736studyguide

OSHAcademy Course 736 Study Guide
Copyright © 2000-2013 Geigle Safety Group, Inc.
Introduction to
Process Safety
Management

Copyright © 2000-2013 Geigle Safety Group, Inc. Page 2 of 51
Introduction to Process Safety Management
Copyright © 2013 Geigle Safety Group, Inc.
No portion of this text may be reprinted for other than personal use. Any commercial use of
this document is strictly forbidden.
Contact OSHAcademy to arrange for use as a training document.
This study guide is designed to be reviewed off-line as a tool for preparation to successfully
complete OSHAcademy Course 736.
Read each module, answer the quiz questions, and submit the quiz questions online through
the course webpage. You can print the post-quiz response screen which will contain the correct
answers to the questions.
The final exam will consist of questions developed from the course content and module quizzes.
We hope you enjoy the course and if you have any questions, feel free to email or call:
OSHAcademy
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Beaverton, Oregon 97006
www.oshatrain.org
instructor@oshatrain.org
+1.888.668.9079

Contents
Course Introduction........................................................................................................................ 6
The purpose for Process Safety Management (PSM)................................................................. 6
Module 1: Why We Have Process Safety Management................................................................. 7
The Problem................................................................................................................................ 7
A Disastrous Record.................................................................................................................... 7
OSHA Proposes the PSM Standard ............................................................................................. 8
The Clean Air Act Amendments and the PSM Standard............................................................. 9
CAAA Requirements for the PSM Standard................................................................................ 9
What are the benefits of an effective PSM program?.............................................................. 11
Module 1 Quiz........................................................................................................................... 12
Module 2: How the PSM Standard Applies................................................................................... 14
Application................................................................................................................................ 14
What does PSM target?............................................................................................................ 14
What does the employer need to develop?............................................................................. 14
What is the impact of the PSM? ............................................................................................... 14
What can employers do to reduce risk?................................................................................... 15
Who is not covered by the PSM Standard?.............................................................................. 15
Module 2 Quiz........................................................................................................................... 17
Module 3: Process Safety Information ......................................................................................... 18
Developing the written PSM Plan............................................................................................. 18
Hazards of the Chemicals Used in the Process......................................................................... 18
Technology of the Process........................................................................................................ 19
Block Flow Diagrams................................................................................................................. 20
Process Flow Diagrams ............................................................................................................. 21
Equipment in the Process ......................................................................................................... 23
Module 3 Quiz........................................................................................................................... 25
Module 4: Process Hazard Analysis (PHA).................................................................................... 27

What is Process Hazard Analysis?............................................................................................. 27
Questions to consider when deciding the methods used in PHA’s.......................................... 27
Limitations of PHA Methods..................................................................................................... 27
Prioritizing PHA’s....................................................................................................................... 28
Methods for Conducting the PHA............................................................................................. 28
The PHA..................................................................................................................................... 29
Employer Response to PHA Team Findings.............................................................................. 30
Review and Revalidation........................................................................................................... 31
Module 4 Quiz........................................................................................................................... 32
Module 5: Operating Procedures ................................................................................................. 34
What are Operating Procedures?............................................................................................. 34
What must operating procedures describe?............................................................................ 34
Elements of the Operating Procedures .................................................................................... 35
Module 5 Quiz........................................................................................................................... 37
Module 6: Employee Participation ............................................................................................... 38
Employers duty to involve employees...................................................................................... 38
Initial Training ........................................................................................................................... 38
Refresher Training..................................................................................................................... 39
Training Documentation........................................................................................................... 39
Module 6 Quiz........................................................................................................................... 40
Module 7: Contractors.................................................................................................................. 42
Application................................................................................................................................ 42
Employer Responsibilities......................................................................................................... 42
Contract Employer Responsibilities.......................................................................................... 43
Pre-Startup Safety Review ........................................................................................................ 43
Module 7 Quiz........................................................................................................................... 44
Module 8: Mechanical Integrity and Hot Work Permit ................................................................ 46
Mechanical Integrity................................................................................................................. 46
Training ..................................................................................................................................... 46

Inspection.................................................................................................................................. 46
Correcting Deficiencies ............................................................................................................. 47
New Construction and Equipment............................................................................................ 47
Hot Work Permit....................................................................................................................... 47
Final words of PSM wisdom! .................................................................................................... 48
Module 8 Quiz........................................................................................................................... 49
Optional Exercise .......................................................................................................................... 51

Course Introduction
The purpose for Process Safety Management (PSM)
The major purpose of process safety management (PSM) of highly hazardous chemicals is to
prevent unwanted releases of hazardous chemicals, especially into locations that could expose
employees and others to serious hazards. OSHA
simply states a hazardous chemical is any chemical
which is a physical hazard or a health hazard.
An effective process safety management program
requires a systematic approach to evaluating the
whole chemical process. Using this approach, the
process design, process technology, process changes, operational and maintenance activities
and procedures, non-routine activities and procedures, emergency preparedness plans and
procedures, training programs, and other elements that affect the process are all considered in
the evaluation.
This course is intended to introduce you to the basic requirements in the PSM standard, the
need for process safety, and the tools used to implement process safety management systems.
It covers the 14 elements required by the standard and some of the tools used to address
process safety requirements, identify hazards, and manage risks. This course does not itself
alter or determine compliance responsibilities, which are set forth in OSHA standards
themselves and the Occupational Safety and Health Act.
Special thanks go out to the U.S. Dept. of Labor, OSHA, for the content and images within this
course.

