The presentation outlines OSHA’s Process Safety Management (PSM) mandates for written operating procedures and related safety programs. It explains that employers must develop clear, written procedures that cover every operating phase—startup, normal, temporary, emergency, shutdown, and post‑turnaround—detailing emergency shutdown conditions, operating limits, and safety/health considerations such as chemical hazards, engineering controls, PPE, inventory control, and safety system functions. Procedures must be kept current, accessible, and certified annually. The talk also covers required safe work practices (lockout/tagout, confined space entry, equipment opening, contractor access), employee participation in hazard analyses, and the need for a written plan to provide employees and their representatives access to these analyses. Training obligations include an overview of the process, hazard education, emergency operations, task‑specific safe practices, competency verification, and refresher training at least every three years, with records kept for each employee. Additional PSM elements—mechanical integrity, management of change, and pre‑startup safety reviews—are highlighted as documentation‑intensive requirements. The segment concludes by noting employer responsibilities during incidents and emergencies.
Chapters
As helpful as it is to identify hazards and analyze processes, it won't make much difference without a plan and procedure to transfer the safe practices to the employees who are dealing with the hazardous chemicals. That's why OSHA mandates that the employer develop and implement written operating procedures that align with the process safety information they compiled earlier. These must provide clear instructions on how to safely complete the activities involved in each process and must be communicated with the employees. The procedures must cover a series of topics within each of the 3 elements of operation. One, steps for each operating phase must include initial startup, normal, temporary and emergency operations, normal and emergency shutdown and startup following a turnaround or after an emergency shutdown. Emergency shutdown steps must outline the conditions under which this must take place and the qualified operators responsible for ensuring that the shutdown is safely executed in a timely manner. 2. Operating limits must cover the consequences of deviating from the plan and the steps required to correct or avoid a deviation. 3. Safety and health considerations must address the properties and hazards associated with chemicals used in the process, necessary precautions to avoid exposure including administrative and engineering controls, and personal protective equipment (PPE) measures to be taken in response to physical or airborne exposure, quality control for raw materials and control of hazardous chemical inventory levels, any special or unique hazards, and finally, safety systems and their functions. Operating procedures must be kept up to date to reflect changes in process chemicals, technology, equipment, and facilities. These procedures need to be accessible to employees who work in or maintain the process so that they can review the most current practices. And every year, the employer is required to certify that the operating procedures are current and accurate. The employer must also develop and implement safe work practices covering the control of hazards in a variety of circumstances. Such as during lockout/tagout, confined space entry, opening process equipment or piping, and entrance into a facility by maintenance contractor, laboratory, or other support personnel. OSHA's PSM standards also mandate employee participation, stating that employers must consult with employees and their representatives on the conduct and development of process hazard analyses and on the development of other elements of process management and they must provide to employees and their representatives access to process hazard analyses and all other information required to be developed by the standard. Employers must develop a written plan of action to implement this requirement. OSHA requires that each employee involved in or newly assigned to an operating process be given an overview of the process and training in its operating procedures. The training must emphasize health and safety hazards associated with the process, emergency operations, and safe practices related to the employee's job tasks. The training must also include a verification of competency for all tasks the employee will complete covered under the PSM. Refresher training must be provided at least every 3 years to each employee involved in operating a process to ensure that they understand and can implement up-to-date practices. The employer must keep a record of each employee, the date of training, and how they verified that the employee understood the training. OSHA also has specific requirements for maintaining the mechanical integrity of critical process equipment, managing change, and conducting pre-startup safety review to ensure process safety when a new hazardous chemical is introduced, or when there's an addition or modification that could impact the process. Each of these areas also requires detailed documentation. We're going to finish up with what employers have to do when there's an incident or emergency.
