A full guide to creating your process safety management program

All companies handling or processing toxic, reactive, or flammable materials in excess of certain quantities must comply with OSHA’s Process Safety Management (PSM) rules. This standard originated in the United States, but many countries have since adopted regulations built around the same principles. Likewise, some of the mandates of PSM have become best practices in industries not directly covered under the regulations.

The PSM standard includes 14 elements, each of which require varying degrees of investment in effort and expense. Some companies take a negative view of this investment: it’s a mandated effort and an obstacle to getting real work done. Consequently, they choose a path of “just enough” – they comply but do not truly commit to the principles. Top management shows no dedication to the program and the employees likewise become apathetic about PSM.

Unfortunately, these companies are missing the point. They fail to see is that investment in a viable PSM program reduces or eliminates much larger costs which can (and often do) occur in PSM’s absence.

Process safety management program elements

PSM not only protects the health and saves lives; ultimately, it also saves money. The following element descriptions are abridged versions of those contained in OSHA’s PSM overview publication.

Process safety information

Employers must compile written process safety information (PSI) to help the employees in identifying and understanding the hazards posed by operating processes involving highly hazardous chemicals. PSI must include information on the hazards of the chemicals themselves, on the technology of the process, and on the equipment used in the process.

Compiling PSI requires extensive research to ensure that sufficient information is available on the hazardous materials, the process, and the facilities. A mere collection of original equipment manufacturer (OEM) manuals and Safety Data Sheets is insufficient to inform employees of the potential hazards.

Initial setup costs may include information management structures to contain the data, and training on the collection and formatting of data to meet PSM standards.

PSI forms the foundation of PSM. Without proper information, none of the other elements can fully address the hazards. Garbage in, garbage out.

With a good understanding of the PSI, employees have the necessary knowledge for protecting their lives and health, and for preventing actions that would cause a release of the hazard outside of facility boundaries.

Process hazard analysis

The process hazard analysis (PHA) is a thorough, orderly, systematic approach for identifying, evaluating, and controlling the hazards of processes involving highly hazardous chemicals. The PHA methodology, selected from a list of OSHA-provided options, must be appropriate to the complexity of the process.

PHA is the next basic building block of PSM. To ensure that the PHA is thorough, the discussion should be led by people with expertise in the methodology, typically third-party consultants or PHA leaders. Companies often try to conduct PHAs with internal personnel who do not lead such sessions on a regular basis; however, this results in missed details and incomplete identification of hazards. Therefore, the added cost of third-party consultants can be worthwhile.

As with PSI, PHA is a fundamental building block of PSM. Without an in-depth analysis of hazards, the resulting PSM cannot reasonably safeguard against accidents and releases which can lead to lost time, liability, and litigation.

Reputable third-party PHA leaders conduct these reviews regularly and have a systematic approach to hazard identification. Properly identifying hazards aids in preventing releases and accidents.

Well run PHAs involve employee input, giving them ownership in the program and stimulating the safety culture necessary to reduce hazards.

Operating procedures

The employer must develop and implement written operating procedures, consistent with the PSI, that provide clear instructions for safely conducting activities involved in each covered process. The tasks and procedures must be clear, consistent, and well communicated to employees.

The development of strong operating procedures requires many man-hours.

It is often advantageous to hire third-party consultants and procedure developers on a contract basis – they bring skills and experience to the effort, they will ensure a consistent approach and effective formatting, and their involvement can make the most efficient use of company employees’ time. Procedures built initially with consultant assistance are less likely to require additional work (fleshing out; reworking) later to ensure they meet the PSM standard.

Even with outside assistance, the entire Operations department (not just supervisors) should be involved to a tap the full knowledge of the organization and to build support for the operating procedures.

A comprehensive understanding of the operating procedures provides employees with the knowledge needed to operate the process consistently and safely. Employee input in the procedures increases support for the program.

Well-developed operating procedures:

Help avoid equipment damage and failure, costing the company thousands of dollars and down time.

Protect safety and health through valid, effective operational practices.

Guide employees away from actions that would cause a release of the hazard outside of facility boundaries which can bring on civil and criminal penalties.

Employee participation

Employers must develop, in consultation with the employees, a written plan of action to implement the employee participation required by PSM.

Employee participation in PSM programs demands time away from the jobs the employees were hired to do. To minimize the impact on individuals, participation in planning and committees can be set up with defined periods, and a rotating schedule.

Involving more people in the system helps to motivate the organization toward an effective PSM program. It also allows a greater influx of ideas on improving safety and managing costs. Employee teams are adept at identifying cost savings since they closest to the work and are better able to see waste and inefficiencies.

Small incentive rewards and recognition by management for cost-saving ideas can stimulate both teams and individuals.