Module 1: Why We Have Process Safety Management
The Problem
Unexpected releases of toxic, reactive, or flammable liquids and gases in processes involving
highly hazardous chemicals have been reported for many years. Incidents continue to occur in
various industries that use highly hazardous chemicals which may be toxic, reactive, flammable,
or explosive, or may exhibit a combination of these
properties. Regardless of the industry that uses these
highly hazardous chemicals, there is a potential for an
accidental release any time they are not properly
controlled. This, in turn, creates the possibility of
disaster.
Recent major disasters include the 1984 Bhopal, India,
incident resulting in more than 2,800 deaths; the
October 1989 Phillips Petroleum Company, Pasadena,
TX, incident resulting in 23 deaths and 132 injuries; the July
1990 BASF, Cincinnati, OH, incident resulting in 2 deaths, and
the May 1991 IMC, Sterlington, LA, incident resulting in 8
deaths and 128 injuries.
A Disastrous Record
Several major disasters involving highly hazardous chemicals
drew international attention to the potential for major
catastrophes; the public record in the U.S. is replete with information concerning many other
less notable releases of highly hazardous chemicals. Hazardous chemical releases continue to
pose a significant threat to employees and provide
impetus, internationally and nationally, for
authorities to develop or consider developing
legislation and regulations to eliminate or minimize
the potential for such events.

Methyl Isocyanate Tank Rupture and Release
Bhopal, India – Dec. 2-3, 1984
On the night of December 2-3, 1984, a sudden
release of about 30 metric tons of methyl
isocyanate (MIC) occurred at the Union Carbide
pesticide plant at Bhopal, India. The accident was
a result of poor safety management practices,
poor early warning systems, and the lack of
community preparedness. The accident led to the
death of over 2,800 people (other estimates put
the immediate death toll as high as 8000) living in
the vicinity and caused respiratory damage and eye damage to over 20,000 others. At least
200,000 people fled Bhopal during the week after the accident. Estimates of the damage vary
widely between $350 million to as high as $3 billion.
Phillips 66 Houston Chemical Complex Pasadena, Texas – Oct. 23, 1989
On October 23, 1989, at approximately 1:00 p.m., an explosion and fire ripped through the
Phillips 66 Company Houston Chemical Complex in Pasadena, Texas. Twenty-three workers
were killed and more than 130 were injured. Property damage was nearly three-quarters of a
billion dollars. The accident resulted from a release of extremely flammable process gases that
occurred during regular maintenance operations on one of the plant's polyethylene reactors.
The evidence showed that more than 85,000 pounds of highly flammable gases were released
through an open valve. A vapor cloud formed and traveled rapidly through the polyethylene
plant. Within 90 to 120 seconds, the vapor cloud came into contact with an ignition source and
exploded with the force of 2.4 tons of TNT.
OSHA Proposes the PSM Standard
On July 17, 1990, the U.S. Dept. of Labor, OSHA published in the Federal Register a proposed
standard, - ”Process Safety Management of Highly Hazardous Chemicals” (PSM) - containing
requirements for the management of hazards associated with processes using highly hazardous
chemicals to help assure safe and healthful workplaces.
OSHA's PSM standard emphasizes the management of hazards associated with highly
hazardous chemicals and established a comprehensive management program that integrated
technologies, procedures, and management practices.

The Clean Air Act Amendments and the PSM Standard
Approximately four months after the publication of OSHA's proposed PSM standard, the Clean
Air Act Amendments (CAAA) were enacted into law. Section 304 of the CAAA requires that the
Secretary of Labor, in coordination with the Administrator of the Environmental Protection
Agency (EPA), promulgate a PSM standard to prevent accidental releases of chemicals that
could pose a threat to employees.
CAAA Requirements for the PSM Standard
The CAAA requires that the standard include a list of highly hazardous chemicals which includes
toxic, flammable, highly reactive, and explosive substances. These requirements have become
widely known as the “14 PSM Program Elements.”
The CAAA also specified 14 minimum elements that the OSHA standard must require employers
to do, as follows:
1. develop and maintain written safety information identifying workplace chemical and
process hazards, equipment used in the processes, and technology used in the processes;
2. perform a workplace hazard assessment, including, as appropriate, identification of
potential sources of accidental releases, identification of any previous release within the
facility that had a potential for catastrophic consequences in the workplace, estimation of
workplace effects of a range of releases, and estimation of the health and safety effects
of such a range on employees;
3. consult with employees and their representatives on the
development and conduct of hazard assessments and the
development of chemical accident prevention plans and
provide access to these and other records required under
the standard;
4. establish a system to respond to the workplace hazard
assessment findings, which shall address prevention,
mitigation, and emergency responses;
5. review periodically the workplace hazard assessment and
response system;

6. develop and implement written operating procedures for the chemical processes,
including procedures for each operating phase, operating limitations, and safety and
health considerations;
7. provide written safety and operating information for employees and employee training in
operating procedures, by emphasizing hazards and safe practices that must be developed
and made available;
8. ensure contractors and contract employees are provided with appropriate information
and training;
9. train and educate employees and contractors in emergency response procedures in a
manner as comprehensive and effective as that required by the regulation promulgated
pursuant to section 126(d) of the Superfund Amendments and Reauthorization Act;
10. establish a quality assurance program to ensure that initial process-related equipment,
maintenance materials, and spare parts are fabricated and installed consistent with
design specifications;
11. establish maintenance systems for critical process-related equipment, including written
procedures, employee training, appropriate inspections, and testing of such equipment to
ensure ongoing mechanical integrity;
12. conduct pre-startup safety reviews of all newly installed
or modified equipment;
13. establish and implement written procedures managing
change to process chemicals, technology, equipment and
facilities; and
14. investigate every incident that results in or could have
resulted in a major accident in the workplace, with any findings to be reviewed by
operating personnel and modifications made, if appropriate.

