1. Employee participation
OSHA requires employee participation to be followed as written, so employers should create formal plans. It is mandatory that employees - including operation and maintenance be involved in every aspect of the PSM programs. They must also participate in PSM related issue discussion.
2. Process safety information
According to OSHA’s PSM mandates, “The employer shall complete a compilation of written process safety information before conducting any process safety hazard analysis required by the standard.” In other words, all workers should be able to access and understand the technical data regarding the HHC-related risks they face on the job.
3. Process hazard analysis (PHA)
One of the most technical elements of PSM, Process Hazard Analysis requires that engineers and maintenance leaders analyze the consequences of safety failures. These analyses must be conducted in teams, and OSHA requires that each team must include one person who is “knowledgeable in the specific process hazard methodology being used.”
4. Operating procedures
There are plenty of potential chemical hazards following turnarounds and emergency shutdowns, which need to be regularly assessed and companies should have plans to keep everyone safe.
Workers involved in processes with hazardous chemicals need to be trained in an efficient and competent manner from a reliable source and also be well aware of safety procedures to be followed. The training should be a well-documented one.
All employees and contractors must be well informed with the risk they are exposed to in the workplace. They must be well trained and aware of all precaution and measures to be taken.
7. Pre-startup safety review
OSHA expects employers to perform pre-startup safety reviews for both new and modified facilities. This rule applies even if the procedural changes only affect a single component or process.
8. Mechanical integrity
- Periodic, documented inspections are required for several systems, including:
- Pressure vessels
- Storage tanks
- Piping systems
- Ventilation systems
The employers or contractors conducting these inspections must not only be officially trained, their testing procedures must follow “recognized and generally accepted good engineering practices,” according to OSHA.
9. Hot Work permit
The employee must possess permit when exposed to high heat environment and working with heat. Training must be provided and state these documents as when and required.
10. Management of Change
In the process safety management standard, change includes all modifications to equipment, procedures, raw materials, and processing conditions other than "replacement in kind." If the operator finds any change in the operating parameters, a review and approval by a written management of change procedure to be followed.
11. Incident investigation
This is usually done to avoid mishaps from recurring by learning from past experiences. The incidents OSHA expects employers to recognize and to investigate are the types of events that resulted in or could reasonably have resulted in a catastrophic release. These events are sometimes referred to as "near misses," meaning that a serious consequence did not occur, but could have happened.
12. Emergency planning and response
Emergency preparedness need to be inculcated in all employers and always be alert of the sudden mishap which can lead to major accidents.
13. Compliance audits
An audit is a technique to gather all information to verify compliance with standards. It is always beneficial to retain the recent audit reports for ready reference.
14. Trade secrets
To enhance worker safety and safe working environment, the “trade secrets” helps employees know the work environment and the hazards they will be exposed to.
The intent of PSM is to ensure that we perform our processes in a manner that is consistent with safety in all operations, engineering, and maintenance tasks that are conducted involving HHCs.