Process Safety Management

of Highly Hazardous &

Explosive Chemicals

29CFR1910.119
Simple Keys to Compliance
Objectives

 Define what is PSM and who is covered

by the standard
 List the elements of the PSM standard
 Locate additional resources

2
What Is Process Safety
Management?
 PSM:
 Addressesthe management of Highly
Hazardous Chemicals (HHC)

 Integrates
 Technology
 OperatingProcedures
 Standard management protocols

3
Why Did OSHA Develop PSM?

 Past Disasters
 Current Disasters
 Perceived Weakness in PSM
Program

4
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

5
Why Did OSHA Develop PSM?

In 1991, OSHA and

EPA respectively,
Released the
Standards, PSM &
RMP that Applies to
Those Companies
that are Affected by
The Standards.

6
Why Did OSHA Develop PSM?
Process Safety
Management is a
regulation, promulgated
by OSHA, intended to
prevent an incident like
the 1984 Bhopal Disaster

And…to Prevent Release

of:
 Toxic,
 Reactive,
 Flammable, or
 Explosive chemicals

7
Not Only PSM, But RMP

A great many industrial

facilities must comply
with OSHA's Process
Safety Management
(PSM) regulations as
well as the CAA 112(r)
EPA Risk
Management Program
(RMP) regulations
(Title 40 CFR Part 68).

8
PSM vs. RMP - What’s the
Difference?
 PSM - Like HAZCOM  RMP-Like Sara Title III
 Protects the  Protects the
Workforce Community
 Protects the General
 Protects Contractors Public Around the
 Protects Visitors to Facility
the Facility  Protects Adjacent
 Basically Protects the Facilities Such as
Workplace Schools & Hospitals

9
The Standard Was Promulgated
in 1991 - Is it Working?

10
The Standard Was Promulgated
in 1991 - Is it Working?
 BP Products Texas
City - March 2005
 15 Workers Killed
 170 Injured
 Major Property
Damage
 $50.6 Million in Fines

