Process Safety Management (PSM)
The ultimate in
Envirosure regularly assists
in the development of OSHA Process Safety Management (PSM) and EPA Risk
Management Programs (RMP)
OSHA's PSM program is
designed to protect the worker in facilities that use hazardous
chemicals. EPA's RMP program is designed to protect the environment and
the surrounding community from hazardous chemicals.
OSHA and EPA have defined
and listed hazardous and extremely hazardous chemicals that, in the
event of accidental release, could cause death, injury or serious health
effects. These lists contain threshold values for each chemical with
specific requirements dependant upon amount of chemical on site.
For anhydrous ammonia (R-717), the most commonly used industrial
refrigerant, the threshold value is 10,000 pounds, and a PSM program as
defined by OSHA Standard 29CFR 1910.119 is required. (Some local
officials have adopted parts of 1910.119 for any facility using
anhydrous ammonia regardless of system charge.)
PSM Program Required Elements
Material Safety Data Sheets (MSDSs)
may be used to comply with this requirement to the extent they
contain the required information, and information on equipment,
piping and instrument diagrams (P&IDs), materials of construction,
electrical classification, relief system design and design basis,
ventilation system design, codes and standards employed, material
and energy balances, and safety systems.
A written plan of action about how employees will participate.
An organized and systematic
effort to identify any potential hazards associated with an
operation. PHA's must be updated and revalidated at
least every 5 years.
To include: initial startup,
normal operations, temporary operations, emergency shutdown,
emergency operations, normal shutdown, startup after an emergency
Records showing the identity of
the person trained, the training date, and determining that the
person understood the training. PSM also calls for refresher
training at least every three years and requires written
documentation of training.
OSHA requires a review of a
contractor's training procedures and review of safety records.
Ensure, before any startup,
that appropriate safety, operating, maintenance, and emergency
procedures are in place.
Requirement to have written
procedures to ensure the integrity of the process systems, new and
A permit system in place for
all hot work operations.
A written program in place to
ensure that any modification made to a process system is performed
in a safe manner.
Incident investigation is the
process of identifying the underlying causes of accidents or near
misses and setting in place procedures to prevent similar accidents.
Need to ensure that the incident investigation procedures tie into
EPA's five year accident history.
Must certify that compliance
with OSHA's PSM and the U.S. EPA's RMP program is evaluated at least
every three years.
Preparedness - Emergency Planning and Response
Develop and implement an
emergency action plan.
It should be noted that
regardless of the amount or type of chemicals in any facility, EPA Clean
Air Act Section 112(r) contains a General Duty Clause (GDC) which in
part states "...the owners and operators of stationary sources
producing, processing, handling, or storing such substances have a
general duty... to identify hazards which may result from such releases
using appropriate hazard assessment techniques to design and maintain a
safe facility... "
For information on a
complete PSM program, or for assistance with any of the required PSM
elements, give us a call at 480-784-4621. We welcome the
opportunity to discuss your requirements.