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Interrelations between process safety management elements

Article  in  Process Safety Progress · March 2016

DOI: 10.1002/prs.11824

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Interrelations Between Process Safety
Management Elements
Hanida Abdul Aziz, Azmi Mohd Shariff, and Risza Rusli
Department of Chemical Engineering, Centre of Advanced Process Safety, Universiti Teknologi PETRONAS, Tronoh, Perak 31750,
Malaysia; [email protected] (for correspondence)
Published online 00 Month 2016 in Wiley Online Library (wileyonlinelibrary.com). DOI 10.1002/prs.11824

OSHA PSM standard has been established with 14 ele- astrophic releases of toxic, reactive, or flammable chemicals
ments that define the management principles to control pro- from a covered process that deal with any of the 137 HHC
cess hazards and protect the workplace. One of the key as per the listed quantities of Appendix A of the regulation,
factors to the success of Process Safety Management (PSM) it also includes flammable liquids and gases in quantities of
implementation is that each element comes as a component 10,000 pounds or more in one location. It also applies to
in an integrated PSM program. Although various kind of pyrotechnics and explosives manufacturers covered under
integrated safety management systems have been introduced, OSHA rules and has special provisions for contractors work-
direct integration system between PSM elements was not ing in covered facilities [4,5]. Outside the United States, Euro-
extensively studied due to vague concept on interrelation pean Union adopted EC Seveso Directive II or Control of
between PSM elements. This also hampers efforts in designing Major Accident Hazards (COMAH) Regulations in United
and developing integrated system for PSM. In this study, the Kingdom which has similar purpose to OSHA PSM [6].
interrelation of critical PSM elements was analyzed based on PSM regulation has been established with the interrelated
objectives and information functional of the elements stipu- elements that define the management principles. Whereby,
lated in OSHA PSM regulations. From the conducted analy- change information of one PSM element may effects the
sis, all the critical elements are interrelated at least with other interrelated elements. For example, pilot studies indi-
other seven PSM elements. Among the elements, Process Haz- cate that higher yields can be obtained by maintaining higher
ard Analysis and Mechanical Integrity were identified to temperatures in a reaction vessel. A change in operating tem-
have the highest interrelations comprising of 12 interrelated perature must be approved by all technical and supports
PSM elements. The developed PSM matrix has systematically functions through Management of Change (MOC) process.
showed the interrelation of critical PSM elements that useful The impact of this change is assessed through revision of
for the development of Integrated PSM system. VC 2016 American
Process Hazard Analysis (PHA), which results in a recom-
Institute of Chemical Engineers Process Saf Prog 000: 000–000, 2016 mendation to modify the pressure relief system. The modifi-
Keywords: process safety management; PSM elements; cations in temperature and pressure system mandate new
OSHA PSM; process safety; interrelations of PSM element steps for process operators through Operating Procedures
(OP), who require Training (TNG) and verification in the
INTRODUCTION new procedures [5]. Therefore, change of process safety data
Large-scale accidents like those in Flixborough (1974), should be captured, managed, and communicated efficiently
Saveso (1976), and Bhopal (1984) caused much grief and are in order to avoid major safety and regulatory implications
major tragedies that have forever altered the process industry [7,8].
landscape and have led to widespread changes in regulations One of the key factors to the success of PSM implementa-
and development of standards and safety management sys- tion is that each element comes as a component in an inte-
tems [1,2]. In response to these accidents, US Occupational grated PSM program [5,9]. A concept that has combined
Safety and Health Administration (OSHA) enacted Process plant reliability programs with PSM efforts, with a focus on
Safety Management (PSM) requirements in the Code of Fed- Mechanical Integrity (MI) program has been developed. The
eral Regulations (CFR) Chapter 29, Section 1910.119, titled steps include identifying safety-critical equipment, ensuring
Process Safety Management of Highly Hazardous Chemicals accurate and up-to-date Process Safety Information (PSI),
(HHC). It was developed through OSHA rulemaking process establishing the MI program, establishing planned mainte-
which includes robust stakeholder involvement. The notice nance programs, and creating equipment-specific mainte-
of proposed rulemaking invited comments on any aspect of nance procedures. Inherent in the approach is adequate
the proposed PSM requirements. In response to the pro- understanding and sharing of critical PSI between the PSM
posed rulemaking, OSHA received more than 175 comments, elements including PHA, MOC, Pre-startup Safety Review
4,000 pages of testimony, and almost 60 posthearing com- (PSSR), and OP besides adherence to the Operational Disci-
ments [2,3]. The purpose of the 14 elements regulation plines (OD) requirements. By combining these reliability and
(Table 1) is to prevent or minimize the consequences of cat- safety efforts, the maintenance, operations, engineering, and
safety groups will speak the same equipment reliability and
integrity language, thus minimizing the overall business risk
C 2016 American Institute of Chemical Engineers
V [10]. Vaughen and Muschara (2011) recommended linking

