1. BLR’s Safety Training Presentations
Process Safety Management of Highly Hazardous Chemicals 29 CFR (PSM)
BLR’s Safety Training Presentations
I. Background for the Trainer:
If the regulation ( ) is available, show it to the attendees.
II. Speaker’s Notes:
This standard is a significant improvement over traditional OSHA standards as it requires a proactive stance by employers.
This standard is usually referred to as the process safety management (PSM) standard.

2. Disasters That Led to Process Safety Management
Bhopal, India (1984)
2,000 deaths Isocyanate release
Pasadena, Tex. (1989)
23 deaths, 132 injuries Petroleum explosion
Cincinnati, Ohio (1990)
2 deaths Explosion
Sterlington, La. (1991)
8 deaths, 128 injuries Chemical release
I. Speaker’s Notes:
There are many catastrophes such as those mentioned, but these four in particular led to the establishment of the PSM standard.
All of these events were caused by the catastrophic release of hazardous materials.
If companies follow the implementation rules found in PSM, it is much less likely that another one of these catastrophes will occur.

3. Clean Air Act Amendments—1990
Required secretary of labor to promulgate a PSM standard
PSM standard must include a list of highly hazardous chemicals
Highly hazardous chemicals list must include: toxics, flammables, highly reactive and explosive materials
Required EPA to establish RMP standard
I. Speaker’s Notes:
This standard was not just a good idea, it was required under the Clean Air Act Amendments of 1990.
Because of this, OSHA had no choice but to promulgate the standard.
Required EPA to establish RMP standard.

4. Minimum Program Requirements
Written safety information
Workplace hazard assessment
Consult with employees
Establish a system to respond to findings
Periodic review of assessments and response
Written operating procedures
Safety training and operating information
I. Background for the Trainer:
If you have a current written program, show it to the class at this time.
II. Speaker’s Notes:
The safety information must be specific to elements within the process.
The hazard assessment must be formal, in writing, and look at all potential hazards within the process.
Operators within a process generally know the most about it.
Corrective action relative to findings is a very important factor in increasing process safety.
Conduct reviews or audits using various groups to ensure that all aspects of the process are evaluated.
These operating procedures may simply be existing standard operating procedures (SOPs).
This training must again be specific to the operation and not general in nature.

5. Minimum Program Requirements (cont.)
Appropriate information and training for contractors
Train and educate employees in emergency response
Establish a quality assurance program
Establish maintenance systems
Prestart-up safety reviews
Management of change
Incident investigation
I. Speaker’s Notes:
Contractors who are unfamiliar with the process can create significant additional hazards within the process.
The emergency response plan must be specific to chemical-related emergencies.
The entire process should be tied in to an overall quality assurance system.
Process equipment must be maintained to ensure system integrity.
Safety reviews are also important to the success of the program. An operation must be proven safe prior to start-up.
The PSM standard also requires that any change necessary in a regulated process be documented and verified as indeed necessary.
Any incident must be thoroughly investigated and corrective action initiated.

6. Application of PSM Companies that process highly hazardous materials
Flammable liquids and gases in quantities in excess of 10,000 pounds
I. Speaker’s Notes:
Petroleum refineries are specifically exempted from the PSM standard.
However, if your company processes a material on the chemical list in a single operation, above the threshold quantities listed in the standard, then PSM applies to you.
Also note that the flammable liquid and gas requirement is in pounds, not gallons. This can be somewhat confusing.

7. Initial Process Hazard Analysis Deadlines
25% complete by May 26, 1994
50% complete by May 26, 1995
75% complete by May 26, 1996
100% complete by May 26, 1997
I. Background for the Trainer:
If examples of process hazard analyses are available, provide them to the class.
II. Speaker’s Notes:
As you can see by the dates on this slide, implementation of the PSM standard was a tiered approach. All process hazard analyses (PHAs) must have been completed by 1997, unless of course a new process is implemented.

