PROCESS

SAFETY
MANAGEMENT
 LUCK can keep you from making
mistakes, but only wisdom can keep
you from making them again !!!
What Is Process Safety Management?
• PSM:
– Addresses the management of Highly Hazardous
Chemicals (HHC)

– Integrates
• Technology
• Operating Procedures
• Standard management protocols

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 Why Did OSHA Develop PSM?
– Past Disasters
– Current Disasters
– Perceived Weakness in PSM Program

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 Why Did OSHA Develop PSM?
• Bhopal, India (1984)
– 2,000 deaths
Isocyanate release
• Pasadena, TX (1989)
– 23 deaths, 132 injuries
Petroleum explosion
• Cincinnati, OH (1990)
– 2 deaths
Explosion
• Sterlington, LA (1991)
– 8 deaths, 128 injuries
Chemical release
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PROCESS SAFETY MANAGEMENT
• Recognition of seriousness of consequences
and mechanisms of causation lead to focus
on the process rather than the individual
worker

• Many of the key decisions influencing safety

may be beyond the control of the worker or
even the site – they may be made by people
at another site, country or organization

• Causes differ from those for personnel

safety

• Need to look at the whole – materials,

equipment and systems – and consider
individuals and procedures as part of the
system

• Management system approach for control

Flixborough, Bhopal, Pasadena

 In General: PSM
• Safety Policy may be formulated to show the management
commitment towards safety

• Safety Committee may be framed with representatives from all

the dept. at a worker level and managerial level

• Safety Training (Usage of Portable Fire Extinguisher, First Aid,

PPE etc.) may be conducted periodically, including contract
workers

• Work permit systems ( hot work and cold work) may be

followed

• SOP should be framed and should be made available at the

work places
• Periodical Medical Examinations for all the employees and
contract workers to be done
• Illumination and Noise Survey should be conducted
periodically
• Emergency plan for MB&DL may be framed
• Mock drill should be conducted periodically
• Security may be given training on fire fighting procedures and
first aid.
• Adequacy of the portable fire extinguishers are to be checked
as per IS:2190 and should be maintained.
The Elements of the PSM Standard
• Application
• Exclusions
• Definitions
• Employee Participation
• Hazards of the Process
• Toxicity
• Technology of the Process
• Equipment in the Process
• Mechanical Integrity
• Inspection & Testing
• Quality Assurance
• Process Hazard Analysis
• Management of Change
• Operating Procedures
• Safe Work Practices
• Training
• Contractor Management
• Emergency Planning &
Response
• Incident Investigation
• Compliance Audits
• Trade Secrets
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 Scope
(elements of process safety management)
1. Process Knowledge and Documentation
2. Capital Project Review and Design Procedures
3. Process Risk Management
4. Management of Change
5. Process and Equipment Integrity
6. Human Factors
7. Training and Performance
8. Incident Investigation
9. Company Standards, Codes and Regulations
10. Audits and Corrective Actions
11. Enhancement of Process Safety Knowledge
CCPS: Guidelines for Technical Management of Chemical Process Safety
 What Types of Industries?
• Industries that Process Chemicals Such As:
– Industrial Organics & Inorganics
– Paints
– Pharmaceuticals
– Adhesives
– Sealants and Fibers
– Petrochemical facilities
– Paper Mills
– Food Processing with Anhydrous Ammonia over
the TQ

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FUNCTIONS OF A MANAGEMENT SYSTEM

Planning
Measurement Direction Organizing

Structure
Leadership

Controlling Results Implementing

CCPS: Guidelines for Technical Management of Chemical Process Safety

 Features and characteristics of a management
system for process safety
Planning Organizing
Explicit goals and objectives Strong sponsorship
Well-defined scope Clear lines of authority
Clear-cut desired outputs Explicit assignments of roles and
Consideration of alternative achievement responsibilities
mechanisms Formal procedures
Well-defined inputs and resource Internal coordination and communication
requirements
Identification of needed tools and training
Implementing Controlling
Detailed work plans Performance standards and
Specific milestones for accomplishments measurement methods
Initiating mechanisms Checks and balances
Performance measurement and reporting
Internal reviews
Variance procedures
Audit mechanisms
Corrective action mechanisms
Procedure renewal and reauthorization

CCPS: Guidelines for Technical Management of Chemical Process Safety

 Strategic Managerial Task

Planning
Planning
Organizing
Planning
Organizing
Implementing
Implementing
Organizing

Controlling Controlling Controlling

Examples of PSM management systems concerns at different

organizational levels

CCPS: Guidelines for Technical Management of Chemical Process Safety

 Assessing an organization’s safety effectiveness

• What is the safety policy and culture (written, unwritten)?

