Process Safety Management requirements

Dennison, M. S., OSHA and EPA Process Safety Management Requirements A Practical Guide to Compliance, Van Nostrand Reinhold, New York, 1994. 

Employee Involvement A written plan of action must be developed regarding employee participation. Employees and their representatives must be con-suiter on the conduct and development of process hazard analyses and on the development of other elements of process safety management required under the rule. Employees and their representatives should have access to process... 

Accidental Release Provisions. The 1990 CAAA includes provisions similar to OSHA s process safety management standard for minimi2ing the accidental release of air toxics. Based on types and quantities of ha2ardous chemicals on-site, a faciUty is required to develop and implement... 

Unless some discipline is imposed, engineering personnel, especially where contractors are involved, will define far more alarms than plant operations require. This situation may be addressed by simply setting the alarm hmits to values such that the alarms never occur. However, changes in alarms and alarm hmits are changes from the perspec tive of the Process Safety Management regulations. It is prudent to impose the necessary discipline to avoid an excessive number of alarms. Potential guidelines are as follows ... 

Though occasionally a time consuming exercise, a well-performed PHA can be a source of satisfaction and may be required by the OS HA Process Safety Management Standard or the EPA Risk Management Program Rule. It is important members actively participate and lively interaction is promoted during the sessions. 

Are materials subject to the requirements of the OSHA Process Safety Management Rule (29 CFR 1910.119) or the EPA Risk Management Program Rule (40 CFR 68) ... 

The audit team, through its systematic analysis, should document areas that require corrective action as well as where the process safety management system is effective. This provides a record of the audit procedures and findings and serves as a baseline of operation data for future audits. It will assist in determining changes or trends in future audits. 

Most or the incidents described were the result or not rollowing good engineering practice. Some violated the law, and many more would if they occurred today. In the United States, they would violate OSHA 1910.147 (1990) on The Control of Hazardous Energy (Lock Out/Tag Out) and the Process Safety Management (PSM) Law (OSHA 1910.119, in force since 1992). which applies to listed chemicals above a threshold quantity. The PSM Law requires companies to follow good engineering practice, codes, industry consensus standards, and even the company s owm standards. OSHA could view failure to follow any of these as violations. 

To assist you in looking beyond this book. Chapter 9 addresses the expansion of process safety management programs and techniques to cover transportation and other business activities requiring environmental, health, and safety control. Chapter 9 also raises some of the issues that readers should consider in implementing process safety management internationally. 

PSM, which appiies a management systems approach to process safety, is required by OSHA 1910.119. The Center for Chemical Process Safety (CCPS) has issued guidelines for recommended PSM practices. 

Develop a plan. Based on established goals and current status, the teams will develop detailed plans for implementing a process safety management system, including projections of time and staffpwer requirements and other resource needs. When completed, these plans will be our blueprint for PSM implementation, subject to refinement based on experience. 

Why is it necessary to sell PSM inside your company Because PSM improvement requires individual as well as corporate commitment. Effective process safety management relies on individual behavior on the job, and... 

Each PSM system can then be examined to determine what system modifications (if any) are needed to address the new issues. For example, the process hazard assessment system might be modified to include participation by industrial hygienists to identify potential sources of exposure. Some process safety management systems (e.g., process documentation) may require no modification to support a wider scope. 

The purpose of this handbook is to facilitate, within the DOE, the performance of chemical process hazards analyses (PrHAs) as required under the PSM Rule. It provides basic information for the performance of PrHAs, and should not be considered a complete resource on PrHA methods. Likewise, to determine if a facility is covered by the PSM rule, the reader should refer to the handbook, "Process Safety Management for Highly Hazardous Chemicals" (DOE-HDBK-1101-96). 

One of the most important elements of the PSM Rule is the process hazard analysis (PrHA). It requires the systematic identification of hazards and related accident scenarios. The PSM Rule allows the use of different analysis methods, but the selected method must be based on the process being analyzed. The PSM Rule specifies that PrHAs must be completed as soon as possible within a 5-year period. However, one-fourth of the PrHAs must have been completed by May 26, 1994, with an additional one-fourth completed each succeeding year. The highest risk processes were to be done first. A schedule for PrHAs must be established at the outset of a process safety management (PSM) program to give priority to the highest risk processes. PrHAs must be reviewed and updated at least every 5 years. 

These five requirements are all part of the OSHA Process Safety Management regulation discussed in chapter 3. 

Process security and process safety have many parallels and use many common programs and systems for achieving their ends. Process security management requires a systems approach to develop a comprehensive security program, which shares many common elements with process safety management. 

Bhopal and a series of other major incidents underscored the need for increased attention to process safety management OSHA began to develop a standard that would incorporate these principles. A proposed standard was published in 1990. Additionally, the Clean Air Act Amendments (CAAA) of 1990 required OSHA to promulgate a standard to protect employees from the hazards associated with releases of highly hazardous chemicals, including reactive chemicals. 

---