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1995-01-22
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INFORMATION DATE 19920805
DESCRIPTION USDOL Program Highlights on Process Safety Management
TOPIC Highly hazardous chemical
SUBJECT Process safety management of highly hazardous chemicals
ABSTRACT Process Safety Management of Highly Hazardous
chemicals covers application, process safety
information, employee involvement, and process hazard
analysis. The employer must consider safety records in
selecting contractors and informing contractors of
potential process hazards etc.
U.S. Department of Labor
Program Highlight
_________________________________________________________________________
Fact Sheet No. OSHA 92-45
Process Safety Management
of Highly Hazardous Chemicals
Application - covers processes involving listed (highly hazardous)
chemicals at specified quantities and flammable liquids or gases in
quantities of 10,000 pounds or more (except products used solely for
heating or fuel). Rules covering pyrotechnic and explosives manufacture
incorporate the PSM provisions by reference.
Process Safety Information - requires compilation of written process
safety information including hazard information, process technology and
information on equipment in the process.
Employee Involvement - requires developing a written plan of action
regarding employee participation; consulting with employees and their
representatives on the conduct and development of process hazard analyses
and on the development of other elements of process safety management
required under the rule; providing to employees and their representatives
access to process hazard analyses and to all other information required
to be developed under the rule.
Process Hazard Analysis - specifies that hazard analyses must be conducted
for each covered process using compiled process safety information in an
order to be determined by the employer. At least twenty-five percent of
initial process hazard analyses must be completed by May 26, 1994; 50
percent by May 26, 1995; 75 percent by May 26, 1996; and 100 percent by
May 26, 1997. Process hazard analyses completed after May 1987, which
meet the requirements of this standard, may be used to comply with this
standard. Process hazard analyses must be updated and revalidated at
least every five years. Records must be maintained of the most recent
analyses.
Process Hazards Analysis Methods - The employer must choose an
appropriate method. The standard mandates what-if; checklist;
what-if/checklist; hazard and operability study (HAZOP); failure mode and
effects analysis (FMEA); fault tree analysis; or an equivalent method.
Contents - must address: hazards of the process; previous hazardous
incidents; engineering and administrative controls; consequences of
failure of engineering and administrative controls; facility siting;
human factors; and evaluation of effects of failure of controls on
employees.
Procedure - team performing analysis must have expertise in
engineering and process operations and must include one employee with
experience and knowledge specific to the process and someone
knowledgeable in the specific process hazard analysis methodology used by
the team.
Follow-up - must establish a system to address hazard analysis
findings and recommendations; assure timely resolution; document actions
planned; complete actions as soon as possible, in accordance with a
written schedule; notify affected operating, maintenance and other
employees of planned actions.
Operating Procedures - must be in writing and provide clear instructions
for safely operating processes; must include steps for each operating
phase, operating limits, safety and health considerations and safety
systems. Procedures must be readily accessible to employees, must be
reviewed as often as necessary to assure they are up to date and must
cover special circumstances such as lockout/tagout and confined space
entry.
Training - mandates training covering specific safety and health hazards,
emergency operations and safe work practices. Initial training must
occur before assignment or employers may certify that employees involved
in the process as of May 26 1992, have the required knowledge, skills and
abilities to safely perform duties and responsibilities specified in the
operating procedures. PSM calls for refresher training at least every
three years and requires written documentation of training.
Contractors - identifies responsibilities of employer regarding contractors
involved in maintenance, repair, turnaround, major renovation or
specialty work, on or near covered processes. The employer must:
consider safety records in selecting contractors; inform contractors of
potential process hazards; explain the facility's emergency action plan;
develop safe work practices for contractors in process areas; evaluate
contractor safety performance; and maintain an injury/illness log for
contractors working in process areas. PSM requires contractors to train
their employees in safe work practices and document that training, assure
that employees know about potential process hazards and the employer's
emergency action plan, assure that employees follow safety rules of
facility, advise employer of hazards contract work itself poses or
hazards identified by contract employees.
Pre-startup Safety Review - mandates a safety review for new facilities
and modified sites to confirm integrity of equipment; to assure that
appropriate safety, operating, maintenance and emergency procedures are
in place; and to verify that a process hazard analysis has been
performed.
Mechanical Integrity - requires written procedures, training for process
maintenance employees and inspection and testing for process equipment
including pressure vessels and storage tanks; piping systems; relief and
vent systems and devices; emergency shutdown systems; pumps; and controls
such as monitoring devices, sensors, alarms and interlocks. PSM calls
for correction of equipment deficiencies and assurance that new equipment
and maintenance materials and spare parts are suitable for the process
and properly installed.
Hot Work - mandates a permit system for hot work operations conducted on
or near a covered process.
Management of Change - specifies a written program to manage changes in
chemicals, technology, equipment and procedures which addresses the
technical basis for the change, impact of the change on safety and
health, modifications to operating procedures, time period for the change
and authorization requirements for the change. The standard requires
employers to notify and train affected employees and update process
safety information and operating procedures as necessary.
Incident Investigation - requires employer to investigate as soon as
possible (but no later than 48 hours) incidents which did result or could
have resulted in catastrophic releases of covered chemicals. The
standard calls for an investigation team, including at least one person
knowledgeable in the process (a contractor employee, if appropriate), to
develop a written report on the incident. Employers must address and
document their response to report findings and recommendations and review
findings with affected employees and contractor employees. Reports must
be retained for five years.
Emergency Planning and Response - requires employers to develop and
implement an emergency action plan.
Compliance Audits - calls for employers to certify that they have evaluated
compliance with process safety requirements at least every three years
and specifies retention of the audit report findings and the employer's
response. Employers must retain the two most recent audit reports.
Trade Secrets - sets requirements similar to trade secret provisions of
the hazard communication standard requiring information to be available
to employees from the process hazard analyses and other documents required
by the Standard. PSM permits employers to enter into confidentiality
agreement to prevent disclosure of trade secrets.
# # #
_________________________________________________________________________
This is one of a series of fact sheets highlighting U.S. Department of
Labor programs. It is intended as a general description only and does not
carry the force of legal opinion. This information will be made
available to sensory impaired individuals upon request. Voice phone:
(202) 523-8151. TDD message referral phone: 1-800-326-2577.