PSMoverview2.ppt

Module Two - Overview of the PSM Rule
Process Safety
Management (PSM)
[Adapted from State of Ohio – Dept. of Commerce, Div. of Labor & Worker Safety]
November, 2019

Purpose of the PSM Standard
 This standard contains requirements for preventing or
minimizing the consequences of catastrophic releases
of chemicals that are:
–Toxic,
–Reactive,
–Flammable,
–Explosive
 These releases may result in toxic, fire or explosion
hazards
 A number of catastrophic accidents have occurred
resulting in loss of life and great property damage.

Impact of PSM Rule
 The Rule affects:
-24,939 establishments nationwide
-127 industry subgroups
-3 million employees including contractors
 First 5 years:
–132 deaths avoided
–767 injuries/illnesses
 Second 5 years:
–264 deaths avoided
–1534 injuries/illnesses

PSM Rule – WAC 296-67
(67-001) Application.
(67-005) Definitions.
(67-009) Employee
participation.
(67-013) Process safety
information.
(67-017) Process hazard
analysis.
(67-021) Operating procedures.
(67-025) Training.
(67-029) Contractors.
(67-033) Pre-startup safety review.
(67-037) Mechanical integrity.
(67-041) Hot work permit.
(67-045) Management of change.
(67-049) Incident investigation.
(67-053) Emergency Planning and
Response.
(67-057) Compliance Audits.
(67-061) Trade secrets.
Link to DOSH PSM Rule

Scope and Application
 A process which involves a chemical at or above the specified
threshold quantities (TQ) listed in Appendix A of the Rule. (TQ
amounts vary by chemical)
OR
 A process which involves a flammable liquid or gas on site in one
location, in a quantity of 10,000 pounds (4535.9 kg) or more
–e.g., 10,000 lbs. of Methane = 223,714 ft3 at STP
Link to Appendix A
Methane produced in a large wastewater treatment plant is covered if the total amount of methane in the
process exceeds 10,000 pounds.

Appendix A Examples
Chemical Name CAS # TQ (lbs)
Ammonia, Anhydrous 7664-41-710000 10,000
Chlorine 7782-50-51500 1500
Hydrogen Sulfide 7783-06-4 1500
NOTE: 1500 lbs. of Hydrogen Sulfide = 16,760 ft3 at NTP
NTP – Normal Temperature and Pressure - is defined as air at 20oC (68°F) and 1
atm (, 14.7 psia, 0 psig, 30 in Hg, 760 torr)
STP – Standard Temperature and Pressure - is defined as air at 0oC ( 32oF) and 1
atm (, 14.7 psia, 0 psig, 30 in Hg, 760 torr)

Definition of a Chemical Process
 Any use, storage, manufacturing, handling, or the on-site movement
of highly hazardous chemicals, or combination of these activities.

A Single Process is:
 Any group of vessels which are interconnected, and
 Separate vessels which are located such that a highly hazardous
chemical could be involved in a potential release

Chlorine Processes
The Threshold Quantity (TQ) for chlorine is 1500 lbs.
The large cylinders will likely exceed the chlorine TQ.

Typical Chlorine Flow Diagram (process)
Source: The Chlorine Institute

“Normally unoccupied remote facility” means a facility which is
operated, maintained, or serviced by employees who visit the
facility only periodically to check its operation and to perform
necessary operating or maintenance tasks. No employees are
permanently stationed at the facility. Facilities meeting this
definition are not contiguous with, and must be geographically
remote from all other buildings, processes, or persons.
 The Rule does not apply to:
–Retail facilities
–Oil or gas well drilling or servicing
–Normally unoccupied remote facilities
Exemptions in the Rule

Other PSM Exceptions
 Hydrocarbon fuels used solely for workplace
consumption as a fuel (e.g., propane used for
comfort heating, gasoline for vehicle
refueling):
- provided such fuels are not a part of a
process containing another highly
hazardous chemical covered by this
standard
 Any flammable liquids stored in atmospheric
tanks or transferred which are kept below their
normal boiling point without benefit of chilling
or refrigeration

1996 Court Case - MEER Decision
Flammable liquid storage tank exemption
Judge ruled - flammable liquids stored or
transferred from atmospheric tanks are
exempted regardless of quantity
WAC 296-800-11005 - the “General Duty
Clause” is used to regulate stored flammables
In a 1996 court decision, the judge ruled that coverage under OSHA's Process Safety Management
Standard does not extend to stored flammables in "atmospheric tanks," even if they were connected
to a "process" within the definition of the standard. DOSH also abides by this decision.

