14 Elements PSM
14 Elements PSM
1. Employee Participation
4. Operating Procedures
5. Training
6. Contractors
8. Mechanical Integrity
1. Employee Participation
Perhaps one of the most important mandates, the employee participation clause requires that
employees—including production and maintenance staff—be involved in every aspect of the
PSM programs at their respective worksites. They must also be represented at the meetings
where PSM-related issues are discussed. OSHA requires employee participation to be followed
as written, so employers should create formal plans.
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.
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 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.
OSHA inspectors want to see that companies have plans for keeping everyone safe as they start
back up.
5. Training
Workers who carry out processes involving highly hazardous chemicals need to be well-trained,
and their training should have been accomplished through a competent source, first-party or
otherwise. Their training also needs to be well-documented. Training management software
makes it much easier to track this.
6. Contractors
Regular employees and contractors alike must be well-informed of the hazards they face. Under
the PSM National Emphasis Program, “The employer shall inform contract employers of the
known potential fire, explosion or toxic release hazards related to the contractor’s work and the
process.”
Are you reviewing your safety procedures every time a worksite starts back up? You should be.
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
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. In other words, your company must be able to explain WHY
your inspectors made their decisions.
Every employer needs to issue permits to employees and contractors who weld or perform other
high-temperature work near covered processes. They also need to train their personnel to post
and file these permits when necessary.
Companies need standard procedures for managing changes to process chemicals, technology,
equipment and procedures. Each change also requires the following considerations:
OSHA’s state standard calls for investigations for all incidents that result in—or could have
resulted in—a catastrophic highly hazardous chemical release. Because of that ambiguous
wording, cautious companies must keep every potential HHC-related scenario in mind.
Even minor chemical releases can lead to major incidents. This element mandates employers to
create emergency plans for handling smaller HHC releases.
According to the PSM-NEP, “Employers shall certify that they have evaluated compliance with
the provisions of this section at least every three years to verify that the procedures and practices
developed under the standard are adequate and are being followed.” This element also requires
employers to retain at least their two most recent audit reports.