OSHA's Process Safety Management standard (29 CFR 1910.119) requires employers to implement 14 specific program elements to prevent catastrophic releases of highly hazardous chemicals. Below we outline each element, explain why it matters, describe what OSHA requires, and show how Ecesis PSM software can help your facility achieve and maintain compliance.
The 14 PSM Elements
1. Employee Participation
Why it matters:
Employee participation improves ownership of a site's safety program, leading to better hazard identification, more effective procedures, and improved overall safety performance. Workers who operate processes daily often have the most practical knowledge of where risks exist.
What OSHA requires:
- Develop a written plan of action for employee participation in PSM
- Consult employees on process hazard analyses and other PSM elements
- Provide employees access to PHAs and other information required by the standard
2. Process Safety Information (PSI)
Why it matters:
Documenting process safety information ensures it becomes part of your company's institutional knowledge and is readily available when analyzing hazards and assessing risks. Without complete PSI, hazard analyses and operating procedures cannot be properly developed.
What OSHA requires:
Employers must complete a compilation of written process safety information before conducting any process hazard analysis. Documentation must include information pertaining to:
- Hazards of highly hazardous chemicals used in the process
- Technology of the process (block flow diagrams, process chemistry, safe operating limits, consequences of deviation)
- Equipment in the process (materials of construction, P&IDs, electrical classification, design codes)
3. Process Hazard Analysis (PHA)
Why it matters:
A PHA or hazard evaluation identifies and ranks the hazards associated with your processes, ensuring controls are in place to manage the risks those hazards create. It is the analytical foundation of your entire PSM program.
What OSHA requires:
- Complete an initial PHA using one or more recognized methodologies (What-If, Checklist, HAZOP, FMEA, Fault Tree, or equivalent)
- Address hazards of the process, previous incidents, engineering and administrative controls, consequences of failure, facility siting, human factors, and qualitative evaluation of safeguard failures
- Update and revalidate PHAs at least every five years
- Promptly address findings and recommendations
4. Operating Procedures
Why it matters:
Documented, reviewed, and approved operating procedures ensure employees use current, accurate information that has been evaluated by subject matter experts. They provide the safety backbone for daily operations.
What OSHA requires:
- Develop and implement written operating procedures for each covered process
- Include steps for initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, and startup following a turnaround
- Address operating limits, safety and health considerations, and safety systems
- Certify annually that procedures are current and accurate
5. Training
Why it matters:
Training is a critical part of ensuring employees have the knowledge needed to safely perform their tasks. Without proper training on process-specific hazards and procedures, even the best written programs cannot protect workers.
What OSHA requires:
- Provide initial training to each employee involved in operating a covered process on an overview of the process and its specific safety and health hazards
- Include training on emergency operations and shutdown procedures
- Provide refresher training at least every three years
- Document that each employee has received and understood the training
6. Contractors
Why it matters:
Contractors provide critical resources and expertise but often lack the same site-specific knowledge and training as your employees. Thorough evaluation and proper training before they are exposed to your site's hazards is essential for preventing incidents.
What OSHA requires:
- Evaluate contractor safety performance and programs when selecting contractors
- Inform contract employers of known fire, explosion, or toxic release hazards
- Ensure contract employees are trained in safe work practices and site-specific hazards
- Maintain a contractor injury and illness log for work in process areas
- Periodically evaluate contractor performance
7. Pre-Startup Safety Review (PSSR)
Why it matters:
Starting up new or modified processes involves many variables, and it is easy for critical safety items to be overlooked. A thorough and standardized PSSR process helps mitigate these risks before operations begin.
What OSHA requires:
Employers must perform a pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in process safety information. The review must confirm that:
- Construction and equipment are in accordance with design specifications
- Safety, operating, maintenance, and emergency procedures are in place and adequate
- A PHA has been performed for new facilities and recommendations resolved
- Modified facilities meet MOC requirements
- Training of affected personnel has been completed
8. Mechanical Integrity
Why it matters:
Equipment exposed to hazardous chemicals and demanding operating conditions deteriorates over time. A proactive mechanical integrity program identifies wear and degradation so equipment can be repaired or replaced before catastrophic failure occurs.
