Process Safety Managementof Highly Hazardous Chemicals is a regulation promulgated by the U.S. Occupational Safety and Health Administration (OSHA).[1] It defines and regulates a process safety management (PSM) program for plants using, storing, manufacturing, handling or carrying out on-site movement of hazardous materials above defined amount thresholds. Companies affected by the regulation usually build a compliant process safety management system and integrate it in their safety management system. Non-U.S. companies frequently choose on a voluntary basis to use the OSHA scheme in their business.
The PSM regulation was the culmination of a push for more comprehensive regulation of facilities storing and/or processing hazardous materials, which began in the wake of the 1984 Bhopal disaster. The regulation was promulgated by OSHA in 1992 in fulfilment of requirements set in the 1990 amendments to the Clean Air Act.[2][3] The EPA followed suit with a similar and complementary regulation in 1996.[3]
Compliance
Any U.S. facility that stores or uses a hazardous material above thresholds defined in section (a)(1) and Appendix A must comply with the PSM regulation. For individual chemical species listed in Appendix A, threshold quantities vary from as low as 100 lb (45 kg; e.g., methyl hydrazine, phosgene) to as much as 15,000 lb (6804 kg; e.g., ammonia solutions, methyl chloride). The threshold for flammable gases and liquids (the latter defined as having a flash point below 100°F or 37.8°C) is 10,000 lb (4536 kg).[1]
All the elements are interlinked and interdependent. Every element either contributes information to other elements for the completion or utilizes information from other elements in order to be completed.
Employee participation
Under PSM, employers must consult with employees and their representatives on the conduct and development of process hazard analyses and on the development of the other elements of process management, and 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.[1] Employee participation in process safety activities and processes helps the organization build a positive climate of collaboration across management and workers, which sustains in turn a strong process safety culture.[7]
Process safety information
Process safety information (PSI) refers to key documentation for identifying and understanding the hazards posed by the plant activities involving highly hazardous chemicals. In order to be in compliance with the OSHA PSM regulation, process safety information should include information pertaining to three areas: hazardous chemicals used or produced, technology of the process, and equipment in the process.[5]
Information pertaining to the material hazards (which is usually collected in dedicated Material Safety Data Sheets [MSDS]) shall consist of at least:
A process hazard analysis (PHA) (or process hazard evaluation) is an exercise for the identification of hazards of a process facility and the qualitative or semi-quantitative assessment of the associated risk. A PHA provides information intended to assist managers and employees in making decisions for improving safety and reducing the consequences of unwanted or unplanned releases of hazardous materials. A PHA is directed toward analyzing potential causes and consequences of fires, explosions, releases of toxic or flammable chemicals and major spills of hazardous chemicals, and it focuses on equipment, instrumentation, utilities, human actions, and external factors that might impact the process.[1]
This element has been called "the heart of the program", as it "impacts or interfaces with all of the other elements". PHA relies on availability and completeness of process safety information; it requires employee participation in order to be effective; it may impact operating procedure through its findings and recommendations; it must be embedded in any management-of-change process and any pre-start-up safety review.[3]
Operating procedures must be consistent with the process safety information and provide clear instructions for safely conducting activities involving hazardous materials. To ensure that a ready and up-to-date reference is available, and to form a foundation for needed employee training, operating procedures must be readily accessible to employees who work in or maintain a process. They must address at least the following elements:
Steps for each operating phase: initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, and startup following a planned or emergency shutdown.
Operating limits: consequences of deviation, and steps required to correct or avoid deviation.
Safety and health considerations: properties and hazards of the chemicals used in the process, precautions (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).
The operating procedures must be reviewed as often as necessary to ensure that they reflect current operating practices, including changes in process chemicals, technology, equipment, and facilities. To guard against outdated or inaccurate operating procedures, the employer must certify annually that these operating procedures are current and accurate.
