March 5, 2021
Facilities (buildings, containers, or equipment that contain a process) that use processes that involve highly hazardous chemicals with threshold values at or above those specified in Appendix A of the Process Safety Management (PSM) of Highly Hazardous Chemicals Standard (29 CFR 1910.119, Appendix A) or flammable liquids or gas of 10,000 pounds or more must comply with the requirements of PSM rule (29 CFR 1910.119) and implement a formal PSM Plan.
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.
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.
It is important that your organization understand the Process Safety Management of Highly Hazardous Chemicals Standard, especially when it comes to hazardous waste transportation & disposal in Arizona.
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