PSM: OSHA Process Safety Guidance and Information

Process Safety Information-Requires compilation of written process safety

information (PSI) including hazard information on HHC's technology information
and equipment information on co!ered processes"
Employee Involvement-Requires de!eloping a written plan of action regarding
employee participation# consulting with employees and their representati!es on
the conduct and de!elopment of process hazard analyses and on the
de!elopment of other elements of process safety management required under
the rule# pro!iding to employees and their representati!es access to process
hazard analyses and to all other information required to $e de!eloped under the
rule" %mployees include wor& site and contractor employees"
Process Hazard Analysis-Specifies that process hazard analyses (PH''s) must
$e conducted as soon as possi$le for each co!ered process using compiled PS
in an order $ased on a set of required considerations" 't least twenty(fi!e percent
of initial process hazard analyses must $e completed $y )ay *+ ,--.# /0
percent $y )ay *+ ,--/# 1/ percent $y )ay *+ ,--+# and ,00 percent $y )ay
*+ ,--1" Process hazard analyses must $e updated and re!alidated at least
e!ery fi!e years and must $e retained for the life of the process"
Operating Procedures-)ust $e in writing and pro!ide clear instructions for
safely conducting acti!ities in!ol!ing co!ered process consistent with PSI# must
include steps for each operating phase operating limits safety and health
considerations and safety systems and their functions# $e readily accessi$le to
employees who wor& on or maintain a co!ered process and $e re!iewed as
often as necessary to assure they reflect current operating practice# and must
implement safe wor& practices to pro!ide for special circumstances such as
loc&out2tagout and confined space entry"
raining-%mployees operating a co!ered process must $e trained in the
o!er!iew of the process and in the operating procedures addressed pre!iously"
3his training must emphasize specific safety and health hazards emergency
operations and safe wor& practices" Initial training must occur $efore assignment
or employers may certify that employees in!ol!ed in the process as of )ay *+
,--* ha!e required &nowledge s&ills and a$ilities" 4ocumented refresher
training is required at least e!ery three years"
!ontractors-Identifies responsi$ilities of wor& site employer and contract
employers with respect to contract employees in!ol!ed in maintenance repair
turnaround ma5or reno!ation or specialty wor& on or near co!ered processes"
Contract employers are required to train their employees to safely perform their
5o$s and document that employees recei!ed and understood training and
assure that contract employees &now a$out potential process hazards and the
wor& site employer's emergency action plan assure that employees follow safety
rules of the facility and ad!ise the wor& site employer of hazards contract wor&
itself poses or hazards identified $y contract employees"
Pre-startup Safety "evie#-)andates a safety re!iew for new facilities and
significantly modified wor& sites to confirm that the construction and equipment of
a process are in accordance with design specifications# to assure that adequate
safety operating maintenance and emergency procedures are in place# and to
assure process operator training has $een completed" 'lso for new facilities the
PH' must $e performed and recommendations resol!ed and implemented $efore
start up" )odified facilities must meet management of change requirement"
Mec$anical Integrity-Requires the on(site employer to esta$lish and implement
written procedures for the ongoing integrity of process equipment particularly
those components which contain and control a co!ered process"
Hot %or&-Hot wor& permits must $e issued for hot wor& operations conducted on
or near a co!ered process"
Management of !$ange-3he wor& site employer must esta$lish and implement
written procedures to manage changes e6cept 7replacements in &ind7 to facilities
that effect a co!ered process" 3he standard requires the wor& site employer and
contract employers to inform and train their affected employees on the changes
prior to start(up" Process safety information and operating procedures must $e
updated as necessary"
Incident Investigation-Requires employers to in!estigate as soon as possi$le
($ut no later than .8 hours after) incidents which did result or could reasona$ly
ha!e resulted in catastrophic releases of co!ered chemicals" 3he standard calls
for an in!estigation team including at least one person &nowledgea$le in the
process in!ol!ed (a contract employee when the incident in!ol!ed contract wor&)
and others with &nowledge and e6perience to in!estigate and analyze the
incident and to de!elop a written report on the incident" Reports must $e
retained for fi!e years"
Emergency Planning and "esponse-Requires employers to de!elop and
implement an emergency action plan" 3he emergency action plan must include
procedures for handling small releases"
!ompliance Audits-Calls for employers to certify that they ha!e e!aluated
compliance with process safety requirements at least e!ery three years" Prompt
response to audit findings and documentation that deficiencies are corrected is
required" %mployers must retain the two most recent audit reports"
rade Secrets-Sets requirements similar to trade secret pro!isions of the
,-,0",*00 Hazard Communication standard requiring information required $y the
PS) standard to $e a!aila$le to employees (and employees representati!es)"
%mployers may enter into confidentiality agreement with employees to pre!ent
disclosure of trade secrets"