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Course 736 - Introduction to Process Safety Management

Safety guides and audits to make your job as a safety professional easier

MOC, Investigation, Emergency Response and Trade Secrets

Management of Change (MOC)

Many of the catastrophic accidents over the past few decades can be traced, in large part, to a management of change system that was not in place or was not functional.

OSHA believes that contemplated 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. To this end, the standard contains a section on procedures for managing changes to processes.

Written procedures to manage changes (except for “replacements in kind") to process chemicals, technology, equipment, and procedures, and change to facilities that affect a covered process, must be established and implemented.

Written PSM procedures must ensure that the following considerations are addressed prior to any change:

  • The technical basis for the proposed change,
  • Impact of the change on employee safety and health,
  • Modifications to operating procedures,
  • Necessary time period for the change, and
  • Authorization requirements for the proposed change.

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 prior to startup of the process or startup of the affected part of the process.

  • If a change covered by these procedures results in a change in the required process safety information, such information also must be updated accordingly.
  • If a change covered by these procedures changes the required operating procedures or practices, they also must be updated.

1. Which of the following considerations must be included in written PSM procedures prior to any change?

a. The ability of the employer to make reasonable changes
b. Timelines for employer compliance
c. Impact of the change on employee safety and health
d. Necessary time required by OSHA for reporting

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Equilon Enterprises oil refinery fire caused six fatalities.

Incident Investigation

A crucial part of the process safety management program is a thorough investigation of incidents to identify the chain of events and causes so that corrective measures can be developed and implemented.

The PSM standard requires the investigation of each incident that resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical in the workplace.

Such an incident investigation must be initiated as promptly as possible, but not later than 48 hours following the incident. The investigation must be by a team consisting of at least one person knowledgeable in the process involved, including a contract employee if the incident involved the work of a contractor, and other persons with appropriate knowledge and experience to investigate and analyze the incident thoroughly.

An investigation report must be prepared including at least:

  • Date of incident,
  • Date investigation began,
  • Description of the incident,
  • Factors that contributed to the incident, and
  • Recommendations resulting from the investigation.

A system must be established to promptly address and resolve the incident report findings and recommendations. Resolutions and corrective actions must be documented and the report reviewed by all affected personnel whose job tasks are relevant to the incident findings (including contract employees when applicable). The employer must keep these incident investigation reports for 5 years.

2. The PSM standard requires the investigation of each incident that resulted in workplace _____.

a. a catastrophic release of a highly hazardous chemical
b. serious illnesses and environmental impacts
c. near misses, injuries, and illnesses
d. OSHA violations and citations

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Emergency Planning and Response

If, despite the best planning, an incident occurs, it is essential that emergency pre-planning and training make employees aware of, and able to execute, proper actions.

  • An emergency action plan for the entire plant must be developed and implemented in accordance with the provisions of other OSHA rules (29 CFR 1910.38(a)).
  • The emergency action plan must include procedures for handling small releases of hazardous chemicals.
  • Employers covered under PSM also may be subject to the OSHA hazardous waste and emergency response regulation (29 CFR 1910.120(a), (p), and (q).

3. Under the PSM standard, which of the following must be developed for handling releases of hazardous chemicals in the workplace?

a. Emergency Evacuation Plan
b. Incident Investigation Plan
c. Community Continuity Plan
d. Emergency Action Plans

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PSM Auditors.

Compliance Audits

PSM compliance auditing is a unique and evolving process in each company. An experienced auditor should scrutinize the Standard Operating Procedures (SOPs) at a facility looking for PSM Program discrepancies in content and format. Special attention should be given to process safety information, mechanical integrity, and contractor qualifications.

