PSM Consulting Service Features
Provides assistance with the development and implementation of the 14 elements of your PSM program
Conducts triennial audits of your 14 elements of PSM
Delivers employee training on required safety-specific health hazards
Updates and submits your PHA every five years
14 Elements of Process Safety Management
Employee Participation [29 CFR §1910.119(c)]
Verify that all employees are involved in the development of your process hazard analysis (PHA) and the information is made available to them.
Mechanical Integrity [29 CFR §1910.119(j)]
Ensure your equipment has been inspected and tested, deficiencies addressed, quality assured, and written procedures were developed for maintaining that equipment.
Process Safety Information [29 CFR §1910.119(d)]
Ensure that all employees can access and understand the technical data regarding highly hazardous chemical (HHC) risks they may face on the job.
Hot Work Permit [29 CFR §1910.119(k)]
Review all hot work permits conducted on or near the covered processes to ensure it meets the fire prevention and protection requirements prior to beginning work.
Process Hazard Analysis (PHA) [29 CFR §1910.119(e)]
Identify and evaluate processes that pose safety hazards, and address those that pose the greatest risk first.
Management of Change [29 CFR §1910.119(l)]
Evaluate proposed changes for their impact to health, safety and operating procedures, and notification to employees of these changes.
Operating Procedures [29 CFR §1910.119(f)]
Analyze instructions for all operational procedures, including initial startup, normal operations, temporary operations and emergency shutdown.
Incident Investigation [29 CFR §1910.119(m)]
Review past incidents to ensure the investigations were initiated promptly, the required information was documented and any findings were promptly addressed.
Training [29 CFR §1910.119(g)]
Review logs of employee training on safety-specific health hazards, emergency operations and safe work practices, including refresher training conducted at least every three years.
Emergency Response and Planning [29 CFR §1910.119(n)]
Evaluate your Emergency Action Plan for compliance with 29 CFR §1910.38, including the handling of small chemical releases.
Contractors [29 CFR §1910.119(h)]
Review records that confirmed a contractor’s safety performance prior to their starting a project on a covered process, and that they were informed of potential risks and health hazards.
Compliance Audits [29 CFR §1910.119(o)]
Certify that you have evaluated your compliance with the regulatory requirements by conducting a triennial audit and addressing all findings in a timely manner.
Pre-Startup Safety Review [29 CFR §1910.119(i)]
Review documentation of pre-startup safety procedures prior to initial operations and following any modification that required a change in the safety process information.
Trade Secrets
Check that all information necessary to comply with the PSM standard, regardless of the trade secret status of that information, is available to PSM personnel.
PSM: What is it and who needs it?
Watch to find out who Process Safety Management (PSM) applies to, who's exempt, and what the standard requires
Additional Supplemental Services
PSM FAQs
What is Process Safety Management (PSM)?
expand_moreexpand_lessProcess Safety Management (PSM) is a performance-based, regulatory-required management system designed to protect workers from highly hazardous chemicals (HHC).
Who is required to comply with Process Safety Management (PSM)?
expand_moreexpand_lessPSM applies to all companies that deal with any of more than 130 toxic and reactive chemicals in quantities listed in Appendix A of OSHA’s Process Safety Management of Highly Hazardous Chemicals Standard (29 CFR 1910.119).
Where can I get the book of standards where I can find 29 CFR 1910.119 for Process Safey Management (PSM)?
expand_moreexpand_lessJ. J. Keller offers quick access to OSHA's 1910 General Industry and 1926 Constructure regulations along with other regulatory requirements within RegSense.
Does OSHA require all 14 elements of the PSM standard be in a written format?
expand_moreexpand_less1910.119(d)(3)(ii) requires the employer document that PSM covered equipment complies with recognized and generally accepted good engineering practices. Additionally, 1910.119(e)(1) requires documentation of a PHA. Though OSHA doesn't outright say all 14 elements must be documented, remember "that which was not documented, was not done" meaning it's hard to demonstrate to OSHA something that isn't documented.
Are the quantities of different Appendix A-listed highly hazardous chemicals (HHCs) when stored in close proximity considered aggregate for the purpose of determining PSM threshold quantity (TQ)?
expand_moreexpand_lessYes. Refer to the TQs listed in 1910.119, Appendix A and consider how each will affect a potential incident or event in combination with the other.
What is the definition of flammable liquids in reference to the PSM standard?
expand_moreexpand_lessThe PSM standard at 1910.119(a)(1)(ii)(a) applies when the threshold quantity (TQ) hits 10,000# of a flammable liquid. Typically, they have flashpoints below 100 degrees F. PSM does have some exemptions, like hydrocarbons. Users should always refer to a product or chemical’s safety data sheet (SDS) and compare with the classifications outlined in 1910.119.
How do I determine if methanol meets the flammable requirement for PSM? I don't see it listed in App A.
expand_moreexpand_less"Flammability" criteria for the PSM standard is Category 1 flammable gases (as defined by 1910.1200©) or flammable liquid with a flashpoint below 100 °F (37.8 °C) on site in one location, in a quantity of 10,000 pounds (4535.9 kg) or more. The only exceptions are Hydrocarbon fuels used solely for workplace consumption as a fuel or flammable liquids with a flashpoint below 100 °F (37.8 °C) stored in atmospheric tanks or transferred which are kept below their normal boiling point without benefit of chilling or refrigeration.
What about water mixtures? What do we do if it is listed in the PSM standard Appendix A but is not a chemical that is used when it is in water, such as anhydrous?
expand_moreexpand_lessWhen it comes to water mixtures, there are so many variables that employers will want to review Appendix A to see what information is available for their specific mixtures.
Does PSM apply to consumer commodities?
expand_moreexpand_lessThere is the retail exemption, so you will want to look at it from the end user’s perspective. OSHA says apply the 50% rule. If half of your income is from direct sales are from retail of chemical quantities, you will apply. Warehouses and storage facilities do fall under PSM.
For PSM, is there a minimum distance to be considered as remote?
expand_moreexpand_lessLOI Feb 15, 1994 - "When processes are in close proximity to each other such that an incident in one process could involve the potential release of a highly hazardous chemical (HHC) in another process, these processes are considered to be a single process. Processes which are not in close proximity are considered to be at a remote distance." It's really up to the employer to determine and is based on type of chemical, quantity, equipment, and other factors.
Is propane covered under PSM?
expand_moreexpand_lessThe general response is “yes”. It is flammable and the TQ is 10,000#. OSHA published a letter of interpretation on March 14, 2000, that gives a great deep dive on PSM and propane.