What are the benefits of an effective PSM program?
Effective PSM helps ensure the proper development of plant systems and procedures to
prevent unwanted releases which may ignite and cause toxic impacts, local fires, or explosions
in plants and installations.
PSM can also improve:
• the operability, productivity, stability, and quality of the outputs of hazardous
chemical processes; and
• the design and specification of safeguards against undesirable events.
Effective PSM results in reduced exposure to lawsuits, OSHA penalties, public liability claims,
and hikes in workers compensation insurance premiums.
Other intangible benefits include an improved corporate image – the community sees the
company as a responsible corporate citizen.

Module 1 Quiz
Use this quiz to self-check your understanding of the module content. You can also go online
and take this quiz within the module. The online quiz provides the correct answer once
submitted.
1. Which of the following is true about the purpose of process safety management (PSM)
of highly hazardous chemicals?
a. to understand the nature of processes
b. to keep hazardous chemicals out of processes
c. to prevent unwanted releases of hazardous chemicals
d. to limit the amount of hazardous chemicals in processes
2. Clean Air Act Amendments (CAAA) specified which of the minimum PSM elements
that OSHA must require employers to do?
a. Develop and maintain written safety information
b. Perform a workplace hazard assessment
c. Train and educate employees and contractors
d. all of the above
3. Under the PSM Program, employers are to train and educate employees and
contractors in which of the following topics?
a. emergency response procedures
b. filing complaints with OSHA
c. notifying employees of unsafe acts
d. what to expect from an OSHA inspection
4. Establish a quality assurance program to ensure which of the following are fabricated
and installed consistent with design specifications?
a. initial process-related equipment
b. maintenance materials
c. spare parts
d. all of the above

5. A workplace hazard assessment is performed to do all of the following, EXCEPT:
a. identification of potential sources of accidental releases
b. evaluation of processes that may cause faulty readings
c. identification of any previous release
d. estimation of workplace effects of a range of releases

Module 2: How the PSM Standard Applies
Application
The various lines of defense incorporated into the design
and operation of the PSM process should be evaluated and
strengthened to make sure they are effective at each level.
Process safety management is the proactive identification,
evaluation and mitigation or prevention of chemical
releases that could occur as a result of failures in
processes, procedures, or equipment.
What does PSM target?
The process safety management standard targets highly hazardous chemicals that have the
potential to cause a catastrophic incident. The purpose of the standard as a whole is to aid
employers in their efforts to prevent or mitigate episodic chemical releases that could lead to a
catastrophe in the workplace and possibly in the surrounding community. It’s important to note
that the PSM standard is a performance-based rule; it does not specifically prescribe how each
element is to be implemented. That’s left up to the employer.
What does the employer need to develop?
To control these types of hazards, employers need to develop the necessary expertise,
experience, judgment, and initiative within their work force to properly implement and
maintain an effective process safety management program as envisioned in the OSHA PSM
standard.
As you learned earlier, the OSHA PSM standard is required by
the Clean Air Act Amendments (CAAA) and the Environmental
Protection Agency's Risk Management Plan (RMP).
Employers who merge the two sets of requirements into their
PSM program will better assure full compliance with CAAA
and the RPM as well as enhance their relationship with the
local community.
What is the impact of the PSM?
OSHA believes that the PSM requirements has a definite positive effect on the safety of
employees and offers other potential benefits to employers, such as increased productivity.

What can employers do to reduce risk?
Employers, including small employers, may establish more
efficient inventory control by reducing, to below the established
threshold, the quantities of highly hazardous chemicals onsite.
This reduction can be accomplished by ordering smaller
shipments and maintaining the minimum inventory necessary
for efficient and safe operation.
When reduced inventory is not feasible, the employer might
consider dispersing inventory to several locations onsite.
Dispersing storage into locations so that a release in one
location will not cause a release in another location is also a
practical way to reduce the risk or potential for catastrophic
incidents.
Who is not covered by the PSM Standard?
The PSM standard does not apply to:
• retail facilities;
• oil or gas well drilling or
servicing operations;
• normally unoccupied remote
facilities;
• hydrocarbon fuels used solely
for workplace consumption as a
fuel (e.g. propane used for
comfort heating, gasoline for
vehicle refueling), if such fuels
are not a part of a process containing another highly hazardous chemical covered by
this standard; and
• flammable liquid stored in atmospheric tanks or transferred which are kept below
their normal boiling point without benefit of chilling or refrigerating and are not
connected to a process.

BP American Refinery Explosion – Texas City, Texas (March 23, 2005)
At approximately 1:20 p.m. on March 23, 2005, a series of explosions occurred at the BP Texas
City refinery during the restarting of a hydrocarbon isomerization unit. Fifteen workers were
killed and 180 others were injured. Many of the victims were in or around work trailers located
near an atmospheric vent stack. The explosions occurred when a distillation tower flooded with
hydrocarbons and was over pressurized, causing a geyser-like release from the vent stack.

