A Universal Framework
Using OSHA’s Process Safety Management Standard to Enhance Your EHS Program
Working from Home but Missing Your Synergist? Update Your Address
If you’ve been working from home during the pandemic, please consider updating your address with AIHA. You can change your address by editing your profile through AIHA.org. To ensure uninterrupted delivery of The Synergist, designate your home address as “preferred” on your profile. Update your address now.
When people hear “process safety,” they think of chemical plants and oil refineries. The OSHA standard Process Safety Management of Highly Hazardous Chemicals (29 CFR 1910.119) reinforces this misunderstanding, since it applies only to processes that involve a chemical at or above the threshold quantities specified in its appendix A, “List of Highly Hazardous Chemicals, Toxics and Reactives.” But process safety actually applies to any process that has potential for harm. Some PSM programs cover an entire plant even though OSHA requires coverage for only a portion of it. Other facilities have applied process safety to any process where loss of containment can result in harm to people, environment, property, or public image.
OSHA’s PSM standard identifies fourteen elements that are required for management of large volumes (that is, threshold quantities) of highly hazardous chemicals. These fourteen elements should be part of every safety management program regardless of the chemicals or processes involved. A previous Synergist article—“Process Safety Management and the IH” in the October 2021 issue at aiha.info/syn2110psm—describes how IHs can help facilities fulfill each of OSHA’s requirements. This article discusses how those elements may be applied to any workplace.
EMPLOYEE PARTICIPATION  The first element in the OSHA PSM standard requires a written program to identify how employees will be involved in every aspect of process safety. Employers must consult with employees and give them access to relevant information about the conduct and development of process hazard analyses, or PHAs.
Employee participation is always a paramount consideration in every safety program. Workers have much to gain from a successful program and the most to lose if the program fails. Often, they know the most about potential hazards associated with their jobs. They have seen or experienced more near misses than any reporting system can collect, and they are often able to recommend a reasonable and effective control to mitigate the hazard. Successful programs tap into this knowledge. Safety programs or procedures written without employee input are much more likely to fail due to missing considerations or a lack of employee buy-in.
PROCESS SAFETY INFORMATION In a chemical operation, process safety information pertains to highly hazardous chemicals and includes toxicity information, permissible exposure limits, physical properties, reactivity data, and more. It also includes information pertaining to the technology of the process, such as a block flow diagram, process chemistry, inventory levels, and operating parameters (temperatures, pressures, flow rates, and so on).
Every workplace compiles a large amount and variety of safety information. The requirements of OSHA’s Hazard Communication standard (29 CFR 1910.1200) represent just one type of safety information that workplaces should already have compiled. But the typical safety program will also incorporate other data such as crane capacities, noise levels, production rates, seasonality of operations, ambient temperatures, process diagrams, flow charts, platform heights, anchor points, voltages, power distribution, safe distances, and many more. So much information is available to safety managers that they can become excessively focused on a specific operation and lose the big picture, or spend so much time collecting information that they never make a decision. A manager’s goal is to find a Goldilocks level of information: neither too much nor too little.
PROCESS HAZARD ANALYSIS The third element of PSM requires that employers perform an initial PHA on processes covered by the standard. The PHA should be appropriate to the complexity of the process and identify, evaluate, and control the hazards involved in the process. The standard requires that the PHA use one or more of the following system safety techniques: the “what if” method, a checklist, a hazard and operability study (HAZOP), a failure mode and effects analysis (FMEA), or a fault tree analysis (FTA).
HAZOP, FMEA, and FTA are complex tools with an engineering bent. They are typically reserved for elaborate systems but can be used for any process, task, or piece of equipment. Similarly, a risk analysis is just another type of PHA. The “what if” technique is ubiquitous among safety professionals and is incorporated into the industrial hygiene framework of anticipate, recognize, evaluate, control, and confirm (ARECC). Many safety programs also use checklists, which can be described as the written summary of someone else’s “what if” knowledge.
Highly hazardous chemicals have played a role in tragedies from Bhopal, India, to West, Texas.
Operating Procedures The PSM standard requires that employers “develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information.” These procedures must address the steps for each operating phase (startup, normal operations, shutdown, and so on), operating limits, and safety and health considerations. Chemical manufacturers can spend a lot of time and budget on developing procedures for their operations. They need to be detailed, thorough, and correct. Such procedures are subsequently converted to checklists or batch cards that document the recipes and steps in the process. Many procedures are also built into the computer programs that allow the plant to be remotely operated from a control room.
Operating procedures should also be commonplace in safety programs. Whether they are step-by-step instructions or checklists, such procedures can be used to guide daily activities or train new personnel. Local EHS procedures, job hazard analyses, job safety analyses, and work instructions are also covered by this element of PSM, but embedding EHS aspects into operation and work instructions is key because no one wants to follow three different documents to get work done. In all cases, the procedures should be reviewed as often as necessary to ensure that they reflect changes in technology, equipment, and facilities.
