Occupational Safety and Health Administration

(OSHA – USA)
Process Safety Management (PSM) Standard
29 CFR 1910.119

Introduction:
Unexpected releases of toxic, reactive, or flammable liquids and gases in
processes involving highly hazardous chemicals have been reported for
many years. Incidents continue to occur in various industries that use
highly hazardous chemicals which may be toxic, reactive, flammable, or
explosive, or may exhibit a combination of these properties. Regardless
of the industry that uses these highly hazardous chemicals, there is a
potential for an accidental release any time they are not properly
controlled. This, in turn, creates the possibility of disaster.

Recent major disasters include the 1984 Bhopal, India, incident resulting
in more than 2000 deaths; the October 1989 Philips Petroleum Company,
Pasadena TX, incident resulting in 23 deaths and 123 injuries; the July
1990 BASF, Cincinnati, OH, incident resulting in 2 deaths, and the May
1991 IMC, Sterlington, LA, incident resulting in 8 deaths and 128
injuries.

OSHA issued the standard “Process Safety Management of Highly

Hazardous Chemicals” on February 24, 1992.
The standard mainly applies to manufacturing industries, particularly,
those pertaining to chemicals, transportation equipment, and fabricated
metal products. Other affected sectors include natural gas liquids; farm
product warehousing; electric, gas, and sanitary services; and wholesale
trade. It also applies to pyrotechnics and explosives manufacturers
covered under OSHA rules and has special provisions for contractors
working in covered facilities.

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In each industry, PSM applies to those companies that deal with any of
more than 130 specific toxic and reactive chemicals in listed quantities; it
also includes flammable liquids and gases in quantities of 10,000 pounds
(4,535.9 Kg) or more.

Elements of Process Safety Management (PSM):

The PSM standard contains 14 Elements that must be addressed in the
PSM Program prepared by the employer, as follows:
1. Employee Participation
2. Process Safety Information (PSI)
3. Process Hazard Analysis (PHA)
4. Operating Procedures
5. Training
6. Contractor Safety
7. Pre-Startup Safety Review
8. Mechanical Integrity
9. Hot Work Program
[Link] of Change (MOC)
[Link] Investigation
[Link] Planning and Response
[Link] Audits
[Link] Secrets

1- Employee Participation:
The standard requires employers to:
- Develop a plan of action for implementation of Employee
Involvement.
- Consult with employees on the conduct of the development of
PSM elements.
- Provide access to PSM information.

2- Process Safety Information (PSI):

Process safety information must include information on the hazards of the
highly hazardous chemicals used or produced by the process, information
on the technology of the process, and information on the equipment in the
process.
o Information on the hazards of the highly hazardous chemicals in
the process shall consist of at least the following:
- Toxicity,
- Permissible Exposure Limits (PEL),
- Physical Data,
- Reactivity data,
- Corrosivity data, and

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 - Thermal and chemical stability data, and hazardous effects of
inadvertent mixing of different materials.

0- Information on the technology of the process must include at

least the following:
- A block flow diagram or simplified process flow diagram,
- Process chemistry,
- Maximum intended inventory,
- Safe upper and lower limits for such items as temperatures,
pressures, flows or compositions, and
- An evaluation of the consequences of deviations, including
those affecting the safety and health of employees.

(Where the original technical information no longer exists, such

information may be developed in conjunction with the process hazard
analysis in sufficient detail to support the analysis.)
(Material Safety Data Sheets (MSDSs) may be used to comply with the
requirement to the extend they contain the required information)

0- Information on the equipment in the process must include the

following:
- Materials of construction,
- Piping and instrument diagrams (P&IDs),
- Electrical Classifications
- Relief system design and design basis,
- Ventilation system design,
- Design codes and standards employed,
- Material and energy balances for processes built after May 26,
1992, and
- Safety systems (e.g., interlocks, detection, or suppression
systems).

