Process Safety Management: Your Ultimate Guide and How To Be OSHA Compliant

The unexpected release of toxic, reactive, or flammable liquids and gases continues to occur across many different industries.

Chemical disasters, such as The Deepwater Horizon disaster in the Gulf of Mexico (U.S. 2010) and the Chevron Refinery Fire in Richmond California (U.S. 2012), cost businesses millions. Yet this financial cost is irrelevant when you consider the loss of life, injury, and environmental damage these disasters caused.

To mitigate chemical accident risk, U.S. Occupational Safety and Health Administration (OSHA) drew up a comprehensive management system. The aim is to properly manage processes dealing with hazardous chemicals. These systems are referred to as process safety management (PSM) systems.

Businesses working in highly hazardous industries, with operations in the U.S. and UK, are required to commit to OSHA’s PSM principles.

With this in mind, in this FAT FINGER article, you’ll learn the details of process safety management systems, and OSHA’s PSM principles. With this knowledge, you can then use your FAT FINGER account to create an internal process safety management audit following Occupational Safety and Health Administration (OSHA) 1910:119.

What is process safety management?
The three systems used to manage process safety
The importance of OSHA’s process safety management system to mitigate chemical accident risk
Process safety information
Ensure compliance by conducting a PSM audit

What is process safety management?

Process safety management (PSM) uses technology platforms, specific procedures, and management frameworks to properly manage hazardous chemicals. The goal is to create a safe workplace and prevent the release of toxic, reactive, or flammable liquids and gases that could cause disaster.

PSM became prominent because of U.S. Occupational Safety and Health Administration (OSHA) regulations. These PSM regulations mandate businesses to properly manage hazardous chemicals. By hazardous we mean chemicals with properties that have the potential to harm human or animal health, the environment, or damage property. Information about hazardous chemicals can be found on the Environmental Protection Agency’s (EPA) and OSHA’s websites.

The three systems used to manage process safety

In recent years there’s been a shift in Process Safety Management to provide clear direction on the elements covering Plant, Processes, and People.

With this in mind, The Energy Institute and Centre for Chemical Process Safety (CCPS) both identify four accident prevention pillars that work towards the same goal. That is, safe operations when dealing with hazardous chemicals.

The Energy Institute’s four-pillar system for process safety management

The four prevention pillars described by the Energy Institute provide a well-structured system with clear direction on all elements covering Plant, Processes, and People. The aim is to ensure safe operations when handling hazardous chemicals.

Pillar one, Process Safety Leadership: Pillar one focuses on the level of performance acceptable to an organization and how they will allocate resources to achieve this.
Pillar two, Risk Identification and Assessment: Pillar two looks to identify hazards, assess risk, identify controls to maintain the integrity of operations, and maintain process safety knowledge developed from risk profiling.
Pillar three, Risk Management: Pillar three focuses on the implementation and management of control measures that have been identified.
Pillar four, Review and Improvement: Pillar four focuses on two elements that measure and review compliance with expectations and implementation of learnings from these measurements and other incidents.

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The CCPS four-pillar system for process safety management

Similar to the Energy Institute’s system, the CCPS four-pillar system gives clear direction on all elements covering Plant, Process, and People. The aim is to ensure safe operations when handling hazardous chemicals.

Pillar one, Commit to Process Safety: Pillar one focuses on leading from the top through all levels, embedding process safety as a core value.
Pillar two, Understand Hazards and Evaluate Risks: Pillar two sets the foundations of a risk-based approach, enabling the business to review the information and apportion resources appropriately.
Pillar three, Manage Risks: Pillar three focuses on the continued execution of risk-based process safety systems.
Pillar four, Learn from Experience: Pillar four collects information from incidents and provides feedback on how the process safety management systems are performing.

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The occupational Safety and Health Administration (OSHA) PSM guidelines

The Occupational Safety and Health Administration (OSHA) provides guidelines to assist employers and employees and maintain PSM compliance. These guidelines can be used in combination with the Energy Institute’s and the CCPS’s four-pillar systems for a comprehensive PSM system.

The major objective of process safety management is to prevent the release of highly hazardous chemicals especially into locations where employees are exposed. To create a system of control, OSHA split process safety management into 14 elements, detailed in the U.S. Occupational Safety and Health Administration (OSHA) 1910:119.

The 14 elements of OSHA’s process safety management system guidelines are as follows :

Process safety information: Staff should have access to basic information about the hazards of the chemicals and tools they are using on the job.
Process hazard information: This helps organizations evaluate their processes and operations to identify potential hazards. Organizations can’t manage safety and hazards until they know what the hazards are in their facilities.
Operating procedures: Work needs to follow a consistent, well-established safety protocol.
Training: Employees should be properly trained on all safety procedures and have access to ongoing refresher training.
Contractors: The safety of contractors and subcontractors should be covered by process safety management systems.
Mechanical integrity: Businesses are required to track and evaluate evolving safety risks and equipment.
Hot work: Working with fire or other sources of ignition requires a systematic process for authorization and oversight.
Management of change: When processes change, businesses should conduct a systematic review of how the changes will affect risk throughout their facility.
Incident investigation: Businesses need a systematic process to record, track, investigate, report and analyze what happened following a near-miss in the workplace.
Compliance audits: Organizations should conduct regular internal audits that ensure procedures and processes are compliant.
Pre startup safety review: Businesses are required to assess new or modified facilities before the introduction of hazardous material.
Emergency planning and response: Organizations should have a carefully planned response plan in the event of something going wrong.
Trade secrets: Employees must be provided with complete documentation of materials and processes, even including those that may be trade secrets, to ensure their health and safety.
Employee participation: Employees should be able to access and sign off policy documents.