Training The PSM standard requires initial training before employees are assigned to a process and refresher training at least every three years. As specified in the standard, “The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee’s job tasks.” The employer must also “ascertain that each employee involved in operating a process has received and understood the training required” and that “a record [that] contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training” is documented.
A “knowledge and skills development” program is key to effective EHS management. Many OSHA standards include explicit safety and health training requirements to ensure that workers have the required skills and knowledge to safely do their work. These requirements reflect that training is an essential part of every employer’s safety and health program for protecting workers from injuries and illnesses. This point is best made by OSHA’s publication “Training Requirements in OSHA Standards” (PDF).
Contractors The PSM standard does a good job discussing the selection and training of contractors and contractors’ responsibilities. This element applies to contractors performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a process covered by the standard; it does not apply to contractors that provide incidental services, such as janitorial work or groundskeeping. According to the standard, “the employer shall obtain and evaluate information regarding the contractor’s safety performance and programs.” Site management is also required to inform the contractor of known hazards related to their work or the location of that work on the site. This two-way communication enhances the contractor’s performance in mitigating the hazards they may create or work around.
Establishing a quality-based contractor selection process is a necessary first step in forming a strong partnership between your plant and your contract service provider. In a competitive environment, it is important to obtain accurate comparisons of providers and thoroughly understand what you are receiving in return for your money. A strong contractor selection process and contractor oversight policy ensure safe, quality work. The publication “Health and Safety Requirements in Construction Contract Documents” written by the AIHA Construction Committee is one of many contractor selection guides available. Companies that provide contractor pre-approval services can do some of the work for you. Keep in mind that the cheapest contractor may not be the most cost effective and that a relationship with your contractor is more important than a purchase order.
Pre-startup safety review The PSM standard requires “a pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information.” This safety review is required before highly hazardous chemicals are introduced to the process and must confirm that the construction and equipment meet the design specifications; all relevant safety, operating maintenance, and emergency procedures have been revised or updated as needed and are in place; PHAs have been completed and mitigations have been implemented and verified before startup and that requirements for change management outlined elsewhere in the standard have been met; and that each employee engaged in the process has been trained on the updated process and procedures.
Ensuring that changed processes are safe to start up is critical for any activity that puts employee safety and health, or the environment, at risk. Pre-startup safety reviews of any new or modified process or activity must ensure the design criteria have been met, that any new hazards are controlled, and that procedures and employee training have been considered, updated, and communicated. It’s good practice to apply pre-startup reviews before initiating any new or modified system, process, or activity, including something as simple as moving into a new office space. Pre-startup safety review is about assessing the risk of the change and verifying that the right controls are in place before “turning the switch on.”
Mechanical integrity OSHA believes it is important to maintain the mechanical integrity of critical process equipment to ensure it is designed and installed correctly and operates properly. PSM mechanical integrity inspection requirements apply to pumps, pressure vessels, storage tanks, piping systems, relief valves, and so on. The employers or contractors conducting these inspections must be trained and their testing procedures must follow recognized and generally accepted good engineering practices.
Integrity is the state of being whole or undivided—of being unified, unimpaired, or sound in construction. A good EHS program is a mechanical integrity program. Many hazards are controlled by design engineering, but maintaining these controls is a challenge. Every routine safety inspection seeks to confirm that machine guards are present, interlocks are functioning, extension cords are in good condition, and other indications that the device is doing its intended job.
Hot work permit A hot work permit must be issued for hot work operations conducted on or near a covered process. The permit must document that the fire prevention and protection requirements in OSHA’s standard for welding, cutting, and brazing (29 CFR 1910.252) have been implemented prior to beginning the hot work operations; indicate the dates authorized for hot work; and identify the object on which hot work is to be performed. Hot work permits are always important, but their significance soars if your extremely hazardous substance is flammable.
All EHS programs should include a hot work permit program. In many locations, these permits are required for compliance with National Fire Protection Association standards. Every year, thousands of fire incidents cause loss of human life and damage to property. Most of these incidents are due to poor practice or inadequate knowledge on the part of workers, which can be avoided with a few precautions. A hot work permit system will help prevent these incidents.
Management of Change Contemplated changes to a process must be thoroughly evaluated. To this end, the PSM standard requires written procedures to manage changes to process chemicals, technology, equipment, and procedures, as well as changes to facilities that affect a process covered by the standard. These written procedures must ensure that the technical basis for the proposed change, its impact on employee safety and health, modifications to operating procedures, and authorization requirements are addressed.
An EHS program should be a perpetual management of change (MOC) program. As a member of management entrusted with the safety and health of employees, the EHS manager is uniquely charged with keeping an eye on the entire system and should be part of the decision matrix in a forward-looking capacity. However, many EHS managers find themselves in reactive situations. Inspections, audits, and incidents all require EHS managers to respond to and mitigate effects or prevent and minimize recurrence. Similar to PHAs, MOC is part of the ARECC framework.
