Process Safety Management Program

Process Safety Management (PSM) is a program that was created by OSHA, then adopted by the EPA, for facilities that contain more than 10,000 pounds of ammonia on site. OSHA mandated facilities put in place the processes and procedures regarding how to “Manage the Process Safely”.

Many companies throughout the United States have chemicals in use at their respective facilities that can threaten employees and the communities surrounding them.  These chemicals pose a potential threat when part of the process that uses the chemicals has an engineering or administrative failure that will release the chemical into the surrounding area. 

The companies using these chemicals must anticipate an eventual failure that can release the chemical.  The causes are many, due to the complexity of the systems in place, to produce a product or sometimes a distribution of products to the general public.  One example of a process that can fail is an ammonia refrigeration system, which is used for refrigeration and product storage at the facilities.

The OSHA Process Safety Management Program (PSM) and the EPA Risk Management Program (RMP) both have requirements that must be met or complied with to understand, maintain and operate the system safely.  The industries usually involved in this standard are the general and construction industries.  

The OSHA PSM program is CFR 1910.119 and the EPA RMP 40 CFR Part 68.  Both of these programs have requirements within the body of the regulations that your facility must be in compliance with or there may be consequences.  The consequences could include an injury, or even a fatality, which affects the safety of the operators and employees at the facility.

This element includes a written plan of action of how employees will participate in the development of each of the aspects of the PSM program.  This will include evidence of employee participation including minutes of meetings, PHA participation/results, etc.

This element contains the information about the refrigeration process.  This information must be gathered before the Process Hazard Analysis can be completed.  Some of the items included are draw block diagrams, Piping and Instrument Diagrams (P&IDs), relief valve design basis, materials of construction, standards used in the design and construction of the facility, Safety Data Sheets (SDS), electrical classification information, engineering/design files and equipment data sheets as well as U1 sheets for pressure vessels and heat exchangers.

This is where the entire ammonia refrigeration system is evaluated to determine if there are any hazards associated with how equipment, piping, etc. is currently situated, operated or maintained.  This should be done after the PSI is gathered and the drawings are verified.

This includes the written procedures for all modes of operations, documentation of annual certifications and safe work practice procedures.

Training records for each employee involved in a covered process including qualification documents and training program guidance documents for your ongoing program are included in the element.

This covers how you manage your work with outside contractors as related to safety training, information transfer, specifications and codes, facility access, etc.

This portion is the program for how and what must be done before starting a refrigeration system or component, after it has been modified or added.

This element includes the typical PM procedures that are required to maintain the integrity of the process.  Also included in this element are the definitions and procedures for inspecting your ammonia system.  These include vibration analysis, alignment check, visual inspection and non-destructive testing.  Verification of the ventilation system is also included in this section.

This element covers the program description of what is involved in and how the program is administered for your hot work permit system.

This element defines the procedures that must be followed when changes are made to the refrigeration system.  This can include additions, changes or modifications.

This element defines the specific methods for investigation of incidents, accidents, and incidental smells or near accidents.

Your written Emergency Action Plan, Fire Prevention and Emergency Response Program all makeup this element.

This defines how and when compliance audits will be conducted.  Also included is the description of the system to ensure that findings are addressed in a timely manner.

This section covers how you would handle the disbursement of information concerning any trade secrets contained within you ammonia refrigeration system.  This usually does not apply to refrigeration systems.