Workforce training

The implementation of an effective training program is one of the most important steps to enhance employee safety. Accordingly, each employee involved in operating a process must receive an overview of the process and its operating procedures. The training must emphasize specific safety and health hazards and emergency operations, including emergency shutdown.

Records must be kept identifying the trained employees, the dates of their training, and the method used to verify that the employee understood the training.

Training demands employee hours; this is often viewed as nonproductive.

Worthwhile training programs can be expensive to develop in-house, consuming both manpower and assets. Depending on employees to simply read materials such as OEM manuals and Safety Data Sheets does not meet PSM standards and produces a workforce unprepared to meet the hazards they will encounter.

Systems must be instituted to record who has been trained, on what topics, and when. Documentation kept on paper or in spreadsheets tends to be inefficient and hard to audit.

The use of quality computer-based training (CBT), available from third-party sources, can mitigate these investments. The expert-prepared software typically provides better quality training at less cost than in-house developments. CBT training allows employees to progress at their own speed and to complete as time allows around their normal responsibilities. The CBT developer can often customize the package to cover or emphasize specific tasks or topics. Training records are typically maintained within the CBT system, ready for review and audit.

Establishing coordinators and/or train-the-trainer programs can increase the effective distribution of training across the company and reduce the cost of scheduled meetings of large groups or departments.

Properly trained employees are safety conscious and able to recognize the hazards associated with performing their jobs. This greatly reduces the chances of accidents and releases that can trigger company liabilities, workers’ compensation claims, and increased insurance premiums.

Contractor management

Many categories of contract labor may be present at a job site, including workers who operate the facility, apply specialized knowledge or skill to a particular aspect of a job, and work short-term when additional staff is needed such as for turnarounds. PSM includes special provisions for contractors to emphasize the importance of everyone taking care that they do nothing to endanger those working nearby.

When selecting a contractor, the company must obtain and evaluate information regarding the contractor’s safety performance and programs. Contractors should be qualified for bid based on this information. Hiring contractors simply on the lowest bid neither guarantees the best work nor acceptable safety practices.

The employer must:

Inform contractors of the known potential hazards related to the contractor’s work and the process;

Explain to contractors the applicable provisions of the emergency action plan (including things such as muster points); and

Implement safe work practices to control the presence, entrance, and exit of contractors in covered process areas.

Quality contractors are usually worth what is often a marginally higher cost. Good, vetted contractors bring a better class of craftsman to the job, more able to complete work safely and on time and to provide accurate bids on jobs.

Contractors are safer when fully informed about hazards and the workplace. Fewer incidents by contractors mean less time spent by company employees on incident investigations and policing of work habits. Good safety practices by contractors also reduce the company’s liability concerns and reputation.

Pre-startup safety review

It is important to perform a safety review before any highly hazardous chemical is introduced into a process. PSM, therefore, requires the employer to perform a pre-startup safety review (PSSR) for new facilities and for facilities where modifications made are significant enough to require a change in the process safety information.

The PSSR must confirm that: the facilities are in accordance with design specifications; appropriate procedures are in place; a PHA has been performed as required, and associated training has been completed.

PSSRs demand employee involvement across multiple skills/crafts and departments. The most knowledgeable personnel should be involved, not the lesser skilled employees simply because they might be more available. This ensures better information brought into the exercise and better ownership coming out.

PSSRs must be well organized and facilitated. You can’t do them haphazardly without the development of a checklist or formal procedure. Doing so leads to missed punch list items and the potential for hazardous releases.

PSSRs and the resulting follow-up items are often captured on paper or in simple spreadsheets, making follow-up and audit reports difficult to produce. Care must be taken to document the PSSR in a manner that can be easily reviewed, approved, and shared.

A well-led PSSR, including proper participation from the workforce, will identify incomplete process details that could result in injuries or unintentional releases of hazardous materials. Releases threaten the health and safety of employees, the community, as well as expose the company to litigation, fines, and decreased employee morale.

Mechanical integrity

It is important to maintain mechanical integrity (MI) of critical process equipment to ensure it is designed and installed correctly and operates properly. PSM mechanical integrity requirements apply to the following equipment: storage (tanks, vessels), pumps, piping systems, and valves, relief/vent systems, emergency shutdown systems, and controls.

Categorizing critical equipment (through PHAs) before and after the initial plant startup requires extensive employee hours.

Systems must be established to track equipment in the MI program. Software is available that will: maintain information on each piece of equipment, generate work requests for preventive maintenance (PM) based on assigned due dates or manufacturer-recommended maintenance periods, and document the work done and dates completed. Such software can reduce mistakes and instances of overdue PM. As compared to hardcopy records and spreadsheets, MI or PM software can also reduce manpower demands and provide more confidence in the data.

Care must be taken not to overlook long lead times, restricted availability, and possible training requirements related to specialty equipment and spare parts.