To be certain process safety management is effective, OSHA requires employers to certify that they have evaluated compliance with the provisions of PSM at least every three years. To a degree, this will verify that the procedures and practices developed under the standard are adequate and are being followed. However, to be more certain that the PSM Program is effective, Tim Williams, Senior Project Manger (PSM) at Stellar.Net recommends employers follow this auditing timeline:

  • Self Audit - Every six months. This is recommended, but not required.
  • Standard Operating Procedures Certification – Annually.
  • PSM Compliance Audit – Every three years. Required by OSHA.
  • PHA and Mechanical Integrity Inspection – Every five years. Update PHAs when a major change is made.
  • Management of Change – Anytime a process change is made.

A common mistake in a compliance auditing program is using an company employee who is responsible for the PSM program at the facility. An internal auditor is typically too familiar with the program components, documentation, and implementation methods which may lead to a false sense of security in the effectiveness of the PSM program.

  • 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.
  • The two most recent compliance audit reports must be kept on file.

4. When conducting a PSM compliance audit, which of the following elements should receive special consideration?

a. Mechanical integrity
b. Trade secrets
c. Training
d. Reporting procedures

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Trade Secrets

Employers must make available all information necessary to comply with PSM to those persons responsible for:

  • compiling the process safety information,
  • developing of the process hazard analysis and operating procedures, and
  • incident investigations, emergency planning and response, and compliance audits.

Information must be made available without regard to the possible trade secret status of such information. Nothing in PSM, however, precludes the employer from requiring those persons to enter into confidentiality agreements not to disclose the information.

The Future of PSM

In December 2014, the U.S. Chemical Safety Board (CSB) formally announced that to "Modernize U.S. Process Safety Management Regulations" is the Board’s newest Most Wanted Safety Improvement, concluding that implementation of key federal and state CSB safety recommendations will result in significant improvement of Process Safety Management (PSM) regulations in the United States.

The CSB recommended that OSHA make the following PSM improvements:

  • Expand the rule’s coverage to include the oil and gas exploration and production sector
  • Cover reactive chemical hazards
  • Add additional management system elements to include the use of leading and lagging indicators to drive process safety performance and provide stop work authority to employees;
  • Update existing Process Hazard Analysis requirements to include the documented use of inherently safer systems, hierarchy of controls, damage mechanism hazard reviews, and sufficient and adequate safeguards; and
  • Develop more explicit requirements for facility/process siting and human factors, including fatigue.

5. According to the PSM trade secret requirement, employers must make available all information to which of the following?

a. Representatives of the local community impacted by PSM
b. EPA and OSHA consultation representatives
c. Persons responsible for compiling process safety information
d. Employees and their representatives exposed to chemicals

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Final words of PSM wisdom!

Process Safety is a team effort. Know your role and work with your fellow employees to protect yourself and others.

Process Safety is a team effort. Know your role and work with your fellow employees to protect yourself and others.

Know the hazards associated with mixing, separating, or storing process materials, including:

  • Which chemicals are reactive or able to cause a runaway reaction.
  • Toxic, fire, or explosive hazards associated with your process chemicals.
  • What to do during an incident or unusual process condition.

Be aware of equipment operation and maintenance requirements, including:

  • Signs of corrosion, leakage, or other signs of equipment problems.
  • Who to alert when you see a problem.

Know your process:

  • Follow operating, safety, and emergency procedures.
  • Keep up-to-date with changes to procedures, equipment, and chemicals.
  • Provide feedback – report all incidents and near misses.

Finally, there’s no magic formula that makes a PSM program effective and successful. It takes education, planning, hard work and dedication to keeping employees safe and healthful. PSM must be a full-time job lead by a team of professionals in every company that manages hazardous processes.

6. Process safety _____.

a. required by the EPA, OSHA, and DOT
b. only applies to the oil and gas industry
c. is a team effort
d. is unlimited in scope

Check your Work

Read the material in each section to find the correct answer to each quiz question. After answering all the questions, click on the "Check Quiz Answers" button to grade your quiz and see your score. You will receive a message if you forgot to answer one of the questions. After clicking the button, the questions you missed will be listed below. You can correct any missed questions and check your answers again.

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Here's a long, but very good video webinar by Triumvirate Environmental on PSM.

Final Exam