By W. Jon Wallace, CSP, MBA

The origins of OSHA’s Process Safety Management (PSM) standard can be traced back to the December 1984 Union Carbide explosion in Bhopal, India. Many Americans became concerned that a similar incident could occur in the United States. To further heighten public concern, in August 1985 Union Carbide experienced a major incident at their Institute, West Virginia facility when approximately two tons of toxic chemicals, including the pesticide aldicarb, was released over the residential area near the factory. At least 135 people had to be treated at local hospitals and another 175 by paramedics. In addition, there were two serious chemical explosions in Houston, Texas—Phillips 66 (October 23, 1989: 23 fatalities) and ARCO (July 6, 1990: 17 fatalities). In 1992, as a result of the previously mentioned incidents, OSHA finalized the PSM standard (1910.119). The PSM standard is a comprehensive standard with 14 major components.    

Recently there have been several industrial explosions involving natural gas. At least one of these facilities was covered by OSHA’s PSM standard (1910.119). How good is your facilities PSM program? When performing PSM program audits for clients, I routinely find significant deficiencies. Listed below are some documents you need available in the event of an OSHA PSM inspection:

Documents for Review:

1. Facility PSM Program—overview of all elements
2. Organizational chart of personnel with assigned duties
3. Priority schedule for conducting PHA’s
4. PHA reports for two most hazardous processes
5. PHA recommendation status reports for facility
6. Operating procedures for two most hazardous processes
7. Incident and “near hit” reports for PSM covered processes
8. Contractor safety program
9. Overall mechanical integrity program:
10. Fixed equipment – Vessels, storage tanks, relief and vent systems
11. Rotating equipment
12. Electrical & Instrumentation—monitoring devices, interlocks, emergency shutdowns
13. API 752 facility siting survey (if applicable)
14. OSHA 300 Log for 3 previous years
15. All internal PSM audit reviews
16. Employee training records/certification
17. Canceled hot work permits

Don’t be surprised to see OSHA significantly increase their emphasis on PSM inspections in the near future. By being prepared, you will ensure employee safety as well as maintain OSHA compliance.

If you have any questions concerning this article or other safety issues, please contact W. Jon Wallace, “The Safety Guru”, at 919.933.5548 or by e-mail