The purpose of this document is to assist U.S. Department of Energy (DOE) contractors who
work with threshold quantities of highly hazardous chemicals (HHCs), flammable liquids or
gases, or explosives in successfully implementing the requirements of the Occupational Safety
and Health Administration (OSHA) OSHA Rule for Process Safety Management of Highly
Hazardous Chemicals (29 CFR 1910.119), hereafter referred to as the PSM Rule. Successful
implementation requires each contractor to study existing and required chemical process safety
management (PSM) systems to determine that a comprehensive program is in place.
Process safety management requires an ongoing effort to prevent catastrophic accidents
involving hazardous process materials and energies. It applies management principles and
analytic techniques to reduce risks to processes during the onsite manufacture, use, handling,
storage, and movement of chemicals. Its focus is on hazards related to the materials and energies
present in chemical process facilities.
The purpose of the PSM Rule is to prevent releases of HHCs (listed in Appendix A) that have
the potential to cause catastrophic fires, explosions, or toxic exposures. This objective is
achieved by first building safety into a process, and then keeping the facility operating safely
throughout its life cycle, by identifying process hazards and providing necessary controls over
the life of the process [Q36, Q47]. PSM integrates 14 elements to manage facilities, technology,
and personnel, as summarized in Table 1.1. The elements of the PSM system are employee
participation, process safety information (PSI), process hazard analysis (PrHA), operating
procedures, training, subcontractor safety, pre-startup safety review, mechanical integrity,
nonroutine work authorizations, management of change (MOC), incident investigation,
emergency management, compliance audits and trade secrets.
Other DOE Orders and OSHA rules address general industrial hazards, industrial hygiene, and
radiation protection. Thus, PSM is just one program in a comprehensive safety management
system. Figure 1.1 shows how PSM and other OSHA chemical safety programs apply to the
accident consequence continuum.
The following example shows how the PSM elements are integrated in actual practice. Pilot
studies indicate that higher yields can be obtained by maintaining higher temperatures in a
reaction vessel. A change in operating temperature must be approved by all technical and
support functions (MOC). The impact of this change is assessed though revision of the process
hazard analysis (PrHA), which results in a recommendation to modify the pressure relief system.
The modifications in temperature and pressure relief system mandate new steps for process
operators (Operating Procedures), who require training and verification in the new procedures
(Training). The modifications to the pressure relief system are made by the supplier (Contractor
Safety) and require that a portion of the process be shut down for this work. The work includes a
brazing operation requiring a Hot Work Permit (Nonroutine Work Authorization). Potential
impacts on the process require a review of emergency response plans (Emergency Planning).