Process Safety Progress (Vol.00, No.00) Month 2016 1

Table 1. Element of process safety management (PSM) Table 3. Refinery NEP most frequently cited PSM elements
standard [4]. [13].

Standard Code PSM Element Percentage of

PSM Element Total Violations (%)
29 CFR 11910.119(c) Employee participation (EP)
29 CFR 11910.119(d) Process Safety Information (PSI) Mechanical integrity 19
29 CFR 11910.119(e) Process Hazards Analysis (PHA) Process safety information 18
29 CFR 11910.119(f) Operating Procedures (OP) Operating procedures 17
29 CFR 11910.119(g) Training (TNG) Process hazard Analysis 16
29 CFR 11910.119(h) Contractor (CON) Management of change 10
29 CFR 11910.119(i) Pre-Startup Safety Review (PSSR)
29 CFR 11910.119(j) Hot Work Permit (HWP)
29 CFR 11910.119(k) Management of Change (MOC)
causes of numbers of reported accidents investigated by US
29 CFR 11910.119(l) Mechanical Integrity (MI)
Chemical Safety and Hazard Investigation Board (CSB) [14].
29 CFR 11910.119(m) Incident Investigation (II)
In 2007, OSHA has developed special emphasis programs
29 CFR 11910.119(n) Emergency Planning
to target specific industries, notably the petroleum refining
and Response (ERP)
and chemical industries. This is by far is specifically aimed to
29 CFR 11910.119(o) Compliance Audit (CA)
enhance its auditing processes and inspection priorities
29 CFR 11910.119(p) Trade Secret (TS)
[2,13]. Between June 2007 and June 2008, OSHA US con-
ducted 14 Petroleum Refinery NEP inspections resulting in
348 citations. The top five PSM elements cited and the corre-
the separate MOC, PSSR, and MI quality assurance (QA)- sponding number of citations is given in Table 2. As of
related efforts together. The combined approach helps the December 31, 2010, OSHA has opened 248 inspections
team ensures that systemic root causes are discovered so that under the Refinery NEP. The same elements gave a signifi-
more appropriate, system-related preventive measures are cant number of PSM violations again (Table 3). These reports
chosen and implemented. Some might view it to operate in clearly demonstrate the urgency on finding effective ways to
its own separate universe, however, in reality its important to implement the above elements. The study will remain
and the interrelationships with other PSM elements are focused on interrelation of critical PSM elements.
unquestioned [3,11].
INTERRELATION OF PSM ELEMENTS
In order to develop integrated PSM program, it is neces-
In this study, the interrelation analysis was derived from
sary to be able to identify the interrelation between the PSM
the objectives and information functional of each PSM ele-
elements to ensure consistency of data cross transferring and
ments based on stipulated OSHA PSM requirements. The
data utilization [12]. Anyhow, complete and details informa-
identified relations were consolidated with the reported rela-
tion of interrelation between the PSM elements still not
tionship of PSM elements obtained from the literatures. Find-
reported. This also hampers efforts in designing and devel-
ing is presented in concept matrix and discussion. Concept
oping integrated PSM program.
matrix was used to address the width of the study to depict
The objective of this study is to analyze the interrelation
relationships between ideas [15] and to keep the focus nar-
of PSM elements. Details interrelation of PSI, PHA, OP, TNG,
row [16].
PSSR, MI, and MOC elements will further be discussed. In Figure 1 shows the PSM matrix developed from the analy-
this study, PSM matrix was developed that systematically sis on the interrelation between critical PSM elements with
showed the interrelations and obtain the flow of process other PSM elements. Detail explanation of interrelation spe-
safety data that useful for the development of integrated PSM cifically for PSI, PHA, OP, TNG, PSSR, MI, and MOC elements
system. were tabulated in Tables (4–10), respectively. As presented
in Figure 1, all the critical elements are interrelated with
other seven PSM elements, in minimum. PHA and MI were
CRITICAL PSM ELEMENTS
identified having the highest interrelation with 12 interrelated
Without question, all the PSM elements are important and PSM elements. Dramatically, similar elements have the high-
must work together to provide the multiple layers of protec- est citation in Refinery NEP inspections and also identified as
tion that we rely upon. However, over the years, certain ele- the most difficult elements to comply with [2,13]. This is may
ments have often come to be viewed as the “heart and soul” be due to diverse and high interrelations that need to be
of PSM. These elements continue to present the highest considered in the implementation program of the above
number of PSM citations, in particular PSI, PHA, OP, MI, elements.
MOC, TNG, and PSSR [2,11,13]. Dramatically, similar ele- Table 4 tabulates the interrelation of PSI element with
ments have identified as significant root and contributing other PSM elements. PSI element primarily focuses on com-
pilation of information related to process. It is a foundational
Table 2. Refinery NEP most frequently cited PSM elements PSM program element for understanding the hazards and
(Issued June 2007–June 2008) [2]. risks because it provides a written body of technical informa-
tion upon which design of other PSM elements depends [3].
Therefore, PHA, OP, TNG, MI, MOC, Emergency Response
PSM Element Number of Citations
and Planning (ERP) and Hot Work Permit (HWP) develop-
Operating procedures 67 ments were significantly depended on technical information
Mechanical integrity 66 under PSI element [3–5]. On top of that PSI must be commu-
Process hazard analysis 60 nicated and made available throughout plant personnel and
Process safety information 44 contractor’s workers. This is to ease their job and the safety
Management of change 30 of process depends on making sure that the workers were
accessible to accurate PSI. The success of any PSM program

