OSHA’s Process Safety Management standard (29 CFR 1910.119) applies to facilities handling highly hazardous chemicals above threshold quantities. PSM is not just a regulatory checkbox – it is a systematic approach to preventing catastrophic releases that kill workers and communities.

Who Must Comply with PSM?

Facilities are covered if they handle any OSHA-listed highly hazardous chemical above its threshold quantity, or any flammable liquid or gas in quantities greater than 10,000 pounds. Common covered chemicals include: chlorine, ammonia, hydrogen, methane, and numerous solvents and petrochemical feedstocks.

The 14 PSM Elements

  1. Process Safety Information (PSI): Document all process chemistry, equipment design data, and P&IDs
  2. Process Hazard Analysis (PHA): HAZOP, What-If, FMEA – systematic hazard identification every 5 years
  3. Operating Procedures: Written procedures for startup, normal operations, shutdowns, and emergencies
  4. Training: Initial and refresher training on hazards, procedures, and emergency response
  5. Contractors: Verify contractor safety performance; inform contractors of process hazards
  6. Pre-Startup Safety Review (PSSR): Formal review before introducing hazardous chemicals after a major change or new installation
  7. Mechanical Integrity: Inspection and testing programmes for pressure vessels, piping, relief systems, and safety systems
  8. Hot Work Permit: Authorisation system for spark-producing work near flammable chemicals
  9. Management of Change (MOC): Formal process for reviewing safety impact of changes to process, equipment, or procedures
  10. Incident Investigation: Investigate all incidents and near-misses; address root causes
  11. Emergency Planning and Response: On-site emergency plan coordinated with local emergency responders
  12. Compliance Audits: PSM programme audit every 3 years
  13. Trade Secrets: Protect confidential process information while ensuring access for safety reviews

PSM and IEC 61511

OSHA PSM Element 7 (Mechanical Integrity) and Element 9 (MOC) interface directly with IEC 61511 SIS requirements. The Safety Instrumented System proof test programme is a Mechanical Integrity deliverable. Changes to SIS setpoints or logic must pass through MOC with a functional safety impact assessment.