MEER Decision
Flammable
Storage
Tank
Process
• Exemption if atmospheric tanks is used solely for storage
• However, process is covered if it involves 10,000 pounds or more of a flammable
liquid
Flammable liquids
in tanks or vessels
used in the process
(not true storage)
Not exempt
Flammable liquids
stored under pressure
or chilled below
boiling point
* No exemption if the atmosphere tanks are used for purposes beyond storage

49 CFR Transportation Regulations
Department of Transportation Hazardous Materials Act:
- Gives OSHA authority to regulate worker safety in hazardous
materials transportation (called a “reverse federal preemption
provision”)
- Hazardous material cargo would not be exempted by DOT Hazmat
rules or from OSHA regulation including PSM (e.g., loading and
unloading facilities)

Process Safety Information
Before completing a hazard analysis the employer
must collect written information on:
–Hazards of the process
–Technology of the process; and,
–The equipment in the process.
The required collection of written process
safety information enables the employer and
the employees involved in operating the
process to identify and understand the
hazards posed by those processes.

Toxicity Information
Information must include:
–Permissible exposure limits;
–Physical data;
–Reactivity data;
–Corrosivity data;
–Thermal and chemical stability data; and
–Foreseeable hazardous effects of inadvertent mixing
of different materials that could occur.
Note: Material Safety Data Sheets may be used to comply with this requirement if they contain all
of the required information.

Trade Secrets
 Employers must make trade secret information
available to persons responsible for:
–Compiling the process safety information
–Developing of the process hazard analysis
and operating procedures;
–Incident investigations, emergency planning
and response, and compliance audits.
 Confidentiality agreements are permitted.

Process Hazard Analysis (PHA)
 PHA (hazard evaluation) must be performed that using
one of the following methods:
–What-If;
–Checklist;
–What-If/Checklist;
–Hazard and Operability Study (HAZOP);
–Failure Mode and Effects Analysis (FMEA);
–Fault Tree Analysis; or
–Appropriate equivalent methodology
Detailed guidance on the content and application of process hazard analysis methodologies is available
from the Center for Chemical Process Safety.

Employee Participation in PHA
 Employee participation is mandatory in the hazard analysis process:
–consult with employees and their representatives on the
development of process hazards analyses
–provide access to process hazard analyses to employees and their
representatives

 PHA must be performed by a team with
expertise in engineering and process
operations
 One team member must have experience and
knowledge specific to the evaluated process
 One team member must be knowledgeable in
the specific PHA methodology implemented at
the site
Process Hazard Analysis (Continued)

 The process hazard analysis must address:
–Engineering and administrative controls applicable to the hazards
such as detection of early warning of releases*
*Acceptable detection methods might
include process monitoring and
control instrumentation with alarms,
and detection hardware such as
chlorine sensors.
At Bhopal, India, smaller accidents had occurred at the plant prior to the disastrous methyl isocyanate (MIC) release in 1984,
and small MIC leaks had been noted on numerous previous occasions highlighting the need for automatic MIC leak detection. In
fact, workers stated that experiencing eye irritation (a symptom associated with low levels of airborne MIC) was not an unusual
phenomenon, but these warnings went unheeded.

 The process hazard analysis must address:
–The identification of any previous incident
which had a likely potential for catastrophic
consequences in the workplace.
–PHA must be updated and revalidated every
5 years.
For example, warnings existed in several of the recent accidents investigated by EPA and OSHA. Prior to an
accident at a Georgia Pacific plant in 1997, the facility had recently experienced a near miss involving similar
circumstances to those resulting in the later accident. An operator was observed adding chemicals to a batch resin
process at too high a rate. Other alert operators noted the procedural deviation, and were able to prevent an
accident. The company investigated the incident and disciplined the first operator. However, no other actions were
taken to change the process and prevent a recurrence. As result an large release of chemical occurred later.

Incident Investigation
 Each incident must be investigated that resulted in, or could reasonably
have resulted in, a catastrophic release of a highly hazardous chemical
in the workplace.
 The investigation must be initiated no later than 48 hours following the
incident.
 An incident investigation team that consists of persons knowledgeable
in the incident process must be established and the team must
thoroughly investigate and analyze the incident.

Incident Investigation (continued)
 A report must be prepared at the conclusion of the
investigation.
 A system must be developed to promptly address,
resolve and document the incident report findings,
recommendations and corrective actions.
 The incident report must be made available to affected
employees as well as contractors; and,
 The report must be retained for at least five years.
At a minimum, the report must contain the following: Date of incident; Date investigation began; A description of
the incident; The factors that contributed to the incident; and, Any recommendations resulting from the
investigation.