2 Month 2016 Published on behalf of the AIChE DOI 10.1002/prs Process Safety Progress (Vol.00, No.00)
Figure 1. PSM matrix for critical PSM elements.

Table 4. Interrelations of PSI element [3–5,7,17]. The outcome of analysis on interrelation of PHA element
with other PSM element is tabulated in Table 5. The objec-
tive of PHA is to determine areas of exercise risk where pre-
PSM Interrelates
ventive and mitigative measures may be warranted to better
Element Element Details
control the hazards [5]. Thus, adequate and accurate informa-
PSI EP  Process chemicals, technology tion from PSI, Trade Secret (TS), previous MOC and reported
and equipment information Incident Investigation (II) must be available to support PHA
should be accessible to all exercises. The outcomes from PHA should be communicated
affected personnel to all affected employers, thus they shall be used in other
PHA  The compilation of written PSI program including OP, TNG, MI, Contractor (CON), and ERP
should be completed before [[3–5,17,19]]. PHA has direct application for identifying chem-
conducting any PHA ical process hazards which is useful in support of emergency
OP  Update PSI information may planning program. They should be used whenever possible
result in changes to the written to satisfy all PSM program requirements [5]. The recommen-
OP and SWP dations from PHA require careful resolution and may repre-
TNG  Update PSI information may sent changes to process chemicals, technology and
result in changes to the TNG equipment, standard procedures, as well as MI program.
contents for plant personnel Thus, MOC and PSSR may need to be performed prior to
MOC  Change to PSI except for RIK changes [7].
must undergo MOC process As presented in Table 6, OP element has the interrelations
CON  Process chemicals, technology with Employee Participation (EP), PSI, PHA, TNG, MI, MOC,
and equipment information CON, HWP, II, Compliance Audit (CA), and TS elements. OP
should be accessible to all
is an important element for achieving safe, consistent, and
affected contractor workers
efficient process operation. OP must discuss operating limits,
HWP  Information of process chemi-
the consequences of deviating from these limits and recovery
cals and equipment involving
from deviation. OP must address normal, abnormal, and
in process should be accurate
to ensure save hot works emergency conditions to prepare workers for any event that
ERP  PSI is referred to construct may reasonably occur. Adequate technical and administrative
emergency response planUp- information from PSI, PHA, TS, and reported II are vital to
date PSI information may result support the preparation of OP [3–5,7,17]. High quality proce-
in changes to the emergency dures alone achieve nothing unless the plant personnel and
plans or procedures contractor workers are trained in their use. Thus, a close
CA  PSI documentation should be relationship exists between OP and TNG element. Estab-
assessed during audit process lished OP shall be used in other program including EP, TNG,
TS  Any related information neces- MI, HWP, CON, and ERP. Besides that, proposed change in
sary to comply with PSI should OP requires a critical and technical soundness justification.
be available for compilation Thus, MOC needs to be performed to manage and control
the change appropriately [3,17,19,20].
