What About the Other Complex but Equally Important PSM/RMP Elements?
Process Safety Management (PSM) and Risk Management Planning (RMP) programs are made up of fourteen elements. Some of the elements are very complex and require a lot of labor to compile and manage while some of the other elements can refer to other regulatory programs. A complex labor-intensive element would include Process Hazard Analysis (PHA) while a less labor intensive one would be Hot Work Permit. Below is the table of PSM/RMP elements covered since this series started in February 2021. The elements highlighted are the one previously covered.
|1||Employee participation||Employee participation|
|2||Process safety information||Process safety information|
|3||Process Hazard Analysis (PHA)||Offsite consequence analysis including worst case and alternative scenarios|
|4||Operating procedures||Operating procedures (Program 2 requires PHA)
Process Hazard Analysis Program 3
|7||Pre-Startup safety review||Pre-Startup safety review|
|8||Mechanical integrity||Mechanical integrity|
|9||Hot work permit||Hot work permit|
|10||Management of Change (MOC)||Management of Change (MOC|
|11||Incident investigation||Incident investigation|
|12||Emergency planning and response||Emergency planning and response|
|13||Compliance audits||Compliance audits|
|14||Trade Secrets||Trade secrets.|
A webinar to address the finer points and experiences with Process Safety Information and Operating Procedures was broadcast on April 12, 2023. The remaining elements will be addressed in future webinars. Both elements may take a significant amount of time to compile as well as manage depending on the complexity of the process. A summary of each element follows.
Process Safety Information
A PSM/RMP-regulated facility must compile written process safety information. This safety information must be compiled and completed under the same schedule as the Process Hazard Analysis (PHA). Information on the hazards must consist of at least the following:
- Permissible Exposure Limits;
- Physical data;
- Reactivity data;
- Corrosivity data; and,
- Thermal and chemical stability data and the effect of inadvertent mixing of the wrong materials.
Multiple contributing items for the technology of the process must include at least the following:
- Block flow diagram or simplified process flow diagram;
- Process chemistry
- Maximum intended inventory
- Safe operating limits
- Consequences of deviation(s).
A PSM/RMP-regulated facility must also compile written operating procedures consistent with the process safety information. The required seven operating phases along with some additional experiences will be presented. Critical items required along with additional information will be presented.
PSM/RMP are labor-intensive regulatory requirements, however, one PSM/RMP incident can be more expensive than managing the program. The other key aspect is the loss of public trust and ultimately loss of the intangible social permit for operating. Restoring a social license can take a generation or more to restore. The value of maintaining the PSM /RMP program is important to both the facility and the corporate culture. The two key elements discussed above as well as intangible value will be presented.