PSM Compliance

Process Safety Management
of Highly Hazardous &

Explosive Chemicals
29CFR1910.119
Simple Keys to Compliance
Objectives
Define what is PSM and who is covered
by the standard
List the elements of the PSM standard
Locate additional resources
What Is Process Safety

Management?
PSM:
Addresses
the management of Highly

Hazardous Chemicals (HHC)
Integrates
Technology
Operating
Procedures
Standard management protocols
Why Did OSHA Develop PSM?

Past
Disasters
Current Disasters
Perceived Weakness in PSM
Program
Bhopal, India (1984)

2,000 deaths
Isocyanate release
Pasadena, TX (1989)
23 deaths, 132 injuries
Petroleum explosion
Cincinnati, OH (1990)
2 deaths
Explosion
Sterlington, LA (1991)
8 deaths, 128 injuries
Chemical release
5

In 1991, OSHA and
EPA respectively,
Released the
Standards, PSM &
RMP that Applies to
Those Companies
that are Affected by
The Standards.

Process Safety
Management is a
regulation, promulgated
by OSHA, intended to
prevent an incident like
the 1984 Bhopal Disaster
Andto Prevent Release
of:
Toxic,
Reactive,
Flammable, or
Explosive chemicals
Not Only PSM, But RMP

A great many industrial
facilities must comply
with OSHA's Process
Safety Management
(PSM) regulations as
well as the CAA 112(r)
EPA Risk
Management Program
(RMP) regulations
(Title 40 CFR Part 68).
8
PSM vs. RMP - Whats the

Difference?
PSM - Like HAZCOM RMP-Like Sara Title III
Protects the
Workforce
Protects Contractors
Protects Visitors to
the Facility
Basically Protects the
Workplace
Protects the
Community
Protects the General
Public Around the
Facility
Protects Adjacent
Facilities Such as
Schools & Hospitals
The Standard Was Promulgated

in 1991 - Is it Working?
10
The Standard Was Promulgated

in 1991 - Is it Working?
BP Products Texas
City - March 2005
15 Workers Killed
170 Injured
Major Property
Damage
$50.6 Million in Fines
11
The Elements of the PSM

Standard
Application
Exclusions
Definitions
Employee Participation
Hazards of the Process
Toxicity
Technology of the
Process
Equipment in the
Process
Mechanical Integrity
Inspection & Testing
Quality Assurance
Process Hazard
Analysis
Management of Change
Operating Procedures
Safe Work Practices
Training
Contractor
Management
Emergency Planning &
Response
Incident Investigation
Compliance Audits
Trade Secrets
12

Standard
Application
Exclusions
Definitions
Toxicity
Technology of the
Process
Equipment in the
Process
Mechanical
Integrity
Process Hazard
Analysis
Safe Work Practices
Training
Contractor
Management
Response
Compliance Audits
Trade Secrets
13

Standard
Application
Exclusions
Definitions
Toxicity
Technology of the
Process
Equipment in the
Process
Quality Assurance
Process Hazard
Analysis
Management of
Change
Safe Work Practices
Training
Contractor
Management
Response
Compliance Audits
Trade Secrets
14

Standard
Process Hazard
Application
Exclusions
Definitions
Toxicity
Technology of the
Process
Equipment in the
Process
Quality Assurance
Analysis
Management of
Change
Operating
Procedures
Safe Work Practices

Training
Contractor
Management
Response
Compliance Audits
Trade Secrets
15

Standard
Application
Exclusions
Definitions
Toxicity
Technology of the
Process
Equipment in the
Process
Quality Assurance
Process Hazard
Analysis
Management of
Change
Safe Work Practices
Training
Contractor
Management
Response
Compliance Audits
Trade Secrets
16

Standard
Process Hazard
Analysis
Management of
Change
Employee
Safe Work Practices
Participation
Training
Contractor
Toxicity
Management
Technology of the
Process
Response
Equipment in the Process Incident Investigation
Compliance Audits
Trade Secrets
Quality Assurance
Application
Exclusions
Definitions
17