From the analysis on the interrelation of TNG element, it
is found that TNG has the interrelations with EP, PSI, OP, MI,
is predicated on a framework of information systems that CON, II, and CA elements (Table 7). All plant personnel
was used to document and communicate essential PSI across involved in operating and maintaining the process must be
the organization [18]. trained to ensure safe operations. This requirement is catered

Process Safety Progress (Vol.00, No.00) Published on behalf of the AIChE DOI 10.1002/prs Month 2016 3
Table 5. Interrelations of PHA element [3–5,7,17].

PSM Interrelates
Element Element Details
PHA EP  PHA outcomes and resolution of recommendation should be informed to affected personnel
 PHA activities must be conducted by a PHA team with specific expertise
PSI  Up-to-date PSI is vital to conduct PHA in order to draw accurate conclusions about the
present process hazards and risks
OP  Identified process hazards should be included in the written operating procedures as a
warnings and cautions
TNG  The content of training module for plant personnel involved in operating the process
should include information of identified process hazards from PHA
MI  The content of training module for maintenance personnel should include information of
the identified hazards from PHA
 Resolution of recommendations made from PHA may require update in ITPM program
MOC  MOC documentation is often reviewed during PHA revalidations to determine what
changes warrant study during the revalidation
 Resolution of recommendations made from PHA may require use of the MOC process
CON  PHA outcomes and resolution of recommendation should be informed to affected con-
tractor workers
II  Reports from previous accidents are reviewed during PHA revalidations
 Investigation process for process safety accident may require PHA to be performed as
part of the process
ERP  Hazards scenarios identified in the PHA should be considered in ERP program
CA  PHA information and documentation should be assessed during audit process
TS  Any related information should be available to those involving in the development of
PHA if necessary

Table 6. Interrelations of OP element [3–5,17,19,20].

PSM Interrelates
Element Element Details
OP EP  Written OP should be accessible to all affected personnel to perform their jobs safely
 The plant operators and maintenance personnel often initiate the safe work practices
PSI  The knowledge and technical information are used in the development of OP (i.e., save
upper and lower operating limits)
 PSI should be reflected accurately in the written OP
PHA  Written OP of each operating phases should include steps to avoid the hazards and con-
sequences of deviations identified during the PHA
TNG  Plant personnel should be trained thoroughly in the content of OP
MI  Maintenance personnel should be trained thoroughly in the content of OP
MOC  Change to OP except for RIK must undergo MOC process
CON  Written OP should be accessible to all affected contractor workers
HWP  The SWP or nonroutine procedures must be in place for hot work activities
II  The findings of incident investigation may result in changes to the written OP
CA  OP-related information and documentation should be assessed during audit process
TS  Any related information should be available to those involving in the development of OP
if necessary