8. Process Safety Information
Toxicity
Permissible Exposure Limits
Physical Data
Reactivity Data
Corrosivity Data
Thermal and Chemical Stability Data
I. Background for the Trainer
If an applicable material safety data sheet (MSDS) is available, pass it out at this time or show it to the attendees.
II. Speaker’s Notes:
Toxicity deals with how the chemical affects humans.
Permissible exposure limits (PELs) are legal levels to which workers can be exposed to a hazardous substance.
Physical data include information such as boiling point, vapor pressure, pH, etc.
Reactivity is important relative to possible adverse reactions.
Is the chemical acidic or alkaline, and what is its strength (pH)?
Is the chemical stable under normal use, and is it unstable when heated?

9. Process Technology Block flow diagram or process flow diagram
Process chemistry
Maximum intended inventory
Upper and lower limits
Consequences of deviations
I. Speaker’s Notes:
All of this information is a “blueprint of hazards” relative to the process itself, not just the material in use.
All of this information should be documented in your written process documents.
How the material is processed and the consequences of deviating from standard procedure are of the utmost importance in disaster planning.

10. Information on Process Equipment
Materials of construction
Piping and instrument diagrams (PIDs)
Electrical classification
Relief system design
Ventilation system design
Design codes
Material and energy balances
Safety systems
I. Speaker’s Notes:
Depending on the materials of construction, there could be additional reactivity or integrity concerns.
The PIDs will identify where the material is transported during the process.
Electrical classifications are important because of the explosive issues related to the electrical equipment installations.
Pressure bleed-off is important in pressurized systems and can help prevent a release of chemicals or an explosion.
Ventilation systems are important to control routine chemical emissions, which will help protect the workers.
Part of the overall PSM plan should include installations that meet all applicable building codes.
It is important to know what the inherent safety systems in the process are and how they work.
All the information listed here should be available through design engineering documents.
By law, this information must be documented for processes that must comply with PSM.

11. Items the PHA Must Address
Hazards of the process
Identification of previous incidents
Engineering and administrative controls
Consequences of failure
Facility siting
Human factors
Qualitative evaluation of safety and health effects
I. Background for the Trainer:
If a PHA is available, show it to the attendees at this time and discuss how it complies with these requirements.
II. Speaker’s Notes:
Each individual hazard must be identified.
Safety specialists should review previous incidents to see if changes were made to help reduce the likelihood of recurrence.
Control methods that do not rely on the human factor are most successful (i.e., local exhaust vs. respiratory protection).
If there is a failure, what is the worst-case scenario, and what is it that is most likely to happen?
Facility siting is very important in the event of a release based on surrounding communities, landscape, etc.
The human interaction is important because the more human involvement, the greater the opportunity for error.

12. Operating Phases Initial start-up Normal operations
Temporary operations
Emergency shutdown
Emergency operations
Normal shutdown
Start-up following turnaround
I. Speaker’s Notes:
It is imperative that all levels of operation be included in the PHA.
It is easy to look at the normal operation, but plans must be made for emergency shutdowns and start-up following repair or turnaround.
When changes take place in any of these phases, additional analyses may be necessary.

13. Operating Limits Consequences of deviation
Steps required to correct or avoid deviation
I. Speaker’s Notes:
Preventing a recurrence or a catastrophic release is essential.
Any deviation should be followed up with corrective action.

14. Safety and Health Considerations
Properties and hazards of the chemicals
Precautions to prevent exposures
Control measures to be taken
Quality control for raw materials/control of inventory
Special or unique hazards
Safety systems and their functions
I. Background for the Trainer:
Many of the issues listed on the slide are dealt with in the company safety and health program. At this time, describe your company’s program to the class.
II. Speaker’s Notes:
Hazards of the chemicals are typically found in the product MSDS.
What control measures are necessary to prevent exposures?
Which types of control measures are required in the routine operation? Are they readily available?
Inventory must be stringently maintained because of the threshold quantity requirements of the PSM standard.
Some special or unique hazards include corrosivity, reactivity, radioactivity, etc.
If the system is already in place, it is not necessary to reinvent the wheel; simply use the safety system that works for your company.

