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  • 8/13/2019 # PSM Psm-checklist

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    Occupational Safety & Health Program

    Page 1of 14

    September 2011www.oshainfo.gatech.edu

    PSM Program Review ChecklistUse this checklist to help determine employer compliance with theProcess Safety Management Standard issued by theOccupational Safety and Health Administration. Please note that the checklist does not include all of the standards

    requirements and does not reflect all OSHAletters of interpretation or compliance directives in particular

    situations.

    There are 3 elements to a review of a PSM program:1. Documentationreviewexamination of the documentation of the programs required by the standard.2. Field Inspection & Verificationexamination of the physical covered process; its equipment, piping,

    instrumentation, procedures, and operation.3. Interviewsdiscussions with employees and contractors to determine if the implemented program matches the

    program outlined in the documentation.

    In order to gather the information needed to audit a PSM program the following questions need to be asked for each PSMprogram element

    Who What When Where Why How WhoWho is responsible for developing and implementing each of the program elements? WhatWhat are the requirements and contents of each program element? WhenWhen are the required actions for each element completed and when were they required to be

    completed?

    WhereWhere have actions been implemented or changed? WhyWhy have the implementation decisions and priorities been made as recorded in the documentation? HowHow is the program implemented and how is the programs effectiveness evaluated and improved?

    An essential part of verifying program implementation is to audit the flow of information and activities among theelements. When information in one element is changed or when action takes place in one element that affects otherelements, an auditor/reviewer should examine a sample of the related elements to see if the appropriate changes andfollowup actions have taken place.

    The following example demonstrates the interrelationship among the elements:During a routine inspection of equipment (Mechanical Integrity), the maintenance worker discovers a valve that nolonger meets the applicable code and must be changed. Because the type of valve is no longer made, a different type of

    valve must be selected and installed (Management of Change). The type of valve selected may mandate different stepsfor the operators (Operating Procedures)who will require training and verification in the new procedures (Training).The rationale for selecting the type of valve must be made available for review by employees and their representatives(Employee Participation).

    When the new valve is installed by the supplier (Contractors), a qualified and safe contractor must be selected to performthe work(Contractor Management). The workwill involve shutting down part of the process (Pre-startup SafetyReview) as well as brazing some of the lines (Safe Work Practices - Hot Work Permit). The employer must review the

    response plan (Emergency Planning) to ensure that procedures are adequate for the installation hazards. AlthoughManagement of Changeprovisions cover interim changes, after the new valve is in place the Process Safety

    Informationwill have to be updated before the (Process Hazard Analysis) is updated or revalidated, to account forpotential hazards associated with the new equipment. Also, inspection and maintenance procedures and training will needto be updated (Mechanical Integrity).

    In summary, 12PSM elements can be affected by changing one valve. A reviewer/inspector/auditor/compliance officerwould check a representative number of these 11 elements to confirm that the required follow-up activities have beenimplemented for the new valve.

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    Occupational Safety & Health Program

    PSM Program Review Checklist

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    September 2011www.oshainfo.gatech.edu

    Application of PSM Standard to Facility - 1910.119(a)

    Does the workplace have any of the following:A process which involves a chemical at or above the specified threshold quantities listed in Appendix A of

    the PSM Standard (attached to checklist); or

    A process which involves a flammable liquid or gas [as defined in 1910.1200(c)] on site in one location, in aquantity of 10,000 pounds (4535.9 kg) or more.

    Exemptions: A threshold quantity of flammable liquids if it is stored in atmospheric tanks or transferred without the

    benefit of chilling or refrigeration

    Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfortheating or gasoline for vehicle refueling.) These fuels cannot be part of a process containing other

    highly hazardous chemicals covered by the PSM standard.

    Retail facilities. Oil or gas well drilling or servicing operations. Normally unoccupied remote facilities. Note: for determining coverage by the PSM standard, the quantity of flammable liquids stored in

    atmospheric tanks may be excluded from the quantity in the covered process pursuant to the Meer

    Decision.

