Safety concerns are a part of every workplace, and various risk management processes need to be implemented to protect workers from harm. Of course, some businesses face greater inherent risks than others. For example, factories that work with hazardous chemicals are under the risk of an unexpected release of toxic, reactive, or flammable liquids or gasses, which can have disastrous consequences for employee safety.
Since this is a serious risk that businesses face, the Occupational Safety and Health Administration (OSHA) issued a comprehensive safety management system tackling the risks associated with hazardous chemicals, called the “Process Safety Management of Highly Hazardous Chemicals.”
OSHA requires all businesses working with hazardous chemicals to follow OSHA’s Process Safety Management (PSM) standard, aiming to prevent accidental release of such chemicals. PSM requires employers to identify, evaluate, and control the hazards related to the toxic chemicals being used.
A PSM differs from other risk management standards and guidelines as it focuses on large-scale, catastrophic events rather than more individual or small-scale safety hazards. But still, an effective PSM program goes over and above helping you avoid such catastrophic releases — it also ensures efficient and reliable operations in general.
OSHA defines 14 basic elements that every process safety management program must include. These serve as guidelines and are meant to help comply with OSHA’s PSM regulations. In this article, we’ll outline each of these principles to help you implement process safety management effectively in your organization.
1. Process Safety Information (PSI)
Employers should collect and document information about the hazards of the chemicals being used in various processes, as well as any related technology and equipment being used. This compilation should include information about the hazardous chemicals such as permissible exposure limits, toxicity, reactivity and corrosivity data, effects of mixing of different chemicals, etc. All this information should be accessible to all employees and staff so that they understand the risks they may face while doing their job.
2. Process Hazard Analysis (PHA)
This is the process used to identify, evaluate, and control the hazards faced during the processes involving toxic chemicals. Different methods can be used to evaluate the hazards, such as:
- What-if: A structured brainstorming technique where the team lists everything that could go wrong during the process.
- Checklist: Checklists can be used to identify potential hazards and evaluate the level of risk faced related to each hazard.
- Fault tree analysis: This is a top-down, graphical method used to determine the root cause of possible safety failures or incidents. Starting from the undesirable loss (for example, a catastrophic release of hazardous chemicals), it involves constructing a tree-like model of pathways that leads to all possible causes.
- Failure mode and effects analysis (FMEA): This is a technique through which every component and assembly that could potentially cause a failure in the system are identified, and the consequences of each failure are mapped.
- Hazard and operability study (HAZOP): A systematic process for identifying hazards, HAZOP is typically used while designing a new project or for major process modifications.
A PHA should be performed in a timely manner and updated at least every five years for as long as the process is running.
3. Operating Procedures
Employers should establish systematic operating procedures for the different tasks in the process, including initial start-up, normal and temporary operations, and emergency situations. These operating procedures should particularly focus on hazards, health considerations, operating limits, and special circumstances. Such a document should also outline any deviations from the norm and what actions to take to correct such deviations.
4. Compliance Audits
OSHA requires employers to conduct a PSM audit at least once in three years, to confirm that all the practices created are being followed satisfactorily, and all the OSHA regulations are being complied with. The audit must be documented, mentioning any deficiencies or corrections to be made in the process, and the two most recent audit reports need to be kept on file.
5. Employee Participation
All employees involved in the process should be included in the process safety management program. The employees and their representatives must be consulted while developing all elements of the PSM, and all related documentation should be accessible to them.
6. Hot Work Permit
For any operations involving high temperatures (like welding), especially in or near confined spaces, the personnel must be issued hot work permits. The permits must be issued on the condition that fire prevention and fire safety measures are taken before the beginning of operations. The permit should also specify details about the location and dates of working.
7. Emergency Response and Emergency Planning
Despite best efforts to prevent incidents, accidents can occur. Employers should be prepared for such an event, with an emergency action plan. The plan would include procedures to follow in case of an accidental release of hazardous chemicals, in line with OSHA’s provisions, and training employees to deal with such a situation.
8. Mechanical Integrity
Employers should conduct routine inspections of critical process equipment to ensure that their mechanical integrity is maintained according to OSHA standards, checking that the equipment is properly designed, installed, and operating according to good engineering practices. Equipment to test for mechanical integrity includes:
- Pressure vessels and vent systems
- Storage tanks
- Piping systems and pumps
- Emergency shutdown systems
- Control systems (including monitoring devices, alarms, interlocks, lockout/tagout systems, etc.)
9. Pre-Startup Safety Review
A safety review must be performed for new facilities and modified job sites. This is to confirm that an initial process hazard analysis has been performed and that appropriate processes are in place to ensure smooth and safe working, such as operating, maintenance, safety, and emergency procedures. This review also serves to verify that all equipment meets design specifications, and that operators have been successfully trained.
10. Process Safety Management Training
Every employee responsible for operating the processes involved needs to receive appropriate training. This training should particularly cover safety and health hazards, safe operating procedures for the task they are to perform, emergency procedures, and best work practices. They must be trained before starting the assignment, and receive regular refresher training, at least once in three years.
11. Contractor Safety
In addition to the company’s own employees, the safety of contractors and subcontractors is also the responsibility of the employer. Under the process safety management system, the contractors’ safety performance should be evaluated before starting a project. They must also be trained and informed about potential hazards, emergency action plans, and safety rules specific to the process they would work on.
12. Management of Change
Any changes to the process should be managed efficiently and safely. Every time such a change occurs, employees and contractors should receive updated training on how to handle the change. The management of change process should address the impact of the change on employee safety (including any new safety risks involved), the technical basis and authorization requirements for the proposed change, modifications to current procedures, and the time period necessary to institute the change.
13. Incident Investigation
Every incident that resulted in a catastrophic accident or a near miss must be investigated within 48 hours of the incident taking place. The incident investigation should be conducted by a knowledgeable team who would analyze the root causes of the incident and write a report recommending safety changes to prevent future incidents.
14. Trade Secret Protection
All materials and operations relevant to the process and its safety must be documented and shared with all the staff to ensure health and safety. This includes even trade secrets. However, OSHA does not prevent employers from requiring confidentiality agreements from their employees to protect these trade secrets.
Manage Your Process Safety Efficiently Through Automation
Implementing a process safety management program can get complicated, especially since it involves so many different processes. And since it is meant to prevent large-scale catastrophes, the consequences of errors in such a program can be quite disastrous.
Automation can make things a lot easier. With a cloud-based platform such as Pulpstream, every step can be streamlined and made more efficient:
- Process safety information, operating procedures, and other relevant documentation can be recorded and stored in a single place, and shared with all stakeholders with the click of a button
- Process hazard analysis and compliance audits can be conducted and recorded easily
- Hot work permits can be created and safely shared with the relevant employees
- The sharing of trade secrets can be controlled
- Incident investigations can be conducted, analyzed, and reported
- And more
Take advantage of Pulpstream’s capabilities to optimize your process safety management today. Book a free demo now!