Curtis Management Resources
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Process Safety Management

The Twelve Elements

Process and Chemical Safety Information
The standard requires that the facility document critical process and chemical safety information such as toxicities, PEL's, physical properties, chemical stability, and effects of mixing.
Process Technology
Companies are required to develop critical process technology information such as process chemistry, safe operating limits, deviation consequences, and maximum safe inventories.
Equipment and Control System Design Basis
Each covered process must develop a complete equipment and control system design basis, including such information as applicable standards, materials of construction, relief design, control system set points, alarm points, interlock logic, and, for newer processes, heat and material balances.

These must be developed as part of the design for new units, or must be recreated for existing units.

Mechanical Integrity
Companies are required to ensure that critical safety systems do not deteriorate with time or during modification or construction activities. Procedures must also be developed that define the inspection methods and intervals, repair and replacement routines, and equipment integrity criteria for each covered piece of equipment.
Standard Operating Procedures
Processes handling materials with catastrophic potential must be run by knowledgeable personnel using the best methods and procedures. In order to ensure that this happens, the PSM standard requires that responses to all anticipatable operating situations be standardized, reviewed for deficiencies, documented as Standard Operating Procedures (SOPs), and used by all operations personnel.
Emergency Response Procedures
Because facilities exceeding the PSM thresholds have the potential to effect entire communities, the development of comprehensive emergency response procedures for the facility, the local emergency response agencies, and the community is vital.
Contractor Control
In the past decade, the failure of some companies to ensure that contractor personnel were fully aware of process hazards and procedures has contributed to the deaths of dozens of employees and the loss of millions of dollars in equipment and lost production. For companies utilizing contract personnel, explicit procedures are required to ensure that contract personnel are no less capable than the company's employees.
Employee Participation
One of the unfortunate lessons learned from many chemical plant disasters is that operating and maintenance personnel were often aware of problems, but were not able to get this information into the hands of managers with the authority to correct the situation. In order to ensure that this does not happen in the future, covered facilities are required to develop effective procedures to allow the participation of employees at all levels in the design, review, and operation of the facility.
Process Hazard Analysis
Because of the potential loss of life and damage to the environment associated with mishaps at covered facilities, the PSM standard requires that facilities conduct formal reviews to determine What Can Go Wrong, and to ensure that the safety systems and procedures are adequate to cope with the situation.
PreStartup Safety Reviews
Many catastrophic incidents have been associated with units that were starting up after an extended shutdown or after modifications. In many cases, after incident investigations found that small changes made during the shutdown had major effects on the operation of the unit, causing a major incident. The PSSR element of the PSM standard requires that covered facilities develop procedures to ensure that changes made during shutdowns or modifications do not compromise the effectiveness of the original design.
Management of Change
In several recent catastrophes, a series of small, seemingly unrelated, changes to equipment and controls combined in unforeseen ways to produce devastating effects. As a result, PSM facilities are required to establish procedures to ensure that changes to the process, equipment, control systems, and procedures do not occur without an in-depth analysis of potential adverse effects.
Incident Investigations
Because small incidents often carry the potential to become catastrophes, the PSM standard requires that all incidents be reviewed for release potential, and those with a significant release potential be investigated to determine the cause and means of prevention.


Contact Information
PO Box 1232, Fairborn, Ohio 45324
Telephone: (937) 767-2117 Fax: (937) 767-5005
Email:
curtissl@cmrsafety.com