OSHA Process Safety Management (29 CFR 1910.119) explained: who it applies to, the 14 PSM elements, PHA revalidation, MOC and compliance audits.
Regulatory citation: 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals
29 CFR 1910.119 requires employers to manage the hazards of processes involving highly hazardous chemicals, to prevent or minimize the consequences of catastrophic releases such as fires, explosions and toxic gas releases. It is commonly known as PSM.
Process safety incidents can kill or injure many people at once and affect surrounding communities. PSM grew out of major chemical disasters and focuses on preventing low-frequency, high-consequence events.
PSM applies to processes involving a listed highly hazardous chemical at or above its threshold quantity, and to processes involving 10,000 pounds or more of a flammable liquid or gas, with certain exemptions.
Employers must compile process safety information and conduct a process hazard analysis (PHA), updated and revalidated at least every five years.
Written operating procedures are required, and employees must be trained on them, with refresher training at least every three years.
Critical equipment such as pressure vessels, piping, relief systems and controls must be inspected, tested and maintained.
Changes to chemicals, technology, equipment and procedures must go through management of change, and pre-startup safety reviews are required for new and significantly modified facilities.
Incidents that resulted in, or could reasonably have resulted in, a catastrophic release must be investigated starting within 48 hours. Employers need an emergency action plan, and must certify compliance audits at least every three years.
PSM also covers employee participation, contractor safety, hot work permits and trade secrets, making 14 elements in total.
Assign clear ownership for each PSM element and track due dates for PHAs, audits and training.
Many incidents trace back to small, undocumented changes. Make MOC easy to use and hard to bypass.
Track PHA, audit and investigation recommendations to closure with documented resolutions.
A refrigerated warehouse uses more than 10,000 pounds of anhydrous ammonia, putting its refrigeration system under PSM. The facility completes a PHA with its operators and an outside facilitator, schedules revalidation for five years later, updates operating procedures, and requires MOC review before a contractor replaces a compressor with a different model.
Related regulations: EPA Risk Management Program, EPA General Duty Clause, OSHA HazCom.
Note: This summary reflects federal OSHA requirements. States with OSHA-approved State Plans may have additional or different requirements. Always check the current regulation text and any state rules that apply to you.
The 14 elements are employee participation, process safety information, process hazard analysis, operating procedures, training, contractors, pre-startup safety review, mechanical integrity, hot work permits, management of change, incident investigation, emergency planning and response, compliance audits, and trade secrets.
A PHA must be updated and revalidated at least every five years by a team with the right expertise, to make sure it stays consistent with the current process.
OSHA's PSM focuses on protecting workers from catastrophic chemical releases. EPA's Risk Management Program, under Clean Air Act Section 112(r)(7), focuses on protecting the public and environment. Many facilities are covered by both, and the programs share similar prevention elements.
This guide is for general information only and is not legal advice. Always check the current text of the regulation with the relevant regulator.
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