11
The Elements of the PSM
Standard
 Application  Process Hazard
 Exclusions Analysis
 Definitions  Management of Change
 Employee Participation  Operating Procedures
 Hazards of the Process  Safe Work Practices
 Toxicity  Training
 Technology of the  Contractor
Process Management
 Equipment in the  Emergency Planning &
Process Response
 Mechanical Integrity  Incident Investigation
 Inspection & Testing  Compliance Audits
 Quality Assurance  Trade Secrets
12
The Elements of the PSM
Standard
 Application  Process Hazard
 Exclusions Analysis
 Definitions  Management of Change
 Employee Participation  Operating Procedures
 Hazards of the Process  Safe Work Practices
 Toxicity  Training
 Technology of the  Contractor
Process Management
 Equipment in the  Emergency Planning &
Process Response
 Mechanical  Incident Investigation
Integrity  Compliance Audits
 Inspection & Testing  Trade Secrets
13
The Elements of the PSM
Standard
 Application  Process Hazard
 Exclusions Analysis
 Definitions  Management of
 Employee Participation Change
 Hazards of the Process  Operating Procedures
 Toxicity  Safe Work Practices
 Technology of the  Training
Process  Contractor
 Equipment in the Management
Process  Emergency Planning &
 Mechanical Integrity Response
 Inspection & Testing  Incident Investigation
 Quality Assurance  Compliance Audits
 Trade Secrets 14
The Elements of the PSM
Standard  Process Hazard
 Application Analysis
 Exclusions  Management of
Change
 Definitions
 Employee Participation  Operating
 Hazards of the Process Procedures
 Safe Work Practices
 Toxicity
 Training
 Technology of the
Process  Contractor
 Equipment in the Management
Process  Emergency Planning &
 Mechanical Integrity Response
 Incident Investigation
 Inspection & Testing
 Compliance Audits
 Quality Assurance
 Trade Secrets 15
The Elements of the PSM
Standard
 Application  Process Hazard
 Exclusions Analysis
 Definitions  Management of
 Employee Participation Change
 Operating Procedures
 Hazards of the Process
 Safe Work Practices
 Toxicity
 Technology of the  Training
Process  Contractor
 Equipment in the Management
Process  Emergency Planning &
 Mechanical Integrity Response
 Inspection & Testing  Incident Investigation
 Quality Assurance  Compliance Audits
 Trade Secrets 16
The Elements of the PSM
Standard  Process Hazard
 Application Analysis
 Exclusions  Management of
Change
 Definitions
 Operating Procedures
 Employee
 Safe Work Practices
Participation
 Training
 Hazards of the Process
 Contractor
 Toxicity Management
 Technology of the  Emergency Planning &
Process Response
 Equipment in the Process  Incident Investigation
 Mechanical Integrity  Compliance Audits
 Inspection & Testing  Trade Secrets
 Quality Assurance
17
The Elements of the PSM
Standard  Process Hazard
 Application Analysis
 Exclusions  Management of
Change
 Definitions
 Operating Procedures
 Employee Participation
 Safe Work Practices
 Hazards of the Process
 Training
 Toxicity
 Technology of the  Contractor
Process Management
 Equipment in the Process  Emergency Planning &
 Mechanical Integrity
Response
 Incident Investigation
 Inspection & Testing
 Compliance Audits
 Quality Assurance
 Trade Secrets
18
The Elements of the PSM
Standard  Process Hazard
 Application Analysis
 Exclusions  Management of
Change
 Definitions
 Operating Procedures
 Employee Participation
 Hazards of the Process  Pre-Start up Safety
 Toxicity Review
 Hot Work Permit
 Technology of the
Process  Safe Work Practices
 Equipment in the Process  Training
 Mechanical Integrity  Contractor
 Inspection & Testing
Management
 Emergency Planning &
 Quality Assurance
Response
19
The Elements of the PSM
Standard  Process Hazard
 Application Analysis
 Exclusions  Management of
Change
 Definitions
 Operating Procedures
 Employee Participation
 Pre-Start up Safety
 Hazards of the Process Review
 Toxicity
 Hot Work Permit
 Technology of the
Process  Safe Work Practices
 Equipment in the Process  Training
 Mechanical Integrity  Contractor
Management
 Inspection & Testing
 Emergency Planning &
 Quality Assurance Response
20
The Elements of the PSM
Standard  Process Hazard
 Application Analysis
 Exclusions  Management of
Change
 Definitions
 Operating Procedures
 Employee Participation
 Pre-Start up Safety
 Hazards of the Process Review
 Toxicity  Hot Work Permit
 Technology of the  Safe Work Practices
Process
 Training
 Equipment in the Process
 Contractor
 Mechanical Integrity
Management
 Inspection & Testing
 Emergency
 Quality Assurance
Planning &
Response 21
The Elements of the PSM
Standard  Process Hazard
 Application Analysis
 Exclusions  Management of
Change
 Definitions
 Operating Procedures
 Employee Participation
 Pre-Start up Safety
 Hazards of the Process Review
 Toxicity  Hot Work Permit
 Technology of the  Safe Work Practices
Process
 Training
 Equipment in the  Contractor
Process Management
 Mechanical Integrity  Emergency Planning
 Inspection & Testing & Response
 Quality Assurance
22
The Elements of the PSM
Standard  Process Hazard
 Application Analysis
 Exclusions  Management of
Change
 Definitions
 Operating Procedures
 Employee Participation
 Pre-Start up Safety
 Hazards of the Process Review
 Toxicity  Hot Work Permit
 Technology of the  Safe Work Practices
Process
 Training
 Equipment in the
 Contractor
Process
Management
 Mechanical Integrity
 Emergency Planning
 Inspection & Testing & Response
 Quality Assurance
23
The Elements of the PSM
Standard  Process Hazard
 Application Analysis
 Exclusions  Management of
Change
 Definitions
 Operating Procedures
 Employee Participation
 Pre-Start up Safety
 Hazards of the Process Review
 Toxicity  Hot Work Permit
 Technology of the  Safe Work Practices
Process
 Training
 Equipment in the
 Contractor
Process
Management
 Mechanical Integrity
 Emergency Planning
 Inspection & Testing & Response
 Quality Assurance
24
 The Elements of the PSM
Standard
Let’s Explore Some of the Elements…

25
Application

1910.119(a)

26
What Facilities are Covered
 Those Who Use Chemicals in Appendix A: A List of
highly hazardous chemicals, toxics and reactive
(Mandatory). Contains a listing of toxic and reactive
highly hazardous chemicals which present a potential
for a catastrophic event at or above the threshold
quantity

