Elements of PSM
At SAIC, our approach to Process Safety Management treats these 14 elements as parts of one holistic continuum.
In its PSM regulations, OSHA lists 14 separate elements. At SAIC, our approach to Process Safety Management treats these 14 elements as parts of one holistic continuum. Each element interrelates to at least one, and frequently several other elements. The descriptions below give a brief explanation of the fundamentals underlying each element. We can audit your current practices in these areas of PSM, and we can help successfully implement a PSM program for your operation with an integrated approach to all 14 elements of Process Safety Management.
- Employee Participation
- Process Safety Information (PSI)
- Process Hazards Analysis (PHA)
- Operating Procedures
- Training
- Contractors
- Pre-Startup Safety Review (PSSR)
- Mechanical Integrity
- Hot Work Permits
- Management of Change (MOC)
- Incident Investigation
- Emergency Planning and Response
- Compliance Audits
- Trade Secrets
- Employee Participation
Employers are required to have a written plan outlining their employee participation. Employee participation should begin at the inception of PSM implementation. Such participation not only improves employee commitment to PSM, but a facility will end up with a much more viable implementation process. The involvement should include employees at all levels of the organization, from field operators, up through supervision, to operations management. The participation should extend to every element of PSM. NOTE: The safety staff should be a resource for PSM, not the ones in charge of the program. - Process Safety Information (PSI)
Occupational Safety & Health Administration (OSHA) states that PSI is "Complete and accurate written information concerning process chemicals, process technology, and process equipment." It is the information necessary for implementation of all other aspects of PSM. Complete information on every chemical involved in the process, including intermediates, is required. Process technology includes not only Process Flow Diagrams (PFDs) and Piping & Instrumentation Diagrams (P&IDs), but operating and storage conditions as well as operating procedures (see below) and operating history (for existing processes). Process equipment information should include the underlying codes and standards relied upon, in addition to information about the specific equipment used in the process. - Process Hazards Analysis (PHA)
A PHA is a systematic evaluation of the hazards involved in the process. PHAs are required for initiation of a process and at least once every five years after that. The PHA team should be multi-disciplinary, including maintenance, operations, and engineering. There are a variety of methods that can be used to conduct a PHA. The method selected will depend on the maturity of the process and operational experience, in addition to process size and complexity. The facilitator of the PHA must be trained in the methodology being used. For proper conduct of a PHA, the PSI must be as complete as possible. - Operating Procedures
Operating procedures include not only the steps for normal operations, but for upset conditions, temporary operations, start-up, and shutdown. Very important safety information must also be included in operating procedures. Such information includes basic hazards of exceeding operational limits, appropriate response to upset conditions, safety and health information, and emergency operations. The procedures need to be up to date and reliable. They are also a critical element in training of personnel. - Training
Training is required for all employees new to a process before they become involved in that process. Training requirements extend beyond operating personnel to anyone involved in the process. This would normally include at least maintenance personnel and, possibly, contractors. The training must include the hazards of the chemicals and process and what is necessary to protect themselves, their fellow employees, and their surrounding communities. Training should be both written/classroom and hands-on. Employers must evaluate the effectiveness of training and make adjustments to content and frequency of training based on those evaluations. - Contractors
Employers using contractors need to ensure that use of those contractors will not jeopardize the safety of operations. This starts with the selection process, where the employer needs to evaluate the safety performance and capabilities of potential contractors. Once selected, the employer must make sure that contractor employees have the appropriate skills and training to perform their work safely. The employer must also provide contractors with sufficient information/training to perform their jobs safely. Ongoing, the employer should keep a log of contractor injuries and illnesses (in addition to its own employees) and periodically evaluate the safety performance of its contractors. The contractors themselves also have various requirements, including ensuring that all of their employees are appropriately trained or informed to perform all of their responsibilities. - Pre-Startup Safety Review (PSSR)
The Pre-Startup Safety Review is done before startup of a new operation or startup following a change in the process (see Management of Change, below). It is a means for ensuring that all essential action items and recommendations from the PHA have been completed prior to beginning operations. It is also the point at which the design parameters and standards used for construction are verified. If training or modifications to PSI are necessary, completion of these items is also verified during the PSSR. Startup should not be allowed to occur until all safety-critical PSSR items have been completed. - Mechanical Integrity
Employers are required to have a written program to ensure the integrity of processes and equipment. Aspects include listing applicable equipment, training of maintenance personnel, inspection and testing, and maintenance of such systems as controls, vessels, piping, safety systems, and emergency systems. Development and modifications to the mechanical integrity program should be made based on operational experience, relevant codes, and industry standards. - Hot Work Permits
Hot work permits must be issued for any work to be performed on, or near, a PSM-covered process. While the OSHA standard specifically lists Hot Work, permits should be developed for any non-routine work to be performed in or around PSM covered processes. In addition to hot work, this could include line breaking, lockout/tagout, confined space entry, etc. Again, while the standard is titled “permit”, it really means an entire procedure covering all hazards of the work to be performed. - Management of Change (MOC)
“Change” includes anything that would require a change in Process Safety Information. This includes changes to equipment, processes, and instrumentation. A proper MOC system requires that any change be evaluated prior to its implementation. The level of evaluation can depend on the degree of change and its criticality to the safety of the operation. In addition to the evaluation and approval of a change, MOC requires that suitable training be conducted (if necessary) and the relevant PSI be updated. - Incident Investigation
Incident Investigation is required for any incident that either did, or could have, resulted in a release of a PSM-covered chemical. There are very specific requirements for the timing of an investigation, the makeup of the investigation team, the resulting report, and the use/dissemination of the information obtained. If done properly, it is one of the primary tools for learning from the operation of a process. It should truly determine the root cause of an incident, not merely find someone or something to blame. - Emergency Planning and Response
Employers are required to develop and implement an emergency action plan for the entire plant, not just the process(es) covered by PSM. It needs to address the actions to be taken in response to the release of any PSM-covered chemical. The plan needs to be comprehensive, including notification to emergency responders, operational responses such as shutdown, and precautions to protect other employees and the public. There is a good probability that requirements for emergency response are also covered by other regulatory standards. - Compliance Audits
Per OSHA, compliance audits must be conducted at least once every three years. The purpose of the audits is to determine whether the practices and procedures developed under the provisions of the PSM standard are being followed and are effective. The auditor(s) must be knowledgeable in PSM and should be impartial to the facility being audited. According to OSHA, selection of appropriate auditors is “critical to the success of the process.” An audit report must be developed and the employer must promptly respond to each of the findings. Once deficiencies are corrected, the corrective action must also be documented. - Trade Secrets
The trade secrets provision of PSM requires that the employer provide all information necessary to comply with PSM to all persons who need it. This does not preclude the employer from taking steps necessary to safeguard the integrity of any information disclosed. It merely prohibits the employer from using trade secrets as an excuse not to provide information to either employees or contractors.