Process Safety Management and the IH
Examining OSHA’s PSM Standard
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Process Safety Management (PSM) is an OSHA standard focused on preventing the unexpected release of toxic, reactive, or flammable liquids and gases. The standard (29 Code of Federal Regulations 1910.119) is very prescriptive and establishes a roadmap for OEHS professionals to ensure the safety of workers and communities.
An industrial hygienist has much to offer in PSM. Process safety management and industrial hygiene are different systems of management with the same goal. OSHA’s PSM standard focuses on preventing large-scale disasters, and industrial hygiene focuses on preventing individual occupational illnesses. But the skillsets needed for each are interchangeable and mutually beneficial. This article provides a high-level overview of OSHA’s PSM standard and some of the program elements where IHs can contribute.
THE ELEMENTS OF PSM OSHA’s PSM standard covers the manufacturing of explosives and processes involving threshold quantities of flammable liquids and flammable gases at 10,000 lbs. and above as well as 137 additional highly hazardous chemicals. Each of the standard’s 14 elements is discussed below, with emphasis on areas where IHs can make a lasting impact. Approaching PSM in a holistic manner can help organizations achieve success. Integrating these elements and building upon each can help companies prevent horrific disasters and ensure employee safety. Employee Participation Employee participation affects nearly every element in the PSM standard. In 1910.119(c), OSHA requires employers to develop a written plan of action for employee participation in PSM. Employers must ensure that information is flowing between management and employees regarding process safety hazards, limitations, and mitigations. Employers must also ensure employees understand the consequences of catastrophic releases of highly hazardous chemicals in the workplace.
Employee understanding and participation is the lifeblood for all health and safety initiatives. IHs must look beyond the regulation and consider the human element when engaging employees and ensuring compliance. Barriers to employee participation include language, reading and comprehension, and motivation.
OEHS professionals therefore need to use words that all employees can understand. The Center for Plain Language estimates that the average American is considered to have a readability level equivalent to a 7th/8th grader. In addition, the Center for Immigration Studies estimates that over 25 million people in the U.S. are less than fluent speakers of English. These factors must be accounted for when encouraging employee participation in PSM.
Training It is necessary for all employees, including maintenance personnel and contractors, who are involved with highly hazardous chemicals to fully understand the safety and health hazards of the chemicals and processes they work with to protect themselves, their fellow employees, and the citizens of nearby communities. Training conducted in compliance with OSHA’s Hazard Communication standard (29 CFR 1910.1200) will help employees be more knowledgeable about the chemicals they work with and familiarize them with reading and understanding safety data sheets. However, employers need to provide additional training in operating procedures, safe work practices, emergency evacuation and response, safety procedures, work authorization activities, and other areas pertinent to process safety and health.
IHs are well qualified to present highly technical information in an understandable manner. Due to their knowledge of chemical and physical properties, IHs can discuss the specific hazards or the process being managed and convey concepts of vapor pressure, flash point, explosive limits, and other considerations.
Process Hazard Analysis A process hazard analysis (PHA), sometimes called a process hazard evaluation, is one of the most important elements of the PSM program. A PHA is a systematic effort to identify and analyze the significance of potential hazards associated with the processing or handling of highly hazardous chemicals. A PHA will help improve safety and reduce the consequences of unplanned releases of hazardous chemicals. PHAs analyze potential causes and consequences of fires, explosions, chemical releases, and major spills of hazardous chemicals. They focus on equipment, instrumentation, utilities, human actions, and external factors that might impact the process. These considerations help determine the hazards and potential points of failure in a process.
Like process engineers, IHs should be cognizant of the entire process and know all the chemical inputs, intermediates, and products along with their chemical and physical properties. The anticipation and recognition of exposure hazards is an essential part of the PHA, and knowledge of chemical handling can improve PHA deliberations. The techniques IHs use when collecting samples or controlling hazards are similar to those used in PHAs. IHs should be at the PHA table.
Incident Investigation Incident investigation is the process of identifying the underlying causes of incidents and implementing steps to prevent similar events from occurring. The intent of an incident investigation is for employers to avoid repeating past mistakes. The incidents OSHA expects employers to investigate are events that could reasonably result in a catastrophic release. Such events are sometimes called “near misses,” meaning that a serious consequence did not occur, but could have.
Employers need to develop in-house capability to investigate incidents that occur in their facilities. A team should be assembled and trained on the techniques of investigation including interviewing witnesses, collecting needed documentation, and writing reports. A multi-disciplinary team is better able to gather and analyze facts and develop plausible scenarios about what happened and why.
