OSHA’s 1910.119 regulation applies to those companies that deal with any of more than 130 specific toxic and reactive chemicals in listed quantities (See 1910.119 Appendix A); it also includes any Category 1 flammable gas (as defined in 1910.1200(c)) or a flammable liquid with a flashpoint below 100°F (37.8°C) on site in one location, in a quantity of 10,000 pounds (4535.9 kg) or more (with a few exceptions, as outlined in 1910.119(a)(1)(ii)(A) and (B)).

Action steps

• Ensure employee participation in the process safety management program.
• Conduct adequate hazard analyses.Implement safety operating procedures.
• Conduct process safety training.
• Ensure process safety for contractors.
• Conduct pre-startup safety reviews.
• Ensure integrity of process equipment.
• Ensure management of change process and procedures are adequate.
• Investigate incidents per OSHA requirements.
• Ensure emergency planning and response efforts are adequate.
• Establish a process safety compliance audit process.

Training action plan

You must train each employee involved in operating a process and each employee before being involved in operating a newly assigned process. Training must include:

• An overview of the process and the operating procedures.
• Specific safety and health hazards.
• Emergency operations including shutdown.
• Safe work practices applicable to the employee’s job tasks.

Also, you must provide refresher training at least every three years, and more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process. You, in consultation with the employees involved in operating the process, must determine the appropriate frequency of refresher training.

Documentation

You must prepare a record that contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training.

Tips

• OSHA’s Process Safety Management (PSM) standard requires that mechanical integrity inspections have to be documented (including the name of the person performing the inspection or test) and list the information to be recorded.
• The PSM standard states that the employer must establish and implement written procedures.
• To comply with the PSM standard, employers must document that equipment complies with recognized and generally accepted good engineering practices. For existing equipment designed and constructed in accordance with codes, standards, or practices that are no longer in general use, the employer must determine and document that the equipment is designed, maintained, inspected, tested, and operated in a safe manner.
• All process hazard analyses must be updated and revalidated, based on their completion date, at least every five years.
• Employers must consult with employees and their representatives on the conduct and development of process hazard analyses and on the development of the other elements of process management, and they must provide to employees and their representatives access to process hazard analyses and to all other information required to be developed by the standard.
• Contract employees must be instructed on known potential fire, explosion, or toxic release hazards related to their job and the process, and in the applicable provisions of the emergency action plan.

Checklist

Review these process safety management checklists.

Process hazard analysis

• Has written process safety information been compiled before conducting any process hazard analysis (PHA)?
• Are the process hazard analyses performed by teams with expertise in engineering and process operations?
• Has a system been established to promptly address the team’s findings and recommendations?
• Are the PHA’s updated and revalidated to assure that the process hazard analysis is consistent with the current process?

Incident investigation

• Has each incident been investigated which resulted in, or could reasonably have resulted in, a catastrophic release of highly hazardous chemicals in the workplace?Has a system been established to promptly address and resolve the incident investigation report findings and recommendations?

Emergency action plan

• Has an emergency action plan been established and implemented for the entire plant in accordance with the requirements of 1910.38?

Written program

• Do you have an appropriate written program for PSM compliance?
• Do you have a written program regarding employee participation?
• Do written operating procedures exist for each covered process?
• Have safety and health considerations been included in the operating procedures?

Contractors

• Have safe work practices been developed and implemented for employees and contractors to control hazards?
• For employees and contractor employees involved in operating a process do initial and refresher training records exist?
• Has each employee and contractor employee been trained before being involved in a newly assigned process?

Pre-startup safety review

• Has a pre-startup safety review been performed for all new facilities and for modified facilities when the modification is significant enough to require a change in process safety information?

Mechanical integrity

• Are there written procedures to maintain the ongoing integrity of process equipment?
• Are appropriate inspections and tests performed on each item of process equipment included in the program?
• Have appropriate checks and inspections been made to assure equipment is installed properly and consistent with design specifications and manufacturer’s instructions?

Hot work permits

• Have hot work permits been issued for all hot work operations conducted on or near a process covered by the PSM standard?

Management of change

• Are there written procedures for managing changes (except for “replacements in kind”) to process chemicals, technology, equipment, and procedures and changes to facilities that affect a covered process?

Audits

• Do you conduct an audit of compliance with PSM at least every three years?
• Do you retain the two most recent compliance audit reports?

Training

• Have employees been trained properly regarding PSM?
• Are appropriate training records kept?