It is mandatory that the following activities be covered in dedicated operating procedures: 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.[8]
Training
Training relevant to PSM 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. The regulation distinguishes between two types of training relevant to PSM, i.e. initial training and refresher training. Training records must be kept and maintained.[1][8]
Contractors
Contractor management is important in any safety management system, including process safety management programs. A contracting company has to be mindful that outsourced personnel are not necessarily aware of the work site hazards and/or the way the contracting company manages those hazards. Contractors may also introduce new hazards to the plant.[9]
OSHA's 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. The contracting party must obtain and evaluate the contractor's safety performance and programs, inform the contracted personnel of the relevant fire, explosion, or toxic release hazards, explain to them the applicable provisions of the emergency action plan, evaluate periodically their performance in fulfilling their obligations, and maintain a contract employee injury and illness log. The contracted company must ensure that its employees have sufficient relevant training for the contracted job, ensure that its employees are instructed in the relevant site process hazards and the applicable provisions of the emergency action plan, document that they have received and understood required training, keep a record of key information about the contracted employees on the job and the activities carried out, and ensure that each contracted employee follows the safety rules of the facility.[8]
A pre-startup safety review (PSSR) shall take place before any highly hazardous material is introduced into a process, i.e. before the plant start-up. The requirement applies to new facilities and modified ones, when the modification causes changes in the process safety information. The review must confirm that:[8]
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.
Modified facilities meet the management of change requirements.
Training of each employee involved in operating a process has been completed.
Mechanical integrity
In the context of OSHA's PSM, mechanical integrity requirements apply to the following equipment:
Among several safety systems of work relevant to hazardous process plants, OSHA's PSM singles out the permit-to-work for hot work as arguably the most critical for the prevention of major process safety accidents. Hot work provides ignition sources to potential flammable vapors, which can cause fires and/or explosions. The permit must document that the fire prevention and protection requirements in OSHA regulations 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.[8]
Management of change
Undocumented, not properly risk assessed changes to a plant handling hazardous materials are a recipe for disaster. An eminent example of this is the Flixborough disaster, where improvised changes involving the bypassing of a stage in a reactor train was at the origin of the accident. The change had not been properly thought out, documented and risk-assessed, so that the event of breach of containment had not been identified.[12] Changes to a process must be thoroughly evaluated to fully assess their impact on employee safety and health and to determine needed changes to operating procedures. Written procedures to manage changes (except for “replacements in kind”) to process chemicals, technology, equipment, and procedures must be established and implemented. Minimum content of the documentation is:
The technical basis for the change.
Impact of the change on safety and health.
Modifications to operating procedures.
Necessary time period for the change.
Authorization requirements.
Employees who operate a process and maintenance and contract employees whose job tasks will be affected by a change in the process must be informed of, and trained in, the change.[8]
Incident investigation
Incident investigation provides a fundamental opportunity to learn from past mistakes and disseminate the new knowledge gathered throughout the organization and, if possible, to external stakeholders.[13] Accordingly, thorough internal investigation of incidents to identify the chain of events and causes is crucial to OSHA's PSM. Investigation must be initiated as promptly as possible, not later than 48 hours following the incident. OSHA establishes requirements for the investigation team selection and the content of the investigation report, which has to conclude with a series of relevant lessons learnt in the form of recommendations. These shall be tracked and closed out accordingly.[8]
Emergency planning and response
The consequences of an accident can be significantly reduced with effective emergency planning and response.[7] By way of example, the response to the Tacoa disaster was largely unorganized and uninformed about the nature of the fire that was burning inside a fuel oil tank. As a result, the responders, as well as scores of bystanders and media workers, stayed well within the area impacted by the violent boilover that took place, which resulted in the death of more than 150 people.[14] Additionally, robust emergency management helps an organization safeguard its public image in case of accidents.[7] Accordingly, the PSM regulation mandates that emergency preparedness arrangements be put in place, including emergency pre-planning and training to make employees aware of, and able to execute, proper actions. The plan must comply with the provisions of other OSHA rules (29 CFR 1910.38).[8][15]
Compliance audits
Similar to incident investigation, audits are an important tool an organization can use to assess whether its process safety management system is in place and it is effectively applied throughout its ranks.[7] To be certain process safety management is effective, employers subject to the PSM regulation must certify by way of audits that they have evaluated compliance with the provisions of PSM at least every three years. The compliance audit must be conducted by at least one person knowledgeable in the process and a report of the findings of the audit must be developed and documented noting deficiencies that have been corrected.[8]
Trade secrets
OSHA's PSM is the only major process safety management code to include trade secrets among its elements.[16] Emphasis is given in the regulation to the fact that trade secrets may in principle restrict circulation of key information in several ambits of process safety management, such as process safety information, compliance audits, operating procedures, process hazard analysis, incident investigation, etc. The regulation makes it compulsory for organizations to release the information to the respective parties, irrespective of whether it is protected by trade secrecy. Nothing in PSM, however, precludes the employer from requiring those persons to enter into confidentiality agreements not to disclose the information.[8]
The Occupational Safety and Health Administration is a regulatory agency of the United States Department of Labor that originally had federal visitorial powers to inspect and examine workplaces. The United States Congress established the agency under the Occupational Safety and Health Act, which President Richard M. Nixon signed into law on December 29, 1970. OSHA's mission is to "assure safe and healthy working conditions for working men and women by setting and enforcing standards and by providing training, outreach, education, and assistance." The agency is also charged with enforcing a variety of whistleblower statutes and regulations. OSHA's workplace safety inspections have been shown to reduce injury rates and injury costs without adverse effects on employment, sales, credit ratings, or firm survival.
