What is Process Safety Management?

Process Safety Management (or Process Safety) is generally used to describe a series of regulations designed to maintain safety of hazardous chemicals used in manufacturing. These regulations were created in response to globally-recognized chemical disasters, with the intent of protecting both internally (workers, contractors) and externally (environment, neighboring communities).

Primary process safety regulations include the following:

PROCESS SAFETY MANAGEMENT (PSM)

OSHA developed Standard 1910.119 - Process Safety Management of Highly Hazardous Chemicals to both define what qualifies as a highly hazardous material and outline the components for a comprehensive safety program to help manage how the hazardous material is stored, handled, and processed. While this is a ‘performance-based standard’ that leaves program specifics to the affected companies, they do require certain elements to be included:

  • Employee Participation

  • Process Safety Information

  • Process Hazard Analysis

  • Operating Procedures

  • Training

  • Contractors

  • Pre-Startup Safety Review

  • Mechanical Integrity

  • Hot Work Permit

  • Management of Change

  • Incident Investigation

  • Emergency Planning & Response

  • Trade Secrets

RISK MANAGEMENT PLAN (RMP)

EPA developed the Risk Management Plan, which implements Section 112(r) of the 1990 Clean Air Act amendments. Similar to the PSM Standard above, the RMP Rule defines extremely hazardous substances (40 CFR part 68 subpart F) and requirements for a complete Risk Management Plan:

  • Hazard Review

  • Operating Procedures

  • Training

  • Maintenance

  • Incident Investigation

  • Compliance Audit

  • Management of Change

  • Pre-Startup Review

  • Contractors

  • Employee Participation

  • Hot Work Permits

CALIFORNIA ACCIDENTAL RELEASE PREVENTION PROGRAM (CalARP)

Companies with California-based sites need to be familiar with the requirements of CalEPA’s Accidental Release Prevention Program, which is similar in many ways to the EPA Risk Management Plan, but can take effect at much lower threshold quantities than the Federal RMP. Elements of theCalARP program include:

  • List of onsite regulated substances

  • Offsite consequences of a release

  • Emergency Response Program

  • Coordination with local emergency responders

  • Hazard review or Process Hazard Analysis

  • Operating procedures

  • Training

  • Maintenance and Mechanical Integrity

  • Incident Investigation

Other differences are that the CalARP program is implemented at the local level by Certified Unified Program Agencies (CUPA) or Participating Agencies (PAs).

 GENERAL DUTY CLAUSE

Even if your company has managed to keep hazardous chemical inventories below the threshold quantities for requiring one of the programs listed above, there is a General Duty Clause under EPA’s Clean Air Act Section 112(r)(1) that requires owners and operators to:

  • Identify chemical-release hazards using appropriate hazard assessment techniques

  • Design and maintain a safe facility, including steps to prevent chemical releases

  • Minimize consequences of accidental chemical releases

The General Duty Clause applies to stationary sources that produce, process, handle, or store extremely hazardous substances (regardless of quantity), even though there’s not a regulation or submission of data to verify the compliance against.