Why Process Safety Management Was Developed
Process Safety Management (PSM) was developed as a standard by OSHA to help companies improve safety. Any company that uses one of the 130+ chemicals identified as dangerous by OSHA should follow the PSM standards.
The risk of unexpected spills or leaks from chemicals that are toxic, flammable, or reactive is present in facilities throughout the world. Since accidental releases can occur at any time, OSHA determined it was necessary to create a set of standards to help reduce the overall risk. When a facility properly implements the process safety management standards, they are working to prevent potential disasters related to dangerous chemicals.
Image Credit: https://en.wikipedia.org/wiki/Process_safety_management - 14 labeled elements from 29 CFR 1910.119 for Process Safety Management.
Proper Use of Labels and Signs in the PSM Standard
Using labels and signs is essential for conveying information concerning chemicals, storage containers, and other key items in the process safety management system. The labels and signs are to be placed directly on the containers or areas where potentially dangerous chemicals are used. This ensures that everyone who works with or around these chemicals is aware of the risks involved.
Required Information for OSHA Labeling
When creating labels for the process safety management system, OSHA requires that specific information be easily visible to those who view it. Making sure all the necessary information is on a given label or sign will ensure the proper actions are taken when working with the chemical or when there is an accidental spill.
Detailed information about the chemical hazards that should be included on labels or signs include the following:
- Thermal or Chemical Stability Information - This includes details about any hazardous effects that can occur when mixed with other substances.
- Information about Corrosiveness - If a chemical has a corrosive nature, the details should be included on the labels.
- Details on Reactivity - If a chemical will react in a dangerous or potentially dangerous way, it must be identified.
- Physical Information - Information about the physical properties of the chemical.
- Exposure Limits - If the chemical has any level of permissible exposure, those limits must be listed on the labels or signs.
- Information about Toxicity - A breakdown of the hazards and other details concerning the toxicity of the chemical.
These are the minimum standard requirements. If additional information is available and it will help improve safety or allow for a better reaction to a dangerous situation, that should also be included on the labels and signs.
Process Hazard Analysis
Another step in the process safety management system is known as the process hazard analysis. It is a detailed approach that will assist with identifying and evaluating the hazards that exist in the facility. Once identified, this analysis will also allow the development of processes to help control dangers effectively.
There are a number of approved methods from OSHA to help complete a process hazard analysis. The following are all acceptable options, and each facility should choose which are appropriate for a given situation:
- A What-if Checklist
- HAZOP (Hazard and Operability Study)
- FMEA (Failure Mode and Effects Analysis)
- Fault Trees
- Appropriate Equivalent Methodology
This video courtesy of ABB Service provides a good introduction to how the process safety management system can help with hazard analysis and keeping a facility safe:
Proper Operating Procedures
Having detailed written operating procedures that can be easily understood is essential for the process safety management system. These procedures have to be in line with the information that was gathered about the chemicals and other hazards in the facility, and they must provide instructions that will guide employees toward the best ways of operating a machine or other item safely.
OSHA specifically requires that there are written operating procedures that are consistent throughout the facility, implemented in a standard way, and followed at all times. The facility will also need to address each of the following steps at a minimum for each operating phase:
- Initial Process Setup - The initial process to startup a machine or other event.
- Normal Operations - Instructions for how things should be done during normal operating conditions.
- Temporary Condition Operations - Operating procedures for temporary conditions.
- Emergency Shutdown Situations - Detailed instructions on how to perform an emergency shutdown.
- Emergency Operations - Information on how to perform operations during an emergency situation. This should include which operations should not take place in an emergency scenario.
- Normal Shutdown Instructions - Detailed instructions on what must take place before, during, and after a normal shutdown occurs.
- Startup Instructions - Startup instructions should include information for after a normal turnaround as well as after an emergency shutdown.
When documenting the safety and health considerations in the process safety management guidelines, a number of specific things must be included. They are:
- Details on the properties and hazards related to the chemicals
- Any necessary precautions that are needed in order to prevent exposure to the chemicals
- What controls should be put in place in the event that there is physical and/or airborne exposure to a chemical
- Instructions for keeping the inventory levels of hazardous chemicals under control
- Details on special hazards that may occur
Safety Systems in a Facility
Whenever working with dangerous chemicals, it is important to have effective safety systems in place. These systems can help prevent accidents, detect risks, and properly respond to events when they occur. The following are some types of systems that may be used in many facilities:
Image Credit: https://en.wikipedia.org/wiki/Trapped_key_interlocking - This is a transfer block, part of a trapped key interlock system.
- Interlocks - Having a physical lock in place can protect employees from entering high-hazard areas. This can also be a system that prevents the engagement of a machine until specific safety checks have passed.
- Detection Systems - Many advanced detection systems can detect small leaks or spills before they become a serious hazard.
- Suppression Systems - In the event of a fire or other hazard, a suppression system can help to keep the risk contained to a small area.
- Filters - Filters can help remove the danger from an area quickly and prevent it from coming into contact with people or the environment.
Choosing the right safety systems for a facility is an important part of the process safety management system from OSHA. Depending on the type of chemicals that are present and how they are used, one or more safety systems may be required.
Training Employees for Process Safety Management
Employees are essential to successful process safety management. OSHA requires that all employees who will be involved in operating any process will need to be given sufficient training in their role. This training has to have a strong emphasis on the safety and health hazards that they will be exposed to. It also needs to give instructions for what to do in the event of an emergency.
In addition to the initial training that is required by OSHA, employees must also be given a refresher course every three years, or more frequently when needed. The employer is responsible for tracking the training needs of each operator and scheduling them for the necessary training to remain in compliance. The training that is scheduled or completed must be tracked using a written record that includes dates, topics covered, and confirmation that the employee has sufficient understanding of the topics covered.
Image Credit: OSHA - Accident Investigation Report
The process safety management system is designed to minimize the risk that dangerous incidents will occur. If there is a safety event, however, it must be fully investigated to help determine the root cause. This will minimize the risk of it happening again, and will also allow the facility to take the necessary steps to improve the responses that took place.
When an investigation is completed, a full report should be prepared and kept for review in the future. The report must include the following items at a minimum:
- Incident Date - Clearly identifying the date and time of an incident, as well as times of key events during the incident, is essential. Keeping track of the dates should continue until the full investigation is completed.
- Description - A detailed description of the incident should be logged in the report.
- Contributing Factors - All contributing factors that led to the incident should be tracked. Included in this would be any factors that prevented proper containment of the incident.
- Recommendations - The report should include recommendations on how to keep this type of event from occurring again, or how to better respond in the event that it does.
Image Credit: OSHA - When it comes to documentation, you can write an inspection on notebook paper; but a standard format and approach helps keep thing organized. Here are some basic criteria for what to put on the report: Have a form which tells who, what, when, why, and where. You'll need this information to get the correction process working.
All parties involved with the incident should be given this report for review. It can also be helpful to form a training session that is based off of a given event to ensure everyone is aware of what should have been done differently.
Engaging in Compliance Audits
OSHA requires that a facility must be evaluated every three years at a minimum in order to remain in compliance. This typically includes an on-site inspection by OSHA or an approved investigative group authorized by OSHA. Once the investigation is completed, a compliance report will be issued that confirms the facility is in compliance.
This report will also include any problems that were discovered. These problems can be used as action items for continuous safety improvements within the facility and should be resolved as soon as possible. To become more familiar with the OSHA compliance audits and reports, facility safety managers should consider reading OSHA 29 CFR 1910.119.