14 Elements of Process Safety Management
Before we get into the 14 elements of Process Safety Management, let’s first look at what Process Safety Management Planning is.
PSM Planning is a critical part of any process safety management program. By definition, PSM planning is the “development of processes and procedures to identify, evaluate, and control hazards associated with the release of highly hazardous chemicals.”
It’s based on the idea of “zero incidents”, meaning that every process is analysed and risk assessed to prevent potential accidents or incidents.
PSM programs typically address four key areas:
- Process hazard analysis
- Operating procedures
- Training, and
- Maintenance
Other elements may include
- Mechanical Integrity
- Incident Investigation
- Emergency Response Planning, and
- Management Commitment
The 14 Elements of PSM
1) PSM Process Safety Information
This element requires developing and maintaining process safety information (PSI) for each covered process. The PSI must include information on the hazards associated with the process, as well as the equipment, materials, and personnel involved in the process.
2) Process Hazard Analysis
A hazard analysis must be performed for each covered process to identify potential hazards and develop controls to mitigate those hazards.
The process:
- The PHA process begins with a review of the process and identification of potential hazards.
- The team then evaluates the risks associated with those hazards and develops controls to mitigate those risks.
- Once the PHA is complete, the results are reviewed and approval is obtained from management.
- The approved PHA becomes the basis for developing the process safety management program.
3) Operating Procedures
Operating procedures must be developed for each covered process and must be followed by all personnel involved in the process. The procedures must address all aspects of the process, including start-up, shut-down, emergency response, and normal operation.
4) Employee Participation
Employees must be involved in all aspects of the PSM program, from hazard identification and analysis to developing operating procedures and training. Employees should also be encouraged to report any unsafe conditions or practices they observe.
5) PSM Training
All personnel involved in a covered process must receive training on the key elements of the Process Safety Management program relevant to their job duties. The training must be specific to the process and cover topics such as hazard identification and control, operating procedures, emergency response, etc.
6) Contractor Training
Contractors who work on or around covered processes must receive training on the elements of the PSM program relevant to their job duties.
The training must be specific to the contractor’s scope of work and cover topics such as hazard identification and control, operating procedures, emergency response, etc.
7) Pre-startup Review
A pre-startup review (PSR) must be conducted for all new or modified processes before start-up. The PSR must ensure that all process hazards have been identified and controls implemented to mitigate those hazards.
8) Mechanical Integrity
Equipment used in covered processes must be maintained safely and reasonably. A mechanical integrity program must be established to ensure that equipment is properly inspected, tested, and repaired/replaced as needed.
9) Management of Change
Any changes made to a covered process must be carefully planned and implemented to prevent any adverse impacts on process safety. Management of change (MOC) procedure must be followed to ensure all changes are reviewed and approved before implementation.
10) Emergency Planning and Response
An emergency response plan (ERP) must be developed for each covered process. The ERP must identify the potential emergencies that could occur and detail the steps that should be taken to respond to those emergencies. All personnel involved in the process must be trained on the ERP.
11) Incident Investigation
All incidents in covered processes must be investigated to determine the root cause(s) and to develop corrective actions to prevent future incidents.
A thorough incident investigation will include interviews with witnesses, a review of physical evidence, and an analysis of any relevant data (such as safety data sheets or maintenance records).
12) Recordkeeping
Records must be kept for all aspects of the PSM program, including process safety information, hazard analyses, operating procedures, training records, etc.
Good record-keeping is essential for two reasons: first, it helps you stay compliant with the law; and second, it helps you track the status of your hazardous materials.
13) Auditing
The PSM program must be audited regularly by qualified personnel to ensure that it is implemented effectively and complies with regulatory requirements. The audit scope should cover all aspects of the PSM system, from managerial oversight to operational procedures.
14) Trade Secret Protection
Process safety information considered a trade secret must be protected from disclosure to unauthorised personnel. There are a number of ways to protect trade secrets, including physical security measures, electronic security measures, and non-disclosure agreements.
- Physical security measures involve keeping the information in a secure location where only authorised individuals have access.
- Electronic security measures include storing the information on a password-protected computer or server, and backing up the data in a secure location.
- Non-disclosure agreements are contracts between the company and employees, contractors, or other parties that prohibit the unauthorised disclosure of trade secrets.
How to Implement Process Safety Management
When it comes to implementing Process Safety Management, there are a few key steps you need to take to get started.