 Examples

Chemical Threshold Quantity (TQ)

 Anhydrous Ammonia 10,000 lbs
 Chlorine 1,500 lbs

27
What Facilities are Covered

 A process which
involves a
flammable liquid or
gas (as defined in
1910.1200(c) of this
part) on-site in one
location, in a
quantity of 10,000
pounds (4535.9 kg)
or more

28
What Facilities are Covered
 Important Interpretation: 2007 - 06/11/2007 - OSHA
defines "on-site in one location" for Process Safety
Management of Highly Hazardous Chemicals
standard

OSHA interprets "on-site in one location" to mean that

the standard applies when a threshold quantity of a
highly hazardous chemical (HHC) exists within an
area under the control of an employer or group of
affiliated employers. It also applies to any group of
vessels that are interconnected, or in separate
vessels that are close enough in proximity that the
HHC could be involved in a potential catastrophic
release.
29
 What Facilities are Covered

Affect of the “Meer” Decision:

MEER ruling and the MEER Memorandum addressed in the

Secretary's letter, OSHA's enforcement policy that the Agency
would not cite employers for violations of 1910.119 where stored
flammable liquids in atmospheric tanks were connected to a
process, unless the process outside of the amount in storage
contained more than 10,000 pounds of the substance

30
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

31
 Exclusions

1910.119(a)(1)(ii)(A)

32
There are Exclusions
 An employer is exempt from the requirements of PSM
when:
 A threshold quantity of flammable liquids is stored in
atmospheric tanks or transferred without the benefit of
chilling or refrigeration
 Hydrocarbon fuels used solely for workplace
consumption as a fuel (e.g., propane used for comfort
heating, gasoline for vehicle refueling),
 If such fuels are not a part of a process containing
another highly hazardous chemical covered by this
standard

33
There are Exclusions

 Retail facilities;

 Oil or gas well drilling or

servicing operations; or,

 Normally unoccupied
remote facilities

34
Employee Participation

1910.119(c)

35
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!

36
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
37
Hazards of the Process

1910.119(d)(1)

38
The Requirements of the Standard
- Hazard Determination
Determine:

 Chemicals in Your Process

 Process Chemistry
 Quantity of Chemicals in lbs
 Compare to Appendix A List with
Threshold Quantities (TQ’s)

39
Toxicity Information

1910.119(d)(1)(i)

40
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
41
Technology of the Process

1910.119(d)(2)

42
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
43
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
44
Equipment in the Process

1910.119(d)(3)

45
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

46
Mechanical Integrity

1910.119(j)

47
The Requirements of the Standard
- Process Equipment
Mechanical Integrity
Certificates
Must be Obtained for Each
Element of the Process
Must be Marked with
Numbering System that
Follows Form

48
Process Hazard Analysis (PHA)

1910.119(e)

49
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

50
 Process Hazard Analysis
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

51
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
52
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
53
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

54
Operating Procedures
 Develop and implement written
operating procedures that are clear
instructions for all expected phases of
operations.
 AKA – Standard Operating Procedures
(SOPs)
 Must cover:
 Operation phase
 Operational limits
 Safety & health considerations
55
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 56
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.

57
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
 Confinedspace entry
 Opening processes, piping or equipment

SWPs are for:

• Operators • Lab personnel
• Maintenance • Or other support
personnel personnel
• Contractors
58
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
59
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 60
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
61
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
62
 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 63
 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
64
Trade Secrets
 Employers must make all necessary
information required to comply with
PSM, regardless of trade secrets,
available to persons involved in
developing or creating:
 Compiling process safety information
 PHAs
 SOPs
 Incident
investigations
 Emergency planning and response
 Compliance audits
 Confidentiality agreements are allowed 65
BP Texas City Refinery Case
Study in PSM
 The third largest petroleum refinery in the
United States with a refining capacity of
475,000 barrels of crude per day.
 Located on a 1,200-acre facility in Texas City,
Texas southeast of Houston in Galveston
County.
 1,200 permanent BP employees and
hundreds of additional contractors at the
facility

66
Anatomy of a Disaster- BP Texas
City
 Things to Think About:
 What went wrong?
 What went right?
 What could/should have been done to
prevent this disaster?

