Process Safety Management Introduction

Subject PROCESS SAFETY MANAGEMENT

Title of Module Process Safety Management - Introduction

At the end of this unit, the student must be able to:

Learning Objectives a. Identify general requirements on safety, health and environment which
have to be compiled in the operations of industrial facilities.
b. Explain the importance of Process Safety Management.

INTRODUCTION

Every workplace has its own particular set of threats and safety issues. That is why there is no one right solution to
risk prevention or safety concerns. Yet systems and procedures like PSM exist so that organisations can take a
well-thought-out blueprint and adapt it to their unique needs.

Process safety management is a regulation put into place by OSHA that investigates all procedures including the
processing, usage, storage, movement or manufacture of extremely dangerous chemicals (HHCs).

It requires the implementation of management standards and systems to identify, understand and monitor process
hazards in order to avoid process-related incidents and accidents.

This is more than just chemical safety. When you look at it, you can find that it is just a guideline for the
implementation of the chemical engineering discipline and technique to improve the productivity of a process
operation in all its aspects.

Figure 1. 14 Elements of PSM

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1. Employee Participation
Employers must create a written action plan to enforce the participation of workers needed by the PSM. Under the
PSM, employers shall communicate with employees and their representatives on the conduct and implementation of
process hazard analyzes and on the creation of other elements of process management, and provide employees
and their representatives with access to the hazard analysis process and any other details needed to establish the
standard.

This includes the consistency of processes, systems and organisation, the quality procedure, the regulation of
exceptions, the use of alternate approaches, the accessibility of management, the discipline of contact and the
standards of the company.

Effective process safety management ensures that senior managers are responsible for being open to their people
for assistance and feedback in decision-making and for addressing priority differences between safety, development
and cost control. Managers need to coordinate process safety accountability so that there are no holes in coverage.
You've got to lead from the front, not from the top. Management should communicate the philosophic and specific
aspects of process safety management and make it acceptable with the limitations and availability of resources.

2. Process Safety Information

Employers shall complete a checklist of written process safety information prior to performing the process hazard
review needed by the standard. The compilation of written process safety records, done within the same timeline
needed for process hazard analysis, would allow the employer and staff engaged in the process to identify and
recognize the risks faced by such processes containing highly dangerous chemicals.

Process safety information shall provide information

on the risks of extremely volatile substances used or
generated by the process, information on process
technologies and information on machinery in the
process.

The details on the risks of extremely toxic chemicals

in the process shall consist at least of the following:
 Toxicity,
 Limits of acceptable exposure,
 Physical knowledge,
 Data on reactivity,
 Data on corrosivity, and
 Data on thermal and chemical stability and
the dangerous effects of inadvertent mixing
of various products.

Process technology information must contain at

least the following:
 A block flow diagram or a condensed
phase flow diagram;
 Chemistry of systems,
 Maximum expected inventory,

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 Healthy upper and lower limits for things such as temperature, pressure, flow or composition, and
 Evaluation of the effects of the variance, particularly those concerning the welfare and wellbeing of
Figure 2. Material Safety Data Sheet
workers.
The employer shall register that the machinery complies with agreed and widely accepted good engineering
standards. In the case of obsolete facilities built and installed in compliance with codes, regulations or procedures
that are no longer in common use, the employer shall assess and register that the equipment is designed,
maintained, inspected, checked and performed in a secure manner.

3. Process Hazard Analysis

This encompasses hazard recognition, operational risk assessments and alternative approaches to risk mitigation.
Residual risk control, process management in emergency situations, supply chain risk management and the
definition of tolerable risks must all be addressed. Risk recognition is the most critical component of risk
assessment. If risks and opportunities are not recognized, they will not be addressed!
Risk optimization allows you to consider the experience, culture, processes and environmental dimensions of the
overall risk situation. Early on, you must understand the full impossibility of removing all threats. You must maximize
by explicitly setting goals, recognizing risks and opportunities, and evaluating impacts and skills.

Figure 3. Risk Identification

The employer shall use one or more of the following approaches, if applicable, to define and measure the hazards
of the mechanism under analysis:

 What, if,
 Check list,
 What-if/the checklist,
 hazard and operability study (HAZOP),
 Failure mode and effects analysis (FMEA),
 Analysis of the Fault tree, or an effective technique similar to that.

