Showing posts with label Process Safety. Show all posts
Showing posts with label Process Safety. Show all posts

Bhopal Incident

Accident Description

Incident:

  • Bhopal Disaster

Date:

  • 3 December 1984

Location:

  • Bhopal, Madhya Pradesh, India

Impact:

  • Immediate death were estimated at over 3,000 peolple but long-term estimates suggest 15,000 to 20,000 people may have died due to exposure.
  • Over 500,000 people suffered injuries ranging from respiratory issues to neurological and reproductive disorders.
  • Many survivors continue to suffer from chronic illnesses, and birth defects have been reported in subsequent generations.
How it happened:

  • A massive leak of methyl isocyanate (MIC) gas from a pesticide plant owned by Union Carbide India Limited (UCIL). The toxic gas spread over nearby densely populated areas, exposing more than 500,000 people and causing thousands of immediate deaths, with long-term health effects still felt today.

Reference:

Macondo Blowout and Explosion

Accident Description

Accident: Macondo Blowout and Explosion

Location: Location: Offshore

Accident Occurred On: 20 April 2010 | Final Report Released On: 20 April 2016

Accident Type: Oil and Refining - Fire and Explosion

Investigation Status: The CSB's investigation was unanimously approved by the board.

On April 20, 2010, a sudden explosion and fire occurred on the oil rig. The accident resulted in the deaths of 11 workers and caused a massive, ongoing oil spill into the Gulf of Mexico. The rig was located approximately 50 miles southeast of Venice, Louisiana, and had a 126-member crew onboard.



Learn more about the CSB's Macondo Blowout and Explosion investigation here: https://www.csb.gov/macondo-blowout-and-explosion/

BP America (Texas City) Refinery Explosion Investigation

Accident Description

Accident: BP America (Texas City) Refinery Explosion

Location: Location: Texas City, TX

Accident Occurred On: 23 March 2005 | Final Report Released On: 20 March 2007

Accident Type: Oil and Refining - Fire and Explosion

Investigation Status: The Board approved its final report by a vote of 5-0 at a public meeting in Texas City on March 20, 2007.

At approximately 1:20 p.m. on March 23, 2005, a series of explosions occurred at the BP Texas City refinery during the restarting of a hydrocarbon isomerization unit. Fifteen workers were killed and 180 others were injured. Many of the victims were in or around work trailers located near an atmospheric vent stack. The explosions occurred when a distillation tower flooded with hydrocarbons and was overpressurized, causing a geyser-like release from the vent stack.




Learn more about the CSB's BP Texas City investigation here: https://www.csb.gov/bp-america-texas-city-refinery-explosion/


Remembering Trevor Kletz

 


Remembering Trevor Kletz, 1922-2013. This is excerpts from CSB video of Dr. Trevor Kletz, a world renowned expert in chemical process safety, who died October 31, 2013.

PGS 1 Methods for Determining Possible Damage (Green Book)

Methods for Determining Possible Damage known as The Green Book as part of the Publication Series on Dangerous Substances (Publicatiereeks Gevaarlijke Stoffen – PGS). (Link)

This publication (also known as the 'green book') presents damage models for determining possible damage to people and goods due to the release of hazardous substances. The use of the damage models will generally be preceded by the application of so-called effect models. With the aid of damage models, the calculated effects can be converted into damage to people or goods. Together, the 'red book' (PGS 4: probabilities), the 'yellow book' (PGS 2: effects), the 'purple book' (PGS 3: Quantitative Risk Analysis) and the 'green book' (PGS 1: damage) formed the series of standard works for risk analyses.

Please note that the coloured books will in principle no longer be updated, but will remain available for the time being as a historical reference work.

The file is available in Portable Document Format (PDF) which can be read from common PDF reader.


PGS 2 Methods for the Calculation of Physical Effects (Yellow Book)

Methods for the Calculation of Physical Effects known as The Yellow Book as part of the Publication Series on Dangerous Substances (Publicatiereeks Gevaarlijke Stoffen – PGS). (link)

This publication (also known as the 'yellow book') presents effect models for determining possible effects due to the release of hazardous substances. Together, the 'red book' (PGS 4: chances), the 'yellow book' (PGS 2: effects), the 'purple book' (PGS 3: Quantitative Risk Analysis) and the 'green book' (PGS 1: damage) formed the series of standard works for risk analyses.