The IH should be a part of this team. IHs have multiple opportunities to observe a given process through sampling and can help identify variations in conditions or chemical handling that may have played a role in an incident. IHs also continually conduct change analysis to identify differences in procedures so they can best select which process to sample.
Approaching process safety management in a holistic manner can help organizations achieve success.
Emergency Planning and Response Each employer must specify the actions employees are to take when an unwanted release of highly hazardous chemicals occurs. For example, employers need to decide whether employees should stop minor incidental releases during an emergency or direct available resources toward a more significant release. Another consideration is whether employees should promptly evacuate the danger area, escape to a preplanned safe zone, and allow local emergency response organizations to handle the release.
IHs probably use the facility’s SDSs more than any other person on staff. Typically, the most relevant information for IHs is in the sections on composition and ingredients or exposure controls and limits, but the sections on physical and chemical properties, accidental release measures, firefighting, and others are beneficial to emergency planning. IHs’ knowledge of SDSs will facilitate this effort.
Pre-Startup Safety Reviews The pre-startup safety review (PSSR) is a critical component of OSHA’s PSM program. Completing the PSSR ensures that new or modified facilities accord with design specifications; operating, safety, and emergency procedures are in place and adequate; a PHA has been performed with recommendations resolved prior to startup; and training has been completed. Challenges that could affect implementation of PSSR components include budget and time constraints and employees’ lack of awareness of the PSSR.
The purpose of the PSSR is to ensure that process facilities are ready to start up safely. IHs can use the PSSR to identify vulnerabilities and ensure employee engagement. IHs can also be valued members of the PSSR team before a process is started or resumed. The orderly approach IHs employ when sampling translates well to implementation of a PSSR, which often relies on a checklist as a final step.
Compliance Audits Employers need to select a trained individual or assemble a trained team of people to audit the PSM system. A small process or plant may need only one knowledgeable person to conduct an audit. The auditor should evaluate the design and effectiveness of the PSM system and inspect safety and health conditions and practices to verify that the employer’s systems are effectively implemented. The audit should be led by a person knowledgeable in auditing techniques and impartial toward the facility or area being audited. Other elements of an audit include implementing and confirming corrective actions and documenting the audit.
Attention to detail is paramount in audits. Through their experience with exposure assessments, IHs are experts at unraveling the threads that make up a PSM program to determine compliance.
Contractors Employers who use contractors to perform work in and around processes that involve highly hazardous chemicals need to establish a screening process so the work will not compromise employees’ safety and health. For each contractor, employers should obtain references and injury and illness rates. In addition, the employer must ensure that contractors have the appropriate skills, knowledge, and certifications. Contractors’ work methods and experiences should be evaluated.
Because of their experience with contractors, IHs are well positioned to contribute to this area of PSM. A good industrial hygiene program will include both employees and contractors. While sampling may be limited to employees, contractors must be made aware of the hazards in the plant. Further, the IH is often notified when the contractor uses a product that an employee is concerned about. IHs must be involved in communication to both employees and contractors to ensure the health and safety of all personnel.
Hot Work Non-routine work conducted in process areas needs to be controlled in a consistent manner. The hazards involved must be communicated not only to those doing the work, but also to other personnel whose work could affect the safety of the process. A work authorization notice must describe the steps the maintenance supervisor, contractor representative, or other person needs to follow to obtain the necessary clearance to get the job started. The notice needs to coordinate, as applicable, lockout/tagout procedures, line breaking procedures, confined space entry procedures, and hot work authorizations, and should provide clear steps to follow once the job is completed so relevant personnel know that the work is done and equipment can be returned to normal.
The PSM standard’s requirements for hot work are often expanded to a general work authorization system. Depending on the plant’s staffing and organizational structure, an IH can be directly involved in this part of the program. The IH can be crucial in the recognition, evaluation, and control of hazards such as confined space entry and line breaking procedures.
Process Safety Information Complete, accurate, written information concerning process chemicals, technology, and equipment is essential to an effective PSM program. This information is necessary for the team that will perform the PHA; those developing the training programs and the operating procedures; contractors whose employees will be working with the process; those conducting the pre-startup reviews; local emergency preparedness planners; and insurance and enforcement officials. The information compiled about the chemicals, including process intermediates, must be comprehensive enough for an accurate assessment of the fire and explosion characteristics, reactivity hazards, safety and health hazards to workers, and the corrosion and erosion effects on the process equipment and monitoring tools.
