Process Safety Management for General Industry Facilities

When people hear “Process Safety Management,” they often assume it only applies to massive refineries or chemical plants. However, the Occupational Safety and Health Administration’s (OSHA’s) Process Safety Management (PSM) standard can apply to a wide range of general industry facilities that store or use hazardous chemicals.

Understanding PSM requirements is critical, because noncompliance can lead to significant regulatory violations and safety risks.

What Is Process Safety Management?

OSHA’s PSM standard (29 CFR 1910.119) applies to the following:

• A process which involves a chemical at or above the specified threshold quantities listed in Appendix A, or
• A process which involves a Category 1 flammable gas (defined in 29 CFR 1910.1200(c)) or a flammable liquid with a flashpoint below 100°F on site in one location, in a quantity of 10,000 lbs or more (with certain exclusions).

The PSM standard is designed to prevent catastrophic releases of highly hazardous chemicals that could result in fires, explosions, or toxic exposures.

Industries commonly affected by PSM may include food manufacturers, metal finishing facilities, wastewater treatment plants, gas storage and distribution centers, and even warehouses that participate in bulk chemical storage.

Elements of a PSM Program

The PSM standard requires multiple elements, including but not limited to:

1.     Process Safety Information (PSI)

• • • • Facilities must maintain accurate information about hazardous chemicals, process technology, and equipment design.

2.     Process Hazard Analysis (PHA)

• • • • Not to be confused with Job Hazard Analysis (JHA); an initial PHA must be done on all covered processes and must identify, evaluate, and control the hazards involved in the process. (Note that a PHA evaluates risks at the system or process level to prevent catastrophic incidents involving hazardous chemicals, while a JHA focuses on task-specific hazards and controls to protect individual workers.)
      • Approved methods of conducting a PHA: What-If Analysis, Checklist, Hazard and Operability Studies (HAZOPs), Fault Tree Analysis, or Failure Mode and Effects Analysis (FMEA).
      • PHAs must be updated at least every five years.

3.     Operating Procedures

• • • • Written procedures must clearly describe startup/shutdown, normal operations, emergency operations, safe operating limits, and more.

4.     Employee Training and Participation

• • • • Employers must develop a written plan of action regarding the implementation of employee participation (as required in the standard).
      • Employees involved in covered processes must receive initial training and refresher training every three years.
      • Employers must consult with their employees on the conduct and development of the process safety management elements.

5.     Mechanical Integrity

• • • • Equipment associated with covered processes must be inspected and tested, maintained (per recognized and generally accepted good engineering practices), and properly documented.

6.     Management of Change (MOC)

• • • • Any change to chemicals, equipment, procedures, or technology must be reviewed before implementation to evaluate safety impacts. *This is one of the most commonly cited PSM deficiencies during OSHA inspections.

Facilities with strong PSM programs typically experience fewer incidents/injuries, better equipment reliability, reduced downtime, operational accountability, and a positive safety culture.

How Walden Can Help

Because applicability depends on chemical type, quantity, and process configuration, a formal applicability review is often the first step.

If you think your facility may be subject to PSM requirements, Walden can assist with:

• Chemical inventories,
• Process Hazard Analyses,
• Management of Change support,
• Employee training,
• And more!

Call our team of EHS experts today at 860-846-4069.