Please note that the coloured books will in principle no longer be updated, but will remain available for the time being as a historical reference work.

The file is available in Portable Document Format (PDF) which can be read from common PDF reader.

PGS 3 Guideline for Quantitative Risk Assessment (Purple Book)

The Guideline for Quantitative Risk Assessment known as The Purple Book as part of the Publication Series on Dangerous Substances (Publicatiereeks Gevaarlijke Stoffen – PGS). (link)

This publication (also known as the 'purple book') describes calculation methods for performing risk calculations. Together, the 'red book' (PGS 4: probabilities), the 'yellow book' (PGS 2: effects), the 'purple book' (PGS 3: Quantitative Risk Analysis) and the 'green book' (PGS 1: damage) formed the series of standard works for risk analyses.

Please note that the coloured books will in principle no longer be updated, but will remain available for the time being as a historical reference work.

The file is available in Portable Document Format (PDF) which can be read from common PDF reader.

PGS 4 Methods for Determining and Processing Probabilities (Red Book)

Methods for Determining and Processing Probabilities known as The Red Book as part of the Publication Series on Dangerous Substances (Publicatiereeks Gevaarlijke Stoffen – PGS). (link)

This publication (also known as the 'red book') describes methods for determining accident scenarios with associated probabilities and how to deal with them (statistics). Together, the 'red book' (PGS 4: probabilities), the 'yellow book' (PGS 2: effects), the 'purple book' (PGS 3: Quantitative Risk Analysis) and the 'green book' (PGS 1: damage) formed the series of standard works for risk analyses.

Please note that the coloured books will in principle no longer be updated, but will remain available for the time being as a historical reference work.

The file is available in Portable Document Format (PDF) which can be read from common PDF reader.

Process Safety: IOGP

IOGP stands for International Association of Oil & Gas Producer. They also support the Process Safety which can be seen from their website. Excerpt from their website as below.

In recent years, major incidents in both the upstream and downstream industries have highlighted the importance of having robust processes and systems in place.

Process safety is a disciplined framework for managing the integrity of operating systems and processes that handle hazardous substances. It relies on good design principles, engineering and operating and maintenance practices. It deals with the prevention and control of events that have the potential to release hazardous materials and energy.

The terms ‘process safety’ and ‘asset integrity’ are both used throughout the petroleum industry, often synonymously. For the oil and gas industry the emphasis of process safety and asset integrity is to prevent unplanned releases which could result in a major incident. A major incident is typically initiated by a hazardous release; it may also result from a structural failure or loss of stability that escalates to become a major incident. - See more at: https://www.iogp.org/workstreams/safety/safety/process-safety/ (Updated 11 May 2025)

PSID: Process Safety Incident Database | CCPS

The Center for Chemical Process Safety (CCPS) developed the Process Safety Incident Database to collect, track and share important process safety incidents and experiences among project participants.

The purpose of the CCPS PSID is to pool process safety incident experience among participating companies so they can learn from the experiences of others without suffering the consequences of failures, while minimizing corporate liability. PSID includes process safety incidents with a potentially important lesson to be learned from incidents that did or could have resulted in a fire, explosion, fatality, multiple injuries, significant release of hazardous materials, or any other unique process safety incident (including near-misses).

PSID is a fully searchable incident database that is accessible on the web and includes more than 700 incidents and grows each month as PSID member companies enter new and informative incidents. It can be accessed from any computer anywhere a secure web connection can be obtained. Hardcopy print outs of incidents are also possible. PSID is designed so that all PSID member companies can grant as many employees access to PSID as they want and is a very versatile and valuable input for PHAs, incident investigations, lessons learned, and general process safety awareness. PSID requires separate dues from CCPS. PSID members do not have to belong to CCPS but get a discount if they do. PSID can be accessed by PSID member company employees. Each PSID member company has the authority to approve or deny/remove any of their employees’ access to the system.

Ref: PSID: Process Safety Incident Database | CCPS

Process Safety

Process safety focuses on preventing fires, explosions and accidental chemical releases in chemical process facilities or other facilities dealing with hazardous materials such as refineries, and oil and gas (onshore and offshore) production installations.

Ref: Wikipedia


Process safety as define by AIChE:

A disciplined framework for managing the integrity of operating systems and processes handling hazardous substances by applying good design principles, engineering, and operating practices.