 A review must be performed for new facilities and for modified facilities when the
modification is significant enough to require a change in the PSM information.
 Prior to the introduction of highly hazardous chemicals to a process, the required
review must confirm that:
–Construction and equipment is in accordance with design specifications;
–Safety, operating, maintenance, and emergency procedures are in place and are
adequate.
 New facilities must perform a process hazard analysis and implement
recommendations before startup.
 Modified facilities must meet the requirements in the Management of Change,
section 67-045.
Pre-startup safety review

Operating Procedures
 Develop and implement written operating procedures* consistent
with the process safety information and addresses at least the
following elements:
–Initial start-up, normal and temporary operations
–Normal and emergency shut-down procedures
–Operating limits and consequences of deviation
–Hazards presented by the process
*Readily accessible to employees

Operating Procedures (Continued)
Develop and implement safe work practices* to provide for
the control of process hazards during:
–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 also apply to contractor employees

Hot Work Permit
 The employer must issue a hot work permit for hot work
operations conducted on or near a covered process.
 The permit must document:
–That the fire prevention requirements in WAC 296-24-
68201(a) have been implemented before starting the hot
work operations;
–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
operations.
Chemical Safety Board Video – Dangers of Hot Work

Mechanical Integrity
 The employer must establish and implement written
procedures to maintain the on-going integrity of process
equipment.
 The employer must train each maintenance employee in
an overview of the process, its hazards, and in the
maintenance procedures to ensure employees can
safely perform assigned tasks.
 Deficiencies in equipment that are outside acceptable
limits must be corrected to assure safe operation.

Inspections and Testing
 Inspections and tests must be performed on process
equipment according to recognized and generally
accepted good engineering practices.
 The frequency of inspections and tests must be
consistent with applicable manufacturers'
recommendations and good engineering practices.
 Prior operating experience may indicate more frequent
testing and inspection than manufacturers’
recommendations.
 Each performed inspection and test on process related
equipment must be documented.

Quality Assurance
 The employer must assure that all new plants and
equipment are fabricated and suitable for the
intended process application.
 Appropriate checks and inspections must be
performed to assure that equipment is installed
properly and consistent with design specifications
and the manufacturer's instructions.
 The employer must assure that maintenance
materials, spare parts and equipment are suitable
for the intended process application.

Management of Change
 Written procedures must be implemented to manage changes (except
for "replacements in kind") to process chemicals, technology,
equipment, procedures, and facilities that affect a covered process.
 Employees and contractors involved in operating or maintaining a
process and whose job tasks will be affected by a change must
receive training and information about the change prior to start-up.
 If a change affects previously documented PSM information,
operating procedures, or practices, then the written PSM plan must be
updated.
 The 1998 Equilon Refinery incident was an example of management
of changes rules not being followed.
Link to Chemical Safety Board “Management of Change” Bulletin

Emergency Planning and Response
 An Emergency Action Plan (EAP) must be developed
to ensure the safe evacuation of employees
 Plan must address all foreseeable emergency
situations (e.g., fire, weather, chemical releases, etc.)
 In addition, an Emergency Response Plan must be
developed if employees will respond to the chemical
release
 Plan must address the means and methods necessary
to protect employees responding to an uncontrolled
release of a process chemical

Compliance Audits
 The adequacy of the employer’s procedures and practices must be
evaluated and certified at least every three years.
 The compliance audit must be conducted by at least one person
knowledgeable in the process.
 A report of the findings of the audit must be developed.
 The employer must document an appropriate response and any
corrective action for each of the findings in the audit.
 The two most recent compliance audit reports must be retained.

Training
 Emphasis on the specific safety and health hazards of the process
 Emergency operations including shutdown,
Safe work practices applicable to the employee's job tasks
 Refresher training at least every three years
 Prepare a record which contains:
–The identity of the employee,
–The date of training, and
–The means used to verify that
employees understood the training

Contractors*
 Applies to contractors performing maintenance or
repair, turnaround, major renovation, or specialty
work on or adjacent to a covered process
 Employer responsibilities:
–Obtain and evaluate information regarding the
contract employer's safety performance and
programs
–Inform contract employers of the known potential
fire, explosion, or toxic release hazards related to
the contractor's work and the process
* Does not apply to contractors providing incidental services which do not influence process safety, such as
janitorial work, food and drink services...

PSM vs. EPA Risk Management Plans(RMP)
The principal areas in which the requirements of the EPA differ
from the OSHA Rule are:
Different chemical list and Threshold Quantities (TQ) for some
chemicals. e.g., Chlorine 1500 lbs. (PSM) v. 2500 lbs. (RMP)
EPA requires hazard assessments that include analyses of the
“worst case” accident consequences.
EPA requires preparation of written risk management plans to
document the risk management program. The plans must be
submitted to designated agencies and will be available to the
public.
Risk Management Plans must be registered with the EPA.

PSM Summary
 Facilities with a process using a highly hazardous chemical in an
amount exceeding the TQ must develop, document and implement:
–Written hazard information, process analysis, operating procedures,
emergency procedures and employee/contractor training.
–Maintenance procedures, inspections, incident evaluations.
–Re-evaluation of PSM information, procedures, compliance audits of
processes and related equipment, and refresher training every three
years.
–PHA must be updated & revalidated every 5 years.

Additional Information
DOSH PSM Rule
WAC 296-67 – Process safety management of highly hazardous chemicals
For additional assistance, you can call one of our consultants.

PSMoverview2.ppt

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