1. Elements of Process Safety Management
A Review of the 14 Elements

2. A Way of Looking at the 14 Elements of PSM
Elements Concerned with Evaluation of Progress Towards Goals
Process Hazards Analysis
Pre-startup Safety Review
Management of Change
Incident Investigation
Compliance Audits
Trade Secrets
Elements Concerned with Achieving Safety Goals
Employee Participation
Process Safety Information
Operating Procedures
Training
Contractors
Mechanical Integrity
Hot Work
Emergency Planning

3. Employee Participation
Purpose
One of the Most Essential Elements for a Successful Program
People at Working Level Know Most about Operations
Serves as a Sanity Check re: Common Sense Problems
Couples with All Other Elements and Ensures Successful Implementation
What is Required, Employers Must
Have a Written Plan to Ensure Employee Participation
Involve Employees in Conduct and Implementation of PHAs & Other Elements of PSM
Provide Access to PHAs and all other Information Required to Be Developed by PSM Rule

4. Process Safety Information
Purpose - Ensure Personnel Have Access to Information Needed Work Safely and Efficiently
What is Required
HHC Hazard Information – MSDS + other Data Needed to Comply
Info on Technology (PFDs, Process Chemistry, Max Inventory, Safe Upper and Lower Limits, Evaluation of Consequences of Deviations)
Info on Equipment (Materials, P&IDs, Electrical Class, Relief System Design and, Design Codes and Standards, Material and Energy Balances, Safety Systems, e.g. Interlocks, etc.)
Documentation Equipment Complies with RAGAGEP
For Equipment Designed in Accordance with Codes and Standards no Longer in Use, Must Document Is Designed, Maintained, Inspected, Tested, and Operating in Safe Manner

5. Process Hazards Analysis
Purpose
Identify Hazards and Provide a Preliminary Estimate as to Seriousness
Correct Problems (Design Changes or Modifications, Adding Safety Features, Improving Procedures and Training)
What is Required
Process Hazard Analysis be Done Using – What If, Checklist, What-If/Checklist, HAZOP, FMEA, Fault Tree Analysis, etc.
PHA will Address –
Hazards & Identification of Previous Potentially Catastrophic Incidents
Engr. and Admin. Controls Applicable, Consequences fo Failure of Engr. and Admin. Controls
Facility Siting, Human Factors
Qualitative Evaluation Of Potential Safety and Health Effects if Controls Fail
Team – Engr. and Process Operations, One Member Specific to Process Evaluated, One Member Knowledgeable in PHA Process
Employer Must
Establish System to Address Findings
Update and Revalidate Every Five Years

6. Operating Procedures Purpose is to Assure Safe and Reliable Operations
What is Required – Employer Must:
Address Safe Actions During Initial Startup, Normal Operations, Temporary Operations, Emergency Shutdown, Emergency Operations, Normal Shutdown, Startup Following Turnaround or Emergency Shutdown
Identify Operating Limits – Consequences of Deviation and Corrective Action
Identify Safety and Health Considerations (properties and hazards and precautions to prevent or correct problems)
Identify Safety Systems and Functions
Safe Work Practices Must be Addressed (e.g. lockout/tag-out, confined space entry, etc.
Procedures Shall be Reviewed as Required to Accurately Reflect Current Operations. Employer Must Certify to this Annually

7. Training Purpose is to Assure Personnel Can Accomplish Duties Safely
What is Required
Initial Training with Emphasis on Safety and Health Hazards, Emergency Operations Including Shutdown, Safe Work Practices
Refresher Training at Least Every Three Years
Training Shall be Documented

8. Contractors
Purpose is to Ensure Contract Employees Observe Same Safety Rules and Standards as Permanent Employees
What is Required
Applies to Contractors Performing Maintenance, Repair, T/A, Renovation or Specialty Work In or Around a Covered Process
Employer Shall:
When Selecting, Evaluate Contractors Safety Performance and Programs
Inform Contract Employees of Known Hazards Related to Work to be Done
Explain Applicable Emergency Action Plan Provisions
Expain Application of Safe Work Practices to Control Contractor
Evaluate Performance
Maintain a Log of Injuries and Illness
Contract Employer Shall
Assure Employees Trained
Assure Employees Instructed in Known Hazards and Emergency Plan
Document Employees Receive and Understand Training
Assure Employees Follow Safety Rules of Plant
Advise Employees of any Unique Hazards Presented by Contractors Work

