14 elements of OSHA’s process safety management

This post covers the 14 elements of process safety management (as identified by OSHA). You must incorporate these elements into your operation to be compliant with the PSM standard.

For your PSM program to work effectively (and remain compliant), you must implement all these elements, not just some. Here’s a good way to look at it:

Imagine you have strong employee participation in safety protocols, but your training model is outdated. While your workers may be willing to participate, they may not have the knowledge or skills needed to spot hazards or prevent incidents.

Review each of the PSM elements below to make sure your system works effectively.

What are the 14 elements of process safety management?

According to OSHA’s website, the goal of the PSM standard is to:

“[Prevent or minimize] the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals…[that] may result in toxic, fire or explosion hazards.”

The PSM standard outlines 14 main components, or elements, of compliant process safety programs, which are defined below.

Employee participation

You must encourage (and sometimes require) employees to participate in PSM-related initiatives such as: training, surveys, feedback, and reward programs.

Process safety information

Process safety information includes documentation outlining the specific safety protocols that you have in place.

Process hazard analysis (PHA)

A process hazard analysis is an assessment of the potential hazards within your operation. You must complete PHAs for all your processes to ensure that preventative safety measures are in place.

Operating procedures

Every business that falls under PSM compliance must have written operating procedures. These procedures must provide clear instructions to workers performing the related task. They should also be easily accessible to all employees.

Employee training

Your PSM program must ensure that employees receive required safety and process-specific training. You must document all training using either a learning management system or by hand, ensuring that records are updated frequently.

Contractor training

Training contractors is one of the hardest elements of PSM compliance to implement, due to the difficulty of managing third-party workers. You must ensure that all contractor workers receive appropriate training for the hazardous chemicals that they’ll work with.

Pre-startup safety review

Whenever you open a new facility, remodel a facility, or introduce a new piece of equipment, you must complete a pre-startup-safety review. You can learn more about PSSR requirements here and use this free PSSR checklist to get started.

Mechanical integrity

Under PSM, your critical process equipment must be designed and installed correctly. This applies to storage tanks and vessels, pumps, piping systems, valves, emergency shutdown systems, and controls.

Check out our mechanical integrity overview for more information about this element.

Hot work permit

Employees must have a hot work permit in order to perform hot work activities conducted on or near a covered process. Here’s a permit template you can use for your operation.

Management of change (MOC)

MOC refers to the standard process that everyone must follow when implementing process, equipment, or personnel changes. Following this requirement can be very difficult without some sort of MOC tracking system or standardized workflow.

Incident investigation

Whenever there is a near miss or safety incident, you must complete an investigation. During this investigation, you should identify the root cause(s), brainstorm corrective actions, and track action items through to completion.

Emergency planning and response

Every site, regardless of whether it falls under the PSM standard, should have comprehensive emergency response plans in place. In addition to documenting these protocols, you should train your employees how to act quickly in a variety of emergency situations.

Compliance audits

At least once every three years, you must certify that your operation is compliant with the PSM standard.

Trade secrets

The last element of PSM is trade secrets which refers to any classified documentation within your organization that pertains to PSM. Under the regulation, you must provide any PSM-related information, regardless of whether it contains trade secrets, to employees and their representatives. OSHA does, however, state that you can require non-disclosure agreements to anyone who receives trade secrets as a result of PSM compliance.

Why do I need process safety management?

The process safety management standard was designed to prevent hazardous chemical safety incidents, but it has many additional benefits as well.

Implementing all 14 elements of PSM compliance helps you build a cohesive incident prevention strategy. Many of these elements have a direct positive impact on other areas of EHS performance.

Additionally, with these measures in place, your workforce is better equipped to identify and control hazards proactively.

For your business to grow, it needs to run efficiently. And efficiency is possible when everyone is on the same page about what to do and why to do it. Under PSM compliance, workers should receive frequent updates when process, equipment, or personnel changes occur.

What are the benefits of PSM?

Here are some of the major ways that PSM compliance can benefit your business if you implement the framework correctly:

1. Avoid incident costs by minimizing hazardous releases, injuries, and down time.
2. Decrease response times to incidents or near-misses.
3. Reduce the impact of incidents before they cause major issues.
4. Analyze the root cause of an incident or near miss.
5. Plan operational changes with a minimal impact on daily operations.

I want to acknowledge how overwhelming it may be to implement a comprehensive PSM compliance program with all 14 of these elements. The process isn’t something you can complete in a week, and it will require thoughtful planning before you make any changes.

If you’re feeling overwhelmed, I’d recommend by reviewing what systems you current have in place for each PSM element. From there, you should be able to identify the gaps that need filled before you’re fully compliant.

Once you know the areas that need work, you should create a list of tasks (documents to create, training to complete, etc.) for your team to tackle. Then, assign all tasks to a member within your team and track them until they’re complete.