Process safety management rule

TABLE 26-1 Process Hazard Analysis Methods Listed in the OSHA Process Safety Management Rule... 

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) ... 

Is any part of the facility covered under OSHA s Process Safety Management rule ... 

Evaluate each task to determine if the task will require a written procedure. Factors that determine if a task requires a written procedure can be the frequency, criticality, and complexity of performing the task. Other factors can include regulatory requirements such as the OSHA 1910.119 Process Safety Management Rule procedure requirements. For example, starting a simple pump may not require a written procedure because it is a very simple task that people are trained to do from memory. However, starting a compUcated pump with many auxiliary systems or a pump that is critical to safety may require a written procedme to ensure the pump is always started correctly. 

Again, hot work is that type of work that involves welding, grinding, cutting, and other flame- or potential spark-producing activity that might be performed in the vicinity of processes covered by the process safety management rule. The hot work permits provide for fire safety in conjunction with that type of work and typically include written authorizations and procedures for special controls and surveillance requirements. Most important is the coordination of maintenance and operations. 

The initials THA" aie used in previous CCPS Guidelines for die Preliminary Hazard Analysis technique. In OSHA s Process Safety Management rule (29CFR1910.119), tfiey refer to the general topic of Process Hazard Analysis. 

The hazard analysis methods described above can be varied to suit circumstances, and many variations are beginning to appear. Other methods exist that are basically different and that are not specifically named by OSHA as satisfying the Process Safety Management rule (Section 7.4.2) Some of these are listed below. 

Process Hazard Analysis (PHA) (Dowell, 1994, pp. 30-34.) The OSHA rule for Process Safety Management (PSM) of Highly Toxic Hazardous Chemicals, 29 CFR 1910.119, part (e), reqmres an initial PHA and an update every five years for processes that handle listed chemicals or contain over 10,000 lb (4356 kg) of flammable material. The PHA must be done by a team, must include employees such as operators and mechanics, and must have at least one person skilled in the methodology employed. Suggested methodologies from Process Safety Management are listed in Table 26-1. 

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. 

Qccupational Safety and Health Administration (QSHA) (1992). 29 CFR Part 1910. Process Safety Management of Highly Hazardous Chemicals Explosives and Blasting Agents Final Rule. Federal Register 57, 36 (February 24), 6356-417. 

PSM Rule - The U.S. Occupational Safety and Health Administration s rule "Process Safety Management of Highly Hazardous Chemicals," 29 CFR 1910.119. 

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. 

The lower losses in the last 5-year period, compared to the previous 5 years between 1987 and 1996, is likely the result of governmental regulations that were implemented in the United States during this time that is, on February 24,1992, OSHA published its final rule Process Safety Management of Highly Hazardous Chemicals. This rule became effective on May 26,... 

---