A number of recent incidents in various parts of the world have highlighted the increasing importance of effective Process Safety Management (PSM). This webinar presents a high-level overview of OSHA’s PSM requirements as well as real-world examples of how companies handle compliance. Objectives • Describe some of the major catastrophes which led to the formulation of PSM regulations. • Introduce the 14 Elements of PSM. • Present examples of various implementation approaches.

1. My Facility is PSM-Covered – Now What?
A real-world introduction to PSM’s 14 Elements
Speaker Host Moderator
Rob Bartlett, PSM Consultant Sajjad Gul, Dir. Business Dev. Ameyra Rosales, Brand Mangr

2. About 360factors, Inc.
Pareto Engineering & Management Consulting
Rob Bartlett owns Pareto Engineering & Management Consulting and.
He uses his over 20 years of experience and partners with companies
to create World Class Process Safety Systems.

3. 350+ EMPLOYEES $25M REVENUE INDUSTRY FOCUSED GLOBAL PRESENCE
3 Offices in 3 Countries
ABOUTUS
INDUSTRY FOCUSED
Oil & Gas
Utilities
Mining
Manila,
Philippines
Karachi,
Pakistan
Austin, TX
(US HQ)

4. Why is PSM Needed?
1984 – Mexico City
650 fatalities. unknown injuries

5. Costs and Benefits of Good Safety Performance
What we see
Direct Costs of Injuries
 Medical costs
 Wage indemnity
 Claims administration fees
What we don’t see
The Hidden Costs of Injuries
 Damaged equipment, vehicles & goods
 Lost production and quality
 Process interruptions, yield losses
 Replacement labor / Overtime
 General liability costs
 Litigation
 Damage to customer relations & public image
Direct Cost
Indirect Cost
5X

6. My Facility is PSM-Covered
Now What?
Process Safety Management
A real-world introduction to PSM’s 14 Elements

7. Process Safety Management
Simple* Elements
 Employee Participation
 Training
 Hot Work
 Incident Investigation
 Emergency Response
 Compliance Audits
 Trade Secrets
*Relative to other elements

8. Process Safety Management
Challenging Elements
 Process Safety Information
 Process Hazard Analyses
 Operating Procedures
 Contractor Management
 Pre-Startup Safety Reviews
 Mechanical Integrity
 Management of Change

9. Process Safety Management
Process Safety Information
 Information pertaining to the
hazards of the highly hazardous
chemicals in the process
 Toxicity information
 Permissible exposure limits
 Reactivity data
 Corrosivity data
 Information pertaining to the technology of
the process

10. Process Safety Information
Real World Advice
 Most information exists in SDSs,
literature, & plant and process
documentation
 Gather all PSI in one place – either
electronic or paper
 Be sure that PSI is updated as
changes are made
 Create an Action Item for annual
review of the PSI

11. Process Safety Management
Process Hazard Analysis
 PHA shall be appropriate to the
complexity of the process and shall
identify, evaluate, and control the
hazards involved in the process
 What if / What if Checklist
 Hazard and Operability Study (HAZOP)
 Failure Mode Effective Analysis (FMEA)
 Fault Tree Analysis
 Layer of Protection Analysis (LOPA)
 Updated/Revalidated at least every
five years

12. Process Hazard Analysis
Real World Advice
 Choose the right method, not every
process needs a HAZOP.
 Chose the right team – experience is
the key.
 PHA doesn’t end with a report -
develop a system to review and
manage PHA recommendations

13. Process Safety Management
Operating Procedures
 Develop and implement written
operating procedures that provide
clear instructions for safety
conducting activities involved in
each covered process
 Steps for each operating phase
 Operating Limit
 Health & Safety consideration
 Safety Systems
 Develop procedures for LOTO, First
Breaks, Confined Space, Facility
Control

14. Operating Procedures
Real World Advice
 Electronic document system often
easiest to maintain.
 Do not try to put all the required
information into one procedure –
combine common information into
one procedure
 Be simple and direct – readability
and understandability are vital

15. Process Safety Management
Contractors
 Applies to contractors performing maintenance
or repair, turnaround, major renovation, or
specialty work on or adjacent to a covered
process
 Obtain and evaluate information regarding the
contract employer's safety performance and
programs
 Inform contract employers of the known
potential fire, explosion, or toxic release
hazards
 Control the entrance, presence and exit of
contract employers and contract employees in
covered process areas
 Contract employer has specific responsibilities

16. Contractor Management
Real World Advice
 Develop an approval process for
contractors
 Allot adequate resources to
maintaining contractor approval and
training documentation
 Ensure that contractor employees
have the required training to
complete

17. Process Safety Management
Pre-Startup Safety Review
 Perform a PSSR for new facilities
and for modified facilities when the
modification is significant enough to
require a change in PSI
 Construction and equipment is in
accordance with design and specifications
 Safety, operating, maintenance and
emergency procedures are in place and
adequate
 PHA and MOC completed, if needed
 Training employees involved in operating a
process completed

18. Pre-Startup Safety Reviews
Real World Advice
 Involve the right people –
experience counts
 Don’t rely on memory - use
checklists
 Develop a system for managing
post-startup actions from PSSR
 Use the PSSR as opportunity to
prove that process is safe to start –
Document everything!

19. Process Safety Management
Mechanical Integrity
 Applies to:
 Pressure Vessels and Storage Tanks
 Piping Systems (including piping
components such as valves)
 Relief and vent systems and devices
 Emergency shut down systems
 Controls (including monitoring devices,
sensors, alarms and interlocks)
 Pumps

20. Process Safety Management
Mechanical Integrity
 Establish and implement written
procedures to maintain the on-going
integrity of process equipment
 Train each employee involved in
maintaining the on-going integrity of
process equipment
 Perform inspections and tests on process
equipment following Recognized and
Generally Accepted Good Engineering
Practices (RAGAGEP)
 Document inspections and correct
deficiencies
 Establish Quality Assurance procedures

21. Mechanical Integrity
Real World Advice
 RAGAGEP = 7 words = infinity of complexity
 Use operations and maintenance manuals
whenever possible (have them readily
accessible)
 Develop ITPM plan using CCPS MI book
 Use a Computerized Maintaining System to
schedule ITPM tasks and track deficiencies
to closure
 Become familiar with API, NFPA, ASME, and
other RAGAGEP

22. Process Safety Management
Management of Change
 Establish and implement written
procedures to manage changes to process
chemicals, technology, equipment, and
procedures; and, changes to facilities that
affect a covered process
 Include :
 Technical basis for the change
 Impact of change on safety & health
 Modifications to operating procedures
 Necessary time period for the change
 Authorizations req. for the change

23. Management of Change
Real World Advice
 There are very few ‘Replacement in
Kind’
 Be sure complete all pre- and post-change
actions
 Include personnel changes
 Paper is ok, but electronic is far
superior

24. My Facility is PSM-Covered – Now What?!?
Review OSHA 1910.119
Complete a Gap-Analysis for compliance of
existing programs
Develop programs to address gaps

25. Success Factors
 Use as many existing processes as possible
 Hot Work, PSI, Operating Procedures
 Use a cross-functional team
 Include operators and mechanics
 Continual training and auditing
 Don’t assume the processes are working

26. At the end of the day, safety is all
about care, saving lives,
families, and the society we
operate in.
Q&A