Do You Need a PSM Plan?

Each process should be evaluated separately to determine whether it is covered by the PSM rule. If several distinct and separate processes at a facility use the same highly hazardous chemical, coverage is determined by comparing the maximum intended inventory of each process to the appropriate total quantity for the chemical. Do not add up the inventory of all processes to determine whether the facility is covered.

If multiple processes at a facility are interconnected, they may be considered a single process under the PSM rule.

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Core Elements of the PSM Plan

The PSM rule is a performance-based rule; that is, it does not prescribe how each element is to be implemented.

Following are recommendations for developing your site-specific PSM Plan in compliance with the core elements required by the PSM rule.

Employee participation. Develop a written plan of action to implement the employee participation required by the PSM. Employers must consult with employees and their representatives on the conduct and development of the process hazard analysis (PHA) and on the development of the other elements of process management. If you already have established methods to keep employees and their representatives informed about relevant safety and health issues, you may be able to adapt these practices and procedures to meet the obligations of the PSM requirements for employee participation.

Process safety information. Compile all written process safety information before conducting any PHA. The compilation should be completed under the same schedule required for the PHA. Make sure you include:

  • Information on the hazards of the highly hazardous chemicals used or produced by the process
  • Information on the technology of the process
  • Information on the equipment in the process

Safety data sheets (SDSs) meeting the requirements of the Hazard Communication Standard (20 CFR 1910.1200) may be used to comply with information on the hazards requirement to the extent they contain the required information.

Process hazard analysis. A process hazard analysis (PHA), sometimes called a process hazard evaluation, is an organized and systematic effort to identify and analyze the significance of potential hazards associated with the processing or handling of highly hazardous chemicals. The PHA focuses on equipment, instrumentation, utilities, human actions (routine and nonroutine), and external factors that might impact the process. Determine and document the priority order for conducting PHAs that includes such considerations as the extent of the process hazards, the number of potentially affected employees, the age of the process, and the operating history of the process.

Standard operating practices (SOPs). Operating procedures describe tasks to be performed, data to be recorded, operating conditions to be maintained, samples to be collected, and safety and health precautions to be taken. The procedures need to be technically accurate, understandable to employees, and revised periodically to ensure that they reflect current operations. Use the process safety information package as a resource to better ensure that the operating procedures and practices are consistent with the known hazards of the chemicals in the process and that the operating parameters are accurate.

Generally, procedures should be written at a level of detail so that an experienced operator who is not familiar with a particular process unit could run the unit with minimal supervision or help from other operators, or the least experienced operator released for unsupervised work could run the unit.

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The following seven steps are suggested for developing SOPs:

  1. Determine the tasks involved in operating a process unit, the relationship between the tasks, and the order in which they are to be carried out. Use the sample Job Hazard Analysis procedures to identify and discuss hazards associated with each task.
  2. Analyze each task and reach consensus on how it should be carried out. The analysis should be done by senior operators and supervisors, with input from management and technical staff. Task analysis is often beneficial because it illuminates inconsistencies in the way tasks are performed by different workers on different shifts.
  3. Write the procedures based on interviews or personal experience, and follow the logic developed in the task analysis.
  4. Distribute written procedures to operators for comment and discussion.
  5. Perform a PHA for the procedures. The PHA team should thoroughly review the procedures and generate the safety and health information to be incorporated.
  6. Ensure that process operators, other workers, and facility users receive the proper training.
  7. Ensure that procedures are written and structured so that they can be updated regularly to reflect changes.

Pre-start-up safety review. The initial start-up procedures and normal operating procedures need to be fully evaluated as part of the pre-start-up review to ensure a safe transfer into the normal operating mode for meeting the process parameters. Piping and instrument diagrams (P&IDs) are to be completed along with having the operating procedures in place and the operating staff trained to run the process before start-up. Any incident investigation recommendations, compliance audits, or PHA recommendations need to be reviewed as well to see what impacts they may have on the process before beginning the start-up.

Mechanical integrity program. Establish and implement written procedures to maintain the ongoing integrity of process equipment. Elements of a mechanical integrity program include the identification and categorization of equipment and instrumentation, inspections and tests, testing and inspection frequencies, development of maintenance procedures, training of maintenance personnel, the establishment of criteria for acceptable test results, documentation of test and inspection results, and documentation of manufacturer recommendations as to meantime to failure for equipment and instrumentation.

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