What OSHA requires:
- Establish and implement written procedures to maintain the ongoing integrity of pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls, and pumps
- Train maintenance employees on the processes and hazards they will be exposed to
- Perform and document inspections and tests in accordance with recognized standards and manufacturer recommendations
- Correct deficiencies in equipment that are outside acceptable limits before further use
- Ensure new equipment is suitable for the process application and properly installed
9. Hot Work Permits
Why it matters:
Hot work activities such as welding, cutting, brazing, and grinding near hazardous chemicals present significant fire and explosion risks. A formal permit system ensures these activities are reviewed and that risk mitigation measures are in place before work begins.
What OSHA requires:
Employers must issue a hot work permit for hot work operations conducted on or near a covered process. The permit must document that fire prevention and protection requirements in 29 CFR 1910.252(a) have been implemented prior to beginning the work and that the permit is kept on file until completion.
10. Management of Change (MOC)
Why it matters:
When changes are made to processes and facilities, it is easy to overlook the need for a new permit, the introduction of a new hazard, or the impact on existing safeguards. An MOC process provides structured review so such items are not missed.
What OSHA requires:
Employers must establish and implement written procedures to manage changes (except replacements in kind) to process chemicals, technology, equipment, procedures, and facilities that affect a covered process. Procedures must address:
- The technical basis for the proposed change
- Impact of the change on safety and health
- Modifications to operating procedures
- Necessary time period for the change
- Authorization requirements for the proposed change
11. Incident Investigation
Why it matters:
When an incident occurs, thorough investigation identifies root causes and contributing factors so corrective actions can prevent recurrence. Failing to investigate and learn from incidents virtually guarantees they will happen again.
What OSHA requires:
- Investigate each incident that resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical
- Initiate the investigation within 48 hours of the incident
- Use an investigation team that includes at least one person knowledgeable in the process and a contract employee if the incident involved contractor operations
- Prepare a written report documenting findings and contributing factors
- Promptly address investigation findings and corrective actions
- Retain reports for five years
12. Emergency Planning and Response
Why it matters:
Knowing how to respond in the event of an emergency keeps responders safe and minimizes the impacts of the event. Without clear emergency procedures, a manageable incident can quickly escalate into a catastrophe.
What OSHA requires:
- Establish and implement an emergency action plan for the entire plant in accordance with 29 CFR 1910.38
- Include procedures for handling small releases of hazardous chemicals
- Comply with OSHA's HAZWOPER standard (29 CFR 1910.120) if applicable
13. Compliance Audits
Why it matters:
Auditing your programs ensures they remain current and effective. After investing significant effort in developing your PSM program, periodic verification confirms it is actually protecting your employees and processes as intended.
What OSHA requires:
- Certify that compliance with PSM requirements has been evaluated at least every three years
- Use at least one person knowledgeable in the process to conduct the audit
- Develop a written report of audit findings
- Promptly determine and document the employer's response to each finding
- Document that deficiencies have been corrected
- Retain the two most recent compliance audit reports
14. Trade Secrets
Why it matters:
The individuals responsible for developing and maintaining your PSM program must have full knowledge and comprehension of all hazards involved, even if some of these hazards involve trade secrets. Without this understanding, it becomes exceedingly difficult to establish and maintain appropriate safety controls.
What OSHA requires:
Regardless of trade secret status, employers must make information necessary to comply with PSM requirements available to persons who are:
- Responsible for compiling process safety information
- Assisting in the development of process hazard analyses
- Responsible for developing operating procedures
- Involved in incident investigations
- Involved in emergency planning and response
- Involved in compliance audits
Employers may require confidentiality agreements as a condition of access, but cannot withhold information needed for PSM compliance.
How the 14 Elements Work Together
While each PSM element has its own requirements, they are designed to function as an integrated system. Process safety information feeds into process hazard analyses. PHA findings drive updates to operating procedures and training programs. Management of change triggers pre-startup safety reviews. Incident investigations reveal gaps in training, procedures, or mechanical integrity. Compliance audits verify that all elements are working as intended.
This interconnected nature means that a weakness in any single element can cascade into failures across the entire program. That is why OSHA evaluates PSM compliance holistically, and why a centralized software platform that connects all 14 elements provides significant advantages over managing each element in isolation.
Ecesis PSM Compliance Software
Incident Investigation
Report, investigate, and track corrective actions for process safety incidents
Management of Change
Submit, route, and approve change requests through customizable workflows
Audits & Inspections
Conduct PSM compliance audits and field inspections with our mobile app
Training Management
Deliver, track, and certify PSM training for employees and contractors
Mechanical Integrity
Schedule inspections, track deficiencies, and manage equipment maintenance
Emergency Planning
Centralize emergency procedures with mobile access for field personnel