Note: Process Safety focuses on efforts to reduce process safety risks associated with processes handling hazardous materials and energies.  Process Safety efforts help reduce the frequency and consequences of potential incidents.  These incidents include toxic or flammable material releases (loss events), resulting in toxic effects, fires, or explosions.  The incident impact includes harm to people (injuries, fatalities), harm to the environment, property damage, production losses, and adverse business publicity.

Ref: AIChE.

*Updated 11 May 2025.

Top 10 worst process safety incidents in history

Top 10 worst process safety incidents in history

This article discusses what the Mary Kay O’Connor Process Safety Center at Texas A&M University in College Station, Texas, consider the top 10 process safety incidents in history. The incidents were ranked based on the cumulative impact on loss of lives and economic losses, and the resulting impact on the development of what today we know as process safety.

1. Bhopal

On the early morning of December 3, 1984, at the Union Carbide plant in India, a storage tank containing methyl isocyanate (MIC) was contaminated with water leading to a runaway reaction causing the release of more than 40 tons of toxic MIC gas through a relief valve.

The incident killed more than 3,000 people and injured hundreds of thousands more. This was arguably the worst chemical industry incident in terms of people affected, however; it was just after this fatal tragedy that the chemical process industry became really conscientious of the importance of process safety and it gained complete acceptance as a standard practice.1

As a direct response to Bhopal, many regulatory initiatives were implemented worldwide. In India, this event led to the Environment Protection Act (1986), the Air Act (1987), the Hazardous Waste (Management and Handling) Rules (1989), the Public Liability Insurance Act (1991) and the Environmental Protection (Second Amendment) Rules (1992).

In the US, the Emergency Planning and Community Right-to-Know Act (EPCRA) was promulgated in 1986,2 and the Clean Air Act Amendments (CAAA) were signed into law in 1990.1

2. Chernobyl

On April 28, 1986, in a power plant in Chernobyl, Ukraine, an experiment performed in order to verify the emergency power supply of a reactor resulted in unfortunate consequences. The core of the reactor was blown out by two violent explosions causing a series of fires and the release of tons of radioactive materials.

It is considered to be the worst nuclear disaster in history. The incident directly killed 56 people and influenced the development of cancer and radiation sickness of hundreds in the subsequent years.3

Before the incident, there were no written rules for the test that led to the catastrophic consequences. This fact has made the adherence to safety-related instructions as the most highlighted lesson learned regarding to process safety.4

3. Piper Alpha

Piper Alpha was a North Sea oil production platform. On July 6, 1988, the backup condensate pump pressure safety valve was removed for routine maintenance. However, since the maintenance could not be completed within the shift, it was decided to complete the remaining work the next day. As a temporary measure, the condensate pipe was sealed with a blind flange.

Communication gaps between different shifts resulted in a catastrophe when the night shift crew unknowingly started the backup condensate pump after the failure of the primary pump. In just 22 minutes, fire broke out everywhere and the event escalated further because of design and operational flaws resulting in 167 deaths. The Piper Alpha incident was a wakeup call for the offshore industries.

Significant changes in safety practice include development and implementation of safety case regulations in UK, adherence to a permit-to-work system and realistic training for emergency response.4

4. The Macondo blowout

The Macondo exploration well located in the Gulf of Mexico (GoM) was drilled by a deep water horizontal semi-submersible rig. On April 20, 2010, a blowout caused a fire and explosion on the rig that killed 11 employees and caused a major oil spill that continued uncontrolled for 87 days.

A series of mechanical failures, lack of human judgment, faulty engineering design and improper team interaction came together to result in the largest oil spill known to mankind. The blowout was the biggest offshore incident in the US and it had a profound impact on safety regulations in the GoM.

As a direct outcome of the Macondo incident, the Drilling Safety Rule regarding wellbore reliability and well control equipment was implemented on October 14, 2010. The Modified Workplace Safety Rule was also implemented on October 15, 2010, based on the lessons learned from the Macondo blowout.5–6

5. BP Texas City

On March 23, 2005, during the startup of an isomerization unit, the safety relief valves of a distillation tower opened due to overfilling, allowing hydrocarbon liquids to flow into a disposal blowdown drum with a stack, which were also overfilled, resulting in a liquid release. The evaporation of the hydrocarbons produced a flammable vapor cloud that ignited and led to a series of fires and explosions. Fifteen workers died and about 180 were injured.7

This incident led to major investigations including the milestone Baker panel report headed by former US Secretary of State James Baker III. This incident also resulted in significantly more interest in and attention to issues such as facility siting, atmospheric venting, leading and lagging indicators and safety culture.