Incident investigation The PSM standard requires an investigation of any catastrophic releases of highly hazardous chemicals, as well as incidents that might have resulted in a catastrophic release. The standard specifies who should be involved in the investigation, how quickly the investigation should be initiated, what should be included in the investigation report, how corrective actions should be planned and documented, and how long investigation reports should be retained. The standard states that those closest to the incident and most knowledgeable about the process should be included in the investigation, and that the investigation report should be shared with all employees—including contracted employees—whose jobs are relevant to the incident and investigation findings.
Incident, event, or near-miss investigations aren’t new to EHS professionals. In fact, they are key elements of any EHS management system, and current guidance calls for a systematic review of incidents and near misses so that processes or activities can be improved. Investigations should involve those closest to the work because they know the work best. It is imperative that blame is left out of any investigation. Humans make errors and act in the context of the environment they work in. Understanding those elements is critical to improving the safety of any system or process.
Emergency planning and response The PSM standard requires emergency action plans for the entire facility covered by the standard. OSHA requirements for emergency action plans are specified in a separate standard (29 CFR 1910.38) and include procedures for reporting emergencies, evacuation or shelter-in-place procedures for identifying personnel who remain to secure critical operations, procedures for accounting for employees, and rescue and medical procedures. Someone must “own” the emergency action plan, update the plan as needed, train employees who have key responsibilities, and provide information about the plan to employees when requested. The PSM standard also requires procedures for handling small releases and states that a facility or process may be within the scope of some elements of the OSHA standard for hazardous waste operations and emergency response (29 CFR 1910.120).
Like incident investigation, emergency planning and response is foundational to any EHS plan, and emergency action planning is a key element in EHS management systems. When considered together, the requirements of the standards for PSM and emergency action plans provide an excellent foundation for developing, implementing, and executing an emergency action plan for any facility, not just those handling hazardous chemicals subject to the PSM standard. But emergency action plans need to consider the hazards and risks, both inherent and external, to the facility and its operations. Emergency procedures for adverse weather events, workplace violence, external disruptions, and other “outside” risks have to be considered in addition to operational hazards and risks. While not referenced in either OSHA standard, practicing the facility emergency action plan is important so that employees and others on site know what to do when an emergency occurs.
Compliance Audits The PSM standard requires that facility procedures and practices be audited at least every three years to ensure compliance with the standard, and that the employer “certify” that compliance has been ensured. Audits must be conducted by persons knowledgeable in both the standard and facility processes, and the audit must be documented in a report of findings. The standard requires employers to address findings and correct deficiencies, and to document these actions. The facility must maintain the two most recent audit reports.
Audits are intended to ensure compliance with regulatory requirements and with a facility’s own EHS management system. They reveal whether you’re doing what you say you’ll do to keep employees safe and healthy while protecting the environment. Generally, audits and inspections are considered “lines of defense” in ensuring a facility’s compliance status. For most organizations, the first line of defense refers to audits and inspections conducted locally by facility personnel; the second line of defense refers to audits and inspections conducted by third parties and may focus on specific areas; and the third line of defense refers to a corporate audit function. Each line of defense is intended to verify compliance or conformance with standards, but when they are done correctly, audits also provide opportunities for learning and improvement.
Trade secrets Employers must make available all information necessary to comply with PSM requirements without regard to the possible trade secret status of such information. This requirement ensures that personnel charged with PSM responsibilities can complete their duties. Nothing in the PSM standard, however, precludes the employer from requiring confidentiality agreements that prohibit disclosure of sensitive information.
Trade secrets are a challenge for most EHS programs. Such information is likely to be limited unless regulation requires its disclosure. But in general industry and construction, access to most information is unrestricted and will not impede hazard analyses, operating procedures, training, incident investigations, or other aspects of the program. The trade secret ingredients listed on many safety data sheets can be problematic, but OSHA’s hazard communication standard requires hazard information to be provided on an SDS, and other information, such as chemical name and composition, must be disclosed if requested by an industrial hygienist for sampling purposes.
A Part of Every Program The PSM standard is a crucial part of the overall OSHA mission. The facilities subject to the standard are complex and dangerous. Highly hazardous chemicals have played a role in tragedies from Bhopal, India, to West, Texas. When a PSM program in these facilities fails, the consequences can include fatalities that number from dozens to tens of thousands and the destruction of a town’s primary employer.
When applying the PSM standard, the level of effort and detail will vary depending on the hazard and associated risk. But the elements of PSM are universal. They should be part of every safety program.
MATTHEW PARKER, MS, CIH, CSP, ARM, is past chair of the AIHA Safety Committee.
VIC D’AMATO, CIH, CSP, is past administrator of the American Society of Safety Professionals IH Practice Specialty Group.
Send feedback to The Synergist.
OSHA: Occupational Safety and Health Standards, Hazardous Materials, Process Safety Management of Highly Hazardous Substances.
The Synergist: “Process Safety Management and the IH” (October 2021).