Standard
Process Hazard
Analysis
Application
Management of
Exclusions
Change
Definitions
Safe Work Practices
Training
Toxicity
Contractor
Technology of the
Management
Process
Equipment in the Process Emergency Planning &
Response
Compliance Audits
Quality Assurance
Trade Secrets
18

Standard
Process Hazard
Analysis
Application
Management of
Exclusions
Change
Definitions
Pre-Start up Safety
Review
Toxicity
Hot Work Permit
Technology of the
Safe Work Practices
Process
Equipment in the Process Training
Contractor
Management
Quality Assurance
Response
19

Standard
Process Hazard
Application
Exclusions
Definitions
Toxicity
Technology of the
Process
Equipment in the Process
Quality Assurance
Analysis
Management of
Change
Pre-Start up Safety
Review
Hot Work Permit
Safe Work Practices

Training
Contractor
Management
Response
20

Standard
Process Hazard
Analysis
Application
Management of
Exclusions
Change
Definitions
Pre-Start up Safety
Review
Toxicity
Hot Work Permit
Technology of the
Safe Work Practices
Process
Training
Contractor
Management
Emergency
Quality Assurance
Planning &
Response
21

Standard
Process Hazard
Application
Exclusions
Definitions
Toxicity
Technology of the
Process
Equipment in the
Process
Quality Assurance
Analysis
Management of
Change
Pre-Start up Safety
Review
Hot Work Permit
Safe Work Practices
Training
Contractor
Management
Emergency Planning
& Response
22

Standard
Process Hazard
Analysis
Management of
Change
Pre-Start up Safety
Review
Hot Work Permit
Safe Work Practices
Training
Contractor
Management
Emergency Planning
& Response
Quality Assurance
Application
Exclusions
Definitions
Toxicity
Technology of the
Process
Equipment in the
Process
23

Standard
Process Hazard
Application
Exclusions
Definitions
Toxicity
Technology of the
Process
Equipment in the
Process
Quality Assurance
Analysis
Management of
Change
Pre-Start up Safety
Review
Hot Work Permit
Safe Work Practices
Training
Contractor
Management
Emergency Planning
& Response
24

Standard
Lets Explore Some of the Elements
25
Application
1910.119(a)
26
What Facilities are Covered
Those Who Use Chemicals in Appendix A: A List of

highly hazardous chemicals, toxics and reactive
(Mandatory). Contains a listing of toxic and reactive
highly hazardous chemicals which present a potential
for a catastrophic event at or above the threshold
quantity
Examples
Chemical
Anhydrous Ammonia
Chlorine
Threshold Quantity (TQ)

10,000 lbs
1,500 lbs
27
A process which
involves a
flammable liquid or
gas (as defined in
1910.1200(c) of this
part) on-site in one
location, in a
quantity of 10,000
pounds (4535.9 kg)
or more
28
Important Interpretation: 2007 - 06/11/2007 - OSHA

defines "on-site in one location" for Process Safety
Management of Highly Hazardous Chemicals
standard
OSHA interprets "on-site in one location" to mean that

the standard applies when a threshold quantity of a
highly hazardous chemical (HHC) exists within an
area under the control of an employer or group of
affiliated employers. It also applies to any group of
vessels that are interconnected, or in separate
vessels that are close enough in proximity that the
HHC could be involved in a potential catastrophic
release.
29

Affect of the Meer Decision:
MEER ruling and the MEER Memorandum addressed in the
Secretary's letter, OSHA's enforcement policy that the Agency
would not cite employers for violations of 1910.119 where stored
flammable liquids in atmospheric tanks were connected to a
process, unless the process outside of the amount in storage
contained more than 10,000 pounds of the substance
30
What Types of Industries?
Industries that Process Chemicals Such As:
Industrial Organics & Inorganics