6. The Flixborough disaster

On June 1, 1974, in a caprolactam production plant, a temporary bypass line ruptured, resulting in the leak of almost 40 tons of cyclohexane that caused a huge vapor-cloud explosion. The tragic disaster killed 28 people including all the employees working in the control room.

There was the alarming possibility of killing more than 500 employees if it were a normal working day instead of weekend. Also, widespread damage to property within a 6-mile radius around the plant was another major consequence. The Flixborough explosion was a critical driver in moving process safety issues forward in the UK.

As a result of the Flixborough incident, at the end of 1974, the Advisory Committee on Major Hazards (ACMH) was formed. The lessons learned from this disaster highlight the importance of HAZOP analysis, blast resistant control rooms and thorough studies prior to any modification in process plants.4

7. Mexico City

On November 19, 1984, in an LPG installation in Mexico City, the failure of the safety valve of an LPG storage tank caused an overpressure inside the tank and a pipe rupture, leading to a leakage of LPG followed by an ignition and violent explosions.

Approximately 500 people were killed and more than 700 were injured.9 This incident represents the largest series of boiling liquid expanding vapor explosions (BLEVEs) in history.4 Mexico City clearly demonstrated the risk of BLEVEs in process facilities and lessons learned from this event have significantly impacted standards for design and operation.

8. Phillips

On October 23, 1989, in the Phillips 66 plant in Pasadena, Texas, the rupture of a seal on a polyethylene reactor caused the release of highly flammable ethylene and isobutene gas, forming a gas cloud and leading to a massive explosion in less than two minutes.

Twenty-three people were killed and more than 300 injured. The day before the incident, a maintenance procedure had been performed by contractor personnel. This incident underscored the importance of rigid adherence to operating procedures and the implementation of an appropriate management system for contract workers.

In response to this incident and other incidents that occurred before in the 1980s (including Bhopal, Shell Norco, Arco Channelview and Exxon Baton Rouge), the US Department of Labor, Occupational Safety and Health Administration developed the Process Safety Management (PSM) regulation.10

9. Columbia disaster

The physical cause of the Columbia shuttle disaster was separation of insulation foam that then hit the carbon–carbon reinforced panel of the left wing, thus damaging the thermal protection system. Aerodynamic pressure caused by superheated air destroyed the wing when the shuttle was reentering earth’s atmosphere at about 10,000 mph on February 1, 2003.

The tragic incident caused the death of all seven astronauts and resulted in shuttle debris being scattered over 2,000 square miles in Texas. However, the underlying causes for the disaster can be traced back to flaws in decision making at NASA.

The Columbia incident also provided important lessons for crisis communication professionals, as well. In fact, the lessons learned from the Columbia incident can be mapped to many other catastrophes such as the Piper Alpha or the Flixborough incident, covering issues such as sense of vulnerability, establishing an imperative for safety and valid on-time risk assessment.11

10. Fukushima Daiichi nuclear incident

On March 11, 2011, this incident drew the attention of the process and power industries around the world, encouraging them to incorporate natural disaster risk in any hazard analysis study. When a powerful earthquake hit the plant, the reactors shut down automatically.

However, because of the earthquake and the following tsunami, a power blackout ensued, leading to the loss of cooling, which, in turn, led to overheating of the reactors (creating serious radiation hazards). Fortunately, no one was killed because of the radiation, but there may be long-term consequences to the workers and to the neighboring communities who were exposed to radiation.

Conclusions

These tragic events and the consequences of these events have provided us with numerous lessons that help our understanding of the hazards and risks of the modern process industry and, more importantly, how design, technology, equipment, management systems, human factors and safety culture can be used to improve the safety performance of the industry.

Understanding the root causes of incidents and learning from mistakes within the company, as well as other organizations, is vital. These lessons need to be implemented both in the engineering and the management sectors.