through the linkage with the implementation EP and CON for process safety-related reasons. Therefore, cross checking
programs [4]. TNG must result in plant personnel understand- of information pertaining PSI, PHA, OP, TNG, MI, and MOC
ing of chemical hazards and the controls, proper procedures, elements is essential as process conformation [3–5,17,21].
safe operating limits and how to avoid unsafe conditions, Rashid et al. (2013) has emphasized that PSSR must be con-
how to respond to upset and emergency conditions, and ducted before the installation of facility. If not, it becomes dif-
opportunities available for plant personnel to contribute of ficult to implement the PSSR recommendations after facility
process safety improvements [3–5]. Thus, development of installation as the items have not been agreed upon at the
TNG program is highly depended with PSI, OP, PHA, MI, and time of contract. As a consequence, complete safety consider-
reported II to achieve the above necessities. Any changes of ations also cannot be confirmed of new facilities or modified
the information from these elements may reflect in update or as recommended by OSHA. On top of that, PSSR information
additional TNG program [4,5,17]. and resolution must be made available throughout affected
Details interrelation of PSSR element with other OSHA PSM plant personnel and contractor’s workers. This is to ease their
elements is shown in Table 8. The purpose of PSSR is to job and the safety of process depends on making sure that
ensure the readiness of new or modified process especially the workers were accessible to accurate PSSR [21].

4 Month 2016 Published on behalf of the AIChE DOI 10.1002/prs Process Safety Progress (Vol.00, No.00)
Table 7. Interrelations of TNG element [3–5,17].

PSM Interrelates
Element Element Details
TNG EP  All the plant personnel involved in operating a process of covered area should be trained
in overview of the process, operating procedures, safety and health hazards, emergency
operations, and safe work practices applicable to their job tasks.
 Training materials, training schedule, and training record should be accessible to all
affected plant personnel
 Employer should acquire consultation from plant personnel on frequency of operational
training
PSI  The content of training module for plant personnel involved in operating the process are
developed utilizing data from PSI
OP  The OP should form the technical basis for the training and qualification program of plant
personnel
MI  The maintenance personnel should be thoroughly trained in the contents of the corrective
and preventive maintenance procedures
 There are several speciality training and qualification needs that should be obtained to
support MI activities such as welding, pressure vessel, tank and piping inspections, non-
destructive testing, vibration monitoring, etc.
CON  Contractor workers should be trained prior to perform the work they are hired to do
II  The findings of incident investigation may result in change to the training content and
increasing the frequency of refresh training
 Plant personnel should be trained in the lessons learned from investigations
CA  TNG-related information and documentation should be assessed during audit process

Table 8. Interrelations of PSSR element [3–5,17,21].

PSM Interrelates
Element Element Details
PSSR EP  PSSR information and resolution of recommendation should be accessible to all affected
plant personnel
PSI  Review and confirm construction and equipment is in accordance with design specifica-
tions prior to startup of a change or new process
PHA  Review and confirm that PHA has been done for new process
 Review and confirm that recommendation from conducted PHA has been completed prior
to startup of a change or new process
OP  Review and confirm safety, operating and emergency procedures are in place, and
adequate prior to startup of a change or new process
TNG  Review and confirm that training of affected personnel has been completed prior to
startup of change or new process
MI  Review and confirm that maintenance procedures are in place and adequate prior to
startup of a change or new process
MOC  Review and confirm that modified process meet the requirements contained in MOC
CA  PSSR information and documentation should be assessed during audit process

