The Code of Federal Regulations (CFR) 1910.119 lists 14 program safety elements required by the Occupational Safety and Health Administration (OSHA) for processes involving highly hazardous chemicals that are used or stored in a location in certain quantities. Each of these 14 elements contain additional components required for the programs, and some of the elements tie directly into other element requirements.
An example of this is when you want to make a change (any change) to the process. You must meet the elements of the Management of Change (MOC) Program, which may require a Process Hazard Analysis (PHA) and does require a Pre-Startup Safety Review (PSSR). It may also require you to make changes to the Process Safety Information (PSI), which may trigger a need to update the Process Flow Diagram (PFD) or the Piping and Instrumentation Drawings (P&IDs).
Even the smallest of changes can create a chain of required tasks and documents to update and complete. It is common for some to compare this situation and resolution to eating an elephant one bite at a time. And while that analogy can be helpful, you cannot forget that it is an “elephant” you are trying to eat.
It’s easy to focus on one task or element at a time to help manage the task load. However, you don’t prevent forest fires by hosing down one tree at a time—you prevent forest fires by practicing good forestry management.
It’s important for regulatory compliance and for the safety of your employees and your process to manage the PSM programs as a whole. PSM has been around for a while. Many companies are doing well managing MOCs or revalidating PHAs every five years or reviewing Standard Operating Procedures either annually or every three years. But are there other elements that are falling behind or that are not as up to date as others.
This is where EHS Support can help. If you’re behind on PHA revalidations, or your standard operating procedures haven’t been maintained, or if the P&IDs haven’t been updated since the process was put in place decades ago, we can get you up to date. Our team of highly trained and experienced professionals can assist with developing, managing, or updating all of your Process Safety Management programs.
When you schedule a compliance audit with EHS Support, our professionals will come in and review the status of your PSM programs. Not only will this satisfy the requirements of the OSHA standard, but it will give you peace of mind knowing your program has been reviewed by our team of experts.
To learn more, contact EHS Support Sr. Health & Safety Specialist Allen Mires.
