Anyone who has been around PSM for any length of time has heard of the "14 elements of PSM." You might be asking yourself why there are so many - or why they matter. Here is a succinct synopsis of each element within the PSM framework:
Process Safety Information: PSI is a compilation of all the technical information related to your covered process (e.g., ammonia refrigeration system). It involves documenting process hazards, technology, and equipment specifications. Examples include the safety data sheet (SDS), maximum intended inventory, and piping and instrumentation diagrams (P&IDs).
Process Hazard Analysis: The PHA is an activity performed initially and every five (5) years thereafter. The purpose of this team activity is to study the risk of the system and produce a list of recommendations in order to mitigate the unacceptable risks.
Operating Procedures: The SOPs needs to cover the operating phases, operating limits, safety and health considerations, and safety systems. They need to be kept up-to-date and certified annually.
Training: Operators must be trained in the procedures relevant for their job tasks. Competency must be verified and refresher training needs to be administered every three (3) years.
Mechanical Integrity: All equipment within the process needs to be inspected, tested, and maintained according to recognized and generally accepted good engineering practice (RAGAGEP). Identified deficiencies need to be fixed or the unit will need to be decommissioned.
Management of Change: Changes to the process chemical, technology, equipment, procedures, and facility (when relevant) need to be managed. Analyzing changes before, during, and after they are made ensures the continuing safety of the covered process and that the written program remains accurate.
Pre-Startup Safety Review: Before a new covered process is commissioned or before the system is modified, a checklist of items needs to be confirmed to ensure the safety of the system.
Compliance Audit: Every three (3) years, the entire PSM program documentation and implementation needs to be audited. A report will be provided which includes recommendations to correct any deficiencies.
Incident Investigation: Should an accidental release or a near-miss occur, a team must be formed to examine the event, culminating in a comprehensive report that details the incident and suggests measures to avert future, similar events.
Employee Participation: Active involvement from employees is fundamental in the PSM program's development, particularly during PHAs.
Hot Work Permit: When hot work (welding, cutting, grinding, drilling, soldering, brazing, etc.) is performed on or near the covered process, internally-generated hot work permits need to be completed to ensure a conflagration does not occur.
Contractors: Contractors need to be qualified for the work they perform, trained regarding the hazards at the facility, and periodically evaluated for their performance and safety record.
Emergency Planning and Response: A plan needs to be established in order to prevent, mitigate, and/or respond to emergency situations—particularly accidental releases of the covered chemical. The plan should cover training and procedures.
Trade Secrets: While this is less relevant in the ammonia refrigeration industry, facilities may stipulate which parts of their program ought to be considered trade secrets. This designation must not prevent employees from properly the developing the program (e.g., the PSI and PHA elements).
Bonus Elements: While they are not traditionally included in the "14 elements of PSM," there are two other elements which might be considered "big rocks" for those who have to comply with EPA's risk management plan:
Hazard Assessment: This is a report developed initially and updated every five (5) years which includes the worst-case release scenario and alternate release scenarios. It is also referred to as the offsite consequence analysis (OCA).
RMP Submit: Initially and every five years, a summary of the program needs to be submitted to EPA. This document also needs to be updated if there are certain triggering events (e.g., new emergency contact information).
Macha PSM is ready and equipped to assist you in developing or implementing any of these 14 elements. Leave us a message through our contact page to discuss how we can help.
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