A safety data sheet (SDS), material safety data sheet (MSDS), or product safety data sheet (PSDS) is a document that lists information relating to occupational safety and health for the use of various substances and products. SDSs are a widely used system for cataloguing information on chemicals, chemical compounds,chemical mixtures. SDS information may include instructions for the safe use and potential hazards associated with a particular material or product, along with spill-handling procedures. The older MSDS formats could vary from source to source within a country depending on national requirements; however, the newer SDS format is internationally standardized.
Dangerous goods, abbreviated DG, are substances that when transported are a risk to health, safety, property or the environment. Certain dangerous goods that pose risks even when not being transported are known as hazardous materials. An example for dangerous goods is hazardous waste which is waste that has substantial or potential threats to public health or the environment.
The Emergency Planning and Community Right-to-Know Act of 1986 is a United States federal law passed by the 99th United States Congress located at Title 42, Chapter 116 of the U.S. Code, concerned with emergency response preparedness.
Lock out, tag out or lockout–tagout (LOTO) is a safety procedure used to ensure that dangerous equipment is properly shut off and not able to be started up again prior to the completion of maintenance or repair work. It requires that hazardous energy sources be "isolated and rendered inoperative" before work is started on the equipment in question. The isolated power sources are then locked and a tag is placed on the lock identifying the worker and reason the LOTO is placed on it. The worker then holds the key for the lock, ensuring that only they can remove the lock and start the equipment. This prevents accidental startup of equipment while it is in a hazardous state or while a worker is in direct contact with it.
Hazardous Waste Operations and Emergency Response is a set of guidelines produced and maintained by the Occupational Safety and Health Administration which regulates hazardous waste operations and emergency services in the United States and its territories. With these guidelines, the U.S. government regulates hazardous wastes and dangerous goods from inception to disposal.
The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) is an internationally agreed-upon standard managed by the United Nations that was set up to replace the assortment of hazardous material classification and labelling schemes previously used around the world. Core elements of the GHS include standardized hazard testing criteria, universal warning pictograms, and safety data sheets which provide users of dangerous goods relevant information with consistent organization. The system acts as a complement to the UN numbered system of regulated hazardous material transport. Implementation is managed through the UN Secretariat. Although adoption has taken time, as of 2017, the system has been enacted to significant extents in most major countries of the world. This includes the European Union, which has implemented the United Nations' GHS into EU law as the CLP Regulation, and United States Occupational Safety and Health Administration standards.
The Control of Substances Hazardous to Health Regulations 2002 is a United Kingdom Statutory Instrument which states general requirements imposed on employers to protect employees and other persons from the hazards of substances used at work by risk assessment, control of exposure, health surveillance and incident planning. There are also duties on employees to take care of their own exposure to hazardous substances and prohibitions on the import of certain substances into the European Economic Area. The regulations reenacted, with amendments, the Control of Substances Hazardous to Work Regulations 1999 and implement several European Union directives.
Right to know is a human right enshrined in law in several countries. UNESCO defines it as the right for people to "participate in an informed way in decisions that affect them, while also holding governments and others accountable". It pursues universal access to information as essential foundation of inclusive knowledge societies. It is often defined in the context of the right for people to know about their potential exposure to environmental conditions or substances that may cause illness or injury, but it can also refer more generally to freedom of information or informed consent.
A job safety analysis (JSA) is a procedure that helps integrate accepted safety and health principles and practices into a particular task or job operation. The goal of a JSA is to identify potential hazards of a specific role and recommend procedures to control or prevent these hazards. Other terms often used to describe this procedure are Job Hazard Analysis (JHA), Hazardous Task Analysis (HTA) and Job Hazard Breakdown.