    Important interpretation: June 11, 2007OSHA defines on-site in one location for PSM to mean that the

    standard applies when a threshold quantity of highly hazardous chemical (HHC) exists within an area underthe control of an employer or group of affiliated employers. It also applies to any group of vessels that are

    interconnected, or in separate vessels that are close enough in proximity that the HHC could be involved in a

    potential catastrophic release.

    * * I F TH E WORKPLACE HAS ANY OF THESE OPERATIONS OR PROCESSES, I T MUST COMPLY

    WITH THE PSM STANDARD. **

    Examples of industries that may have highly hazardous chemicals and processes covered by the PSM standard:

    Industrial production of organics and inorganicmaterials

    Paints Pharmaceuticals Adhesives

    Sealants and Fibers Petrochemical facilities Paper Mills Food Processing with Anhydrous Ammonia over

    the TQ

    Conversion Example

    Gallons to lbs conversion = gal lons x 8.33 x specif ic gravity of the liquid = lbs of li quidExample: Weight of 10,000 gall ons of gasoli ne = 10,000 x 8.33 x 0.739 = 61,559 lbs

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    YES NO Employee Participation1910.119(c)(1)

    Has the employer developed a written plan of action for implementation of employeeparticipation?

    YES NO Employee Participation1910.119(c)(2)Has the employer consulted with employees and their representatives on the conduct and

    development of process hazard analyses and on the development of all other elements of the

    PSM standard?

    YES NO Employee Participation1910.119(c)(3)Do employees and their representatives have access to process hazard analyses and all other

    information required by the PSM standard?

    YES NO Hazard Information Collection1910.119(d)(1)

    Has the employer collected information pertaining to the hazards of the process?

    Toxicity PELs Physical data Reactivity

    Corrosivity Thermal & chemical stability Hazards of mixing chemicals MSDSs

    YES NO Technology of the Process Information Collection1910.119(d)(2)(i)(A)Does the employer have block diagrams or simplified process flow diagrams for each

    covered process?

    YES NO Technology of the Process Information Collection1910.119(d)(2)(i)(B-D)Does the employer have information on the technology of the covered process for the

    following:

    Process chemistry1910.119(d)(2)(i)(B). Maximum intended inventory1910.119(d)(2)(i)(C). Safe upper and lower limits for: temperature, pressures, flows, levels, compositions

    or other pertinent metrics for the process1910.119(d)(2)(i)(D).

    YES NO Technology of the Process Information Collection1910.119(d)(2)(i)(E)Has the employer performed and documented an evaluation of the consequences ofdeviations in the covered process, including those affecting the health and safety of

    employees?

    YES NO Equipment of the Process Information Collection1910.119(d)(3)(i)(A-H)Does the employer have information on the equipment of the covered process for thefollowing:

    Materials of construction1910.119(d)(3)(i)(A). Piping and instrument diagrams (P&IDs)1910.119(d)(3)(i)(B). Electrical classification1910.119(d)(3)(i)(C). Relief system design and design basis1910.119(d)(3)(i)(D). Ventilation system design1910.119(d)(3)(i)(E). Design codes or standards used1910.119(d)(3)(i)(F). Material and energy balances for processes1910.119(d)(3)(i)(G). Safety systems1910.119(d)(3)(i)(H).

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    YES NO Equipment of the Process Information Collection1910.119(d)(3)(i)(A-H)

    Has the PSM documentation including all elements above been field verified and comparedto the actual equipment and components in the covered process?

    YES NO Process Hazard Analysis 1910.119(e)(1)Has the employer performed an initial process hazard analysis on the covered processes?

    YES NO Process Hazard Analysis

    1910.119(e)(2)(i-vii)Has the employer used one or more of the following methodologies to perform the processhazard analysis (PHA)?

    What if1910.119(e)(2)(i). Checklist1910.119(e)(2)(ii). What if/Checklist1910.119(e)(2)(iii). Hazard and Operability Study (HAZOP)1910.119(e)(2)(iv). Failure mode and effects analysis (FEMA)1910.119(e)(2)(v). Fault tree analysis1910.119(e)(2)(vi). An appropriate