Paints
Pharmaceuticals
Adhesives
Sealants and Fibers
Petrochemical facilities
Paper Mills
Food Processing with Anhydrous Ammonia over
the TQ
31
Exclusions
1910.119(a)(1)(ii)(A)
32
There are Exclusions
An employer is exempt from the requirements of PSM

when:
A threshold quantity of flammable liquids is stored in
atmospheric tanks or transferred without the benefit of
chilling or refrigeration
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
33
There are Exclusions
Retail facilities;
Oil or gas well drilling or

servicing operations; or,
Normally unoccupied
remote facilities
34
1910.119(c)
35
Now that we are required to

comply, then what?
Form a Team in
Your Company, i.e..
Process Engineers
Operators
Safety
Maintenance
Management
Consultants
RememberYou Cant Do it Alone!
36
Now that we are required to

comply, then what?
Form a Plan,
Determine:
Responsibilities
Duties
Reporting
Document Control
Progress Reports
Tracking Changes
ThenBegin the Process of Developing &

Implementing the PSM Program
37

1910.119(d)(1)
38
The Requirements of the Standard

- Hazard Determination
Determine:
Chemicals in Your Process

Process Chemistry
Quantity of Chemicals in lbs
Compare to Appendix A List with
Threshold Quantities (TQs)
39
Toxicity Information
1910.119(d)(1)(i)
40

- Develop Toxicity Information
Obtain Toxicity
Information on the
Chemical(s) in the
Process
MSDS are Typical
Resource
You May Need
Other References,
NIOSH Pocket
Guide, ACGIH TLVs
41
Technology of the Process

1910.119(d)(2)
42

- Process Technology
Block flow diagram

or process flow
diagram
Process chemistry
Maximum intended
inventory
Upper and lower
limits
Consequences of
deviations
43

- Process Equipment
Materials of
construction
Process and instrument
drawings (P&IDs)
Electrical classification
Relief system design
Ventilation system
design
Design codes
Material and energy
balances
Safety systems
44

1910.119(d)(3)
45

- Process Equipment
Now:
Identify Each Piece of
Equipment in the
Covered Process by
P&ID, Block Diagram
and Number Them
Remember - Must
Follow Form
Must be Able to Track
Each Number Through
the Entire Program
46
1910.119(j)
47

- Process Equipment
Certificates
Must be Obtained for Each
Element of the Process
Must be Marked with
Numbering System that
Follows Form
48
Process Hazard Analysis (PHA)

1910.119(e)
49
Process Hazard Analysis

(PHAs)
Arguably the Most Difficult Part of
Performing the Standard
PHA process is dynamic and subject to
revision whenever changes are made
Performed by Your PSM Team
Takes Significant Time & Effort
PHAs are Never Ending
50
Process Hazard Analysis

A PHA Process Must be
Performed on Each
Element of the Covered
Process:
A PHA From Block
Diagram to P&ID to Every
Equipment Component to
Determine What Might
Happen if an Element of
the Covered Process Fails
51
There is Much More to PSM

Quality Assurance
Safe Work Practices
Training
Contractor Management
Emergency Planning & Response
Compliance Audits
Trade Secrets
52
Procedures to manage changes to the

covered process.
Exception:
replacement in kind
Management of Change includes:

Process
chemicals
Technology
Equipment
Facilities
53
Management of Change Addresses

1.
2.
3.
4.
5.
Technical basis of the change

Impact to employee safety and health
Modification to operating procedures
Time period for change
Authorization of change
54
Develop and implement written
operating procedures that are clear
instructions for all expected phases of
operations.
AKA Standard Operating Procedures
(SOPs)
Must cover:
Operation
phase
Operational limits
Safety & health considerations
55
OPs Must Address

Initial start-up
Normal operations
Temporary operations
Emergency shutdown
Emergency operations
Normal shutdown
Start-up following turnaround
Consequences of deviation
Steps required to correct or avoid
deviation
56
SOPs
Must be readily available to employees
Must be reviewed as needed to ensure
they reflect current operating practicce.
Must cover:
Process
chemicals
Technology and equipment
Facilities
SOPs must be certified annually that

they are correct and accurate.
57
Safe Work Practices (SWPs)
Must be developed and implemented to

provide for the control of hazards during
work activities such as:
Lock-out/Tag-out
Confined
space entry
Opening processes, piping or equipment
SWPs are for:
Operators
Maintenance
personnel
Contractors
Lab personnel
Or other support
personnel
58
Training
PSM specific training is required
Must cover:
Safety
and health hazards associated with

the covered process
Safe work practices
Refresher training is required every 3

years or as needed to ensure
employees are complying with all PSM
requirements
59
Contractors
Contractors involved in or around a
covered process must be informed of
required PSM elements.
Contract work includes:
Maintenance
and repair
Turn
around
Major renovations
Specialty knowledge or services
Does
not include support services not

involved with the covered process, like
laundry or vending machine supply
60
Emergency Action Plans (EAP)

