1. Introduction to Process Safety Management (PSM) of Highly Hazardous Chemicals
Aimed at preventing unwanted releases of hazardous chemicals especially into locations which could expose employees and others to serious hazards
Provides a systematic approach to evaluating the “whole process”
Employers develop the necessary expertise, experiences, judgement and proactive initiative within their workforce to properly implement and maintain and effective PSM program
Targets highly hazardous chemicals that have the potential to cause a catastrophic incident
Why should you care about PSM?
For our own personal safety and the safety of those who work around us.

2. Major Incidents 1984 - Mexico City
Union Carbide Corp, Bhopal India
Phillips Petroleum, Pasadena Texas
ARCO Petroleum, Channelview Texas
IMC, Sterlington Louisiana
Let’s talk about the “why” of PSM.
Unexpected releases of highly hazardous chemicals have been reported for many years. No matter the industry that uses these highly hazardous chemicals there is a potential for accidental releases anytime, they are not properly controlled.
1984 LPG explosion in Mexico City 650 deaths
1984 process leak at Union Carbide in Bhopal, India 2000 deaths
1989 explosion at Phillips Petroleum in Pasadena, TX 23 deaths and 132 injuries. Also just had an accident in June 1999 that killed 2 and in March 2000 that killed 1 and injured 71.
1990 explosion at ARCO in Channelview,TX 17 deaths
1991 explosion at IMC in Sterlinton, LA 8 deaths and 128 injuries.
While these incidents have drawn national attention to the potential for major catastrophes, the public record is filled with information concerning many less notable releases. Though these incidents do give us some background on the need for PSM, they still allow us some distance from the problems. Take a minute to think of the potential for a catastrophic release here at MLI.
OSHA looked at these incidents and new something needed to become a Federal Regulation. They looked at the companies that were successful and asked, what do they have in place to prevent or mitigate these releases that lead to these catastrophic events? The following slide shows some of their finding of successful programs.

3. 14 Elements to PSM Employee Participation Process Safety Information
Process Hazard Analysis
Operating Procedures
Training
Contractors
Hot Work
Mechanical Integrity
Management of Change
Pre-Startup Safety Review
Incident Investigation
Emergency Planning and Response
Compliance Audits
Trade Secrets
They found fourteen programs that helped prevent or mitigate the release of Highly Hazardous Chemicals. They are listed in this slide.

4. The 14 Elements System Wide Prevention Reaction Control
Process Safety Information
Process Hazard Analysis
Employee Participation
Hot Work
OSHA requires that covered process comply by implementing and adhering to the fourteen elements of this standard. To help organize ones thinking, the fourteen elements can be grouped into four major areas.
System Wide: To successfully establish an effective PSM system a process facility must plan effectively. Effective planning requires involvement from all employees within a facility
Prevention: Incident reduction requires a determination of the current level of risk and then the implementation of controls to reduce that risk.
Reaction: When an incident does occur, a facility must be ready to handle it quickly and effectively
Control: To remain effective a PSM system must be evaluated and updated as changes occur within the facility.
As you can see MLI has addressed the majority of these elements over the last year.
Mechanical Integrity
Trade Secrets
Training
Operating Procedures
Contractors
Reaction
Control
Management of Change
Emergency Planning and
Response
Pre-Startup Safety Review
Incident Investigation
Compliance Audits

5. Employee Participation Everyone plays a part
PSM is far and beyond just a “program,” it is the new way of managing process hazards. Meeting the requirements of this standard requires the dedication of everyone within a facility, from the top executive to the operator in the field.
President/CEO
Ultimate authority and decision-maker for PSM compliance
Directors/Vice Presidents/General Managers
Approve departmental objectives and allocate resources to achieve departmental PSM objectives
Department Managers
Establish departmental PSM objectives and develop an implementation plan to achieve PSM objectives
Safety Department
Develop, in cooperation with the operating units, specific program goals and expected outcomes to meet regulatory requirements and coordinate implementation of PSM with the operating units
Every employee has the accountability, authority, and organizational freedom to
Initiate actions to prevent the potential or actual release of any hazardous chemical
Identify and record any process safety concerns
Initiate, recommend, and provide solutions to process safety concerns, through designated channels and to then verify the application of solutions

