An Overview of Process Safety Management Elements in Program Development

Exterior of an industrial processing plant

The issuance of the OSHA Process Safety Management of Highly Hazardous Chemicals standard sets specific regulations in place to prevent potentially catastrophic events caused by the accidental release of toxic, flammable, explosive, and highly reactive substances.

Plant managers and engineers working in industries involving hazardous chemical processing are familiar with Process Safety Management (PSM) programs. However, it often requires expert guidance to develop and implement a plan in compliance with OSHA standards. There are 14 process safety management elements to consider in program development. Below, we will highlight and expand on a few key areas.

Process Safety Management Elements Every Program Needs

PSM programs can look different depending on the industry, facility type, and work performed in the facility. State regulations and other directives also influence the makeup of a program in addition to industry-standard process safety management regulations. Even with these varying factors, all programs must include certain elements for OSHA compliance.

Facility Process Hazard Analysis (PHA)

Every PSM program implementation or renewal process requires a Process Hazard Analysis to identify and analyze site hazards related to hazardous chemical and material processing and handling. For facilities with an existing program, this step also involves reviewing and analyzing current documentation and processes in addition to revalidating the site risk assessment. Potential hazards identified during the analysis guide the development of the OSHA process safety management plan.

Multi-Phase Operating Procedures

All processes outlined in a PSM plan must have written operating procedures with safety instructions. Within each process are multiple elements outlining the operating steps and operating limits for different phases of operations (i.e., normal operations, startup, shutdown). Under OSHA’s published guidelines, “tasks and procedures related to the covered processes must be appropriate, clear, consistent…and well communicated to employees.”

Employee Participation and Training

Programs are only effective when properly implemented. Requirements in this area include initial training plus refresher training at a minimum interval of every three years. Facilities should have an individual responsible for PSM program implementation with the resources to ensure employees and contractors are trained and participate in the PSM elements.

Incident Investigation Process

Failure to properly and promptly handle minor incidents can lead to big disasters in the future. Process safety management regulations require an incident investigation plan detailing your facility’s response to small chemical releases and other potentially dangerous or “near-miss” events. The plan must outline all action steps, including the person(s) responsible for leading the investigation, documentation procedures, and an incident-specific plan to implement corrective measures.

Emergency Planning and Response

In the event of a fire or accidental chemical release, you must prove to OSHA investigating officials that you have the necessary processes established to control and contain hazards, along with a detailed emergency response plan for every likely disaster scenario. For this reason, emergency response is one of the most critical process safety management elements of your PSM plan.

The above categories provide a sampling of the Process Safety Management plan requirements. Hot work permits, compliance audits, mechanical integrity programs, management of change procedures, and other elements are also required and must be planned and meticulously documented to ensure a safe workplace in compliance with the OSHA Process Safety Management of Highly Hazardous Chemicals standard.

Get Expert Help with Your PSM Program Development

Developing a PSM program and supporting documentation requires expertise to ensure no detail is overlooked. Pinnacle Engineering has a team specialized in process safety management regulations and program development. With decades of experience, we understand different industries’ unique challenges and requirements and the protocols needed to operate safely and mitigate risk.

Learn more about our OSHA Process Safety Management program services and how they can help bring your facility into compliance.