Must have EAP for entire facility
EAP must have provisions for small
releases of HHCs
Develop a Early Warning Method for
Releases
Train on the Meaning of the Alarms
Develop Emergency Evacuation Written
Plans, Evacuation Maps & Assembly
Points
61
Incident Investigations
Must be initiated ASAP, but within 48
hours
Team must include:
Person
knowledgeable in the process

involved
Includes contractor if work of the contractor
involved
Other persons with appropriate knowledge
of the covered process
62
Incident Investigation Report
Report must be produced with the following:

Date
of incident
Date of start of investigation
Description of incident
Factors contributing to incident
Recommendations
System must be established to promptly

address recommendations and findings of
report
Resolutions and corrective action must be
63
documented
Compliance Audit
To ensure that PSM is effective, employers

must certify every 3 years that they have
evaluated compliance with the standard
Must be completed by at least on person

knowledgeable in the process
Report must be developed and documented
Deficiency corrections must be documented
Last two compliance audits must be kept on
file
64
Trade Secrets
Employers must make all necessary

information required to comply with
PSM, regardless of trade secrets,
available to persons involved in
developing or creating:
Compiling
process safety information
PHAs
SOPs
Incident
investigations
Emergency planning and response
Compliance audits
Confidentiality agreements are allowed 65
BP Texas City Refinery Case

Study in PSM
The third largest petroleum refinery in the

United States with a refining capacity of
475,000 barrels of crude per day.
Located on a 1,200-acre facility in Texas City,
Texas southeast of Houston in Galveston
County.
1,200 permanent BP employees and
hundreds of additional contractors at the
facility
66
Anatomy of a Disaster- BP Texas

City
Things to Think About:

What
went wrong?
What went right?
What could/should have been done to
prevent this disaster?
67
BP Texas City Refinery Case

Study in PSM
Fact Sheet on BP 2009 Monitoring Inspection
The U.S. Department of Labor's Occupational Safety and Health Administration (OSHA)
has proposed $87,430,000 in propose penalties against BP Products North America, Inc.
for 709 alleged failures to comply with the 2005 settlement agreement and citations, and
violations of safety and health standards identified during the agency's inspection of the
corporation's refinery in Texas City, TX (BPTCR). The inspection of the refinery was
conducted from May through October 2009.
BP Texas City Refinery (BPTCR):
The third largest petroleum refinery in the United States with a refining capacity
of 475,000 barrels of crude per day.
Located on a 1,200-acre facility in Texas City, Texas southeast of Houston in
Galveston County.
1,200 permanent BP employees and hundreds of additional contractors at the
facility
Prior History at BPTCR:
On March 23, 2005, an explosion and fire in the Isomerization Unit of the BP
Texas City Refinery (BPTCR) resulted in the death of 15 contractor employees
and injury of at least 170 other BP employees and contractors.
OSHA initiated safety and health inspections into the March 2005 incident
and issued citations and fines totaling over $21 million, the highest
penalty that OSHA had ever issued.
The Report of the BP U.S. Refineries Independent Safety Review Panel
(aka Baker Report) issued in January 2007 identified a number of
systemic process safety issues at BP refineries in the U.S.
March 2007, U.S. Chemical Safety and Hazard Investigation Board
(CSB) released its report Refinery Explosion and Fire (15 Killed, 180
Injured). CSB found, "The Texas City disaster was caused by
organizational and safety deficiencies at all levels of the BP Corporation".
OSHA has conducted 17 separate inspections at the refinery in the last 4 years.
Prior to the 2005 incident, two employees of BPTCR died due to a
breakdown of the companys lockout and tagout program.
Since the 2005 incident, four more fatal incidents have occurred at the
facility, involving one BPTCR employee and 3 contractors.
2005 Settlement Agreement
As a result of the March 2005 explosion and subsequent inspection, BP entered
into a settlement agreement with OSHA in September 2005
BP agreed to pay $21 million in penalties
68
JORDAN BARABDeputy
Assistant Secretary
After BP-Texas City, Have We Learned Anything?
Now, in spite of your efforts, we have to acknowledge
that something is desperately wrong. The status quo isn't
working.
In the past three months alone, 58 workers have died in
explosions, fires and collapses at refineries, coal mines,
an oil drilling rig, and a natural-gas-fired power plant
construction site.
OSHA is particularly concerned about the recent number
of serious incidents at refineries that have scalded,
burned or struck down your fellow workers. We are
tracking these catastrophes and looking for trends -including problems resulting from aging facilities. Since
the BP Texas City explosion in 2005, OSHA has counted
over 20 serious incidents in refineries across the country.
69
There is Much More to PSM
Now, The OSHA PSM National Emphasis