OSHA assumes that the process hazard analysis is ideally conducted by a team with skills in engineering and
process operations, and that the team should have at least one person with experience and understanding of the

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process being analyzed. In addition, one team member must be informed on the particular techniques of analysis
being used.

The employer must set up a mechanism to comply quickly with the conclusions and suggestions of the team; ensure
that the recommendations are resolved in a timely way and that the resolutions are documented; record the steps to
be taken; draw up a written timeline for the execution of such actions; complete the actions as soon as possible; and
convey decisions to employees, maintenance personnel and other staff whose work duties are in progress and who
may be impacted by advice or actions.

At least every five years after the conclusion of the original hazard analysis phase, the hazard analysis process
must be revised and re-validated by a team meeting the standard criteria to ensure that the hazard analysis is
compatible with the new process.

4. Operating Procedures
This is where you get a chance to institutionalize the accumulated knowledge
and wisdom of your company. This encompasses environmental and industrial
health risks, process definition and design requirements, process and equipment
design, safety mechanisms, operational processes, process risk control
decisions, information management. Operating protocols must be easily
available and up-to-date! They would include initialization, usual shutdown,
emergency shutdown and safe restart, as well as normal operational
conditions, the explanations for them and how to fix the deviations.

Figure 4. Gas Chromatography

Operational Manual
Information on the technology of the process
must include at least the following:

 A block flow diagram or simplified

process flow diagram,
 Process chemistry,
 Maximum intended inventory,
 Safe upper and lower limits for such
items as temperatures, pressures, flows or
compositions, and
 An evaluation of the consequences of
deviations, including those affecting the safety
and health of employees.

In order to ensure that a ready and up-to-date

guide is available and to form the basis for the
appropriate preparation of staff, operating
procedures must be readily available to
Figure 5. Operational Procedures

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employees who work in or manage a process. Operational procedures must be checked as much as possible to
ensure that they match existing working standards, including improvements in process chemicals, technologies and
equipment and facilities. In order to defend against obsolete or erroneous operating practices, the contractor shall
verify on an annual basis that all operating procedures are present and reliable.

5. Training and Performance

In the present frame of reference, we are talking about a comprehensive approach to selecting and designing
systems to educate factory workers on the service, repair and emergency actions associated with industrial
processes. Ensuring that the mentor curriculum is successful is part of the scope. Start with a simple description of
the skills and expertise required.

6. Contractors
When choosing a contractor, the company must collect and review reports on the safety results and programs of the
contract employer. The employer may also notify the contractor of the identified possible burn, accident or
hazardous release risks involved with the contractor's work and process; clarify to the contractor the relevant
provisions of the emergency response plan; Establish and enforce healthy workplace procedures to monitor the
participation, arrival and departure of contract employers and contract workers in the areas protected by the
procedure; regularly review the success of contract employers in meeting their obligations; and maintain a contract
staff accident and sickness record relevant to the contractor's operation in the process areas.

7. Pre-startup Safety Review

It is critical that a safety check is carried out before any highly dangerous chemical is added into the process. PSM
also allows the employer to carry out a safety evaluation prior to the start-up of new installations and updated
installations where the alteration is severe enough to warrant a change in the process safety records.

Prior to the incorporation of a highly volatile chemical into the operation, the safety analysis prior to the start-up must
ensure that the following:
 Construction and machinery shall conform with the requirements of the design;
 Safety, service, repair and emergency protocols are in force and are appropriate;
 Method threat review has been carried out for new facilities and guidelines have been resolved or enforced
prior to start-up, and changed facilities satisfy change management requirements;
 Education of each person engaged in the implementation of the process has been completed.

8. Mechanical Integrity
The field of concern here covers reliability engineering, building materials, assembly and testing processes,
installation procedures, preventive maintenance and pre-start safety tests. Preventive maintenance measures must
define essential units, determine frequency, maintain discipline in the execution of the schedule as established, and
ensure proper record keeping!

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Figure 6. Equipment/Preventive Maintenance Schedule

OSHA believes it is important to maintain the mechanical integrity of critical process equipment to ensure it is
designed and installed correctly and operates properly. PSM mechanical integrity requirements apply to the
following equipment:
 Pressure vessels and storage tanks;
 Piping systems (including piping components such as valves);
 Relief and vent systems and devices;
 Emergency shutdown systems;
 Controls (including monitoring devices and sensors, alarms, and interlocks); and
 Pumps.

