Process Safety Management Program

29 CFR 1910.119—Process Safety Management of Highly Hazardous Materials

29 CFR 1926.64—Process Safety Management of Highly Hazardous Materials

Scope/Application: This standard requires a Process Safety Management Program if chemicals are used in excess
of specific quantities listed in Appendix A, have 10,000 pounds or more of a flammable liquid or gas on site in one
location, or flammable liquids stored in atmospheric tanks that are kept below their normal boiling point.

Note:29 CFR 1926.64—Process Safety Management of Highly Hazardous Materials for construction is the same as
general industry.

The following standards are referenced in 29 CFR 1910.119—Process Safety Management of Highly Hazardous
Materials:
 29 CFR 1910.38—Emergency Action Plan
 29 CFR 1910.120—HAZWOPER
 29 CFR 1910.1020—Access to Employee Exposure and Medical Records

Note: 29 CFR 1910.119—Process Safety Management of Highly Hazardous Materials requires an Emergency
Action Plan that meets the requirements of 29 CFR 1910.38—Emergency Action Plan. The standard also references
that the hazardous waste and emergency response provisions of 29 CFR 1910.120—HAZWOPER may be applicable
to the organization. 29 CFR 1910.1020—Access to Employee Exposure and Medical Records requires medical
records to be retained for duration of employment plus 30 years and exposure records for 30 years.

Standard Requirements for 29 CFR 1910.119—Process Safety Management of Highly Hazardous Materials:
 Programs/Plans: Process Safety Management Program, Employee Participation Plan
 Procedures/Practices/Controls: Work practice procedures, operating procedures, incident reporting
procedures, hazard evaluation procedures, management of change procedures, employee participation
procedures, emergency response procedures
 Training: Initially, annually
 Inspections: Per manufacturer’s specifications, frequently
 Recordkeeping/Documentation: Programs, plan, training, inspections, injury log, compliance audits, hot
work permits, hazard analysis, management of change, process safety information, hazard analysis,
medical surveillance records, exposure records

Note: Please reference 29 CFR 1910.119—Process Safety Management of Highly Hazardous Materials to ensure
that all the standard requirements are being met.

Example Program: The following example program may be modified to be site-specific to the organization.

Process Safety Management Program

Purpose

The major objective of process safety management (PSM) of highly hazardous chemicals is to prevent unwanted
releases of hazardous chemicals especially into locations that could expose employees and others to serious hazards.
An effective process safety management program requires a systematic approach to evaluating the whole chemical
process. Using this approach, the process design, process technology, process changes, operational and maintenance
activities and procedures, non-routine activities and procedures, emergency preparedness plans and procedures,
training programs, and other elements that affect the process are all considered in the evaluation.

1
Process Safety Management Program

Note: This document is intended to be consistent with existing OSHA standards; therefore, if an area is considered by the reader to be inconsistent with a
standard, then the OSHA standard should be followed.
 Application

The various lines of defense that have been incorporated into the design and operation of the process to prevent or
mitigate the release of hazardous chemicals need to be evaluated and strengthened to ensure their effectiveness at
each level. Process safety management is the proactive identification, evaluation and mitigation or prevention of
chemical releases that could occur as a result of failures in processes, procedures or equipment.

The Process Safety Management Standard targets highly hazardous chemicals that have the potential to cause a
catastrophic incident. The purpose of the standard as a whole is to aid employers in their efforts to prevent or
mitigate episodic chemical releases that could lead to a catastrophe in the workplace and possibly in the surrounding
community.

To minimize our exposure to highly hazardous chemicals, we will use alternative avenues of decreasing the risks
associated with highly hazardous chemicals at our workplace. One of these methods is reducing inventory of the
highly hazardous chemical. This reduction in inventory results in reducing the risk or potential for a catastrophic
incident. Also, we have established more efficient inventory control by reducing, to below the established threshold,
the quantities of highly hazardous chemicals onsite. This reduction has been accomplished by ordering smaller
shipments and maintaining the minimum inventory necessary for efficient and safe operation and by dispersing
inventory to several locations onsite. Dispersing storage into locations so that a release in one location will not cause
a release in another location is also a practical way to reduce the risk or potential for catastrophic incidents. When
the above alternative measures are not feasible, a comprehensive PSM program will be implemented.