The IH is a good resource for this information. An IH is well versed in the SDSs, knowledgeable about process chemistry, and skilled in conducting investigations. Because SDSs are often inadequate, most IHs have a bevy of alternate references to consult.
Mechanical Integrity Equipment used to process, store, or handle highly hazardous chemicals needs to be properly designed, constructed, installed, and maintained to minimize the risk of releases. These PSM requirements are managed through a mechanical integrity program. Elements of a mechanical integrity program include the identification and categorization of equipment and instrumentation, testing and inspections, maintenance procedures, training of maintenance personnel, development of criteria for acceptable test results, documentation of test and inspection results, and documentation of manufacturers’ recommendations for equipment and instrumentation. Employers also need to review their maintenance programs and schedules to determine whether “breakdown” maintenance is used rather than ongoing maintenance to verify mechanical integrity. In addition, a replacement-in-kind process is imperative to ensure that maintenance or repair work conforms to specifications.
IHs have several skills that apply to the mechanical integrity area of PSM. The routine calibration of pumps and direct-reading instruments is crucial to data validity and prevents failure when the equipment is needed for sampling. IHs also establish criteria for acceptable test results and documentation of manufacturer recommendations, which require skills similar to those practiced by maintenance personnel.
Operating Procedures Operating procedures describe tasks to be performed, data to be recorded, operating conditions to be maintained, samples to be collected, and precautions to be taken. The procedures need to be technically accurate, understandable to employees, and revised periodically to ensure that they reflect current operations. The operating procedures must be consistent with the known chemical hazards and the operating parameters described in the process safety information. Operating procedures should be reviewed by engineering staff and operations personnel to ensure that they provide accurate, practical instructions on how to perform job duties safely.
IHs are very familiar with operating procedures through sampling methods and user manuals for direct-reading instruments. The step-by-step format of operating procedures, which identifies expected results and what to do when a failure occurs, is consistent with IH programs.
Management of Change In the PSM standard, “change” includes all modifications to equipment, procedures, raw materials, and processing conditions other than “replacement in kind.” These changes need to be reviewed prior to implementation. For example, any operation outside of the parameters established by the operating procedures requires review and written approval.
Like mechanical integrity, replacement in kind is familiar to IHs, whose sampling media are specific to the analyte being sampled. Replacement in kind is a strict requirement for the IH and a matter of rote practice.
Trade Secrets Compliance with the trade secrets element of the PSM standard requires employers to provide confidential business information when constructing process safety information, PHAs, and incident investigations. This information may be difficult to acquire from a supplier and protect from competitors. Navigating between these tasks will be challenging.
IHs have experience working with trade secrets. Many of the ingredients on an SDS are protected by trade secret exclusions. IHs often must persuade companies to reveal the identities of these compounds. PSM trade secrets raise similar concerns. The information pertaining to a process or incident may be documented and spread throughout the organization. The tasks of locating and accessing this data can be assigned to the IH. IHs who are outside consultants are very familiar with non-disclosure agreements and the commercial necessity for limiting such information.
SUCCESS IN PSM Compliance with the PSM standard can be daunting. Good IHs are well informed about the chemical hazards of their facility or client. They use much of the same information in anticipating, recognizing, evaluating, controlling, and confirming health hazards that a PSM manager uses in developing a PHA. Including an IH on the PSM team can improve the overall compliance and success of the program.
MATTHEW PARKER, MS, CIH, CSP, ARM, is a safety and health consultant with Paragon Technical Services. He is the current chair of the AIHA Safety Committee, president of the Pensacola chapter of the American Society of Safety Professionals, and president-elect of AIHA’s Florida Local Section.
MERAIAH MARVEL, CSP, is a safety, health, and environment director at Parsons Corporation and a member of the AIHA Safety Committee.
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American Society of Safety Professionals: Safety Management: A Human Approach (2001).
Center for Immigration Studies: “67.3 Million in the United States Spoke a Foreign Language at Home in 2018” (October 2019).
Center for Plain Language: “What Is Readability and Why Should Content Editors Care About It?” (March 2017).
Chemical Safety and Hazard Investigation Board: “Process Safety Management Investigations.”
Chemical Safety and Hazard Investigation Board: “Process Safety Management for the 21st Century.”
EPA: Risk Management Plan (RMP) Rule.
EPA: Voluntary Implementation and Submission of RMP.
OSHA: Final Rule on Process Safety Management of Highly Hazardous Chemicals; Explosives and Blasting Agents.