6. You Make the Difference
Your Participation is a critical part of PSM
The participation of employees is required for an effective PSM system. The participation will, at a minimum, involve two-way exchange between a company and its employees and their representatives. During this exchange MLI will elicit and respond to employees’ concerns and suggestions regarding PSM. Employee participation may also involve active participatory duties in the various PSM related functions.
What are the benefits of your participation?
This participation is vital to promote ownership in any system, especially one as large as PSM. The broad base of knowledge and experience provides the best advantage for developing a system, within a facility, that will not only be usable but will also be used.
How do employees currently participate?
Conduct and development of process hazard analyses
Development of employee training programs
Program and operating procedure development and review
Incident Investigations
Pre-Startup Safety Reviews (PSSR)
Unit safety meetings
Nothing happens unless we pull together

7. Process Safety Information
To provide an adequate database to support the required elements of a process safety management system it is necessary to compile and document information concerning process chemicals, technology, and equipment. This information is intended to provide a foundation for identifying and understanding the hazards associated with the process.
Process Chemical Information - Includes toxicity, permissible exposure limits, physical data, reactivity, corrosion, and erosion effects, thermal and chemical stability, and the potential effects of accidental mixing of different chemicals. MSDSs provide this information
Process Technology Information - Includes a block flow diagram or a simplified process flow diagram showing the flow of material and process chemistry, evaluation of the results of a change, inventories of chemicals to be used, and safe upper and lower limits for parameters such as temperature, pressure, flow, and composition.
Process Equipment Information - Includes materials of construction, piping and instrument diagrams, electrical classification, design codes and standards used, safety systems, and relief and ventilation system designs. Documentation will verify equipment follows generally accepted good engineering practices.
Process safety information is to be kept for the lifetime of the process and updated whenever changes, other than replacement-in-kind, are made.
Provides the foundation for understanding the
chemical, technical, and equipment hazards
associated with the processes
Retains basic research and development
information to guide future efforts

8. Process Hazard Analysis
PHAs are the cornerstone of an
effective hazard management
program and are aimed at reducing
The PHA is the cornerstone of an effective hazard management program. It is an in-depth review of a process to identify it’s current level of risk. It can significantly reduce incidents through it’s orderly and systematic approach for identifying and analyzing the significance of potential hazards within processes involving highly hazardous chemicals.
What is “RISK”?
Risk = Severity + Probability - When you reduce either, you reduce risk.
To ensure the PHA is consistent with the current process, PHAs will be updated and revalidated at least every five years. PHAs, updates, and revalidation for each covered process, with documented resolution of recommendations, for the life of the process.
risk
RISK = SEVERITY + LIKELIHOOD

9. Operating Procedures Ensures that all individuals
The purpose of operating procedures is to ensure that facilities carry out all operations in a safe, consistent, and an efficient manner. The importance of having accurate and up-to-date procedures cannot be overstated. The procedures used within a facility provide not only instructions for completing a task but also are the foundation for a facility training program. Procedures also provide a basis for the employees thinking and reasoning.
Procedures need to include:
Steps for each operating phase
Initial start-up and startup after a maintenance or emergency shutdown;Normal, temporary, and emergency operations;Normal and emergency shutdowns.
Operating limits
Consequences of deviations,Steps required to correct or avoid deviation
Safety and health considerations
Process chemicals’ properties and hazards,Necessary precautions to prevent exposure,Control measures if physical or airborne exposure occurs,Quality control of raw materials and control of hazardous chemicals inventory,Safety systems and their functions.
Annual review and certification of the operating procedures ensure they are current and accurate.
Ensures that all individuals
are doing their job, the same way
and in the safest manner
possible