MI universally recognized as one of the most impactful tion should be communicated to all affected employers, thus
elements of a facility’s PSM program. Some might view it to they shall be used in other program including EP and CON
operate in its own separate universe, however, in reality its elements. Managing equipment deficiency may require
importance to and interrelationships with other PSM ele- changes to the process equipment, as well as ITPM program.
ments are unquestioned [11]. Table 9 tabulates the interrela- Thus, MOC and PSSR may need to be performed prior to
tion between MI element and other PSM elements. The changes.
purpose of MI element is to ensure the integrity and safe Interrelation of MOC element with other PSM elements is
operation through inspection and maintenance program and presented in Table 10. In PSM, anytime that process chemi-
QA. Equipment in contact with HHC forms the first line of cals, equipment, technology, or facilities are intended to be
defense in preventing uncontrolled catastrophic HHC release. changed, MOC requires procedures that guarantee advance
The second line of defense is typically a combination of con- consideration of impacts and approval of that change. There-
tainment and safety system. The MI program must ensure fore, up-to-date PSI and PHA outcomes are vital in order to
that components in both primary and secondary lines of address the technical soundness of proposed change and
defenses are designed, installed, and operated properly. assess the potential safety and health impact. Once the pro-
Thus, development of MI program must be supported with posed change is approved, the PSI, PHA, OP, TNG, and MI
accurate and up-to-date information from PSI, PHA, OP, elements must be considered and addressed whenever a
TNG, PSSR, II, and ERP elements [4,5,10,17,22]. MI informa- change is made to the PSM-covered process [3–5,23]. On the

Process Safety Progress (Vol.00, No.00) Published on behalf of the AIChE DOI 10.1002/prs Month 2016 5
Table 9. Interrelations of MI element [4,5,10,17,22].

PSM Interrelates
Element Element Details
MI EP  MI procedures, ITPM, and equipment deficiency information should be accessible to all
affected plant personnel
PSI  The ITPM procedures and program relies heavily on the data from PSI specifically RAGAGEP
 PSI is referred for the development of training module for maintenance personnel
PHA  In addition to the equipment that required in the MI program by the governing regula-
tion, the selection of equipment to be included in the MI program should also rely on
the identified PHA, that the failure could contribute to a process safety accidents and the
action to add protective equipment to serves as a safeguard against such accidents
OP  Placing the process in the appropriate mode of operation to support maintenance activity
requires the use of correct OP
TNG All the maintenance personnel involved in maintenance activities of covered area should be
trained in overview of the process, maintenance procedures, ITPM procedures, operating
procedures, safety and health hazards, emergency operations, and safe work practices
applicable to their job tasks
PSSR  Verifying equipment under MI program should be installed according to plan, standards,
etc. before start-up
MOC  Managing equipment deficiency may require the use of MOC
CON  MI procedures, ITPM, and equipment deficiency information should be accessible to all
affected contractors workers
II The findings of incident investigation may result in changes to the MI program
ERP  Equipment relied upon in the emergency response plan should be maintained as part of
the MI program
CA  MI information and documentation should be assessed during audit process

Table 10. Interrelations of MOC element [3–5,17,23].

PSM Interrelates
Element Element Details
MOC EP  Approved change of process should be notified to all affected personnel prior to start-up
PSI  Up-to-date PSI is required to support the generation of MOC in order to address the tech-
nical soundness of proposed change and assess the potential safety and health impact
 PSI must be updated accordingly if process change results in a change of PSI
PHA  While not mandatory, PHA may be performed to assess the impact of proposed change
on process safety
OP  OP must be updated accordingly if process change results in a change of OP
TNG  Plant personnel should be trained in the process change if the job tasks will be affected
by a change prior to start-up of the process
MI  Maintenance personnel should be trained in the process change if the job tasks will be
affected by a change prior to start-up of the process
PSSR  PSSR recommendation must be resolved prior to start-up in change
CON  Contractor workers should be informed and trained in change prior to start-up with the
change in place if necessary
CA  MOC information and documentation should be assessed during audit process

other hand, PSSR element is important in MOC after a pro- significantly interrelated with other PSM elements. The devel-
cess has been modified or shut down prior to ensure the oped PSM matrix has showed the interrelation between PSM
readiness. Approved changes should be communicated to all elements in structured manner and provides the flow of pro-
affected employers, thus they shall be used in other program cess safety data. As PSM program is poor without good com-
including EP and CON elements. MOC, when put in effect in munication and coordination among elements, the use of
isolation its benefit will not fully materialize. integration system to implement PSM becomes a possible
Finally, PSI, PHA, OP, TNG, PSSR, MI, and MOC programs approach in improving the effectiveness of implementation
will be assessed through CA element (Tables (4–10) to see PSM program from this perspective. At this point, informa-
whether the management system in place adequately tion of interrelation between the elements would be useful
addresses all the above PSM elements requirements [4,17]. to guide PSM data linkages that eases the data sharing in the
development of integration system which resulting up-to-
CONCLUSION date and consistent PSM data of any update. This is neces-
Analysis of interrelation between PSM elements showed sary to prevent safety implication and assist organizations
that PSI, PHA, OP, TNG, PSSR, MI, and MOC elements have compliance with the OSHA PSM regulation.