3- Process Hazard Analysis (PHA):

The process hazard analysis (PHA) is the key provision of the Process
Safety Management Standard.
The process hazard analysis is a thorough, orderly, systematic approach
for identifying, evaluating, and controlling the hazards of processes
involving highly hazardous chemicals. The employer must perform an
initial process hazard analysis (hazard evaluation) on all processes
covered by this standard. The process hazard analysis methodology
selected must be appropriate to the complexity of the process and must
identify, evaluate, and control the hazards involved in the process.

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The employer must use one or more of the following methods, as
appropriate, to determine and evaluate the hazards of the process being
analyzed:
o What-if,
o Checklist,
o What-if / checklist,
o Hazard and operability study (HAZOP),
o Failure mode and effects analysis (FMEA),
o Fault tree analysis, or
o An appropriate equivalent methodology.

Whichever method(s) are used, the process hazard analysis must address
the following:
o The hazard of the process;
o The identification of any previous incident that had a potential for
catastrophic consequences in the workplace;
o Engineering and administrative controls applicable to the hazards
and their interrelationships, such as appropriate application of
detection methodologies to provide early warning of releases.
o Consequences of failure of engineering and administrative
controls;
o Facility siting;
o Human factors, and
o A qualitative evaluation of a range of the possible safety and health
effects on employees in the workplace if there is a failure of
controls.

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At least every five years after the completion of the initial process hazard
analysis, the process hazard analysis must be updated and revalidated by
a team meeting the standard’s requirements to ensure that the hazard
analysis is consistent with the current process.

4- Operating Procedures:
The employer must develop and implement written operating procedures,
consistent with the process safety information, that provide clear
instructions for safely conducting activities involved in each covered
process. The procedures must address at least the following elements:
Steps for each operating phase:
 Initial startup;
 Normal operations;
 Temporary operations;
 Emergency shutdown, including the conditions under which
emergency shutdown is required, and the assignment of shut down
responsibility to qualified operators to ensure that emergency
shutdown is executed in a safe and timely manner;
 Emergency operations;
 Normal shutdown; and
 Startup following a turnaround, or after an emergency shutdown.

Operating Limits:
 Consequences of deviation, and
 Steps required to correct or avoid deviation.

Safety and health considerations:

 Properties of, and hazards presented by, the chemicals used in the
process;
 Precautions necessary to prevent exposure, including engineering
controls, administrative controls, and personal protective
equipment;
 Control measures to be taken if physical contact or airborne
exposure occurs;
 Quality control for raw materials and control of hazardous
chemical inventory levels; and
 Any special or unique hazards.
 Safety systems (e.g., interlocks, detection or suppression systems)
and their functions.

Operating procedures must be readily accessible to employees who work

in or maintain a process.

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5- Training:
PSM requires that each employee presently involved in operating a
process or a newly assigned process must be trained in an overview of the
process and in its operating procedures.
The training must include emphasis on the specific safety and health
hazards of the process, emergency operations including shutdown, and
other safe work practices that apply to the employee's job tasks.

Refresher training:
Refresher training shall be provided at least every three years, and more
often if necessary, to each employee involved in operating a process to
assure that the employee understands and adheres to the current operating
procedures of the process.

6- Contractors:
PSM includes special provisions for contractors and their employees to
emphasize the importance of everyone taking care that they do nothing to
endanger those working nearby who may work for another employer.
PSM applies to contractors performing maintenance or repair,
turnaround, major renovation, or specialty work on or adjacent to a
covered process.

When selecting a contractor, the employer must obtain and evaluate

information regarding the contract employer's safety performance and
programs. The employer also must inform contract employers of the
known potential fire, explosion, or toxic release hazards related to the
contractor's work and the process; explain to contract employers the
applicable provisions of the emergency action plan; develop and
implement safe work practices to control the presence, entrance, and exit
of contract employers and contract employees in covered process areas.

7- Pre-Startup Safety Review:

PSM requires the employer to perform a pre-startup safety review for
new facilities and for modified facilities when the modification is
significant enough to require a change in the process safety information.
Prior to the introduction of a highly hazardous chemical to a process, the
pre-startup safety review must confirm that the following:
 Construction and equipment are in accordance with design
specifications;
 Safety, operating, maintenance, and emergency procedures are in
place and are adequate;
 A process hazard analysis has been performed for new facilities
and recommendations have been resolved or implemented before

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 startup, and modified facilities meet the management of change
requirements; and
 Training of each employee involved in operating a process has
been completed.