Module 2 Quiz
submitted.
1. Process safety management is the ________ identification, evaluation and mitigation
or prevention of chemical releases that could occur as a result of failures in processes,
procedures, or equipment.
a. proactive
b. reactive
c. systematic
d. random
2. According to the text, the process safety management standard targets highly
hazardous chemicals that have the potential to cause a _________ incident.
a. dangerous
b. catastrophic
c. horrendous
d. fatal
3. The OSHA PSM standard is required by which of the following?
a. Clean Air Act Amendments (CAAA)
b. Environmental Protection Agency Management Plan (RMP)
c. 1970 Occupational Safety and Health Act (OSHA)
d. Both A & B
4. Employers may establish more efficient inventory control by reducing the quantities
of highly hazardous chemicals to below which of the following?
a. minimum HAZCOM levels
b. maximum HAZCOM levels
c. established threshold
d. detectable threshold
5. The PSM standard does not apply to the following:
a. Retail facilities
b. Oil or gas well drilling or servicing operations
c. Normally unoccupied remote facilities
d. All of the above

Module 3: Process Safety Information
Developing the written PSM Plan
Employers must compile written process safety information before conducting any process
hazard analysis required by the standard. The written process safety information will help the
employer and the employees involved in operating the process to identify and understand the
hazards posed by those processes that involve highly hazardous chemicals.
To develop an effective PSM program and Process Hazard Analysis (PHA), it is important to
develop and maintain complete and accurate written information on each of the following:
1. process chemicals,
2. process technology, and
3. process equipment
This information will be used by:
• the team performing the process hazard
analysis;
• 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.
Hazards of the Chemicals Used in the Process
The information about the chemicals, including process intermediates, needs to be
comprehensive and accurate. Information on the hazards of the highly hazardous chemicals in
the process shall consist of at least the following:
• Toxicity
• Permissible exposure limits
• Physical data
• Reactivity data

• Corrosivity data
• Thermal and chemical stability data
• The hazardous effects of inadvertent mixing of different materials
Current safety data sheets (SDS) can be used to help gather information about hazardous
chemicals, but it must be supplemented with process chemistry information, including runaway
reaction and over-pressure hazards, if applicable.
Technology of the Process
Process technology information is a part of the process safety information package and should
include employer-established criteria for:
• maximum inventory levels for process chemicals;
• limits beyond which would be considered upset conditions; and
• a qualitative estimate of the consequences or results of deviation that could occur if
operating beyond the established process limits.
Information on the technology of the process must include at least the following:
• A block flow diagram or simplified process flow diagram,
• Process chemistry,
• Maximum intended inventory,
• Safe upper and lower limits for such items as temperatures, pressures, flows or
compositions, and
• An evaluation of the consequences of deviations, including those affecting the safety
and health of employees.
Where the original technical information no longer exists, information may be developed in
conjunction with the process hazard analysis in sufficient detail to support the analysis.
Note: Safety Data Sheets (SDSs) meeting the requirements of the Hazard Communication
Standard (20 CFR 1910.1200) may be used to comply with this requirement to the extent they
contain the required information.

Block Flow Diagrams
A block flow diagram can be used to show the major process equipment and interconnecting
process flow lines and flow rates, stream composition, temperatures, and pressures when
necessary for clarity. The block flow diagram is a simplified diagram. See the sample block flow
diagram below:

Process Flow Diagrams
Process flow diagrams are more complex and show all main flow streams including valves to
enhance the understanding of the process as well as pressures and temperatures on all feed

and product lines within all major vessels and in and out of headers and heat exchangers, and
points of pressure and temperature control.
Also, information on construction materials, pump capacities and pressure heads, compressor
horsepower, and vessel design pressures and temperatures are shown when necessary for
clarity.
In addition, process flow diagrams usually show major components of control loops along with
key utilities.

Equipment in the Process
Piping and instrument diagrams (P&IDs) may be used to describe the relationships between
equipment and instrumentation as well as other relevant information that will enhance clarity.
Computer software programs that create P&IDs or other diagrams useful to the information
package may be used to help meet this requirement.
Information on the equipment in the process must include the following:
• materials of construction;

• piping and instrument diagrams (P&IDs);
• electrical classification;
• relief system design and design basis;
• ventilation system design;
• design codes and standards employed;
• material and energy balances for processes built after May 26, 1992; and
• safety systems (e.g., interlocks, detection, or suppression systems).
The employer must document that equipment complies with recognized and generally
accepted good engineering practices.
For existing equipment designed and constructed in accordance with codes, standards, or
practices that are no longer in general use, the employer must determine and document that
the equipment is designed, maintained, inspected, tested, and operated in a safe manner.
Compiling and maintaining this information is important to:
• To provide the basis for identifying and understanding the hazards of a process
• To develop the process hazard analysis
• Comply with other provisions of PSM such as management of change and incident
investigations.
For existing equipment designed and constructed many years ago the employer must:
• document which codes and standards were used
• certify that the design and construction along with the testing, inspection, and
operation are still suitable for the intended use.
Where the process technology requires a design that departs from the applicable codes and
standards, the employer must document that the design and construction are suitable for the
intended purpose.