LITERATURE CITED
1 Mannan, M. S., et al., “The legacy of Bhopal: The impact over the last 20 years and future direction,” Journal of Loss Prevention in the Process Industries, 2005. 18(4–6): pp. 218–224.
2 Mannan, M. S., J. Makris and H. J. Overman, Process Safety and Risk Management Regulations: Impact on Process Industry, Encyclopedia of Chemical Processing and Design, ed. R. G. Anthony, Vol. 69, Supplement 1, pp. 168–193, Marcel Dekker, Inc., New York, 2002.
3 Dara, S. I. and J. C. Farmer, “Preparedness Lessons from Modern Disasters and Wars,” Critical Care Clinics, 2009. 25(1): pp. 47–65.
4 Mannan, M. S., Lees’ Loss Prevention in the Process Industries, 3rd Edition, Elsevier, 2005.
5 McAndrews, K. L., “Consequences of Macondo: A Summary of Recently Proposed and Enacted Changes to US Offshore Drilling Safety and Environmental Regulation,” Society of Petroleum Engineers Americas E&P Health, Safety, Security and Environmental Conference, Houston 2011. Available online: http://www.jsg.utexas.edu/news/files/mcandrews_spe_143718-pp.pdf, accessed on March 16, 2012.
7 Kaszniak, M. and D. Holmstrom, “Trailer siting issues: BP Texas City,” Journal of Hazardous Materials, 2008. 159(1): pp. 105-111.
8 Snorre, S., “Comparison of some selected methods for incident investigation,” Journal of Hazardous Materials, 2004. 111(1–3): pp. 29–37.
9 C.M, P., “Analysis of the LPG-disaster in Mexico City,” Journal of Hazardous Materials, 1988. 20(0): pp. 85-107.
10 Guidelines for Vapor Cloud Explosion, Pressure Vessel Burst, BLEVE, and Flash Fire Hazards, 2nd Edition, August 2010, Process Safety Progress, 2011. 30(2): p. 187.
11 American Institute of Chemical Engineers (AIChE), Lessons from the Columbia Disaster-Safety and Organizational Culture, Center for Chemical Process Safety, 2005.

The Problem Led to Process Safety in US

Unexpected releases of toxic, reactive, or flammable liquids and gases in processes involving highly hazardous chemicals have been reported for many years. Incidents continue to occur in various industries that use highly hazardous chemicals which may be toxic, reactive, flammable, or explosive, or may exhibit a combination of these properties. Regardless of the industry that uses these highly hazardous chemicals, there is a potential for an accidental release any time they are not properly controlled. This, in turn, creates the possibility of disaster.

Recent major disasters include the 1984 Bhopal, India, incident resulting in more than 2,000 deaths; the October 1989 Phillips Petroleum Company, Pasadena, TX, incident resulting in 23 deaths and 132 injuries; the July 1990 BASF, Cincinnati, OH, incident resulting in 2 deaths, and the May 1991 IMC, Sterlington, LA, incident resulting in 8 deaths and 128 injuries.

Although these major disasters involving highly hazardous chemicals drew national attention to the potential for major catastrophes, the public record is replete with information concerning many other less notable releases of highly hazardous chemicals. Hazardous chemical releases continue to pose a significant threat to employees and provide impetus, internationally and nationally, for authorities to develop or consider developing legislation and regulations to eliminate or minimize the potential for such events.

On July 17, 1990, OSHA published in the Federal Register (55 FR 29150) a proposed standard, - ”Process Safety Management of Highly Hazardous Chemicals” - containing requirements for the management of hazards associated with processes using highly hazardous chemicals to help assure safe and healthful workplaces.

OSHA's proposed standard emphasized the management of hazards associated with highly hazardous chemicals and established a comprehensive management program that integrated technologies, procedures, and management practices.

The notice of proposed rulemaking invited comments on any aspect of the proposed standard for process safety management of highly hazardous chemicals and announced the scheduling of a hearing to begin on November 27, 1990, in Washington, DC.

On November 1, 1990, OSHA published a Federal Register notice (55 FR 46074) scheduling a second hearing to begin on February 26, 1991, in Houston, TX, enumerating additional issues, and extending the written comment period until January 22, 1991.

The hearings on the proposed standard were held in Washington, DC, from November 27, 1990, through December 4, 1990, and in Houston, TX, from February 26, 1991, through March 7, 1991. The Administrative Law Judge presiding at the hearings allowed participants to submit post-hearing comments until May 6, 1991, and file post-hearing briefs until June 5, 1991. OSHA received more than 175 comments in response to the notice of proposed rulemaking. In addition to these comments, the hearings resulted in almost 4,000 pages of testimony and almost 60 post-hearing comments and briefs. For readers' convenience, this publication includes, as an appendix, the full text of the final OSHA standard issued in the Federal Register on February 24, 1992, including the list of covered chemicals and threshold amounts.