10. Awareness causes Action
Training
Training is your map through the maze.
As part of a PSM system, training ensures that employees handle highly hazardous processes in a consistent and safe manner. The goal of training is to have a work force that understands the nature, hazards, and problems arising from process operations.
The amount of training isn’t as important as the quality of the training
While the program requirements are the same for all individuals operating or involved in a covered process, the contents may differ based upon the job functions of the position.
A training program contains three requirements
Initial Training
Facility Safety Overview, Facility Process Overview, and Operating Procedures
Refresher Training (for operators, every three years)
Periodic training on unchanged processes, policies and procedures and the review of all accidents and near misses in the past three years.
Supplemental Training (MOC)
Training on new or revised process information, policies and procedures, introduction of new chemicals, process changes, installation of new equipment, etc.
All initial, refresher, and supplemental training will be documented. This documentation will contain the identity of the employee, the date of training, and the method used to objectively verify that they understood the training
Awareness causes Action

11. Contractors Contractors need to be informed of the
Chemical 1 (ABC)
Chemical 2 (123)
Review (Hazards)
As we find it necessary to have certain tasks done by contractors, these facilities need to ensure that the actions of these contractors do not lead to a catastrophic event. These facilities control these incidents through the selection, training, and continued evaluation of on-site contractors.
Needing to keep everyone safe is one reason why we train contractors. - The more they know about our process the safer “we” are.
Guidelines, to control the activities of on-site contractors, will include provisions for the following elements and responsibilities:
Selection
Review and evaluation of a contractor’s safety record, injury/illness rates, safety program, and training; Communication of known process hazards related to the contract work; Review of contractors work experience, practices, and qualifications
Training
Provide initial on-site training to contract employees covering safety rules, hazard communications, hazardous work permitting requirements, and emergency response; specific training that covers hazards and controls unique to the unit to be worked in
Evaluation
Periodic evaluation that the contract employer has provided training to their employees that is equivalent to a direct-hire employee, maintain an injury/illness log for each contract employer
Contractors need to be informed of the
potential hazards related to the Process

12. A Hot Work Permit is Required.
This element establishes the criteria to ensure any work that may cause a source of ignition is done safely. This includes open flame, running combustible engines, running electronics and test equipment that is not intrinsically safe, grinding, drilling, or any other possible
source of ignition.
A Hot Work Permit is Required.
One way to reduce the potential for a catastrophic event is through the control of non-routine jobs. These types of jobs, by their nature, offer the greatest potential for an unwanted incident because normal controls are usually bypassed and/or disabled so the work can be done.
These permits are intended to ensure that unit managers, unit employees, and maintenance personnel are aware of the work being done and that they have ensured all safety precautions have been taken before the work starts. Maintenance of and adherence to these procedures, that control the performance of non-routine or hot work jobs, is required.

13. Mechanical Integrity
Critical equipment is identified, designed, installed, and properly maintained
A mechanical integrity (MI) program identifies required test and inspection needs on installed systems and equipment. In addition, it provides assurances that equipment has been fabricated, installed, or repaired according to generally accepted good engineering practices.
The MI program will apply to pressure vessels and storage tanks, piping systems and components, relief and vent systems and devices, control systems, emergency shutdown systems, and pumps.
Training of maintenance personnel
An overview of process chemicals and associated hazards, Maintenance personnel will be trained in maintenance related procedures, and The program will identify crafts that require special training or certification, such as welders, machinists, NDE inspectors, etc.
Correction of defects
Deficiencies outside established limits must be corrected before further use of equipment, Justification requirements if repairs are not made before further use
Quality assurance
Fabrication, Installation, and Repair QA will ensure that materials, spare parts and equipment are suitable for the process intended
Employees maintaining equipment are trained to do so
Defects are resolved before continued use of equipment

14. Ensures changes are not made without due consideration
Management of Change
Ensures changes are not made without due consideration
To remain effective the system must be continually evaluated and updated as changes occur within a facility.
Why do we manage change?
The safe operation of any process requires not only initial design, construction, operation, and maintenance considerations but also requires the control of changes to or within the process. Changes can be obvious (like the installation of a new sized pump) or subtle (like the changing of gasket material). Unintentional and unintended change can produce unpredicted events that may result in explosions, fires, and injuries. A Management of Change(MOC) system is set up to prevent these events by controlling change. “Replacement-in-kind” is exempt from this requirement.
What is “replacement-in-kind”?
MOC procedures will address the following areas before a change is made to the process:
Time period for the change, Technical basis for the change, Health/Safety considerations, Changes to operating and maintenance procedures, Authorization requirements for proposed change
All employees (operations and maintenance) and contractors involved in or affected by the process, are informed of and trained in the change as early as practical before the change
Improves communications among facility employees affected by the change

