Facilities that manufacture, use, store, or handle certain highly hazardous chemicals may be required to comply with OSHA’s Process Safety Management (PSM) standard. Determining whether your facility is covered is an important part of protecting employees, preventing serious chemical releases, and maintaining regulatory compliance.
Process Safety Management goes beyond everyday workplace safety. It focuses on preventing or minimizing catastrophic releases of toxic, reactive, flammable, or explosive chemicals that could result in fires, explosions, toxic exposures, serious injuries, or other major incidents.
What Is Process Safety Management?
OSHA’s Process Safety Management standard, found in 29 CFR 1910.119, establishes requirements for managing hazards associated with processes involving highly hazardous chemicals.
A PSM program takes a systematic approach to the entire process rather than addressing individual safety issues separately. It examines equipment, chemicals, operating procedures, employees, maintenance practices, emergency planning, and management systems that work together to keep a process operating safely.
How Do I Know If My Facility Is Covered by PSM?
One of the first steps is determining which hazardous chemicals are present and how much of each chemical is involved in a process.
OSHA’s PSM standard generally applies to a process involving a chemical at or above the threshold quantity listed in Appendix A of 29 CFR 1910.119. OSHA’s Appendix A contains specific highly hazardous chemicals and the threshold quantity for each.
The standard can also apply to processes involving certain flammable gases or flammable liquids with a flashpoint below 100°F when 10,000 pounds or more are present in one location, although OSHA provides specific exceptions.
Because determining coverage can involve the chemical, concentration, quantity, storage configuration, process and applicable exemptions, facilities should carefully evaluate their operations rather than assuming they are or are not covered.
What Types of Facilities May Need PSM?
PSM requirements can affect many industries that handle significant quantities of hazardous chemicals.
Examples can include:
- Chemical manufacturing facilities
- Industrial manufacturing plants
- Food processing and cold-storage facilities using ammonia refrigeration
- Petroleum and chemical processing operations
- Facilities using chlorine or other hazardous chemicals
- Certain warehouses and distribution operations
- Facilities with large refrigeration systems
- Other industrial operations involving highly hazardous chemicals
Coverage is based on the processes and chemicals involved, not simply the type or size of the business.
What Does a PSM Program Include?
When a process is covered by OSHA’s PSM standard, the employer must address multiple elements designed to work together as a comprehensive safety management system.
These requirements include process safety information, process hazard analysis, operating procedures, employee participation, training, contractors, pre-startup safety reviews, mechanical integrity, hot work permits, management of change, incident investigation, emergency planning and response, compliance audits, and protection of certain confidential information.
One of the most important components is the Process Hazard Analysis, or PHA. OSHA describes the PHA as a careful review of what could go wrong with a process and what safeguards are needed to prevent hazardous chemical releases.
What Is a Process Hazard Analysis?
A Process Hazard Analysis is a systematic evaluation of potential hazards associated with a covered process.
The goal is to identify possible scenarios that could lead to a hazardous chemical release and evaluate the safeguards already in place. This may involve reviewing equipment, controls, operating procedures, human factors, previous incidents, facility layout, and potential consequences of equipment or process failures.
A PHA isn’t simply a checklist. It is intended to help a facility understand how different parts of a process interact and where additional safeguards may be appropriate.
What If My Facility Changes a Process?
PSM compliance is not a one-time project.
Changes to equipment, chemicals, technology, operating procedures, or other aspects of a covered process may require a formal Management of Change evaluation.
This is important because even a seemingly small modification can create new hazards or affect existing safeguards. Facilities need procedures for evaluating changes and updating relevant process safety information, operating procedures, and employee training when appropriate.
What Is Mechanical Integrity?
Mechanical integrity is another important component of Process Safety Management.
Facilities with covered processes need procedures for maintaining critical process equipment. Depending on the operation, this can include pressure vessels, storage tanks, piping systems, relief devices, emergency shutdown systems, controls, pumps, and other equipment.
A strong mechanical integrity program helps facilities identify equipment problems before they contribute to a release or other serious incident.
PSM and EPA Risk Management Programs
Facilities evaluating PSM requirements should also determine whether EPA’s Risk Management Program (RMP) regulations apply.
EPA’s RMP requirements apply to stationary sources with more than a threshold quantity of a regulated substance in a process. The RMP program focuses on preventing chemical accidents and reducing potential consequences to surrounding communities and the environment.
OSHA PSM and EPA RMP have similarities, but they are separate regulatory programs. EPA notes that a process subject to OSHA PSM will generally fall under RMP Program 3 unless it qualifies for Program 1; even where the prevention requirements substantially overlap, additional RMP requirements can still apply.
When Should You Review Your PSM Program?
Facilities should not wait for an OSHA inspection or serious incident to evaluate PSM compliance.
Consider reviewing your program when:
- Hazardous chemical quantities change
- New chemicals are introduced
- Equipment or processes are modified
- Production capacity increases
- New process equipment is installed
- Operating procedures change
- A significant incident or near miss occurs
- Facility ownership or operations change
- Questions arise about whether a process is covered
- Existing PSM documentation has not been reviewed recently
Regular evaluations can help identify gaps and keep process safety programs aligned with current facility operations.
Process Safety Management Consulting from Hygieneering
Determining whether PSM applies to your facility can be complicated. Once a process is determined to be covered, developing and maintaining the required program involves multiple technical, operational, and management responsibilities.
Hygieneering provides Process Safety Management and environmental health and safety consulting services for industrial and commercial facilities throughout the Chicago area, Northern Illinois, and Southern Wisconsin.
Our team can assist facilities with PSM applicability evaluations, process safety information, process hazard analyses, operating procedures, mechanical integrity programs, management of change, compliance audits, employee training, and other elements of an effective process safety program.
If your facility manufactures, stores, handles, or uses highly hazardous chemicals, contact Hygieneering to discuss your operations and determine what Process Safety Management requirements may apply.