Module 3 Quiz
submitted.
1. To develop an effective PSM program and Process Hazard Analysis (PHA), it is
important to develop and maintain complete and accurate written information on
each of the following, EXCEPT:
a. process equipment
b. process theory
c. process chemicals
d. process technology
2. Information on the hazards of the highly hazardous chemicals in the process shall
consist of at least which of the following?
a. Toxicity
b. Permissible exposure limits
c. Reactivity Data
d. All of the above
3. Under the PSM Program, current safety data sheets (SDS) can be used to help gather
information about hazardous chemicals.
a. True
b. False
4. A __________can be used to show the major process equipment and interconnecting
process flow lines and flow rates, stream composition, temperatures, and pressures
when necessary for clarity.
a. piping diagram
b. brain-storming session
c. block flow diagram
d. what-if flow diagram

5. Where the process technology requires a design that departs from the applicable
codes and standards, the employer must do which of the following?
a. document suitability for the intended purpose
b. state that the technology complies with CAAA
c. prove the technology has been approved by OSHA
d. obtain the related permits for installation

Module 4: Process Hazard Analysis (PHA)
What is Process Hazard Analysis?
A PHA, or evaluation, is one of the most important elements of the process safety management
program.
A PHA is an organized and systematic effort to identify and analyze the significance of potential
hazards associated with the processing or handling of highly hazardous chemicals.
A PHA provides information that will assist employers and employees in making decisions for
improving safety and reducing the consequences of unwanted or unplanned releases of
hazardous chemicals.
A PHA analyzes potential causes and consequences of fires, explosions, releases of toxic or
flammable chemicals, and major spills of hazardous chemicals.
The PHA focuses on equipment, instrumentation, utilities, human actions (routine and non-
routine), and external factors that might affect the process.
The employer must perform an initial process hazard analysis (hazard evaluation) on all
processes covered by the PSM standard.
Questions to consider when deciding the methods used in PHA’s
The process hazard analysis method selected must be appropriate to the complexity of the
process and must identify, evaluate, and control the hazards involved in the process.
The selection will be influenced by many factors including how much is known about the
process.
• Is it a process that has been operated for a long period of time with little or no
innovation and extensive experience has been generated with its use?
• Is it a new process or one that has been changed frequently by the inclusion of
innovation features?
Also, the size and complexity of the process will influence the decision as to the appropriate
PHA method to use.
Limitations of PHA Methods
All PHA methods are subject to certain limitations. For example:

• The checklist method works well when the process is very stable and no changes are
made, but it is not as effective when the process has undergone extensive change.
The checklist may miss the most recent changes and consequently they would not
be evaluated.
• Another limitation to be considered concerns the assumptions made by the team or
analyst. The PHA is dependent on good judgment and the assumptions made during
the study need to be documented and understood by the team and reviewer and
kept for a future PHA.
Prioritizing PHA’s
First, employers must determine and document the priority order for conducting process
hazard analyses. Consideration should be given first to those processes with the potential of
adversely affecting the largest number of employees. Other considerations include:
• the extent of the process hazards;
• the number of potentially affected employees;
• the age of the process; and
• the operating history of the process.
Together, these factors would suggest a ranking order using either a weighting factor system or
a systematic ranking method.
The use of a preliminary hazard analysis will assist an employer in determining which process
should be of the highest priority for hazard analysis resulting in the greatest improvement in
safety at the facility occurring first.
Methods for Conducting the PHA
The employer must use one or more of the following methods, as appropriate, to determine
and evaluate the hazards of the process being analyzed:
• What-if,
• Checklist,
• What-if/checklist,
• Hazard and operability study (HAZOP),

• Failure mode and effects analysis (FMEA),
• Fault tree analysis, or
• An appropriate equivalent method.
A discussion of these methods of analysis is contained in the publication, OSHA 3133, Process
Safety Management Guidelines for Compliance. Whichever method(s) are used, the process
hazard analysis must do the following:
• address the hazards of the process;
• identify any previous incident that had a potential for catastrophic consequences in
the workplace;
• determine engineering and administrative controls applicable to the hazards and
their interrelationships, such as appropriate application of detection methods to
provide early warning of releases (acceptable detection methods might include
process monitoring and control instrumentation with alarms, and detection
hardware such as hydrocarbon sensors);
• identify the consequences of failure of engineering and administrative controls;
• address facility siting;
• address human factors; and
• conduct a qualitative evaluation of a range of the possible safety and health effects
on employees in the workplace if there is a failure of controls.
Different methods for various parts of the process may be used. For example, a process
involving a series of unit operations of varying sizes, complexities, and ages may use different
methods and team members for each operation. Then the conclusions can be integrated into
one final study and evaluation.
The PHA Team
OSHA believes that the process hazard analysis is best performed by a team with expertise in
engineering and process operations. The team conducting the PHA needs to understand the
method that is going to be used. The PHA team should include:

• at least one employee who has experience with and knowledge of the process being
evaluated; and
• one member (preferably the team leader) knowledgeable in the specific analysis
methods and proper implementation of methods being used in the evaluation.
The other full or part-time team members need to provide the team with expertise in areas
such as:
• process technology;
• process design;
• operating procedures and practices;
• alarms;
• emergency procedures;
• instrumentation;
• maintenance procedures, both routine and non-routine tasks, including how the
tasks are authorized;
• procurement of parts and supplies;
• safety and health; and
• any other relevant subjects.
The ideal team will have an intimate knowledge of the standards, codes, specifications, and
regulations applicable to the process being studied. The selected team members need to be
compatible and the team leader needs to be able to manage the team and the PHA study. The
team needs to be able to work together while benefiting from the expertise of others on the
team or outside the team to resolve issues and to forge a consensus on the findings of the
study and recommendations.
Employer Response to PHA Team Findings
In response to the PHA Team’s findings and recommendations, the employer must establish a
system to:
• address promptly the team's findings and recommendations;
• ensure that the recommendations are resolved in a timely manner and that the
resolutions are documented;
• document what actions are to be taken;
• develop a written schedule of when these actions are to be completed;
• complete actions as soon as possible; and

• communicate the actions to operating, maintenance, and other employees whose
work assignments are in the process and who may be affected by the
recommendations or actions.
Review and Revalidation
At least every five years after the completion of
the initial process hazard analysis, the process
hazard analysis must be updated and revalidated
by a team meeting the standard's requirements to
ensure that the hazard analysis is consistent with
the current process.
Employers must keep on file and make available to
OSHA, upon request, process hazard analyses and
updates or revalidation for each process covered
by PSM, as well as the documented resolution of
recommendations, for the life of the process.