A well-prepared PHA will identify critical equipment along with lead times, required spare parts, and craft training needs.

Effective MI programs prevent downtime and lost production which can be devastating to a company. Expediting parts and equipment can be very expensive and is reactive, not proactive.

A good MI program will ensure that new equipment is designed and installed correctly and operates properly.

MI leads to fewer equipment failures. This reduces replacement costs, downtime, and lost production/revenue, and helps to prevent hazardous releases which expose the company to liability and insurance increases.

Hot work permit

A permit must be issued for hot work operations conducted on or near a covered process. The permit must: document that OSHA fire prevention and protection requirements have been implemented prior to beginning the work, indicate the dates authorized for hot work, and identify the area/object on which hot work is to be performed. The permit must be kept on file until completion of the hot work.

The application of hot work permits requires a recordkeeping system, available fire suppression equipment, and trained fire watch personnel.

The hot work permit process prevents or controls the presence of flammable/explosive materials in the area of spark-producing work activities and monitors hot work for possible ignition. This reduces the potential for fires that can destroy equipment and jeopardize employee health, safety, and morale.

Management of change

Process changes under consideration must be rigorously evaluated to fully assess their impact on employee safety and health and to determine needed changes to operating procedures. Except for “replacements in kind”, written action plans must be implemented to manage changes in facilities, process chemicals, technology, equipment, and operating procedures that affect a PSM covered process.

Management of Change (MOC) considers all aspects of plant operation and the potential consequences of poorly enacted changes. Time must be allowed for the review, processing, and approval of changes.

MOC documentation must be well managed. Hard copy and spreadsheet systems are sometimes viewed as “free”, but this ignores the manpower required to maintain them and the consequences in the plant that can occur from inefficient identification and tracking of changes.

Third-party MOC software simplifies MOC initiation, review, approval, tracking, and personnel notification. Changes can be categorized, sorted, and easily reported for management and audit.

By examining and tracking the details of changes and their associated hazards, the company is better able to plan changes and minimize their impacts (releases, injuries, damage to facilities, etc.).

Incident investigation

A crucial part of PSM is a thorough investigation of incidents to identify the chain of events and causes so that corrective measures can be developed and implemented. Accordingly, an investigation is required for each incident that resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical.

Employees often view the incident investigation as an attempt to place blame. Instead, the aim is to identify the root cause of an incident or near miss and to avoid a repeat in the future.

Investigations to capture the facts and crucial timelines should take place as soon as possible after the incident before memories blur or people become unavailable. This requires significant effort to gather and analyze the information.

Software systems are available to help document incident investigations, sort information for analysis, generate reports, and manage resulting action items.

Failure to identify the root cause of an incident or near-miss can cause history to repeat itself. Effective root cause analysis provides a pathway to preventive action which, in turn, reduces the company’s risk of further incidents, liabilities, costs, and damages.

Emergency planning and response

Incidents may occur despite the best planning. It is essential that emergency pre-planning and training make employees aware of, and able to execute, suitable actions in response.

Emergency planning and response typically require special equipment, dedicated personnel, training, and potential overtime.

To ensure that plans are actionable and effective, response exercises must be held during which normal work is often disrupted plant-wide.

Emergency readiness allows for a rapid and correct response, negating, or reducing the effects of incidents before they grow into larger problems.

Compliance audits

To be certain PSM is effective, employers must certify that they have evaluated compliance with PSM provisions at least every three years, thus verifying that the procedures and practices are adequate and are being followed.

Audits require the expenditure of man-hours, and normal work activities may be interrupted while audits are in progress.

Compliance audits look at the effectiveness of the whole PSM program and allow the opportunity to improve working portions and eliminate dysfunctional ones. A working PSM program minimizes hazardous releases, injuries, and downtime. The avoidance of incident costs greatly outweighs the cost of implementing the PSM program.

Trade secrets

Employers must make all information available (regardless of trade secret status) as is necessary to comply with PSM standards for PSI, PHA, operating procedures, incident investigations, emergency planning and response, and compliance audits.

The employer may wish to require confidentiality agreements of those people with whom the trade secret information will be shared.

Sharing all information pertinent to a hazardous process helps ensure that all benefits of the PSM program can be realized. For instance, a team performing a PHA without critical information may come to mistaken conclusions; failure of a fully informed PHA leads to failure of the PSM program as a whole.

PSM creates long-term savings

Companies may balk at the costs associated with creating and maintaining a proper PSM program, but they are overlooking the opportunity. Besides the protection of health and safety, the long-term effects of PSM include improvements or reductions in:

An accidents or release that could have been prevented with effective PSM can have devasting effects on the company, the employees, and the community. Realistically, one avoidable accident or release that results in fatalities inside the fence and damages or health concerns outside the fence will precipitate enough financial consequences to have funded PSM correctly multiple times over.