67
BP Texas City Refinery Case
Study in PSM
Fact Sheet on BP 2009 Monitoring Inspection

The U.S. Department of Labor's Occupational Safety and Health Administration (OSHA)
has proposed $87,430,000 in propose penalties against BP Products North America, Inc.
for 709 alleged failures to comply with the 2005 settlement agreement and citations, and
violations of safety and health standards identified during the agency's inspection of the
corporation's refinery in Texas City, TX (BPTCR). The inspection of the refinery was
conducted from May through October 2009.

BP Texas City Refinery (BPTCR):

The third largest petroleum refinery in the United States with a refining capacity
of 475,000 barrels of crude per day.

Located on a 1,200-acre facility in Texas City, Texas southeast of Houston in

Galveston County.

1,200 permanent BP employees and hundreds of additional contractors at the

facility

Prior History at BPTCR:

On March 23, 2005, an explosion and fire in the Isomerization Unit of the BP
Texas City Refinery (BPTCR) resulted in the death of 15 contractor employees
and injury of at least 170 other BP employees and contractors.

OSHA initiated safety and health inspections into the March 2005 incident
and issued citations and fines totaling over $21 million, the highest
penalty that OSHA had ever issued.

The Report of the BP U.S. Refineries Independent Safety Review Panel

(aka Baker Report) issued in January 2007 identified a number of
systemic process safety issues at BP refineries in the U.S.

March 2007, U.S. Chemical Safety and Hazard Investigation Board

(CSB) released its report Refinery Explosion and Fire (15 Killed, 180
Injured). CSB found, "The Texas City disaster was caused by
organizational and safety deficiencies at all levels of the BP Corporation".

OSHA has conducted 17 separate inspections at the refinery in the last 4 years.

Prior to the 2005 incident, two employees of BPTCR died due to a

breakdown of the company’s lockout and tagout program.

Since the 2005 incident, four more fatal incidents have occurred at the
facility, involving one BPTCR employee and 3 contractors.

2005 Settlement Agreement

As a result of the March 2005 explosion and subsequent inspection, BP entered

into a settlement agreement with OSHA in September 2005

BP agreed to pay $21 million in penalties

68
JORDAN BARAB
Deputy
Assistant Secretary
After BP-Texas City, Have We Learned Anything?
 Now, in spite of your efforts, we have to acknowledge
that something is desperately wrong. The status quo isn't
working.
 In the past three months alone, 58 workers have died in
explosions, fires and collapses at refineries, coal mines,
an oil drilling rig, and a natural-gas-fired power plant
construction site.
 OSHA is particularly concerned about the recent number
of serious incidents at refineries that have scalded,
burned or struck down your fellow workers. We are
tracking these catastrophes and looking for trends --
including problems resulting from aging facilities. Since
the BP Texas City explosion in 2005, OSHA has counted
over 20 serious incidents in refineries across the country.
69
There is Much More to PSM

Now, The OSHA PSM National Emphasis

Program for Refineries & Chemical
Facilities & Severe Violator Enforcement
Program (SVEP)

70
OSHA National Emphasis
Program (NEP) for Refineries &
Chemical Facilities
 Petroleum
Refineries NEP
 Issued August
2009
 Chemical Facilities
NEP
 Issued July 2010

71
Typical Standards Cited

 1910.119 PSM – 249 violations

 1910.147 Lock and Tag - 20
 1910.120 Hazwoper - 19
 1910.1200 Hazcom - 12
 1910.146 Confined Space - 11
 5A.001 General Duty - 9
 1910.307 Hazardous Locations - 7

72
Most Frequent NEP PSM Citations
1910.119
 (f)(1) Operating procedures…………..38
 (d)(3) PSI pertaining to equipment ….28
 (e)(3) PHA specific criteria……………26
 (j)(4) MI Inspection & Testing ………..21
 (e)(5) PHA recommendation ...………12
 (l)(1) MOC implementation …………..12

73
Severe Violator Enforcement
Program (SVEP)
 This Instruction establishes enforcement
policies and procedures for OSHA's Severe
Violator Enforcement Program (SVEP), which
concentrates resources on inspecting
employers who have demonstrated
indifference to their OSH Act obligations by
willful, repeated, or failure-to-abate violations.
This Instruction replaces OSHA's Enhanced
Enforcement Program (EEP).