• How are the following handled?

– Establishing what has to be done
• Benchmarking
• Communicating
• Assigning accountabilities
– Ensuring that it gets done
• Monitoring and corrective action
• Evidence (documentation) and audit process
• Resourcing – not only for ideal but for anticipated conditions
• Balancing with other priorities

• How are exceptions handled?

 Employee Participation
Now that we are required to comply, then what?
• Form a Team in Your
Company, i.e..
– Process Engineers
– Operators
– Safety
– Maintenance
– Management
– Consultants

Remember…You Can’t Do it Alone!

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 Now that we are required to comply,
then what?
• Form a Plan, Determine:
– Responsibilities
– Duties
– Reporting
– Document Control
– Progress Reports
– Tracking Changes

Then…Begin the Process of Developing &

Implementing the PSM Program
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 Toxicity Information
The Requirements of the Standard - Develop
Toxicity Information
 Obtain Toxicity
Information on the
Chemical(s) in the
Process
 MSDS are Typical
Resource
 You May Need Other
References, NIOSH
Pocket Guide, ACGIH
TLV’s
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 Technology of the Process
The Requirements of the Standard - Process
Technology
 Block flow diagram or
process flow diagram
 Process chemistry
 Maximum intended
inventory
 Upper and lower
limits
 Consequences of
deviations

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The Requirements of the Standard -
Process Equipment
 Materials of construction
 Process and instrument
drawings (P&ID’s)
 Electrical classification
 Relief system design
 Ventilation system design
 Design codes
 Material and energy
balances
 Safety systems

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 Widely known Hazard Identification Techniques

• Safety Reviews
• Check list analysis
• Relative Ranking
• Preliminary Hazard Analysis
• What If analysis
• Hazard and Operability Analysis (HAZOP)
• Failure Mode and Effect Analysis (FMEA)
• Fault Tree / Event Tree Analysis
• Cause and Consequence Analysis
• Quantitative Risk Analysis (QRA)
 Equipment in the Process
The Requirements of the Standard -
Process Equipment
Now:
 Identify Each Piece of
Equipment in the
Covered Process by
P&ID, Block Diagram and
Number Them
 Remember - Must Follow
Form
 Must be Able to Track
Each Number Through
the Entire Program

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 Process Hazard Analysis
(PHA’s)
 Arguably the Most Difficult Part of
Performing the Standard
 PHA process is dynamic and subject to
revision whenever changes are made
 Performed by Your PSM Team
 Takes Significant Time & Effort
 PHA’s are Never Ending

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A PHA Process Must be Performed on Each Element of the Covered Process:
A PHA From Block Diagram to P&ID to Every Equipment Component to Determine
What Might Happen if an Element of the Covered Process Fails

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 There is Much More to PSM
• Inspection & Testing
• Quality Assurance
• Management of Change
• Operating Procedures
• Safe Work Practices
• Training
• Contractor Management
• Emergency Planning & Response
• Incident Investigation
• Compliance Audits
• Trade Secrets
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 Management of Change
• Procedures to manage changes to the
covered process.
– Exception: “replacement in kind”
• Management of Change includes:
– Process chemicals
– Technology
– Equipment
– Operating Procedures
– Facilities
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 Management of Change Addresses
1. Technical basis of the change
2. Impact to employee safety and health
3. Modification to operating procedures
4. Time period for change
5. Authorization of change

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 Operating Procedures
• Develop and implement written operating
procedures that are clear instructions for all
expected phases of operations.
• Standard Operating Procedures
(SOPs)
• Must cover:
– Operation phase
– Operational limits
– Safety & health considerations
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 OPs Must Address
• Initial start-up
• Normal operations
• Temporary operations
• Emergency shutdown
• Emergency operations
• Normal shutdown
• Start-up following turnaround
• Consequences of deviation
• Steps required to correct or avoid deviation

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 SOPs
• Must be readily available to employees
• Must be reviewed as needed to ensure they
reflect current operating practicce.
• Must cover:
– Process chemicals
– Technology and equipment
– Facilities
• SOPs must be certified annually that they
are correct and accurate.