Module 4 Quiz
submitted.
1. A _______ is an organized and systematic effort to identify and analyze the
significance of potential hazards associated with the processing or handling of highly
hazardous chemicals.
a. Job Hazard Analysis (JHA)
b. Process Hazard Analysis (PHA)
c. Change Analysis (CA)
d. Potential Hazard Analysis (PHA)
2. The employer must perform an initial process hazard analysis on which of the
following processes covered by the PSM standard?
a. Hazardous
b. Identified
c. Potential
d. all of the processes
3. All of the following are methods to determine and evaluate the hazards of a process
being analyzed, EXCEPT:
a. what-if
b. checklist
c. what-if/checklist
d. pareto chart
4. At least every ____ years after the completion of the initial process hazard analysis,
the process hazard analysis must be updated and revalidated.
a. two
b. three
c. four
d. five

5. OSHA believes that the process hazard analysis is best performed by a team with
which of the following areas of expertise?
a. accident investigation
b. engineering
c. process operations
d. Both B & C

Module 5: Operating Procedures
What are Operating Procedures?
Operating procedures provide specific instructions or details on what steps are to be taken or
followed in carrying out the stated procedures. The specific
instructions should include the applicable safety precautions and
appropriate information on safety implications.
For example, the operating procedures addressing operating
parameters will contain operating instructions about pressure
limits, temperature ranges, flow rates, what to do when an upset
condition occurs, what alarms and instruments are pertinent if an
upset condition occurs, and other subjects.
Another example of using operating instructions to properly
implement operating procedures is in starting up or shutting down the process. In these cases,
different parameters will be required from those of normal operation. These operating
instructions need to clearly indicate the distinctions between startup and normal operations,
such as the appropriate allowances for heating up a unit to reach the normal operating
parameters. Also, the operating instructions need to describe the proper method for increasing
the temperature of the unit until the normal operating temperatures are reached.
The employer must develop and implement written operating procedures, consistent with the
process safety information, that provide clear instructions for safely conducting activities
involved in each covered process.
What must operating procedures describe?
PSM operating procedures describe:
• tasks to be performed,
• data to be recorded,
• operating conditions to be maintained,
• samples to be collected, and
• safety and health 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 process safety information package helps to ensure that the operating procedures and
practices are consistent with the known hazards of the chemicals in the process and that the
operating parameters are correct.
Operating procedures should be reviewed by engineering staff and operating personnel to
ensure their accuracy and that they provide practical instructions on how to actually carry out
job duties safely.
OSHA believes that tasks and procedures related to the process must be appropriate, clear,
consistent, and most importantly, well communicated to employees.
Elements of the Operating Procedures
The procedures must address at least the following elements:
Steps for each operating phase:
1. initial startup;
2. normal operations;
3. temporary operations;
4. emergency shutdown, including the conditions under which emergency shutdown is
required, and the assignment of shut down responsibility to qualified operators to
ensure emergency shutdown is executed in a safe and timely manner;
5. emergency operations;
6. normal shutdown; and
7. startup following a turnaround, or after an emergency shut down.
Operating limits:
• consequences of deviation, and
• steps required to correct or avoid deviation.
Safety and health considerations:
• properties of, and hazards presented by, the chemicals used in the process;
• precautions necessary to prevent exposure, including engineering controls,
administrative controls, and personal protective equipment;
• control measures to be taken if physical contact or airborne exposure occurs;
• quality control for raw materials and control of hazardous chemical inventory levels;
• any special or unique hazards; and

• safety systems (e.g., interlocks, detection or suppression systems) and their
functions.
Operating procedures must be readily accessible to employees who work in or maintain a
process:
• to make sure that a ready and up-to-date reference is available, and
• to form a foundation for needed employee training.
The operating procedures must be reviewed as often as necessary to ensure that they reflect
current operating practices, including changes in process chemicals, technology, and
equipment, and facilities.
The employer must certify annually that these operating procedures are current and accurate
to guard against outdated or inaccurate operating procedures.
The employer must develop and implement safe work practices to provide for the control of
hazards during work activities such as:
• lockout/tagout;
• confined space entry;
• opening process equipment or piping; and
• control over entrance into a facility by maintenance, contractor, laboratory, or other
support personnel.
These safe work practices must apply both to employees and to contractor employees.

Module 5 Quiz
submitted.
1. Operating procedures provide general instructions or details on what steps are to be
taken or followed in carrying out the stated procedures.
a. True
b. False
2. PSM operating procedures describe:
a. tasks to be performed
b. cautions to be taken
c. operating conditions to be maintained
d. all of the above
3. Which of the following does OSHA believe to be most important about the tasks and
procedures related to the process?
a. they should be appropriate
b. they should be clear
c. they should be well communicated
d. they should be consistent
4. The employer must certify every three years that these operating procedures are
current and accurate to guard against outdated or inaccurate operating procedures.
a. True
b. False
5. Safe work practices under the PSM program must apply to which of the following?
a. employees
b. contractors
c. employers
d. both a and b above

Module 6: Employee Participation
Employers duty to involve employees
Employers must develop a written plan of action to implement
and ensure employee participation required by PSM.
Under PSM, employers must consult with employees and their
representatives on the:
• conduct and development of process hazard analyses
and
• development of the other elements of process
management.
They must provide to employees and their representatives access
to process hazard analyses and to all other information required to be developed by the
standard.
Initial Training
The implementation of an effective training program is one of the most important steps that an
employer can take to enhance employee safety.
Accordingly, PSM requires that each employee presently involved in operating a process or a
newly assigned process must be trained in:
• an overview of the process, and
• in its operating procedures.
The training must include:
• emphasis on the specific safety and health hazards
of the process;
• emergency operations including shutdown; and
• other safe work practices that apply to the
employee's job tasks.
Those employees already involved in operating a process on the PSM effective date do not
necessarily need to be given initial training. Instead, the employer may certify in writing that
the employees have the required knowledge, skills, and abilities (KSA’s) to safely carry out the
duties and responsibilities specified in the operating procedures.

