System Safety for the 21st Century, 2nd Edition

CHAPTER 24Process Safety Implementation

INTRODUCTION

In this chapter, we will additionally discuss the 29 CFR 1910.119 Process Safety Management (PSM) Rule provisions and some thoughts about the method of implementation of it and 40 CFR 68 Risk Management Process (RMP) rule. The chapter addresses each of the 14 elements of the OSHA PSM rule and provides implementation thoughts and suggestions for each element. The chapter additionally has a section about the EPA RMP implementation that varies based on the results of the consequence analysis or dependent on the type of process industry.

PSM IMPLEMENTATION

The very first step to take in the implementation of any program is to research the issue. Does the PSM rule even apply to the site and, if so, to what facilities/processes? The PSM rule is extensive and implementing it requires scoping, planning, and scheduling of actions. Then, the next step and prior to getting into the PSM implementation details involves preparing that plan of action, identifying resources needed for accomplishment. Finally, and prior to starting, the plan needs to be approved and coordinated. Only then, should one begin the implementation detail. That detail is shown in Figure 24‐1 and discussed in the next several pages. When fully implemented throughout the country, the PSM rule is estimated to prevent more than 260 deaths and 1,500 injuries annually (U.S. Department of Labor 1992).

1. Employee Participation

The contractor/owner should develop a plan ...