Process safety is an interdisciplinary engineering domain focusing on the study, prevention, and management of large-scale fires, explosions and chemical accidents in process plants or other facilities dealing with hazardous materials, such as refineries and oil and gas production installations. Thus, process safety is generally concerned with the prevention of, control of, mitigation of and recovery from unintentional hazardous materials releases that can have a serious effect to people, plant and/or the environment.
Effective safety training is an unofficial phrase used to describe the training materials designed to teach occupational safety and health standards developed by the United States government labor organization, Occupational Safety and Health Administration (OSHA). OSHA has produced many standards and regulations that affect employers and employees in the United States. United States employers have a legal responsibility to educate employees on all workplace safety standards and the hazards that their employees may face while on the job, and providing effective safety training meets that responsibility.
Workplace health surveillance or occupational health surveillance (U.S.) is the ongoing systematic collection, analysis, and dissemination of exposure and health data on groups of workers. The Joint ILO/WHO Committee on Occupational Health at its 12th Session in 1995 defined an occupational health surveillance system as "a system which includes a functional capacity for data collection, analysis and dissemination linked to occupational health programmes".
A process hazard analysis (PHA) (or process hazard evaluation) is an exercise for the identification of hazards of a process facility and the qualitative or semi-quantitative assessment of the associated risk. A PHA provides information intended to assist managers and employees in making decisions for improving safety and reducing the consequences of unwanted or unplanned releases of hazardous materials. A PHA is directed toward analyzing potential causes and consequences of fires, explosions, releases of toxic or flammable chemicals and major spills of hazardous chemicals, and it focuses on equipment, instrumentation, utilities, human actions, and external factors that might impact the process. It is one of the elements of OSHA's program for Process Safety Management.
Pesticide regulation in the United States is primarily a responsibility of the Environmental Protection Agency (EPA). In America, it was not till the 1950s that pesticides were regulated in terms of their safety. The Pesticides Control Amendment (PCA) of 1954 was the first time Congress passed guidance regarding the establishment of safe limits for pesticide residues on food. It authorized the Food and Drug Administration (FDA) to ban pesticides they determined to be unsafe if they were sprayed directly on food. The Food Additives Amendment, which included the Delaney Clause, prohibited the pesticide residues from any carcinogenic pesticides in processed food. In 1959, pesticides were required to be registered.
Operations Plus WMD is a training level in dealing with hazardous materials.
Contractor management is the managing of outsourced work performed for an individual company. Contractor management implements a system that manages contractors' health and safety information, insurance information, training programs and specific documents that pertain to the contractor and the owner client. Most modern contracts require the effective use of contract management software to aid administration between multiple parties.
The Hazardous Materials Transportation Act (HMTA), enacted in 1975, is the principal federal law in the United States regulating the transportation of hazardous materials. Its purpose is to "protect against the risks to life, property, and the environment that are inherent in the transportation of hazardous material in intrastate, interstate, and foreign commerce" under the authority of the United States Secretary of Transportation.
The operations manual is the documentation by which an organisation provides guidance for members and employees to perform their functions correctly and reasonably efficiently. It documents the approved standard procedures for performing operations safely to produce goods and provide services. Compliance with the operations manual will generally be considered as activity approved by the persons legally responsible for the organisation.
Process safety management (PSM) is a practice to manage business operations critical to process safety. It can be implemented using the established OSHA scheme or others made available by the EPA, AIChE's Center for Chemical Process Safety, or the Energy Institute.
1 2 3 Mannan, M. Sam; Makris, Jim; Overman, H. James (2002). "Process Safety and Risk Management Regulations: Impact on Process Industry". In Anthony, Rayford G.; McKetta, John J. (eds.). Encyclopedia of Chemical Processing and Design. Vol.69: Supplement 1. Basel and New York, N.Y.: Marcel Dekker. ISBN0-8247-2621-9.
↑ Atherton, John; Gil, Frederic (2008). Incidents That Define Process Safety. New York, N.Y. and Hoboken, N.J.: Center for Chemical Process Safety and John Wiley & Sons. ISBN978-0-470-12204-4.
↑ Nwankwo, C.D.; Theophilus, S.; Arewa, A. (2020). "A Comparative Analysis of Process Safety Management (PSM) Systems in the Process Industry". Journal of Loss Prevention in the Process Industries. 66: 104171ff. doi:10.1016/j.jlp.2020.104171.
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