Refresher Training
Refresher training must be provided at least every three years, or more often if necessary, to
each employee involved in operating a process to ensure that the employee understands and
adheres to the current operating procedures of the process.
The employer, in consultation with the employees involved in operating the process, must
determine the appropriate frequency of refresher training.
Training Documentation
The employer must determine whether each employee operating a process has received and
understood the training required by PSM.
A record must be kept containing the identity of the employee, the date of training, and how
the employer verified that the employee understood the training.
Employees should also be able to demonstrate the necessary skills needed to safely complete
PSM procedures.

Module 6 Quiz
submitted.
1. According to the text, under the PSM standard, employers must consult with
employees and their representatives on which of the following?
a. conduct and development of process hazard analyses
b. development of accident and incident investigations
c. results of process hazard initial testing
d. results of OSHA complaint inspections
2. The PSM standard requires that each employee involved in operating a process or a
newly assigned process must be trained in an overview of the process, and in its
operating procedures.
a. True
b. False
3. Refresher training must be provided at least every ______years, or more often if
necessary, to each employee involved in operating a process.
a. two
b. three
c. four
d. five
4. The employer may certify in writing that experienced employees have the required
knowledge, skills, and abilities (KSA’s) to safely carry out the duties and
responsibilities specified in the operating procedures.
a. True
b. False

5. Under the PSM Program, an employee training record must be kept containing which
of the following information?
a. identity of the employee
b. date of training
c. how employer verified understanding
d. All of the above

Module 7: Contractors
Application
Many categories of contract labor may be present
at a jobsite. Some workers may actually operate
the facility or do only a particular aspect of a job
because they have specialized knowledge or skill.
Others work only for short periods when there is
need for increased staff quickly, such as in
turnaround operations.
PSM includes special provisions for contractors
and their employees to emphasize the importance
of everyone taking care that they do nothing to
endanger those working nearby who may work for another employer.
PSM, therefore, applies to contractors performing maintenance or repair, turnaround, major
renovation, or specialty work on or adjacent to a covered process.
It does not apply, however, to contractors providing incidental services that do not influence
process safety, such as janitorial, food and drink, laundry, delivery, or other supply services.
Employer Responsibilities
When selecting a contractor, the employer must obtain and evaluate information regarding the
contract employer's safety performance and programs. The employer also must:
• inform contract employers of the known potential fire, explosion, or toxic release
hazards related to the contractor's work and the process;
• explain to contract employers the applicable provisions of the emergency action
plan;
• develop and implement safe work practices to control the presence, entrance, and
exit of contract employers and contract employees in covered process areas;
• evaluate periodically the performance of contract employers in fulfilling their
obligations; and
• maintain a contract employee injury and illness log related to the contractor's work
in the process areas.

Contract Employer Responsibilities
The contract employer must:
• ensure that contract employees are trained in the work practices necessary to
perform their job safely;
• ensure that contract employees are instructed in the known potential fire,
explosion, or toxic release hazards related to their job and the process, and in the
applicable provisions of the emergency action plan;
• document that each contract employee has received and understood the training
required by the standard by preparing a record that contains the identity of the
contract employee, the date of training, and the means used to verify that the
employee understood the training;
• ensure that each contract employee follows the safety rules of the facility including
the required safe work practices required in the operating procedures section of the
standard; and
• advise the employer of any unique hazards presented by the contract employer's
work.
Pre-Startup Safety Review
It is important that a safety review takes place before any highly hazardous chemical is
introduced into a process.
PSM, therefore, requires the employer to perform 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.
Prior to the introduction of a highly hazardous chemical to a process, the pre-startup safety
review must confirm that the following:
• construction and equipment are in accordance with design specifications;
• safety, operating, maintenance, and emergency procedures are in place and are
adequate;
• a process hazard analysis has been performed for new facilities and
recommendations have been resolved or implemented before startup, and modified
facilities meet the management of change requirements; and
• training of each employee involved in operating a process has been completed.

