Process safety information (“PSI”) is the foundation on which the rest of the PSM and RMP elements are built. Process safety information is that information that is needed to make sound safety decisions and it includes descriptions of the hazardous chemicals, the technology of the process, and the equipment in the process. Both regulations contain a detailed list of required PSI. See 29 CFR 1910.119(d) and 40 CFR 68.65. PSI must be gathered and documented prior to initiating a process hazard analysis (“PHA”).
The two rules have been in effect for over two decades and initial PHAs have long been performed on existing units. “The process hazard analysis shall be appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process.” 40 CFR 68.67(a). Every five years, a facility must update and revalidate the PHA. 40 CFR 68.67(f). Employers, through their PHA teams, must perform a PHA on new process units or must go through the management of change (MOC), where a change is made to an existing unit.
The dependence of a PHA on the quality of PSI is critical to the evaluation. For example, the PSI will indicate the metallurgy of a section of pipe in the facility and codes addressing the safe operating limits will be addressed in codes. Also included in the PSI are the consequences of deviation of operating outside of those limits are considered PSI. The PHA team takes the next step and identifies and evaluates the hazard involved in the process, and where appropriate suggest further controls. In response to identifying a hazard, the PHA team may make a recommendation (or action items) to control or mitigate the hazard. The facility must have a system in place to promptly address the team’s findings. Prior to introduction of regulated substances into a Program 3 process units, the employer must go under a Pre-startup review to make sure that recommendations have been resolved or implemented, that construction was done in accordance with the design, and that procedures are in place and training performed.
Both PSM and RMP require that the employer create and follow a schedule for maintenances and inspection of equipment on a set frequency. These requirements are found under the Mechanical Integrity requirements. See 29 CFR 1910.119(j) and 40 CFR 68.56 (for Program 2) or 40 CFR 68.73 (for Program 3). Often, frequency and methods are available via industry codes and standards. These codes and standards are generally considered to be factors in defining recognized and generally accepted good engineering practices (“RAGAGEP”). PSM and RMP also require operating procedures and training for the facilities. Sometimes, the recommendation from a PHA could be to create a procedure or increase training as a method of reducing risk.
In conclusion, both PSM and RMP have a common mechanism to reduce risk from covered processes. The first step is to gather information (PSI) related to the process in anticipation of performing a PHA or MOC. A team of appropriate employees considers the information, given their knowledge, and where appropriate makes recommendations to enhance safety. This team may recommend physical changes, changes in chemicals, added layers of controls, new or modified procedures and increased training, etc. Prior to startup of the unit, the recommendation must be resolved or implemented. Facilities must also have ongoing maintenance programs to assure regular testing and inspection of equipment.
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