3.0 PSM Program Development
This section describes a logical process for developing and implementing a PSM program at sites
with processes covered by the PSM Rule.
3.1 Defining Process Safety Management Policy, Goals, and Objectives
Many of the elements of the PSM Rule can be applied to chemical safety programs in general.
For years DOE safety programs have been concerned with releases of radioactive materials,
without a commensurate emphasis on chemical safety. Therefore, affected DOE contractors
should develop a policy giving adequate attention to process safety management. This policy
must integrate existing programs that may be operating independently.
The primary goal of process safety management is to minimize catastrophic releases of HHCs.
The minimum program goal is compliance with the PSM Rule. Although the immediate goal is
compliance, contractors should focus on the ultimate goal of preventing all hazardous chemical
Although the PSM Rule does not emphasize the same elements contained in the Chemical
Manufacturers Association's Responsible Care Process Safety Code, the Center for Chemical
Process Safety (CCPS) PSM program or the American Petroleum Institute Hazard Management
program, these programs address nearly identical issues. Contractors may wish to supplement
their PSM programs with concepts from industry programs or applicable in-house programs. In
addition, contractors should be familiar with the proposed EPA Risk Management Program
elements and incorporate these into their policies, goals and objectives. A comparison of the
OSHA PSM and EPA's proposed Risk Management Program is provided in Appendix C.
3.2 Process Safety Management Planning
Identifying Chemical Processes Covered by the Rule
DOE contractors can determine the applicability of the PSM Rule by comparing the list of HHCs
in Appendix A of the OSHA Rule with their chemical inventory information. Because the list of
regulated substances which invoke coverage under EPA's Risk Management Program differs
somewhat from those in the OSHA Rule, it is recommended that contractors use the integrated
OSHA and EPA listing of HHCs in Appendix A to avoid doing this task twice. This assumes that
contractors have systems in place for tracking chemical inventory and use. The TQs of the HHCs
listed in Appendix A apply not to aggregate quantities at a site, but to individual processes which
must be sufficiently separated from each other so that a release, fire, or explosion in one process
will be unlikely to affect others. When processes are not adequately separated, aggregate
quantities of individual HHCs used in adjacent processes are used for comparing TQs.
Contractors should also check inventories of flammable gases and liquids and any manufacturing
Where quantities of HHCs approach but do not exceed TQs, or chemicals are used which, though
not on the OSHA list of HHCs, are known to be highly hazardous, DOE contractors may want to