Each
process should be evaluated separately to determine whether it is covered by
the PSM rule. If several distinct and separate processes at a facility use
the same highly hazardous chemical, coverage is determined by comparing the
maximum intended inventory of each process to the appropriate total quantity
for the chemical. Do not add up the inventory of all processes to determine
whether the facility is covered.
If
multiple processes at a facility are interconnected, they may be considered a
single process under the PSM rule.
Core Elements of the PSM Plan
The
PSM rule is a performance-based rule; that is, it does not prescribe how each
element is to be implemented.
Following
are recommendations for developing your site-specific PSM Plan in compliance
with the core elements required by the PSM rule.
Employee
participation. Develop a written plan of action
to implement the employee participation required by the PSM. Employers must
consult with employees and their representatives on the conduct and
development of the process hazard analysis (PHA) and on the development of
the other elements of process management. If you already have established
methods to keep employees and their representatives informed about relevant
safety and health issues, you may be able to adapt these practices and procedures
to meet the obligations of the PSM requirements for employee participation.
Process
safety information. Compile all written process
safety information before conducting any PHA. The compilation should be
completed under the same schedule required for the PHA. Make sure you
include:
Safety
data sheets (SDSs) meeting the requirements of the Hazard Communication
Standard (20 CFR 1910.1200) may be used to comply with information on the
hazards requirement to the extent they contain the required information.
Process
hazard analysis. A process hazard analysis (PHA),
sometimes called a process hazard evaluation, is an organized and systematic
effort to identify and analyze the significance of potential hazards
associated with the processing or handling of highly hazardous chemicals. The
PHA focuses on equipment, instrumentation, utilities, human actions (routine
and nonroutine), and external factors that might impact the process.
Determine and document the priority order for conducting PHAs that includes
such considerations as the extent of the process hazards, the number of potentially
affected employees, the age of the process, and the operating history of the
process.
Standard
operating practices (SOPs).
Operating procedures describe tasks to be performed, data to be recorded,
operating conditions to be maintained, samples to be collected, and safety
and health precautions to be taken. The procedures need to be technically
accurate, understandable to employees, and revised periodically to ensure
that they reflect current operations. Use the process safety information
package as a resource to better ensure that the operating procedures and
practices are consistent with the known hazards of the chemicals in the
process and that the operating parameters are accurate.
Generally,
procedures should be written at a level of detail so that an experienced
operator who is not familiar with a particular process unit could run the
unit with minimal supervision or help from other operators, or the least
experienced operator released for unsupervised work could run the unit.
The
following seven steps are suggested for developing SOPs:
Pre-start-up
safety review. The initial start-up procedures
and normal operating procedures need to be fully evaluated as part of the
pre-start-up review to ensure a safe transfer into the normal operating mode
for meeting the process parameters. Piping and instrument diagrams
(P&IDs) are to be completed along with having the operating procedures in
place and the operating staff trained to run the process before start-up. Any
incident investigation recommendations, compliance audits, or PHA
recommendations need to be reviewed as well to see what impacts they may have
on the process before beginning the start-up.
Mechanical
integrity program. Establish and implement written
procedures to maintain the ongoing integrity of process equipment. Elements
of a mechanical integrity program include the identification and
categorization of equipment and instrumentation, inspections and tests,
testing and inspection frequencies, development of maintenance procedures,
training of maintenance personnel, the establishment of criteria for
acceptable test results, documentation of test and inspection results, and
documentation of manufacturer recommendations as to meantime to failure for
equipment and instrumentation.
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Primary PSM Plan Pieces
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