PSM Implementation
Guide

Establish the PSM Team and Employee Participation Plan

Appoint a PSM coordinator with clear authority and accountability. Form a cross-functional PSM team that includes operations, maintenance, engineering, and safety personnel. Write the employee participation plan that OSHA requires, defining how employees will be involved in PHA development, procedure reviews, incident investigations, and access to PSM information. Begin communicating the PSM initiative to the entire workforce.

Compile Process Safety Information

This is the single most time-consuming step in PSM implementation and must be completed before process hazard analyses can begin. Gather and organize documentation covering three categories:

• Chemical hazard information: SDSs, toxicity data, permissible exposure limits, physical data, reactivity data, corrosivity data, and thermal and chemical stability data for every highly hazardous chemical in your covered processes
• Process technology: Block flow diagrams or simplified process flow diagrams, process chemistry, maximum intended inventory, safe upper and lower operating limits, and consequences of deviations
• Equipment information: Materials of construction, piping and instrument diagrams (P&IDs), electrical classification, relief system design and design basis, ventilation system design, design codes and standards employed, material and energy balances, and safety systems

Develop Operating Procedures

While PSI compilation is underway, begin developing or updating written operating procedures for each covered process. Procedures must address initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, and startup following a turnaround or emergency shutdown. Include operating limits, consequences of deviation, steps to correct deviations, and safety and health considerations.

Conduct Process Hazard Analyses

The PHA is the analytical engine of your PSM program. Select an appropriate methodology (HAZOP, What-If, Checklist, FMEA, Fault Tree, or a combination) based on the complexity of your processes. Form PHA teams that include at least one member with expertise in the process and one with expertise in the PHA methodology. The analysis must address:

• Hazards of the process
• Previous incidents with catastrophic potential
• Engineering and administrative controls and their interrelationships
• Consequences of control failures
• Facility siting
• Human factors
• A qualitative evaluation of possible safety and health effects of control failure

Document all findings and recommendations. Establish a system to track resolution of each recommendation to completion with responsible parties and target dates.

Build the Management of Change Program

Establish written MOC procedures before making any changes to covered processes. Define what constitutes a change (versus a replacement in kind), who must review and authorize changes, what impact assessments are required, and how affected employees will be notified and trained. Implement workflows for submitting, reviewing, and closing out change requests with complete documentation.

Establish Pre-Startup Safety Review Procedures

Develop PSSR checklists and procedures that are integrated with your MOC process. Every MOC-approved change and every new facility startup should trigger a PSSR to confirm construction matches design specifications, procedures are in place, PHAs have been completed, and training is current.

Launch the Mechanical Integrity Program

Develop an equipment inventory covering pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls, and pumps. Write inspection and testing procedures based on manufacturer recommendations and recognized industry standards (API, ASME, NFPA). Establish inspection frequencies, train maintenance personnel, and set up a system to track findings, deficiencies, and corrective actions.

Implement the Training Program

Develop initial training for each employee currently operating or maintaining a covered process. Training must cover an overview of the process and its specific safety and health hazards, emergency operations including shutdown, and safe work practices. Establish a refresher training schedule (at least every three years) and a documentation system that records training dates, content, comprehension verification, and instructor qualifications.

Establish Contractor Management Procedures

Develop contractor evaluation criteria for safety performance and programs. Create site-specific orientation and training materials for contract employees. Establish a system for informing contractors of known process hazards, providing safe work practice rules, and maintaining a contractor injury and illness log. Define how contractor performance will be periodically evaluated.

Develop Emergency Planning and Response

Write or update your emergency action plan per 29 CFR 1910.38, specifically addressing potential catastrophic releases of highly hazardous chemicals. Include procedures for small releases, evacuation routes and assembly areas, emergency contact information, and coordination with local emergency responders. Conduct initial drills to test the plan and identify gaps.

Implement Hot Work Permit System

Create a hot work permit form that documents fire prevention measures per 29 CFR 1910.252(a) before any welding, cutting, brazing, or grinding near covered processes. Define who is authorized to issue permits, what inspections are required before and after work, and how permits are filed and retained.

Build the Incident Investigation Program

Establish procedures for investigating any incident that resulted in, or could reasonably have resulted in, a catastrophic release. Define investigation team composition requirements, the 48-hour initiation deadline, root cause analysis methodologies, report documentation standards, and corrective action tracking. Train investigation team members before incidents occur.

Establish the Compliance Audit Cycle

Schedule your first comprehensive PSM compliance audit within three years of initial implementation. Develop audit protocols that systematically evaluate each of the 14 elements. Identify qualified auditors (at least one must be knowledgeable in the process). Plan for a written audit report with findings, employer responses, and corrective action tracking. Retain the two most recent audit reports.

Address Trade Secrets

Review your processes for any information that may be considered a trade secret. Develop confidentiality agreements for personnel who need access to this information for PSM purposes. Ensure that trade secret protections never prevent employees from accessing information they need for PHA participation, procedure development, incident investigation, or any other PSM activity.