Process Safety Information

Hazards of the Chemicals Used in the Process—Complete and accurate written information concerning process
chemicals, process technology and process equipment is essential to an effective process safety management
program and to a process hazard analysis. The compiled information will be a necessary resource to a variety of
users, including the team performing the process hazard analysis as required by PSM; those developing the training
programs and the operating procedures; contractors whose employees will be working with the process; those
conducting the pre-startup reviews; as well as local emergency preparedness planners, insurance and enforcement
officials.

The information to be compiled about the chemicals, including process intermediates, may be comprehensive
enough for an accurate assessment of the fire and explosion characteristics, reactivity hazards, the safety and health
hazards to workers, and the corrosion and erosion effects on the process equipment and monitoring tools. Current
safety data sheet (SDS) information will be used to help meet this but will be supplemented with process chemistry
information, including runaway reaction and over-pressure hazards, if applicable.
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Technology of the Process—Process technology information will be a part of the process safety information package
and will include established criteria for maximum inventory levels for process chemicals; limits beyond which
would be considered upset conditions; and a qualitative estimate of the consequences or results of deviation that
could occur if operating beyond the established process limits.
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Equipment in the Process—Piping and instrument diagrams (P&IDs) are appropriate diagrams to show some of the
above details as well as display the information for the piping designer and engineering staff. The P&IDs are to be
used to describe the relationships between equipment and instrumentation as well as other relevant information that
will enhance clarity. The information pertaining to process equipment design will be documented.
2
Process Safety Management Program

Note: This document is intended to be consistent with existing OSHA standards; therefore, if an area is considered by the reader to be inconsistent with a
standard, then the OSHA standard should be followed.
 _____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Employee Involvement—Under our existing safety and health program, we have established methods to keep
employees informed about relevant safety and health issues to meet our obligations under PSM.

Process Hazard Analysis—A process hazard analysis (PHA), or evaluation, is one of the most important elements of
the process safety management program. A PHA is an organized and systematic effort to identify and analyze the
significance of potential hazards associated with the processing or handling of highly hazardous chemicals. A PHA
provides information that will assist employers and employees in making decisions for improving safety and
reducing the consequences of unwanted or unplanned releases of hazardous chemicals.

A PHA analyzes potential causes and consequences of fires, explosions, releases of toxic or flammable chemicals,
and major spills of hazardous chemicals. The PHA focuses on equipment, instrumentation, utilities, human actions
(routine and non-routine), and external factors that might affect the process.

We use a generic PHA, evolved from a checklist or what-if questions, that has been developed and effectively used
to reflect our process.
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Operating Procedures—Operating procedures describe tasks to be performed, data to be recorded, operating

conditions to be maintained, samples to be collected, and safety and health precautions to be taken. The procedures
need to be technically accurate, understandable to employees, and revised periodically to ensure that they reflect
current operations. The process safety information helps to ensure that the operating procedures and practices are
consistent with the known hazards of the chemicals in the process and that the operating parameters are correct.
Operating procedures will be reviewed by engineering staff and operating personnel to ensure their accuracy and
that they provide practical instructions on how to actually carry out job duties safely. We also certify annually that
all operating procedures are current and accurate.

Operating procedures provide specific instructions or details on what steps are to be taken or followed in carrying
out the stated procedures. The specific instructions include the applicable safety precautions and appropriate
information on safety implications.

Operating procedures and instructions are to be used for training operating personnel. The operating procedures are
viewed as the standard operating practices (SOPs) for operations. Control room personnel and operating staff, in
general, need to have a full understanding of operating procedures. Operating procedures need to be changed when
there is a change in the process.

Training will include instruction on how to handle upset conditions as well as what operating personnel are to do in
emergencies such as pump seal failures or pipeline ruptures. Communication among operating personnel and
workers within the process area performing non-routine tasks must be maintained. The hazards of the tasks are to be
conveyed to operating personnel in accordance with established procedures and to those performing the actual tasks.
When the work is completed, operating personnel will be informed to provide closure on the job.
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Employee Training—All employees, including maintenance and contractor employees involved with highly
hazardous chemicals, need to fully understand the safety and health hazards of the chemicals and processes they
3
Process Safety Management Program

