Process Safety Management (OSHA regulation)
[3] Any U.S. facility that stores or uses a hazardous material above thresholds defined in section (a)(1) and Appendix A must comply with the PSM regulation.
Usually, these facilities are also subject to another, similar regulation issued by the Environmental Protection Agency (EPA), known as the Risk Management Program (RMP) rule (Title 40 CFR Part 68).
A PHA provides information intended to assist managers and employees in making decisions for improving safety and reducing the consequences of unwanted or unplanned releases of hazardous materials.
[1] Operating procedures must be consistent with the process safety information and provide clear instructions for safely conducting activities involving hazardous materials.
It is mandatory that the following activities be covered in dedicated operating procedures: lockout/tagout, confined space entry, opening process equipment or piping, and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel.
[8] A pre-startup safety review (PSSR) shall take place before any highly hazardous material is introduced into a process, i.e. before the plant start-up.
The review must confirm that:[8] In the context of OSHA's PSM, mechanical integrity requirements apply to the following equipment: In order to minimize the risk of unwanted releases of hazardous materials, companies must establish and implement adequate maintenance strategies.
[8] PSM schemes other than OSHA's usually extend this element to cover the integrity assurance of safety-critical systems in general,[10] not just those directly responsible for fluid containment, according to a wider asset integrity management strategy that includes systems such as active and passive fire protection, fire and gas detection, sources of emergency power, etc.
The permit must document that the fire prevention and protection requirements in OSHA regulations have been implemented prior to beginning the hot work operations.
[8] Undocumented, not properly risk assessed changes to a plant handling hazardous materials are a recipe for disaster.
An eminent example of this is the Flixborough disaster, where improvised changes involving the bypassing of a stage in a reactor train was at the origin of the accident.
[8] Incident investigation provides a fundamental opportunity to learn from past mistakes and disseminate the new knowledge gathered throughout the organization and, if possible, to external stakeholders.
[7] By way of example, the response to the Tacoa disaster was largely unorganized and uninformed about the nature of the fire that was burning inside a fuel oil tank.
[8][15] Similar to incident investigation, audits are an important tool an organization can use to assess whether its process safety management system is in place and it is effectively applied throughout its ranks.
The regulation makes it compulsory for organizations to release the information to the respective parties, irrespective of whether it is protected by trade secrecy.