74
Severe Violator Enforcement
Program (SVEP)
References:

 OSHA Instruction CPL 03-00-010, Petroleum

Refinery Process Safety Management
National Emphasis Program, August 18, 2009

75
Severe Violator Enforcement
Program (SVEP)
 Enhanced Follow-up Inspections
 Nationwide Inspections of Related
Workplaces/Worksites
 Increased Company Awareness of OSHA
Enforcement
 Enhanced Settlement Provisions
 Federal Court Enforcement under Section
11(b) of the OSH Act

Bottom Line: OSHA is Serious About

Compliance and Enforcement of PSM
76
EPA Risk Management Plans
(RMP) Basics
CAA 112(r)

77
One More Thing to Discuss…
EPA Risk Management Plans
(RMP)
 Many Times Companies Who Must Comply
with PSM, must also Comply with the
Requirements of EPA Risk Management
Plans (RMP)
 The RMP Standard was to be a Mirror of the
PSM Standard…Didn’t happen!
 Remember…PSM Protects the Workforce,
RMP Protects the Community

78
EPA RMP

 Basic Requirements
 Executive summary
 Registration
 Off-site consequence analysis
 Five-year accident history
 Emergency response plan
 Prevention program summary information
 Certification

79
 Release
All Public Facilities Plume
in this Release
Plume Must be
Identified &
Surveyed
80
OSHA PSM Summary
 PSM is a Comprehensive, Difficult Standard
 Although it was Promulgated in 1991,
Catastrophes Continue to Occur
 Recognizing these Facts, OSHA has
Developed a National Emphasis Program for
Refineries and Chemical Manufacturers
 More Emphasis Planned for all PSM Sites
 There is Much More Work to be Done…
 RMP Must Also be Considered for Many
Facilities

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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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PSM Checklist
Use this checklist to help determine employer compliance with the Process Safety Management Standard issued by the
Occupational Safety and Health Administration. Please note that the checklist does not include all of the standard’s
requirements and does not reflect all OSHA letters of interpretation or compliance directives in particular
situations.

There are 3 elements to a review of a PSM program:

1. Documentation review – examination of the documentation of the programs required by the standard.
2. Field Inspection & Verification – examination of the physical covered process; its equipment, piping,
instrumentation, procedures, and operation.
3. Interviews – discussions with employees and contractors to determine if the implemented program matches the
program outlined in the documentation.

In order to gather the information needed to audit a PSM program the following questions need to be asked for each PSM
program element

 Who  What  When  Where  Why  How

 Who – Who is responsible for developing and implementing each of the program elements?
 What – What are the requirements and contents of each program element?
 When – When are the required actions for each element completed and when were they required to be
completed?
 Where – Where have actions been implemented or changed?
 Why – Why have the implementation decisions and priorities been made as recorded in the documentation?
 How – How is the program implemented and how is the program’s effectiveness evaluated and improved?

An essential part of verifying program implementation is to audit the flow of information and activities among the
elements. When information in one element is changed or when action takes place in one element that affects other
elements, an auditor/reviewer should examine a sample of the related elements to see if the appropriate changes and
followup actions have taken place.

The following example demonstrates the interrelationship among the elements:

During a routine inspection of equipment (Mechanical Integrity), the maintenance worker discovers a valve that no
longer meets the applicable code and must be changed. Because the type of valve is no longer made, a different type of
valve must be selected and installed (Management of Change). The type of valve selected may mandate different steps
for the operators (Operating Procedures) who will require training and verification in the new procedures (Training).
The rationale for selecting the type of valve must be made available for review by employees and their representatives 83
(Employee Participation).
For More Information
www.psmtraining.com

www.oshainfo.gatech.edu

www.pe.gatech.edu/safety

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Contact Information
 Michelle Dunham, MSPH, MSM
 michelle.dunham@gtri.gatech.edu
 404-407-8284
 Bob Hendry
 bob.hendry@gtri.gatech.edu
 Art Wickman, CIH
 art.wickman@gtri.gatech.edu

 Georgia Tech Occupational Safety & Health Program

 www.oshainfo.gatech.edu
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Funding
Funding for:
Process Safety Management of Highly
Hazardous and Explosive Chemicals:
Simple Keys to Compliance
By special funding from the Occupational
Safety and Health Administration

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