Program for Refineries & Chemical
Facilities & Severe Violator Enforcement
Program (SVEP)
70
OSHA National Emphasis

Program (NEP) for Refineries &
Chemical Facilities
Petroleum
Refineries NEP
Issued August
2009
Chemical Facilities
NEP
Issued July 2010
71
Typical Standards Cited
1910.119
1910.147
1910.120
1910.1200
1910.146
5A.001
1910.307
PSM 249 violations

Lock and Tag - 20
Hazwoper - 19
Hazcom - 12
Confined Space - 11
General Duty - 9
Hazardous Locations - 7
72
Most Frequent NEP PSM Citations

1910.119
(f)(1) Operating procedures..38
(d)(3) PSI pertaining to equipment .28
(e)(3) PHA specific criteria26
(j)(4) MI Inspection & Testing ..21
(e)(5) PHA recommendation ...12
(l)(1) MOC implementation ..12

73
Severe Violator Enforcement

Program (SVEP)
This Instruction establishes enforcement

policies and procedures for OSHA's Severe
Violator Enforcement Program (SVEP), which
concentrates resources on inspecting
employers who have demonstrated
indifference to their OSH Act obligations by
willful, repeated, or failure-to-abate violations.
This Instruction replaces OSHA's Enhanced
Enforcement Program (EEP).
74

Program (SVEP)
References:
OSHA Instruction CPL 03-00-010, Petroleum

Refinery Process Safety Management
National Emphasis Program, August 18, 2009
75

Program (SVEP)
Enhanced Follow-up Inspections

Nationwide Inspections of Related
Workplaces/Worksites
Increased Company Awareness of OSHA
Enforcement
Enhanced Settlement Provisions
Federal Court Enforcement under Section
11(b) of the OSH Act
Bottom Line: OSHA is Serious About

Compliance and Enforcement of PSM
76
EPA Risk Management Plans

(RMP) Basics
CAA 112(r)
77
One More Thing to Discuss

EPA Risk Management Plans
(RMP)
Many Times Companies Who Must Comply

with PSM, must also Comply with the
Requirements of EPA Risk Management
Plans (RMP)
The RMP Standard was to be a Mirror of the
PSM StandardDidnt happen!
RememberPSM Protects the Workforce,
RMP Protects the Community
78
EPA RMP
Basic Requirements
Executive summary
Registration
Off-site consequence analysis
Five-year accident history
Emergency response plan
Prevention program summary information
Certification
79
All Public Facilities

in this Release
Plume Must be
Identified &
Surveyed
Release
Plume
80
OSHA PSM Summary
PSM is a Comprehensive, Difficult Standard

Although it was Promulgated in 1991,
Catastrophes Continue to Occur
Recognizing these Facts, OSHA has
Developed a National Emphasis Program for
Refineries and Chemical Manufacturers
More Emphasis Planned for all PSM Sites
There is Much More Work to be Done
RMP Must Also be Considered for Many
Facilities
81
Tools for Additional PSM