15. Pre-Startup Safety Review
The Pre-Startup Safety Review (PSSR) forms the final check for new or significantly modified processes. It requires that all actions required have been completed to ensure safe operation of the process. Several actions are confirmation that other sections (Process Safety Information updated, Management of Change completed) of the PSM standard have been accomplished.
Gives different groups input for proposed changes
Facilities will conduct a PSSR for:
New facilities and Significant modifications that require a change in the process safety information
The PSSR will ensure and confirm that:
Process construction and equipment is according to design specifications
Safety, operating, maintenance, and emergency procedures are in place and are adequate
A risk analysis has been performed and recommendations have been resolved or carried out for new facilities
Management of change requirements has been met for modified facilities
Training of employees involved in or affected by the process has been completed.
The final "thought stop" to make
sure a new or changed facility
doesn't contain any surprises

16. Incident Investigation
Spotlights the chain of events leading to an incident, to avoid a future occurrence
Even with the finest planned and implemented PSM system, the potential for a major or potentially major incident is ever present. If this potential becomes a reality it becomes necessary to investigate the causes that led to the incident.
Why do we investigate?
The focus of these investigations is to identify the factors leading to and causing the incident, and then using this information to develop corrective actions to prevent their recurrence.
What is a near-miss?
An undesired event that under different circumstances could have or if left unresolved may result in a serious incident.
Investigation guidelines will address the following areas:
Assemble an Investigation team
Describe “What Happened”, determine “How” it happened, understand “Why” it happened, and provide suggestions for corrective actions that will prevent recurrence.
Reporting
Communication of results
Near-misses also require an investigation. They are not minor incidents, they are free spins on the wheel

17. Emergency Planning and Response
Small problems can become major if not handled properly
So the unexpected happens, what do we do now?
Emergency planning and response is key to reducing the consequences to such events.
Planning and response systems will address:
Alarm systems
Response to emergencies
Evacuation plans
Emergency planning
Written plans allow everyone to know what to do in the event of an emergency

18. Incre Compliance Audits
Audits can verify if programs are in place and measure their effectiveness
Auditing is a fundamental tool for ensuring that a PSM system is in place, working, and effective. Audits enable the identification of system weaknesses and provide a vehicle for the initiation of appropriate corrective actions.
The only way we can see if it works, is to check
Facilities are required to complete a compliance audit of their PSM programs at least every three years. These audits should ensure that effective PSM programs are in place and working.
Incre
ases the awareness of process safety throughout a facility, by reviewing documentation, inspecting facilities and interviewing employees

19. Trade Secrets Pssst! Any information needed to comply
Top
Secret
All necessary information, despite trade secret status, needs to be made available to individuals involved in complying with the PSM standard.
These compliance activities may include:
Gathering process safety information
Process hazard analyses
Operating procedures
Incident investigations
Emergency response and planning
Compliance audits
MLI may take steps to protect against the unauthorized disclosure of information to third parties. These steps may include the signing of a confidentiality agreement.
Any information needed to comply
with PSM must be available
"Sensitive" material may require the
signing of a confidentiality
agreement before it is provided

20. Benefits of PSM For the Employee
reduces chances of being injured by catastrophic releases
For the Environment
reduces chances of loss of containment of Highly Hazardous Chemicals
For the Community
Creates a sense of security
What are the benefits of PSM?
A major benefit, beyond your safety, is the continued operation of this facility.
Other benefits would be in the following areas
Health and Safety-Reduction of minor incidents and injuries, improvements in ergonomics, reduction of chronic safety problems, and increased morale
Economic - Enhanced production due to fewer process disruptions, integrated approach to design, construction and operation, better trained employees
Environmental - Reduction and control of a major release that could potentially affect the public.
For the Facility and Equipment...
Increases reliability and reduces unscheduled downtime
For the Customer...
Provides a reliable, steady flow of product from a responsible supplier
For the Industry...
Contributes to overall reduction in catastrophic incidents