What Is OSHA’s Process Safety Management and How Can It Improve Safety Culture?

Want to give a boost to safety culture? Consider implementing the 14 elements of the Process Safety Management standard—even if you use no toxic chemicals on your shop floor.

Although the Occupational Safety and Health Administration specifically created the Process Safety Management standard to address how businesses handle hazardous chemicals, it’s an approach that any safety team can use to develop a framework for its safety program.

OSHA designed PSM as an analytical tool to help companies prevent harmful chemicals from being mishandled or released.

What Is OSHA’s Process Safety Management Standard?

The Process Safety Management standard sets guidelines for managing the release of dangerous and toxic chemicals. While there has been an increasing push to reduce the use of the most toxic chemicals in metalworking, there is still enormous risk of exposure in some shops to chemicals that can harm and even kill.

“The Process Safety Management standard targets highly hazardous chemicals that have the potential to cause a catastrophic incident,” OSHA notes in its Process Safety Management Guidelines for Compliance. “The purpose of the standard as a whole is to aid employers in their efforts to prevent or mitigate episodic chemical releases that could lead to a catastrophe in the workplace and possibly in the surrounding community.”

That means that in some instances, larger metalworking and manufacturing plants must comply with the PSM standard for highly hazardous chemicals, OSHA 1910.119.

How Can OSHA’s PSM Improve Your Safety Culture?

Clearly, if highly toxic chemicals are in use, your company must comply with PSM.

But here’s the thing: PSM is also a useful analytical tool for establishing the elements of a robust safety program—even if your company uses no highly hazardous chemicals. It’s a valuable approach because it looks across the entire process, taking an analytical perspective that is helpful when dealing with safety generally.

“Increasingly companies are turning to PSM as a best practice, regardless of whether they are engaged in covered processes,” notes a post on the Intelex Technologies blog.

A chief reason beyond the established PSM framework is that it focuses on employee involvement, which is critical to drive a culture of safety.

“The PSM standard places an appropriate level of importance on employee participation, acknowledging that the ability to influence companywide employee participation in safety initiatives can make or break safety outcomes,” the Intelex post adds.

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The 14 Elements of the Process Safety Management Standard

OSHA has crafted extensive guidance to help businesses understand and implement its PSM standard. The main instructional information can be found in OSHA 3132, Process Safety Management. In addition, OSHA has released multiple industry-specific guides as well.

OSHA developed PSM in accordance with the 1990 Clean Air Act Amendments, which specified that the standard require companies perform 14 specific elements:

1. Develop and maintain written safety information identifying workplace chemical and process hazards, and any equipment and technology used in the processes.
2. Perform a workplace hazard assessment that identifies potential sources of accidental releases, documents any previous potentially catastrophic releases, estimates the possible workplace effects, and details the possible health and safety effects.
3. Consult with employees and their representatives on the development and conduct of hazard assessments and the development of chemical accident prevention plans and provide access to these and other records required under the standard.
4. Establish a system to respond to the assessment findings that addresses prevention, mitigation and emergency responses.
5. Periodically review the assessment and response system.
6. Develop and implement written procedures for chemical processes, including procedures for each operating phase, operating limitations, and safety and health considerations.
7. Provide written safety and operating information for employees and employee training, emphasizing the hazards and detailing the required safe practices.
8. Ensure contractors and contract employees also receive information and training.
9. Train employees and contractors in emergency response procedures pursuant to section 126(d) of the Superfund Amendments and Reauthorization Act.
10. Establish a quality assurance program to ensure that initial process-related equipment, maintenance materials and spare parts are fabricated and installed consistent with design specifications.
11. Establish maintenance systems for critical process-related equipment, including written procedures, employee training, inspections and testing to ensure mechanical integrity.
12. Conduct pre-startup safety reviews of all new or modified equipment.
13. Establish and implement written procedures managing any changes to processes for chemicals, technology, equipment and facilities.
14. Investigate every incident that results in or could have resulted in a major accident and then modify processes and safety practices as appropriate.

These 14 elements—when stripped of their chemical references—apply to nearly all sound safety best practices and can help businesses comply with a host of OSHA and ANSI standards.

“It wouldn’t be a bad practice to document your activities as if you were under the watchful eyes of OSHA through a PSM program,” notes Michael Washington, a process safety specialist, in an abstract for a safety presentation.