15. Management of Change Technical basis for the proposed change
Impact of the change on safety and health
Modifications of the operating procedures
Necessary time period for the change
Authorization requirements for the change
I. Speaker’s Notes:
If a process is regulated under PSM, any minor or typical change that affects the process must be justified and documented.
Documentation must also verify whether the change will have an impact on safety and health.
No change should be implemented without the proper authorization of management officials.
The authorization should not just be a management signature. The official signing the change is responsible for verifying that the change has been adequately implemented.

16. Training Requirements
Initial training
Prior to work assignment
Waved for those already in a process
Refresher training
Every three years
Training documentation
I. Speaker’s Notes:
As is the case with almost any regulatory training, workers involved in the process must be trained on key components and hazards prior to initiating work.
Refresher training must also be provided at least every three years.
All training should be documented for compliance purposes.
Make certain that when a significant change is implemented in a process, that training is provided to affected employees.

17. Contractor Requirements
PSM applies to contractors in or adjacent to a process performing
Maintenance
Repair
Turnaround
Major renovation
Specialty work
PSM does not apply to incidental contractors
Food service
Laundry
Delivery, etc.
I. Speaker’s Notes:
Workers under contract and involved in the hazardous process must be trained and included in the PSM program just like a full-time employee.
However, if the contract work is incidental or peripheral, the PSM program does not apply.
The main concern is with individuals whose job has a direct impact on the process itself.

18. Incident Investigation Reports
Date of incident
Date investigation began
Description of the incident
Factors contributing to the incident
Recommendations resulting from the investigation
I. Speaker’s Notes:
The final element of an effective PSM program is incident investigation.
If the unfortunate incident does happen, the investigation is the key to providing lessons learned so that a recurrence can be avoided.
Most safety professionals can use their standard accident investigation skills to handle a PSM incident.
It is important to document the incident as well as all corrective action planned as a result of the incident.

19. Quiz Review Coming Up I. Speaker’s Notes:
The final element of an effective PSM program is incident investigation.
If the unfortunate incident does happen, the investigation is the key to providing lessons learned so that a recurrence can be avoided.
Most safety professionals can use their standard accident investigation skills to handle a PSM incident.
It is important to document the incident as well as all corrective action planned as a result of the incident.

20. Quiz
1. The PSM standard was drafted as a requirement of the Clean Air Act. True or False
2. The PSM program must include a list of highly hazardous chemicals. True or False
3. The initial start-up of a process is not included as an operating phase under the PSM standard. True or False
4. List three items that the process hazard analysis must address: ___________, __________, and __________.
5. PSM does not apply to contractors, regardless of the work they are doing. True or False
I. Background for the Trainer:
Hand out the quiz copies. Go over the questions verbally and have the employees write their answers on their quiz sheets.

21. Quiz (cont.)
6. The PSM standard applies to companies that either process highly _____________ materials or use _____________ liquids and gases in excess of 10,000 pounds.
7. Process safety information includes: ______________, _____________, and _____________.
8. Fault tree analysis is one form of an approved method of performing a process hazard analysis. True or False
9. A technical basis is not required to change a process covered by the PSM standard. True or False
10. Two types of training required by the PSM standard are _____________ and _________________.

22. Quiz Answers
1. True. The PSM standard was drafted as a result of the Clean Air Act Amendments of 1990.
2. True.
3. False. The initial start-up of a process is an operating phase that must be included.
4. The items that a process hazard analysis must address include hazards of the process, identification of previous accidents, engineering and administrative controls, consequences of failure, facility siting, human factors, and qualitative evaluation of S and H effects.
5. False. PSM does apply to contractors who work on or adjacent to a process.

23. Quiz Answers
1. True. The PSM standard was drafted as a result of the Clean Air Act Amendments of 1990.
2. True.
3. False. The initial start-up of a process is an operating phase that must be included.
4. The items that a process hazard analysis must address include hazards of the process, identification of previous accidents, engineering and administrative controls, consequences of failure, facility siting, human factors, and qualitative evaluation of S and H effects.
5. False. PSM does apply to contractors who work on or adjacent to a process.

24. Training
Completed