State plan States, approved under section 18(b) of the Occupational Safety and Health Act of 1970 (see list on page 36) must adopt standards and enforce requirements which are at least as effective as Federal requirements. There are currently 25 State plan States; 23 covering private and public (State and local government) sectors and two covering public sector only. Plan States must adopt comparable standards to the Federal within six months of a Federal standard's promulgation.

Approximately four months after the publication of OSHA's proposed standard for process safety management of highly hazardous chemicals, the Clean Air Act Amendments (CAAA) were enacted into law (November 15, 1990). Section 304 of the CAAA requires that the Secretary of Labor, in coordination with the Administrator of the Environmental Protection Agency (EPA), promulgate, pursuant to the Occupational Safety and Heath Act of 1970, a chemical process safety standard to prevent accidental releases of chemicals that could pose a threat to employees.

The CAAA requires that the standard include a list of highly hazardous chemicals which includes toxic, flammable, highly reactive, and explosive substances. The CAAA also specified minimum elements that the OSHA standard must require employers to do, as follows:
(1) Develop and maintain written safety information identifying workplace chemical and process hazards, equipment used in the processes, and technology used in the processes;
(2) Perform a workplace hazard assessment, including, as appropriate, identification of potential sources of accidental releases, identification of any previous release within the facility that had a potential for catastrophic consequences in the workplace, estimation of workplace effects of a range of releases, and estimation of the health and safety effects of such a range on employees;
(3) Consult with employees and their representatives on the development and conduct of hazard assessments and the development of chemical accident prevention plans and provide access to these and other records required under the standard;
(4) Establish a system to respond to the workplace hazard assessment findings, which shall address prevention, mitigation, and emergency responses;
(5) Review periodically the workplace hazard assessment and response system;
(6) Develop and implement written operating procedures for the chemical processes, including procedures for each operating phase, operating limitations, and safety and health considerations;
(7) Provide written safety and operating information for employees and employee training in operating procedures, by emphasizing hazards and safe practices that must be developed and made available;
(8) Ensure contractors and contract employees are provided with appropriate information and training;
(9) Train and educate employees and contractors in emergency response procedures in a manner as comprehensive and effective as that required by the regulation promulgated pursuant to section 126(d) of the Superfund Amendments and Reauthorization Act;
(10) Establish a quality assurance program to ensure that initial process-related equipment, maintenance materials, and spare parts are fabricated and installed consistent with design specifications;
(11) Establish maintenance systems for critical process-related equipment, including written procedures, employee training, appropriate inspections, and testing of such equipment to ensure ongoing mechanical integrity;
(12) Conduct pre-startup safety reviews of all newly installed or modified equipment;
(13) Establish and implement written procedures managing change to process chemicals, technology, equipment and facilities; and
(14) Investigate every incident that results in or could have resulted in a major accident in the workplace, with any findings to be reviewed by operating personnel and modifications made, if appropriate.

Also the CAAA, identifies specific duties for EPA relative to the prevention of accidental releases (see section 301 (r)). Generally, EPA must develop a list of chemicals and a Risk Management Plan.

Reference: OSHA US

*Updated 11 May 2025.

Emergency Planning and Response

Process Safety Requirement - Emergency Planning and Response

If, despite the best planning, an incident occurs, it is essential that emergency pre-planning and training make employees aware of, and able to execute, proper actions. For this reason, an emergency action plan for the entire plant must be developed and implemented in accordance with the provisions of other OSHA rules (29 CFR 1910.38(a)). In addition, the emergency action plan must include procedures for handling small releases of hazardous chemicals. Employers covered under PSM also may be subject to the OSHA hazardous waste and emergency response regulation (29 CFR 1910.120(a), (p), and (q). 

Trade Secrets

Process Safety Requirement - Trade Secrets

Employers must make available all information necessary to comply with PSM to those persons responsible for compiling the process safety information, those developing the process hazard analysis, those responsible for developing the operating procedures, and those performing incident investigations, emergency planning and response, and compliance audits, without regard to the possible trade secret status of such information. Nothing in PSM, however, precludes the employer from requiring those persons to enter into confidentiality agreements not to disclose the information.