Note: This document is intended to be consistent with existing OSHA standards; therefore, if an area is considered by the reader to be inconsistent with a
standard, then the OSHA standard should be followed.
 work with so they can protect themselves, their fellow employees and the citizens of nearby communities. Training
conducted in compliance with the OSHA Hazard Communication Standard informs employees about the chemicals
they work with and familiarize them with reading and understanding SDSs. However, additional training in the
following subjects such as operating procedures and safe work practices, emergency evacuation and response, safety
procedures, routine and non-routine work authorization activities, and other areas pertinent to process safety and
health will also be covered in our training program.
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Contractors—Contract employees must perform their work safely. Considering that contractors often perform very
specialized and potentially hazardous tasks, such as confined space entry activities and non-routine repair activities,
their work must be controlled while they are on or near a process covered by PSM. A permit system or work
authorization system for these activities will be used. The use of a work authorization system keeps us informed of
contract employee activities.
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Pre-Startup Safety Review—The initial startup procedures and normal operating procedures has been fully evaluated
to ensure a safe transfer into the normal operating mode.
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Mechanical Integrity of Equipment—We have implemented a mechanical integrity program to ensure the continued
integrity of process equipment. Elements of our mechanical integrity program includes identifying and categorizing
equipment and instrumentation, inspections and tests and their frequency; maintenance procedures; training of
maintenance personnel; criteria for acceptable test results; documentation of test and inspection results; and
documentation of manufacturer recommendations for equipment and instrumentation.
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Process Defenses—The first line of defense is to operate and maintain the process as designed and to contain the
chemicals. This is backed up by the second line of defense that is to control the released chemicals through venting
to scrubbers or flares, or to surge or overflow tanks designed to receive such chemicals. This also would include
fixed fire protection systems like sprinklers, water spray, or deluge systems, monitor guns, dikes, designed drainage
systems, and other systems to control or mitigate hazardous chemicals once an unwanted release occurs.
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Inspection and Testing—The mean time to failure of various instrumentation and equipment parts would be known
from the manufacturer’s data or the employer’s experience with the parts, which then influence inspection and
testing frequency and associated procedures. Also, applicable codes and standards—such as the National Board
Inspection Code, or those from the American Society for Testing and Materials, American Petroleum Institute,
National Fire Protection Association, American National Standards Institute, American Society of Mechanical
Engineers, and other groups—provide information to help establish an effective testing and inspection frequency, as
well as appropriate methodologies.
_____________________________________________________________________________________________

4
Process Safety Management Program

Note: This document is intended to be consistent with existing OSHA standards; therefore, if an area is considered by the reader to be inconsistent with a
standard, then the OSHA standard should be followed.
 _____________________________________________________________________________________________
_____________________________________________________________________________________________

Quality Assurance—A quality assurance system helps ensure the use of proper materials of construction, the proper
fabrication and inspection procedures, and appropriate installation procedures that recognize field installation
concerns. The quality assurance program is an essential part of our mechanical integrity program and will help
maintain the primary and secondary lines of defense designed into the process to prevent unwanted chemical
releases or to control or mitigate a release.

Equipment installation jobs need to be properly inspected in the field for use of proper materials and procedures and
to ensure that qualified craft workers do the job. The use of appropriate gaskets, packing, bolts, valves, lubricants
and welding rods may be verified in the field. Also, procedures for installing safety devices need to be verified, such
as the torque on the bolts on rupture disc installations, uniform torque on flange bolts, and proper installation of
pump seals. If the quality of parts is a problem, it may be appropriate for the employer to conduct audits of the
equipment supplier's facilities to better ensure proper purchases of required equipment suitable for intended service.
Any changes in equipment that may become necessary will need to be reviewed for management of change
procedures.
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Non-routine Work Authorizations—Non-routine work conducted in process areas must be controlled in a consistent
manner. The hazards identified involving the work to be accomplished must be communicated to those doing the
work and to those operating personnel whose work could affect the safety of the process. A work authorization
notice or permit must follow a procedure that describes the steps the maintenance supervisor, contractor
representative or other person needs to follow to obtain the necessary clearance to start the job. The work
authorization procedures must reference and coordinate, as applicable, lockout/tagout procedures, line breaking
procedures, confined space entry procedures and hot work authorizations. This procedure also must provide clear
steps to follow once the job is completed to provide closure for those that need to know the job is now completed
and that equipment can be returned to normal.