Assistance
PSM Checklist
www.oshainfo.gatech.edu
OSHA Website
www.osha.gov
Chemical Safety Board Website

www.csb.gov
82
PSM Checklist
Use this checklist to help determine employer compliance with the Process Safety Management Standard issued by the
Occupational Safety and Health Administration. Please note that the checklist does not include all of the standards
requirements and does not reflect all OSHA letters of interpretation or compliance directives in particular
situations.
There are 3 elements to a review of a PSM program:
1. Documentation review examination of the documentation of the programs required by the standard.
2. Field Inspection & Verification examination of the physical covered process; its equipment, piping,
instrumentation, procedures, and operation.
3. Interviews discussions with employees and contractors to determine if the implemented program matches the
program outlined in the documentation.
In order to gather the information needed to audit a PSM program the following questions need to be asked for each PSM
program element
Who
What
When
Where
Why
How
Who Who is responsible for developing and implementing each of the program elements?
What What are the requirements and contents of each program element?
When When are the required actions for each element completed and when were they required to be
completed?
Where Where have actions been implemented or changed?
Why Why have the implementation decisions and priorities been made as recorded in the documentation?
How How is the program implemented and how is the programs effectiveness evaluated and improved?
An essential part of verifying program implementation is to audit the flow of information and activities among the
elements. When information in one element is changed or when action takes place in one element that affects other
elements, an auditor/reviewer should examine a sample of the related elements to see if the appropriate changes and
followup actions have taken place.
The following example demonstrates the interrelationship among the elements:
During a routine inspection of equipment (Mechanical Integrity), the maintenance worker discovers a valve that no
longer meets the applicable code and must be changed. Because the type of valve is no longer made, a different type of
valve must be selected and installed (Management of Change). The type of valve selected may mandate different steps
for the operators (Operating Procedures) who will require training and verification in the new procedures (Training).
The rationale for selecting the type of valve must be made available for review by employees and their representatives
(Employee Participation).
83
For More Information

www.psmtraining.com
www.pe.gatech.edu/safety
84
Contact Information
Michelle Dunham, MSPH, MSM

michelle.dunham@gtri.gatech.edu
404-407-8284
Bob Hendry
bob.hendry@gtri.gatech.edu
Art Wickman, CIH

art.wickman@gtri.gatech.edu
Georgia Tech Occupational Safety & Health Program

85
Funding
Funding for:
Process Safety Management of Highly
Hazardous and Explosive Chemicals:
Simple Keys to Compliance
By special funding from the Occupational
Safety and Health Administration
86

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Process Safety Management

of Highly Hazardous &

What Is Process Safety

the management of Highly

Why Did OSHA Develop PSM?

Why Did OSHA Develop PSM?

Bhopal, India (1984)

Why Did OSHA Develop PSM?

Why Did OSHA Develop PSM?

Not Only PSM, But RMP

PSM vs. RMP - Whats the

PSM - Like HAZCOM RMP-Like Sara Title III

The Standard Was Promulgated

The Standard Was Promulgated

The Elements of the PSM

The Elements of the PSM

Inspection & Testing

The Elements of the PSM

The Elements of the PSM

Safe Work Practices

The Elements of the PSM

The Elements of the PSM

The Elements of the PSM

The Elements of the PSM

The Elements of the PSM

Hot Work Permit

Safe Work Practices

The Elements of the PSM

The Elements of the PSM

The Elements of the PSM

The Elements of the PSM

The Elements of the PSM

What Facilities are Covered

Those Who Use Chemicals in Appendix A: A List of

Threshold Quantity (TQ)

What Facilities are Covered

What Facilities are Covered

Important Interpretation: 2007 - 06/11/2007 - OSHA

OSHA interprets "on-site in one location" to mean that

What Facilities are Covered

What Types of Industries?

Industries that Process Chemicals Such As:

Industrial Organics & Inorganics

There are Exclusions

An employer is exempt from the requirements of PSM

There are Exclusions

Oil or gas well drilling or

Now that we are required to

Now that we are required to

ThenBegin the Process of Developing &

Hazards of the Process

The Requirements of the Standard

Chemicals in Your Process

The Requirements of the Standard

Technology of the Process

The Requirements of the Standard

Block flow diagram

The Requirements of the Standard