PSM Program Review Checklist

1 Occupational Safety & Health Program Page 1 of 14 September 2011 PSM Program Review Checklist Use this Checklist to help determine employer compliance with the Process Safety Management Standard issued by the Occupational Safety and Health Administration. Please note that the Checklist does not include all of the standard s requirements and does not reflect all OSHA letters of interpretation or compliance directives in particular situations. There are 3 elements to a Review of a PSM Program : 1. Documentation Review examination of the documentation of the programs required by the standard.

2 2. Field Inspection & Verification examination of the physical covered process; its equipment, piping, instrumentation, procedures, and operation. 3. Interviews discussions with employees and contractors to determine if the implemented Program matches the Program outlined in the documentation. In order to gather the information needed to audit a PSM Program the following questions need to be asked for each PSM Program element Who What When Where Why How Who Who is responsible for developing and implementing each of the Program elements?

3 What What are the requirements and contents of each Program element? When When are the required actions for each element completed and when were they required to be completed? Where Where have actions been implemented or changed? Why Why have the implementation decisions and priorities been made as recorded in the documentation? How How is the Program implemented and how is the Program s effectiveness evaluated and improved? An essential part of verifying Program implementation is to audit the flow of information and activities among the elements.

4 When information in one element is changed or when action takes place in one element that affects other elements, an auditor/reviewer should examine a sample of the related elements to see if the appropriate changes and followup actions have taken place. The following example demonstrates the interrelationship among the elements: During a routine inspection of equipment (Mechanical Integrity), the maintenance worker discovers a valve that no longer meets the applicable code and must be changed. Because the type of valve is no longer made, a different type of valve must be selected and installed (Management of Change).

5 The type of valve selected may mandate different steps for the operators (Operating Procedures) who will require training and verification in the new procedures (Training). The rationale for selecting the type of valve must be made available for Review by employees and their representatives (Employee Participation). When the new valve is installed by the supplier (Contractors), a qualified and safe contractor must be selected to perform the work (Contractor Management). The work will involve shutting down part of the process (Pre-startup Safety Review ) as well as brazing some of the lines (Safe Work Practices - Hot Work Permit).

6 The employer must Review the response plan (Emergency Planning) to ensure that procedures are adequate for the installation hazards. Although Management of Change provisions cover interim changes, after the new valve is in place the Process Safety Information will have to be updated before the (Process Hazard Analysis) is updated or revalidated, to account for potential hazards associated with the new equipment. Also, inspection and maintenance procedures and training will need to be updated (Mechanical Integrity). In summary, 12 PSM elements can be affected by changing one valve.

7 A reviewer/inspector/auditor/compliance officer would check a representative number of these 11 elements to confirm that the required follow-up activities have been implemented for the new valve. Occupational Safety & Health Program PSM Program Review Checklist Page 2 of 14 September 2011 Application of PSM Standard to Facility - (a) Does the workplace have any of the following: A process which involves a chemical at or above the specified threshold quantities listed in Appendix A of the PSM Standard (attached to Checklist ); or A process which involves a flammable liquid or gas [as defined in (c)] on site in one location, in a quantity of 10,000 pounds ( kg) or more.

8 Exemptions: A threshold quantity of flammable liquids if it is stored in atmospheric tanks or transferred without the benefit of chilling or refrigeration Hydrocarbon fuels used solely for workplace consumption as a fuel ( , propane used for comfort heating or gasoline for vehicle refueling.) These fuels cannot be part of a process containing other highly hazardous chemicals covered by the PSM standard. Retail facilities. Oil or gas well drilling or servicing operations. Normally unoccupied remote facilities. Note: for determining coverage by the PSM standard, the quantity of flammable liquids stored in atmospheric tanks may be excluded from the quantity in the covered process pursuant to the Meer Decision.

9 Important interpretation: June 11, 2007 OSHA defines on-site in one location for PSM to mean that the standard applies when a threshold quantity of highly hazardous chemical (HHC) exists within an area under the control of an employer or group of affiliated employers. It also applies to any group of vessels that are interconnected, or in separate vessels that are close enough in proximity that the HHC could be involved in a potential catastrophic release. ** IF THE WORKPLACE HAS ANY OF THESE OPERATIONS OR PROCESSES, IT MUST COMPLY WITH THE PSM STANDARD.

10 ** Examples of industries that may have highly hazardous chemicals and processes covered by the PSM standard: Industrial production of organics and inorganic materials Paints Pharmaceuticals Adhesives Sealants and Fibers Petrochemical facilities Paper Mills Food Processing with Anhydrous Ammonia over the TQ Conversion Example Gallons to lbs conversion = gallons x x specific gravity of the liquid = lbs of liquid Example: Weight of 10,000 gallons of gasoline = 10,000 x x = 61,559 lbs Occupational Safety & Health Program PSM Program Review Checklist Page 3 of 14 September 2011 YES NO Employee Participation (c)(1) Has the employer developed a written plan of action for implementation of employee participation?