Figure 7. Equipment Repair Log

Alarms and instrumentation are often ignored because they do not usually seem to be recorded missing tons. They
do, however, reflect possible reductions in process performance due to quality fluctuations and chemical use, and
they do have safety consequences! It is important to recognize what is crucial and to exert control over future
improvements. There must be a routine follow-up and test discipline.

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9. Hot Work Permit

Hot work refers to work involving electrical or gas welding, cutting, brazing or equivalent flame or spark-producing
activities. Permits must be provided for hot work carried out in or around the covered process. The permit must
record that the fire safety and safety provisions of the OSHA Regulations (1910.252(a)) have been enforced prior to
the start of hot work; must indicate the date(s) of the hot work permit; and must describe the object on which hot
work is to be done. The permit must be kept in file before the hot work is done.

10. Management of Change

Specifically, it refers to improvements in production technology, physical structures, the manner in which the staff
and the management team are structured and aligned, and procedures for coping with uncertainty. Always be on
the lookout for permanent improvements, as opposed to transient ones, and how they can drift through the former.

You need a mechanism to avoid the development of new hazards or an unknown rise in the danger associated with
current hazards arising from improvements in plant operations. The framework must create a systematic, recorded
authorisation mechanism for any transition that is not merely a substitution in kind.

11. Incident Investigation

Learning from accidents ensures that even near-miss events continue to be analysed. Do the study timely and
involve qualified experienced people; use the participation of third parties if necessary.

The subsequent study contains sound, root-cause detection and follow-up action to deter recurrence. If the analysis
report does not say explicitly who is going to do what by whom, it actually did not do the job. Communication of the
result is important so that all partners know what is going to be achieved better from now on.

An investigation report must be prepared including at least:

• Date of incident,
• Date investigation began,
• Description of the incident,
• Factors that contributed to the incident, and
• Recommendations resulting from the investigation.

A mechanism must be developed to quickly investigate and resolve the findings and recommendations of the
incident report. Resolutions and disciplinary measures shall be reported and the report shall be reviewed by all
involved employees whose employment is applicable to the results of the incident (including contract employees
when applicable). The employer has been allowed to hold these incident review records for 5 years.

12. Emergency Planning

When, in the best preparation, an incident happens, it is important that the pre-planning and instruction of
emergency services be made aware of and prepared to take suitable action. For this purpose, an emergency
response plan for the whole plant must be established and enforced in compliance with the terms of the other OSHA
rules (29 CFR 1910.38(a)). In addition, the emergency response plan would provide protocols for the treatment of

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minor leaks of toxic chemicals. Employers protected by the PSM will also be liable to the OSHA Hazardous Waste
and Emergency Response Law (29 CFR 1910.120(a), (p) and (q).

13. Compliance Audits

In order for such process safety management to be successful, employers must verify that they have assessed
compliance with the requirements of the PSM at least every three years. This will check that the protocols and
processes established in compliance with the norm are acceptable and are being practiced.

It refers to the ISO discipline that all of us have already

been subjected to in consistency (9000 series) and
climate (14000 series) for organizing, staffing,
conducting and reporting audits of process safety
management systems and operational processes. It
handles the resolution of the conclusions and corrective
action produced by the audits.

As the method matures and progresses, it can include

process safety assessments, compliance evaluations
and the systematic use of internal and external auditors.

14. Trade Secrets

Employers shall give access to those responsible for compiling process safety information, those responsible for
developing process threat analysis, those responsible for developing operating procedures all the information
required to comply with the PSM; and those undertaking incident reports, emergency preparation and response, and
enforcement audits, without respect to the potential trade secret status of such information. Nothing in the PSM,
however, forbids the employer from forcing those individuals to enter into confidentiality agreements and not to
reveal the details.

The new era of process safety control discipline started in the mid-1980's. In 1985, the Center for Chemical Process
Safety (CCPS) was founded by the American Institute of Chemical Engineers to encourage the enhancement of
process safety among those who ship, ingest, process and store dangerous materials.

SELF -LEARNING ASSESSMENT

1. Differentiate Preventive Action and Corrective Action.
2. Define Process Safety.
3. Give at least 3 importance of Process Safety Management.

REFERENCES:
1. The discipline of process safety management, Solutions!, Online Exclusives, September 2005,
Vol. 88( (tappi.org)
2. Process Safety Management | Occupational Safety and Health Administration (osha.gov)

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