900 Oil and Gas Safety Management

14 PSM Elements

3. Process Hazard Analysis (PHA)

A PHA is a systematic review of potential hazards involving highly hazardous chemicals. The PHA team must include people knowledgeable in engineering, operations, the specific process, and the PHA method used. The team evaluates possible fires, explosions, toxic or flammable releases, and major spills, and recommends safeguards such as inherently safer design, engineering controls, or administrative controls.

Facilities with identical processes may use one PHA and adapt it for each site. PHAs must be reviewed and updated at least every five years. Employers must address identified hazards, document how recommendations are resolved, and inform affected employees of changes.

Key considerations for storage facilities include: separation of incompatible materials, siting hazards (e.g., vehicle impact, building separation), temperature-sensitive materials, toxic hazards and ventilation, fire zone separation, and consequences of accidental releases. PHAs may use various accepted methods; storage facilities often use simpler approaches such as What-if, Checklists, or combined techniques.

Examples: In a gas plant, a HAZOP identifies H₂S release risks from pump failures, recommending SIL-rated interlocks via LOPA; unresolved PHA findings, like inadequate check valves in throughput increases, lead to citations. Human factors analysis in refineries evaluates inaccessible valves in pipe racks.

4. Operating Procedures

Employers must create and maintain written operating procedures that clearly describe how to safely run each PSM-covered process—including normal operations, startup, temporary operations, and emergency shutdown. Procedures must describe process hazards, be accurate and current, and be readily available to operators. Employers must verify they are using the latest version before each use and may need to halt operations if outdated or incorrect procedures are found unless addressed through Management of Change (MOC). Procedures must be certified as current each year.

Helpful sources include equipment manufacturers, employees familiar with operations, chemical suppliers, and external references. Even facilities with few procedures must ensure they are clear, thorough, and reinforced through training and PSM compliance audits. Employees must understand and consistently follow them.

Examples include:

• Container handling and storage procedures
• Tank loading/unloading instructions
• Administrative controls (e.g., restricted access, ignition-source limits)
• Emergency procedures for spills, fire response, and evacuation

Examples: Emergency shutdown procedures in refineries assign operators for hydrocracker depressurization during power loss, separate from headcount duties. Safe work practices prevent vehicle collisions in flammable areas without permits, common in tank farms.

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