• Employers must ensure employee participation, keep records, conduct analyses, and more to ensure safety in the workplace and comply with regulation standards.

Employers with covered processes in Process Safety Management (PSM) must:

• Ensure employee participation in the PSM program,
• Compile information about the process,
  • Compiling written process safety information enables the employer and the employees involved in process operations to identify and understand the hazards posed by highly hazardous chemicals. This process safety information must include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, the technology of the process, and the equipment in the process.
• Conduct adequate process hazard analyses (PHA),
  • The type of method used needs to be analyzed thoroughly for compatibility with the process. After the initial PHA, employers must revalidate the analysis at least every five years.
• Implement safe operating procedures,
  • 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.
• Conduct process safety training,
  • All employees, including maintenance and contractor employees, involved with highly hazardous chemicals need to fully understand the safety and health hazards of the chemicals and processes they work with for the protection of themselves, their fellow employees, and the citizens of nearby communities. Training conducted in compliance with 1910.1200, the Hazard Communication standard, will help employees to be more knowledgeable about the chemicals they work with, as well as familiarize them with reading and understanding safety data sheets (SDSs). However, additional training in subjects such as operating procedures and safety work practices, emergency evacuation and response, safety procedures, routine and non-routine work authorization activities, and other areas pertinent to process safety and health will need to be covered by an employer’s training program.
• Ensure process safety for contractors,
  • Employers who use contractors to perform work in and around processes that involve highly hazardous chemicals will need to establish a screening process to ensure hired contractors don’t compromise the safety and health of employees at a facility.
• Conduct pre-startup safety reviews,
• Ensure integrity of process equipment,
  • Equipment used to process, store, or handle highly hazardous chemicals needs to be designed, constructed, installed, and maintained to minimize the risk of chemical releases. This requires that a mechanical integrity program be in place to assure the continued integrity of process equipment. Elements of a mechanical integrity program include the identification and categorization of equipment and instrumentation, inspection and test processes, 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 mean time to failure for equipment and instrumentation.
• Ensure management of change process and procedures are adequate,
  • To properly manage changes to process chemicals, technology, equipment, and facilities, one must define what is meant by change. Change includes all modifications to equipment, procedures, raw materials, and processing conditions other than “replacement in kind.” These changes need to be properly managed through proper identification and review prior to implementation of the change. For example, the operating procedures contain the operating parameters (pressure limits, temperature ranges, flow rates, etc.) and the importance of operating within these limits. While the operator must have the flexibility to maintain safe operation within the established parameters, any operation outside of these parameters requires review and approval by a written management of change procedure.
• Investigate incidents per Occupational Safety and Health Administration (OSHA) requirements,
  • Incident investigation is the process of identifying the underlying causes of incidents and implementing steps to prevent similar events from occurring. This process allows employers to learn from past experiences and avoid repeating past mistakes. OSHA expects employers to become aware of and to investigate the types of events which result in or could reasonably have resulted in a catastrophic release. Some events are sometimes referred to as “near misses,” meaning that a serious consequence did not occur, but could have. Employers need to develop in-house capability to investigate incidents that occur in their facilities. A team needs to be assembled by the employer and trained in the techniques of investigation.
• Ensure emergency planning and response efforts are adequate, and
• Establish a process safety compliance audit process.
  • Employers need to select a trained individual or assemble a trained team of people to audit the PSM system and program at least once every three years. A small process or plant may need only one knowledgeable person to conduct an audit. The audit must include an evaluation of the design and effectiveness of the PSM system and a field inspection of safety and health conditions and practices to verify that the employer’s systems are effectively implemented. The audit should be conducted or led by a person knowledgeable in audit techniques who is impartial toward the facility or area being audited. The essential elements of an audit program include planning, staffing, conducting the audit, evaluation, corrective action, follow-up, and documentation.