What Is PSM?

The Process Safety Management (PSM) framework established by OSHA applies to facilities that handle Highly Hazardous Chemicals (HHCs) and anhydrous ammonia under its regulatory oversight. Employers need to establish procedures for identifying and assessing and controlling potential release hazards.

A PSM Program consists of several essential components. The 14 elements of PSM established by OSHA function as an integrated system which must operate as a living system.

The following summary provides an overview of the main points.

1. The PSM activities require active worker participation for their success.
2. The written collection of chemical and equipment and technological data (PSI) needs to be complete before starting a hazard analysis process.
3. The Process Hazard Analysis (PHA) requires formal studies using methods like HAZOP and What-If to identify and control potential hazards.
4. The operating procedures (SOPs) need to provide clear instructions for all operational stages.
5. The training program provides essential information to workers about both hazards and operational procedures through initial and periodic refreshers.
6. The PSM | NEP requirements apply to all contractors who need to receive emergency hazard training.
7. The Pre-Startup Safety Review (PSSR) process verifies that new or modified systems operate safely before startup.
8. The equipment maintenance program includes inspections and tests and repairs to stop failures from happening.
9. Hot Work Permits function as safety controls which regulate welding and cutting operations and all activities that generate sparks.
10. The Management of Change (MOC) process requires organizations to conduct formal assessments for all process modifications including equipment changes and chemical substitutions and procedure updates and personnel adjustments.
11. The organization needs to conduct immediate investigations for all release incidents and near-miss occurrences.
12. The emergency response plan includes written documentation and scheduled drills and emergency response team coordination with local authorities.
13. The system requires compliance audits to take place at least once every three years for verification purposes.
14. The protection of trade secrets requires complete disclosure of safety data to employees and auditors through the elimination of all NDAs.

Facility-Specific = Your Obligation

IIAR 2 and IIAR 9 serve as guidelines for system design and evaluation yet OSHA will enforce the program you create. Follow through on your stated actions. The failure of operators to follow daily valve checks according to your SOP will result in a citation regardless of the valve’s new status.

The program needs to maintain simplicity while maintaining authenticity. A program becomes ineffective when staff members cannot execute its requirements because of excessive complexity. The program needs to achieve a proper equilibrium between complete implementation and operational feasibility.

Bottom Line

The PSM program serves as an active system which protects human life and maintains ammonia containment within pipes while protecting your organization from severe financial penalties.

Start with IIAR guidelines but create a customized program that matches your facility needs while training staff properly and conducting continuous audits. When you take ownership of something you gain the ability to protect it from legal challenges. The borrowed program will become evident to OSHA inspectors.

These elements play a significant role in minimizing the severity and likelihood of an unwanted incident. OSHA inspectors look for each element when reviewing the PSM program of a facility.

Implement PSM Program at Your Facility with Ice Cold Consulting

Ice Cold Consulting is a leading consulting firm that helps facility managers ensure regulatory compliance. Our team identifies limitations in your system operations and offers opportunities for improvement to help you comply with safety and efficiency standards.

With our PSM program management, you can implement all key elements of PSM in your processes and avoid any hazards, incidents, and penalties. Our team also performs regular compliance audits and mechanical integrity audits to ensure the safe and seamless operation of your mechanical assets. For more details, contact us now.