Managing Change—To properly manage changes to process chemicals, technology, equipment and facilities, one
must define what is meant by change. In the Process Safety Management Standard, change includes all
modifications to equipment, procedures, raw materials and processing conditions other than “replacement in kind.”
These changes must be properly managed by identifying and reviewing them prior to implementing them.

Changes in process technology can result from changes in production rates, raw materials, experimentation,
equipment unavailability, new equipment, new product development, change in catalysts, and changes in operating
conditions to improve yield or quality. Equipment changes can be in materials of construction, equipment
specifications, piping prearrangements, experimental equipment, computer program revisions, and alarms and
interlocks.

We use a change form that includes a description and the purpose of the change, the technical basis for the change,
safety and health considerations, documentation of changes for the operating procedures, maintenance procedures,
inspection and testing, P&IDs, electrical classification, training and communications, pre-startup inspection,
duration (if a temporary change), approvals, and authorization.
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Incident Investigation—We will investigate all incidents that occur in our facilities. The report, its findings and
recommendations will be shared with those who can benefit from the information. The cooperation of employees is
5
Process Safety Management Program

Note: This document is intended to be consistent with existing OSHA standards; therefore, if an area is considered by the reader to be inconsistent with a
standard, then the OSHA standard should be followed.
 essential to an effective incident investigation. The focus of the investigation will be to obtain facts and not to place
blame. The investigative process will deal with all involved individuals in a fair, open and consistent manner.
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Emergency Preparedness—Emergency preparedness is our third line of defense that will be relied on along with the
second line of defense, which is to control the release of chemical. Control releases and emergency preparedness
will take place when the first line of defense to operate and maintain the process and contain the chemicals fails to
stop the release.

Our employees will follow our emergency action plan that will facilitate the prompt evacuation of employees when
there is an unwanted release of a highly hazardous chemical.
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Compliance Audits—An audit is a technique used to gather sufficient facts and information, including statistical
information, to verify compliance with standards. Our audit includes an evaluation of the design and effectiveness of
the process safety management system and a field inspection of the safety and health conditions and practices to
verify that the systems are effectively implemented.
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

Evaluation and Corrective Action—Any deficiency identified in the audit will be addressed, the corrective action to
be taken is noted, and the responsible audit person will be documented.
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

6
Process Safety Management Program

Note: This document is intended to be consistent with existing OSHA standards; therefore, if an area is considered by the reader to be inconsistent with a
standard, then the OSHA standard should be followed.
 Process Safety Management—Management of Change
CHANGE INFORMATION Date:
Originator:
Proposed Date of Change:
Permanent Temporary Location of change:

Description of change:

Basis for change:

NATURE OF THE CHANGES List Items

Type of Change: Safety Environmental
Health Equipment Removal
Alarm Chemical
Job Procedure Other
Task Procedure

PREMODIFICATION
Applicable N/A Initials List Items to check

BEFORE STARTUP:
Applicable N/A Initials List Items to check

Approvals: Name Date

Originator: _________________________________ _________________________________
First Reviewer: _________________________________ _________________________________
Manager: _________________________________ _________________________________

7
Process Safety Management Program

Note: This document is intended to be consistent with existing OSHA standards; therefore, if an area is considered by the reader to be inconsistent with a
standard, then the OSHA standard should be followed.
 Free Outreach Resources:
Safety and Health Programs and Plans (i.e., Example Programs to be Made Site-Specific)
A - Z Safety and Health Topics (i.e., Learn More About Safety and Health Topics)
Which Standards Apply? (Identify the Standards Applicable to Your Worksite)
Safety and Health Presentations (Downloadable Presentations to be Made Site-Specific)
OSH Training Calendar (i.e., Register for Webinars, In-Person Classroom Training, Virtual Events)
Streaming Video Services (On-Demand Training)
Request Outreach Services (i.e., Request Training, Booths, Guest Speaker)
AskOSH (Interpretations)

8
Process Safety Management Program

Note: This document is intended to be consistent with existing OSHA standards; therefore, if an area is considered by the reader to be inconsistent with a
standard, then the OSHA standard should be followed.
 9
Process Safety Management Program

Note: This document is intended to be consistent with existing OSHA standards; therefore, if an area is considered by the reader to be inconsistent with a
standard, then the OSHA standard should be followed.