6 Month 2016 Published on behalf of the AIChE DOI 10.1002/prs Process Safety Progress (Vol.00, No.00)
 12. J.A. Klein and B.K. Vaughen, A revised program
LITERATURE CITED for operational discipline, Process Saf Prog 27 (2008), 58–
1. J. Atherton and F. Gil, Incidents that Define Process 65.
Safety, Wiley, New Jersey, 2008. 13. L.A. Long, M.L. Marshall, and J. Lay, Update on OSHA’s
2. L.A. Long, History of Process Safety at OSHA, Process Saf PSM national emphasis programs, Process Saf Prog 30
Prog 28 (2009), 128–130.
(2011), 303–306.
3. CCPS, Guidelines for Risk Based Process Safety, Wiley,
New Jersey, 2007. 14. H. Luo, The effectiveness of U.S. OSHA process safety
4. U.S. Occupational Safety and Health Administration management inspection - A preliminary quantitative eval-
(OSHA). OHSA Law & Regulations, 2011, Available at uation, J Loss Prev Process Ind 23 (2010), 455–461.
http://www.osha.gov/law-regs.html, Accessed on Decem- 15. B.A. Schuldt, Concept matrix approach to teaching man-
ber 20, 2014. agement information systems, J Learn Higher Educ 1
5. Department of Energy, Process Safety Management for (2005), 11–16.
Highly Hazardous Chemicals, US DOE, Washington, 1996. 16. R. Klopper and S. Lubbe, The matrix method of literature
6. A.C. Brackey, Process safety management: 21 Years plus or review, Alternation 14 (2007), 262–276.
minus what i wish i’d known then and what we can’t afford 17. CCPS, Guidelines for Auditing Process Safety Manage-
to forget now! Process Saf Prog 32 (2013), 260–263. ment Systems, 2nd Edition, Wiley, New York, 2011.
7. M.I. Rashid, N. Ramzan, T. Iqbal, S. Yasin, and S. Yousaf, 18. M. Alloco, Safety Analyses of Complex Systems: Consid-
Implementation issues of PSM in a fertilizer plant: An erations of Software, Firmware, Hardware, Human, and
operations engineer’s point of view, Process Saf Prog 32 the Environment, Wiley, Hoboken, NJ, 2010.
(2013), 59–65. 19. J.F. Louvar, Improving the effectiveness of process safety
8. K. Hanchey and J.R. Thompson, The challenge to imple- management in small companies, Process Saf Prog 27
ment and maintain an effective PSM program, Process Saf (2008), 280–283.
Prog 30 (2011), 319–322.
20. D.J. Leggett, Process safety in the future - A view from
9. CCPS, Guideline for Process Safety Documentation,
AIChE, New York, 1995. the chemistry, Process Saf Prog 23 (2004), 163–169.
10. B.K. Vaughen, J.F. Nagel, and M.J. Allen, Integrate plant 21. CCPS, Guidelines for Performing Effective Pre-Startup
reliability efforts with mechanical integrity, Process Saf Safety Review, Wiley, New Jersey, 2007.
Prog 30 (2011), 323–327. 22. CCPS, Guidelines for Mechanical Integrity Systems, Wiley,
11. C. Reese and B. Taylor, Surviving and thriving in the era New Jersey, 2006.
of enhanced OSHA PSM audits, Hydrocarbon Process 91 23. CCPS, Guidelines for Management of Change for Process
(2012), 47–48. Safety, Wiley, New Jersey, 2008.

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