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 Safe Work Practices (SWPs)
• Must be developed and implemented to
provide for the control of hazards during
work activities such as:
– Lock-out/Tag-out
– Confined space entry
– Opening processes, piping or equipment

SWPs are for: • Lab personnel

• Operators • Or other support personnel
• Maintenance personnel
• Contractors
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 Training
• PSM specific training is required

• Must cover:
– Safety and health hazards associated with the
covered process
– Safe work practices

• Refresher training is required every 3 years

or as needed to ensure employees are
complying with all PSM requirements
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 Personal Protective Equipment (PPE)
1. Safety Glasses
Must be worn in all chemistry laboratories.
Must be worn in mechanical workshops.
Must be worn when transferring cryogenic liquids.
2. Lab coats
Cotton laboratory coats must be worn when
doing chemical work. If you spill or splash
corrosive chemicals on Yourself, it is easier to
take off a lab coat than
taking off your clothes.
3. Shoes.
Sandals and open shoes are not allowed in
chemical laboratories, Mechanical workshops
or when transferring cryogenic liquids.
4. Gloves.
When handling hazardous chemicals wear
rubber disposable gloves. Remove and dispose
of them before you leave the lab or answer the
telephone. When handling cryogenic liquids
wear loose fitting insulating gloves.

Chemicals
Keep quantities you are
working with to the minimum
required.
Transport with care, in proper
containers.
Always label containers
Always wash your hands after
handling chemicals. Do not
eat, drink or smoke in the labs.
Always dispose waste of
correctly.
Other safety
Gas Cylinder Electrical
Always use the correct, three wheeled There is always a risk when working with
trolleys, for transporting cylinders and
electricity, particularly supplies over
never move a cylinder with the
regulator fitted. 120volts.
Before using any electrical apparatus
Never use PTFE tape, grease or oil
check that has been tested for safety.
when fitting regulators. Any oil based
product in an oxygen regulator can Special care should be taken when using
cause an explosion.
portable tools, inspect the cables and
plugs before use.
Always use the correct gas regulator on
the cylinder. Never mix gas types the When working on live circuits or
regulators are designed to work with
equipment where authorised to do so,
the gas they are made for.
use supplies that are protected by
Always support the cylinder with RCCB’s.
chains or clamps, never leave it free
standing.
 Contractors
• Contractors involved in or around a covered
process must be informed of required PSM
elements.
• Contract work includes:
– Maintenance and repair
– Turn around
– Major renovations
– Specialty knowledge or services
– Does not include support services not involved
with the covered process, like laundry or
vending machine supply 36
 Emergency Action Plans (EAP)
• Must have EAP for entire facility
• EAP must have provisions for small releases
of HHCs
• Develop a Early Warning Method for
Releases
• Train on the Meaning of the Alarms
• Develop Emergency Evacuation Written
Plans, Evacuation Maps & Assembly Points

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 Incident Investigations
• Must be initiated ASAP, but within 48 hours
• Team must include:
– Person knowledgeable in the process involved
– Includes contractor if work of the contractor
involved
– Other persons with appropriate knowledge of the
covered process

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 Incident Investigation Report
• Report must be produced with the following:
– Date of incident
– Date of start of investigation
– Description of incident
– Factors contributing to incident
– Recommendations

• System must be established to promptly address

recommendations and findings of report
• Resolutions and corrective action must be
documented
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 Compliance Audit
• To ensure that PSM is effective, employers must
certify every 3 years that they have evaluated
compliance with the standard

• Must be completed by at least on person

knowledgeable in the process
• Report must be developed and documented
• Deficiency corrections must be documented
• Last two compliance audits must be kept on file
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 Tools for Additional PSM Assistance
• PSM Checklist
– www.oshainfo.gatech.edu
• OSHA Website
– www.osha.gov
• Chemical Safety Board Website
– www.csb.gov

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