These elements are all interlinked and there’s a tremendous interdependency of the various elements of a process safety management system. Every element contributes information to support the other elements. The completion of all elements is necessary.

Businesses working with highly hazardous chemicals with operations in the U.S. and UK are required to commit to OSHA’s PSM principles. With this in mind, the remainder of this article looks at why and how to be OSHA compliant.

The importance of OSHA’s process safety management system in the mitigation of chemical accident risk

Process safety management focuses on having robust processes and systems in place to prevent disaster. When failings do occur they result in the release of hazardous materials, with huge societal and environmental effects. These process errors are both lethal and costly.

For instance, the Chevron Refinery Fire in August 2012 cost the business $2 million in fines and restitution. More importantly, six employees who were at the scene suffered varying degrees of injury. In addition, 15,000 people needed treatment for respiratory problems.

The fire was caused by a diesel leak in the crude oil distillation unit. It took 5 hours to put out the flames. Chevron failed to adequately analyze and document refinery safety technology. The U.S. Chemical Safety Board (CSB) report concluded:

“Chevron has repeatedly failed to implement the proposed inherently safer recommendations. Had this been done, the investigation team concluded, the accident could have been prevented.”

U.S. Chemical Safety Board (CSB), CSB Report: Chevron Ignored Safety Procedures Prior to Refinery Fire

Had the correct process hazard information been acted upon, the mechanical integrity checked, and the appropriate incident prevention procedures carried out, this failure could have been avoided.

Understanding chemical accident risk

The implementation of process safety management offers a solution to control chemical accident risk, and prevent incidents such as the above from reoccurring.

For instance, if we look into the European Commission’s database of chemical accidents worldwide, we see that the number of deaths in OECD countries is significantly lower than the number of deaths in non-OECD countries. OECD countries have stronger procedures in place to control chemical accident risk, such as comprehensive PSM systems.

This data suggests that implementing effective chemical accident risk control measures reduces the number of deaths and injuries from the majority of chemical incidents that occur.

It must be noted, however, that the number of incidents resulting in injuries is not significantly lower between OECD and non-OECD countries. Accidents in the last 10 years include the previously described Chevron Refinery Fire, The Deepwater Horizon disaster in the Gulf of Mexico (U.S. 2010), the Ajka alumina sludge spill (Hungary, 2010), and the ammonium nitrate fire and explosion in West Texas (U.S. 2013).

These last three examples – the Deepwater Horizon disaster; the Ajka aluminum sludge spill, and the ammonium nitrate fire and explosion – could have been prevented if the correct safety procedures had been followed correctly. However, these disasters could have had an even higher death toll if no process safety systems were in place.

Understanding chemical accident causality (e.g. why chemical accidents happen in the first place) is critical to effectively prevent these incidents. Regarding a PSM system, this understanding comes when thinking about the Process Safety Information element.

Process safety information

Process safety information (PSI) is considered a keystone in a PSM system. This is the element that tells you what you’re dealing with from both an equipment and process standpoint.

To be compliant with the OSHA PSM system regulations, the process safety information should control information regarding the hazards of the chemicals used or produced by the process under consideration. Other hazardous information about the technology used and equipment used in the process should also be included, as detailed below.

Chemical information to be included in a PSI:

Toxicity information
Permissible exposure limit
Physical data
Reactivity data
Corrosivity data
Thermal and chemical stability data
Hazardous effects from the inadvertent mixing of different materials that could occur

Technology information to be included in a PSI:

A block flow diagram or simplified process flow diagram
Process chemistry and its properties
Maximum intended inventory
Upper and lower safety limits such as temperatures, pressures, flows, or compositions
An evaluation of the consequences of deviations, including those affecting the safety and health of the employees

Equipment information to be included in a PSI:

Materials of construction
Piping and instrument diagram (P&IDs)
Electrical classification
Relief system design and design basis
Ventilation system design
Design codes and standards employed
Material and energy balances for processes built after May 25, 1992
Safety system (for example, interlocks, detection, or suppression systems)

Ensure compliance by conducting a PSM audit

A process safety management audit helps companies determine whether they are doing what’s required for compliance against OSHA’s PSM mandate.

OSHA 1910.119 requires compliance audits every three years. A PSM audit is a safety audit designed to comprehensively analyze a company’s health and safety policies, processes, and systems that relate to employees handling hazardous chemicals. The ultimate goal is to make sure health and safety measures are carried out as intended.

Use FAT FINGER to conduct regular internal PSM compliance audits against OSHA’s principles

Use the OSHA’s PSM mandate together with FAT FINGER to conduct regular internal PSM compliance audits. This way you can continually assess your operations to see if they’re functioning as they should and so mitigate chemical accident risk.

List the steps that you need to complete to conduct an effective audit as per the

OSHA mandate. This will ensure you’re consistently following the mandate correctly and to the highest standard. You can record all the relevant information and data in your FAT FINGER OSHA compliance audit checklist. Plus, it’s easy to document your audit process using FAT FINGER’s no-code, drag-and-drop checklist builder.

For a better understanding of FAT FINGER, and how it can help you be PSM compliant, watch the below video.

Once you’ve documented your OSHA compliance audit, your employees can jump into the relevant checklist, and check off the steps as they go.

If you’re looking to improve the health and safety of your business operations, then FAT FINGER is the tool for you. We have a wealth of pre-made templates and resources, drawn from industry-standard safety protocols to help you keep your staff safe across a wide range of operations. Check out the articles below to understand how else FAT FINGER can improve health and safety in your business – PSM and beyond.