Process Safety Management — a QEHS primer

OSHA 29 CFR 1910.119 (PSM) applies to processes that contain a threshold quantity of a highly hazardous chemical. EPA 40 CFR Part 68 (RMP) layers on top for the same chemical list but with community-impact reporting. If you are PSM-regulated, you are almost always RMP-regulated.

• Employee participation — written plan, workforce consulted on PSM activities.
• Process safety information — chemical, technology, equipment documentation.
• Process hazard analysis (PHA) — HAZOP / What-If / FMEA every 5 years.
• Operating procedures — written, current, accessible.
• Training — initial + refresher on process and procedures.
• Contractors — selection, training, audit.
• Pre-startup safety review (PSSR).
• Mechanical integrity — equipment inspection and testing.
• Hot work permit.
• Management of change (MoC).
• Incident investigation — recordable process-safety incidents.
• Emergency planning and response.
• Compliance audits — every 3 years.
• Trade secrets — protected but disclosable to those who need it.