8-Mechanical Integrity:
PSM mechanical integrity requirements apply to the following
equipment:
 Pressure vessels and storage tanks;
 Piping systems (including piping components such as valves);
 Relief and vent systems and devices;
 Emergency shutdown systems;
 Controls (including monitoring devices and sensors, alarms, and
interlocks);
 Pumps.

The employer must establish and implement written procedures to

maintain the ongoing integrity of process equipment.
Inspection and testing must be performed on process equipment, using
procedures that follow recognized and generally accepted good
engineering practices.

Equipment deficiencies outside the acceptable limits defined by the

process safety information must be corrected before further use.

In constructing new plants and equipment, the employer must ensure that
equipment as it is fabricated is suitable for the process application for
which it will be used.

The employer also must ensure that maintenance materials, spare parts,
and equipment are suitable for the process application for which they will
be used.

9- Hot Works:
A permit must be issued for hot work operations conducted on or near a
covered process. The permit must document that the fire prevention and
protection requirements (OSHA 29 CFR 1910.252) have been
implemented prior to beginning the hot work operations; it must indicate
the date(s) authorized for hot work; and identify the object on which hot
work is to be performed.
The permit must be kept on file until completion of the hot work.

10- Management of Change (MOC):

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The standard contains a section on procedures for managing changes to
processes.
The employer shall establish and implement written procedures to
manage changes (except for "replacement in kind") to process chemicals,
technology, equipment, and procedures; and changes to facilities that
affect a covered process. These written procedures must ensure that the
following considerations are addressed prior to any change:
 The technical basis for the proposed change,
 Impact of the change on employee safety and health,
 Modifications to operating procedures,
 Necessary time period for the change, and
 Authorization requirements for the proposed change.

Employees who operate a process and maintenance and contract

employees whose job tasks will be affected by a change in the process
must be informed of, and trained in, the change prior to startup of the
process or startup of the affected part of the process.

11- Incident Investigation:

PSM requires the investigation of each incident that resulted in, or could
reasonably have resulted in, a catastrophic release of highly hazardous
chemical in the workplace.
An investigation report must be prepared including at least:
 Date of incident,
 Date investigation began,
 Description of the incident,
 Factors that contributed to the incident, and
 Recommendations resulting from the investigation.

A system must be established to promptly address and resolve the

incident report findings and recommendations. Resolutions and corrective
actions must be documented and the report reviewed by all affected
personnel whose job tasks are relevant to the incident findings (including
contract employees when applicable).
The employer must keep these incident investigation reports for 5 years.

12- Emergency Planning Response:

If, despite the best planning, an incident occurs, it is essential that
emergency pre-planning and training make employees aware of, and able
to execute, proper actions. For this reason, an emergency action plan for
the entire plant must be developed and implemented (OSHA 29 CFR
1910.38). In addition, the emergency action plan must include procedures
for handling small releases of hazardous chemicals.

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Employers covered under PSM also may be subject to the OSHA
hazardous waste operation and emergency response regulations.

13- Compliance Audits:

To be certain process safety management is effective, employers must
certify that they have evaluated compliance with the provisions of PSM
at least every three years. This will verify that the procedures and
practices developed under the standard are adequate and are being
followed.
The compliance audit must be conducted by at least one person
knowledgeable in the process and a report of the findings of the audit
must be developed and documented noting deficiencies that have been
corrected.
The two most recent compliance audit reports must be kept on file.

14- Trade Secrets:

Employers must make available all information necessary to comply with
PSM to those persons responsible for compiling the process safety
information, those developing process hazard analysis, those responsible
for developing the operating procedures, and those performing incident
investigations, emergency planning and response, and compliance audits,
without regards to the possible trade secret status of such information.
Nothing in PSM, however, precludes the employer from requiring those
persons to enter into confidentiality agreements not to disclose the
information.

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