Module 7 Quiz
submitted.
1. The PSM standard applies to contractors performing maintenance or repair,
turnaround, major renovation, or specialty work ______________.
a. on or adjacent to a covered process
b. only when union contractors are involved
c. during the PHA phase of the construction
d. prior to the start of construction
2. The PSM standard does not apply to contractors providing incidental services that
____________.
a. are on covered processes
b. do not influence process safety
c. are approved prior to the start of work
d. have attended a pre-job conference
3. The PSM standard generally does not apply to any of the following services, EXCEPT:
a. janitorial services
b. delivery of food, drink or laundry
c. other supply services
d. maintenance on covered processes
4. According to the text, ensuring that each contract employee follows the safety rules is
the responsibility of which of the following?
a. safety manager
b. contract employer
c. host employer
d. all employees

5. Prior to the introduction of a highly hazardous chemical to a process, the pre-startup
safety review must confirm which of the following?
a. Construction and equipment conform to specifications
b. All procedures are in place and adequate
c. A PHA has been performed for new facilities
d. All of the above

Module 8: Mechanical Integrity and Hot Work Permit
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 requirements apply to the following
equipment:
• pressure vessels and storage tanks;
• piping systems (including piping components such
as valves);
• relief and vent systems and devices;
• emergency shutdown systems;
• controls (including monitoring devices and sensors,
alarms, and interlocks); and
• pumps.
The employer must establish and implement written
procedures to maintain the ongoing integrity of process
equipment.
Training
Employees involved in maintaining the ongoing integrity of process equipment must be trained
in an overview of that process and its hazards and trained in the procedures applicable to the
employee's job tasks.
Inspection
Inspection and testing must be performed on process equipment,
using procedures that follow recognized and generally accepted
good engineering practices. The frequency of inspections and tests
of process equipment must conform to manufacturers'
recommendations and good engineering practices, or more
frequently if determined to be necessary by prior operating
experience.
Each inspection and test on process equipment must be
documented, identifying the date of the inspection or test, the

name of the person who performed the inspection or test, the serial number or other identifier
of the equipment on which the inspection or test was performed, a description of the
inspection or test performed, and the results of the inspection or test.
Correcting Deficiencies
Equipment deficiencies outside the acceptable limits defined by the process safety information
must be corrected before further use. In some cases, it may not be necessary that deficiencies
be corrected before further use, as long as deficiencies are corrected in a safe and timely
manner, when other necessary steps are taken to ensure
safe operation.
New Construction and Equipment
In constructing new plants and equipment, the employer
must ensure that equipment as it is fabricated is suitable for
the process application for which it will be used. Appropriate
checks and inspections must be performed to ensure that
equipment is installed properly and is consistent with design
specifications and the manufacturer's instructions.
The employer also must ensure that maintenance materials,
spare parts, and equipment are suitable for the process application for which they will be used.
Hot Work Permit
A 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 regulations
(1910.252(a)) have been implemented prior to beginning the hot work operations;
• it must indicate the date(s) authorized for hot work; and
• identify the object on which hot work is to be performed. The permit must be kept
on file until completion of the hot work.

Final words of PSM wisdom!
Process Safety is a team effort. Know your role and work with your fellow employees to protect
yourself and others.
Know the hazards associated with mixing, separating, or storing process materials, including:
• Which chemicals are reactive or able to cause a runaway reaction.
• Toxic, fire, or explosive hazards associated with your process chemicals.
• What to do during an incident or unusual process condition.
Be aware of equipment operation and maintenance requirements, including:
• Signs of corrosion, leakage, or other signs of equipment problems.
• Who to alert when you see a problem.
Know your process:
• Follow operating, safety, and emergency procedures.
• Keep up-to-date with changes to procedures,
equipment, and chemicals.
• Provide feedback – report all incidents and near misses.

Module 8 Quiz
submitted.
1. According to the text, PSM mechanical integrity requirements apply to all of the
following equipment, EXCEPT:
a. Pressure vessels and storage tanks
b. Relief and vent systems and devices
c. Mechanical startup systems
d. Pumps
2. Employees involved in maintaining the ongoing integrity of process equipment must
be trained in an overview of that process and its hazards and trained in the
procedures applicable to the employee's job tasks.
a. True
b. False
3. Equipment deficiencies outside the acceptable limits defined by the process safety
information must be corrected or tagged with “caution” signs.
a. True
b. False
4. The employer also must ensure that all of the following are suitable for the process
application for which they will be used, EXCEPT:
a. spare parts
b. maintenance materials
c. recognition plans
d. equipment

5. A permit must be issued for hot work operations conducted on or near a covered
process. The permit must:
a. document implementation of fire prevention
b. indicate the date(s) hot work is authorized
c. identify the object on which hot work is performed
d. All of the above

Optional Exercise
Scenario:
Art and Ray were sent to the Tank Farm to replace bearings on an isopropanol pump located on
the alcohol pad. They found the bearings “frozen” in place. When Art told his supervisor they
would have to pull the pump, he said, “Let’s see if we can’t pull those bearings in place; we’ve
got too much downtime in that area already.” First they tried to loosen the bearings with a
bearing heater, a powerful electric heat gun, without success. Ray then called a welder who
heated the casing with her torch until the bearings came free. While the welder was there, the
supervisor had her weld brackets on an I-beam so he could install a “Warning-Flammable Area”
sign.
A piece of slag from the welding rolled into a nearby pile of damp wooden shims. After the
mechanics and the welder left the area, the wood began to smolder and then burst into flames.
At the same time an operator began to charge ethanol to his unit by remote computer control.
The ethanol transfer pump started to leak around its mechanical seal creating a pool of alcohol
on the pad. The vapors from the pool traveled towards the fire, which then ignited them.
The fire spread instantly to the pump and grew in intensity as the heat increased the size of the
leak. The tank farm operator saw the fire, sounded the alarm and attacked the fire with an
extinguisher. She was overcome by vapors and fell unconscious. Quick response by the in-
plant emergency response team saved her life and stopped a potentially disastrous fire.
Task:
In your groups, choose a scribe. Discuss the incident and, based on your experience, answer
the following questions.
1. What could have been done to prevent this fire? List the factsheet(s) you used to back
up your answer.
2. Now, think about the hot work program in your plant, are there any changes or
improvements that should be made to improve the program? Please list and explain.

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