Safe Actions During Initial Startup, Normal Operations, Temporary
Operations, Emergency Shutdown, Emergency Operations, Normal
Shutdown, Startup Following Turnaround or Emergency Shutdown
• Identify Operating Limits – Consequences of Deviation and Corrective
Action
• Identify Safety and Health Considerations (properties and hazards and
precautions to prevent or correct problems)
• Identify Safety Systems and Functions
• Safe Work Practices Must be Addressed (e.g. lockout/tag-out, confined
space entry, etc.
19
… Operating Procedures
• Real World Advice
• Electronic document system often easiest to maintain.
• Do not try to put all the required information into one procedure – combine
common information into one procedure
• Be simple and direct – readability and understandability are vital
20
Training
• Purpose is to Assure Personnel Can Accomplish Duties Safely
• What is Required
• Initial Training with Emphasis on Safety and Health Hazards, Emergency
Operations Including Shutdown, Safe Work Practices
• Refresher Training at Least Every Three Years
• Training Shall be Documented
21
Contractors
• Purpose is to Ensure Contract Employees Observe Same Safety Rules and Standards as
Permanent Employees
• What is Required
• Applies to Contractors Performing Maintenance, Repair, T/A, Renovation or Specialty Work In or
Around a Covered Process
• Employer Shall:
• When Selecting, Evaluate Contractors Safety Performance and Programs
• Inform Contract Employees of Known Hazards Related to Work to be Done
• Explain Applicable Emergency Action Plan Provisions
• Explain Application of Safe Work Practices to Control Contractor
• Evaluate Performance
• Maintain a Log of Injuries and Illness
• Contract Employer Shall
• Assure Employees Trained
• Assure Employees Instructed in Known Hazards and Emergency Plan
• Document Employees Receive and Understand Training
• Assure Employees Follow Safety Rules of Plant
• Advise Employees of any Unique Hazards Presented by Contractors Work
22
… Contractors
• Real World Advice
• Develop an approval process for contractors
• Allot adequate resources to maintaining contractor approval and training
documentation
• Ensure that contractor employees have the required training to complete
23
Mechanical Integrity
• Applies to:
• Pressure Vessels and Storage Tanks
• Piping Systems (including piping components such as valves)
• Relief and vent systems and devices
• Emergency shut down systems
• Controls (including monitoring devices, sensors, alarms and interlocks)
• Pumps
24
… Mechanical Integrity
• Establish and implement written procedures to maintain the on-going
integrity of process equipment
• Train each employee involved in maintaining the on-going integrity of
process equipment
• Perform inspections and tests on process equipment following
Recognized and Generally Accepted Good Engineering Practices
(RAGAGEP)
• Document inspections and correct deficiencies
• Establish Quality Assurance procedures
25
… Mechanical Integrity
• Real World Advice
• RAGAGEP = 7 words = infinity of complexity
• Use operations and maintenance manuals whenever possible (have them
readily accessible)
• Develop ITPM plan using CCPS MI book
• Use a Computerized Maintaining System to schedule ITPM tasks and track
deficiencies to closure
• Become familiar with API, NFPA, ASME, and other RAGAGEP
26
Hot Work
• Purpose is to Assure Workers are Not Exposed to Sources of High
Energy, e.g. Explosive Substances, Toxic Chemicals, Heat, Electricity,
Moving Machinery, etc.
• What is Required
• Employer Issue Hot Work Permit for Work on or Near Covered Process
• Permit Must Document Fire Prevention and Protection in Place
• Principles Apply to Energy Control Procedures or Permits to Work As
Well, e.g. digging near buried cable or pipelines
27
Emergency Planning and Response
• Purpose is to Minimize Injuries and Damage in Event of an
Incident or Accident
• What is Required
• Establishment and Implementation of an Emergency Action Plan
• Procedures for Handling Small Releases
• Training
28
Textbook
• Sanders R. E. Chemical process safety: learning
from case histories. Butterworth-Heinemann;
2015.
• Process Safety Management
OSHA 3132 - 2000
‫• راهنماي آشنايي با اجزاء مديريت‬
(PSM) ‫ايمني فرآيند‬
1389 ‫شرکت ملی صنايع پتروشیمی‬
29