Compliance Audits

Process Safety Requirement - Compliance Audits

To be certain process safety management is effective, employers must certify that they have evaluated compliance with the provisions of PSM at least every three years This will verify that the procedures and practices developed under the standard are adequate and are being followed. The compliance audit must be conducted by at least one person knowledgeable in the process and a report of the findings of the audit must be developed and documented noting deficiencies that have been corrected. The two most recent compliance audit reports must be kept on file.

Incident Investigation

Process Safety Requirement - Incident Investigation

A crucial part of the process safety management program is a thorough investigation of incidents to identify the chain of events and causes so that corrective measures can be developed and implemented. Accordingly, PSM requires the investigation of each incident that resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical in the workplace.

Such an incident investigation must be initiated as promptly as possible, but not later than 48 hours following the incident. The investigation must be by a team consisting of at least one person knowledgeable in the process involved, including a contract employee if the incident involved the work of a contractor, and other persons with appropriate knowledge and experience to investigate and analyze the incident thoroughly.

An investigation report must be prepared including at least:
  • Date of incident,
  • Date investigation began,
  • Description of the incident,
  • Factors that contributed to the incident, and
  • Recommendations resulting from the investigation. A system must be established to promptly address and resolve the incident report findings and recommendations. Resolutions and corrective actions must be documented and the report reviewed by all affected personnel whose job tasks are relevant to the incident findings (including contract employees when applicable). The employer must keep these incident investigation reports for 5 years.

Management of Change

Process Safety Requirement - Management of Change

OSHA believes that contemplated changes to a process must be thoroughly evaluated to fully assess their impact on employee safety and health and to determine needed changes to operating procedures. To this end, the standard contains a section on procedures for managing changes to processes. Written procedures to manage changes (except for “replacements in kind”) to process chemicals, technology, equipment, and procedures, and change to facilities that affect a covered process, must be established and implemented. These written procedures must ensure that the following considerations are addressed prior to any change:
  • The technical basis for the proposed change,
  • Impact of the change on employee safety and health,
  • Modifications to operating procedures,
  • Necessary time period for the change, and
  • Authorization requirements for the proposed change.
Employees who operate a process and maintenance and contract employees whose job tasks will be affected by a change in the process must be informed of, and trained in, the change prior to startup of the process or startup of the affected part of the process. If a change covered by these procedures results in a change in the required process safety information, such information also must be updated accordingly. If a change covered by these procedures changes the required operating procedures or practices, they also must be updated.

Hot Work Permit

Process Safety Requirement - Hot Work Permit

A permit must be issued for hot work operations conducted on or near a covered process. The permit must document that the fire prevention and protection requirements in OSHA regulations (1910.252(a)) have been implemented prior to beginning the hot work operations; it must indicate the date(s) authorized for hot work; and identify the object on which hot work is to be performed. The permit must be kept on file until completion of the hot work.

Mechanical Integrity

Process Safety Requirement - Mechanical Integrity

OSHA believes it is important to maintain the mechanical integrity of critical process equipment to ensure it is designed and installed correctly and operates properly. PSM mechanical integrity requirements apply to the following equipment:

  • Pressure vessels and storage tanks;
  • Piping systems (including piping components such as valves);
  • Relief and vent systems and devices;
  • Emergency shutdown systems;
  • Controls (including monitoring devices and sensors, alarms, and interlocks); and
  • Pumps.
The employer must establish and implement written procedures to maintain the ongoing integrity of process equipment. Employees involved in maintaining the ongoing integrity of process equipment must be trained in an overview of that process and its hazards and trained in the procedures applicable to the employees's job tasks.

Inspection and testing must be performed on process equipment, using procedures that follow recognized and generally accepted good engineering practices. The frequency of inspections and tests of process equipment must conform with manufacturers' recommendations and good engineering practices, or more frequently if determined to be necessary by prior operating experience. Each inspection and test on process equipment must be documented, identifying the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test.

Equipment deficiencies outside the acceptable limits defined by the process safety information must be corrected before further use. In some cases, it may not be necessary that deficiencies be corrected before further use, as long as deficiencies are corrected in a safe and timely manner, when other necessary steps are taken to ensure safe operation.

In constructing new plants and equipment, the employer must ensure that equipment as it is fabricated is suitable for the process application for which it will be used. Appropriate checks and inspections must be performed to ensure that equipment is installed properly and is consistent with design specifications and the manufacturer's instructions.

The employer also must ensure that maintenance materials, spare parts, and equipment are suitable for the process application for which they will be used.