900 Oil and Gas Safety Management

14 PSM Elements

1. Employee Participation

Employees with experience in hazard identification and prevention are vital to workplace safety. Employee participation is important in PSM because it helps workers identify and prevent hazards through active involvement. Workplace safety is taken seriously if employees are committed to following health and safety procedures and have a sincere interest in developing them.

The PSM standard requires that employers covered under the standard:

• Develop a written plan of action regarding how they will implement employee participation.
• Consult their employees and their representatives regarding conducting and developing process hazard analysis (PHAs) and other elements of process safety management.
• Ensure that their employees and their representatives have access to PHAs and all other information required to be developed by the PSM standard.

Examples: In a refinery, operators participate in Process Hazard Analysis (PHA) teams to identify human factors like alarm fatigue during hydrocracker operations. Facilities must consult employees on emergency plans for ammonia refrigeration systems in LNG plants, ensuring buy-in for safe practices.

2. Process Safety Information (PSI)

Employers are required to compile written process safety information (PSI). The compilation of written process safety information will help the employer and the workers involved in operating the process to identify and understand the hazards involved in their processes.

Process safety information must include information on the hazards of the highly hazardous chemicals used or produced by the process, information on the technology of the process, and information on the equipment used in the process. Process safety information for the storage of highly hazardous chemicals will usually be considerably less extensive than that required for the manufacture or use of such chemicals.

Information on Highly Hazardous Chemicals: Employers must compile key safety information for each highly hazardous chemical, including toxicity, exposure limits, physical and reactive properties, corrosivity, stability, and hazards from accidental mixing. OSHA’s Hazard Communication standard also requires facilities to maintain Safety Data Sheets (SDSs) containing much of this information. If an SDS is not already available, the employer must obtain one from the chemical supplier.

Information on Process Technology: Process technology is likely much less complicated when the employer only stores chemicals, rather than processing, mixing, or deliberately reacting them.

Process technology information must include:

• Diagrams (Block, Process Flow) – an example of which is shown in non‑mandatory Appendix B of the PSM standard
• Maximum inventory levels for all chemicals in the PSM-covered process,
• Safe upper and lower process limits for such items as temperatures, pressures, flows or compositions
• An evaluation of the consequences of deviation, including those affecting the safety and health of employees, that could occur if operating beyond the established process limits.

Process Equipment Information: Facilities must document all equipment in a PSM-covered process, such as tanks, piping, pumps, relief systems, ventilation, alarms, and controls. Required information includes materials of construction, P&IDs (if applicable), electrical classifications, relief and ventilation designs, and safety systems. Packaged systems usually come with this data. Facilities with only small containers and no piping may not have P&IDs. For unusual situations, consult OSHA’s Enforcement Programs or OSHA Consultation. Employers must also verify that equipment meets recognized and generally accepted good engineering practices (RAGAGEP), as clarified in OSHA guidance.

Examples: In petroleum refineries, document relief valve sizing for overpressure scenarios in crude units, including back pressure calculations to prevent chattering; violations occur with undersized valves or high back pressure. Facility siting information protects control rooms from blast risks in alkylation units using HF.

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