9. Pre-Startup Safety Review
Purpose is to Assure Initial Startups or Startups Following Turnarounds or Abnormal Shutdowns are Carried Out Safely
What is Required
Review for New Facilities or Modified Facilities when The Modification Requires a Change in the Process Safety Information
Must Be done Prior to Introduction of HHCs
Must Confirm
Construction and Equipment Meets Design Specifications
Safety, Operating, Maintenance, and Emergency Procedures are Adequate
For New Facilities a PHA has Been Done and Issues Resolved
For Modified Facilities, Management of Change Procedures Have Been Completed

10. Hot Work
Purpose is to Assure Workers are Not Exposed to Sources of High Energy, e.g. Explosive Substances, Toxic Chemicals, Heat, Electricity, Moving Machinery, etc.
What is Required
Employer Issue Hot Work Permit for Work on or Near Covered Process
Permit Must Document Fire Prevention and Protection in Place
Principles Apply to Energy Control Procedures or Permits to Work As Well, e.g. digging near buried cable or pipelines

11. Management of Change Purpose What is Required – Employers Must
All Accidents are a Result of Uncontrolled Changes
Make Sure Changes are Properly Identified and Controlled Before Implemented
What is Required – Employers Must
Write Procedures to Manage Changes (Except for Replacement in Kind) that Address
Technical Basis for the Change
Impact of Change on Safety and Health
Modifications to Operating Procedures
Necessary Time Period for the Change
Authorization Requirements for the Change
Inform and Train Operations, Maintenance, and Contract Employees Affected by the Change Prior to Start-up
Update Applicable Process Safety Information
Update Operating Procedures or Practices

12. Incident Investigation
Purpose
Provide Feedback for Prevention of Future Problems
Incidents are Analogous to Hazards ( Potential Problem), Become Accidents When Someone is Harmed
After the Fact vs. Other Elements Aimed at Anticipation and Prevention
What is Required
Investigation of any Incident that Resulted or Could Have Resulted in Catastrophic Release of a HHC
Prompt Initiation, Within 48 Hours
Investigation Team Formed Consisting of Knowledge of Process Affected, Contractor if Involved, Others with Appropriate Knowledge
Report Prepared
Employer has a System to Promptly and Effectively Address Findings and Recommendations; and Document this Resolution
Report is Reviewed with Affected Personnel
Reports are Retained for Five Years

13. Emergency Planning and Response
Purpose is to Minimize Injuries and Damage in Event of an Incident or Accident
What is Required
Establishment and Implementation of an Emergency Action Plan
Procedures for Handling Small Releases
Training

14. Compliance Audits
Purpose is to Compare Performance Against the Written Standards and Procedures
What is Required
Employer Certify Every Three Years He Has Verified Procedures and Practices Required by The Rule are Adequate and Being Followed
Audit Team Include One Person Knowledgeable in Process and Other Knowledgeable Personnel
Audit Report Developed
Employer Respond to Findings and Document Deficiencies Have Been Resolved
Two Most Recent Audit Reports Be Retained

15. Trade Secrets – Only Non-Technical Element in the Rule
Purpose
To Insure Employees Have Access to Information Needed to Perform Job Safely, Regardless of Trade Secrets
A Trade Secret is Knowledge not Patented but Gives a Co. a Competitive Advantage
What is Required
Information (Regardless of Status) be Made Available to Persons Responsible for
Compiling Process Safety Information
Development of Process Hazard Analysis
Development of Operating Procedures
Involved in Incident Investigations, Emergency Planning and Response, and Compliance Audits
Allows Employer’s to Require Confidentiality Agreements of Employees

16. Summary Consistent Roadmap Through the PSM Program
The Elements Make Good Business Sense to Assure Safe and Reliable Operations