Occupational Safety & Health Program PSM Program Review Checklist Page 2 of 14 September 2011 www.oshainfo.gatech.edu Application of PSM Standard to Facility - 1910. OSHA Safety Plans - customizable and prewritten help to keep you in compliance with OSHA rules for written safety programs - free downloadable safety plan. How they affect maintenance processes . To stem the nature and effect of these accidents, the Department of Labor, through its OSHA agency, initiated PSM in 1. NEP for refineries in 2. A few short years after that, riding on the success of the refinery NEP, OSHA initiated a CHEMNEP (Chemical National Emphasis Program) to lay a level of oversight on the other HHC facilities, in line with what was accomplished in the petroleum industry. If the physical nature of the work to be demonstrated was adequate, the documentation was most likely missing or not ready for inspection. There was a lot of work to do around the country for HHC- related companies to improve on the management of their processes; and there still remains a good bit of work to be accomplished. Employee participation. The employee participation element is perhaps the one with the shortest number of mandates, but with one of the largest impacts. Right from CFR 1. Employers shall develop a written plan of action regarding the implementation of the employee participation. Your employee participation program must be written and all meetings well documented. Employee participation is a process that has to be thought out, and followed as written, to ensure that the workers have a clear and documented path of communication for these important PSM discussions. Maintenance technicians are involved in the complex task of testing and repairing the production equipment, and their well- being is on the line with every turn of the wrench. When any aspect of the system involving HHCs is involved, maintenance must be involved in the discussion. This process of including maintenance (and operators) must be documented and followed, with an extensively objective, evidence- laden path. Process safety information. This element contains one of the most highly concentrated, maintenance- specific listings of all the elements. CFR 1. 91. 0. 1. 19 states our obligation as maintenance leaders very clearly: “the employer shall complete a compilation of written process safety information before conducting any process safety hazard analysis required by the standard. This process safety information shall include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process.”. Process safety management is a regulation, promulgated by the U.S. Occupational Safety and Health Administration (OSHA). A process is any activity or combination of. What is an occupational health and safety (OH&S) program? What is a policy statement? What are the program elements? ![]() In this text, “operators” includes maintenance insomuch as maintenance works on and around the HHCs. The CFR text above indicates that your MSDS (material safety data sheets) information needs to be accessible and current, as do your P& IDs, component information listing, electrical classification, ventilation systems, and safe operating limits, and much, much more. This is a very intense element. Our maintenance technicians have to have access to and understand all the technical data around our production systems, including the component particulars and information on the hazards of the HHC involved. 1 Elements of an Effective Safety and Health Program Voluntary Safety and Health Program Management Guidelines Wholesale and Retail Trade Sector. OSHA Rulemaking on Basic Program Elements for Federal Employee Occupational Safety and Health Programs and Related Matters. Process hazard analysis (PHA)This element is extremely technical in nature and includes a comprehensive what- if evaluation. The CFR reads, “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.” In this element engineers and maintenance leaders hone their Failure Mode and Effects Analysis (FMEA) skills, as well as exploring the consequence of failure. This process analysis will be conducted as a team and includes a review of the facility siting for possible hazards. In fact, the standard requires this team has both “engineering and process operations” expertise. The team makeup also includes at least one person “who has experience and knowledge specific to the process being evaluated.” Additionally, there has to be one person on the team that is “Knowledgeable in the specific process hazard analysis methodology being used.”. After an initial PHA is conducted, the process hazard analysis is required to be updated and revalidated by a team no less than every five years. Operating procedures. At first blush it might not seem that there would be a maintenance impact under the heading of operating procedures, but this element has a few items of interest. If you’ve ever been at a plant during an emergency shutdown or a release, then you can attest to the fact that maintenance is heavily involved in addressing the situation. Training. This element does specifically address the needs for those operating a process. To be sure, though, maintenance technicians need to be fully trained for all the functions they are performing, and that training needs to have been accomplished through a competent source and very well documented. Contractors. There are a lot of opportunities in this element to trip up an otherwise healthy and well- executed maintenance strategy. Contractors are perhaps unfairly known to do what they can get away with to get a job done. ![]() OSHA Training and Reference Materials Library - Elements of an Effective Safety and Health Program. Draft for Public Comment OSHA Safety and Health Program Management Guidelines ITRODUCTIO 3 How to Use the Guidelines Each guideline section describes a core program. Under the auspices of PSM- NEP, there are some very unforgiving rules: “The employer, when electing a contractor, shall obtain and evaluate information regarding the contract employer’s safety performance and programs. The employer shall inform contract employers of the known potential fire, explosion, or toxic release hazards related to the contractor’s work and the process.” This element continues with other very hefty requirements. Many times the supervision of a contractor will fall under the office of the maintenance manager; the impact on plant maintenance should be obvious for this fact. ![]() ![]() ![]() A formal fleet safety program can help maximize fleet efficiency, enhance safety, and more. Learn more about creating a fleet safety program from Travelers. According to OSHA, the best safety and health programs involve every level of. The sample program contains descriptions of how each of the key program elements.
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