14 Elements of PSM Compliance

Introduction:

In the below matrix we outline the 14 elements of process safety management (PSM) compliance, why they are importand and what OSHA requires. We also discuss how PSM Software can help companies like yours efficiently achieve, maintain and demonstrate compliance with 29 CFR 1910.119.

Process Safety Management Matrix:

Requirement:	Why It Is Important:	What OSHA Requires:	29 CFR Citation:	How Ecesis Can Help:
Employee Participation	Employee participation improves ownership of a site's safety program. This results in better safety programs and improved safety performance.	Employers must: Develop a written plan of action regarding the implementation of the employee participation. Consult employees on PHAs and elements of their PSM Program. Provide employees access to PHA other information required by the PSM Standard.	1910.119(c)	Ecesis makes it easy for employees to participate through our intuitive mobile EHS App. On our EHS App, employees can: Take Training Report Incidents Manage and Complete Tasks - Submit safety forms Submit Safety Forms Report Hazards Submit Change Requests Additionally, our EHS App makes it easy for employees to access PSM Information.
Process Safety Information	Documenting process safety information ensures it is part of your company's institutional knowledge and that it is available when analyzing hazards and associated risks.	Employers must complete a compilation of written process safety information before conducting any process hazard analysis required by the standard. This documentation must include information pertaining to: Hazards of highly hazardous chemicals Technology of processes Equipment	1910.119(d)	The Ecesis Documents Solution provides a simple, centralized and easily accessible location for all of your Process Safety Information.
Process Hazard Analysis (PHA)	A PHA or hazard evaluation identifies and ranks the hazards associated with your processes so you can ensure controls are in place to manage the risk(s) those hazards create.	Employers must complete a process hazard analysis that identifies and evaluates the hazards of their process. Findings and recommendations that result from the PHA must then be promptly addressed.	1910.119(e)	The Ecesis Task Managment Solution makes it easy to manage PHA information as well as track preventive and corrective actions to ensure they are resolved in a timely manner.
Operating Procedures	Having documented, reviewed, approved and controlled operating procedures ensures employees are using current and accurate information that has been evaluated by subject matter experts.	Employers must develop and implement written procedures that provide clear instructions for safely conducting activities.	1910.119(f)	The Ecesis Documents Solution provides: A centralized and readily accessible location for your Company's operating procedures. A built-in approval process that ensures only reviewed and approved procedures are being used as the basis for performing tasks and activities.
Training	Training is a critical part of ensuring employees have the knowledge that is needed to safely perform their tasks.	Employers must conduct initial and refresher training on: Specific safety and health hazards Emergency operations including shutdown Safe work practices applicable to the employee's job tasks	1910.119(g)	The Ecesis Training Solution helps you: Create site-specific training classes Deliver training anytime/anywhere using our mobile EHS App Track employee training and certifications Track certifications for compliance
Contractors	Contractors provide critical resources and expertise; however, they often do not have the same site-specific knowledge and training as your employees do. As such, it is important that they be thoroughly evaluated and properly trained prior to being exposed to your site's hazards.	Contract employers must assure that each contract employee: Is trained in the work practices necessary to safely perform his/her job Is instructed in the known potential fire, explosion, or toxic release hazards Follows the safety rules of the facility including the safe work practices Is Advised of any unique hazards presented by the contract employer's work, or of any hazards found by the contract employer's work	1910.119(h)	The Ecesis Contractor Management Solution can help: Evaluate and maintain contractor safety performance information Provide site-specific training on hazards and procedures Make site-specific procedures, forms and information readily available to contractors Track and evaluate contractor incidents
Pre-Startup Safety Review (PSSR)	There are many things to think about when starting up new or modified process and its easy for things to wrong. Having a thorough and standardized PSSR process will help mitigate these risks.	When adding new facilities or modifying current facilities, employers are required to conduct a pre-startup safety review.	1910.119(i)	Ecesis incorporates PSSR forms into its MOC process to help ensure potential hazards are addressed and managed prior to startup.
Mechanical Integrity	Use and environmental conditions create wear and tear on equipment. A proactive mechanical integrity program helps track this wear and tear so equipment can be replaced and/or repaired before it fails.	Employers must: Establish and implement written procedures to maintain the on-going integrity of process equipment Train integrity management employees on the processes and hazards they will be exposed to. Perform and document integrity testing in accordance with industry standards and manufacturer recommendations Correct deficiencies that are outside of acceptable limits.	1910.119(j)	With Ecesis the Integrity Management Solution you can: Maintain written integrity procedures Limit task completion to only trained/certified personnel Track integrity deficiencies and associated findings to closure
Hot Work Permit	Projects involving hot work around hazardous chemicals present many risks. A hot work permitting process ensures these activities are reviewed and risk mitigation measures are implemented so fires do not occur.	Employers must issue hot work permits for hot work operations on or near covered processes.	1910.119(k) 1910.252	The Ecesis Safety Forms Solution lets you replace your paper forms with electronic forms. It is simple to create forms and permits with custom content and streamlined workflows so you can stop shuffling paper copies and automatically store your records in one centralized location.
Management of Change (MOC)	It is easy to overlook something when making changes to processes and facilities. This might be the need for a new permit or the introduction of a new hazard that needs to be controlled. An MOC process provides for a structured review of these changes so such items are not overlooked.	Employers must establish and implement written procedures to manage changes to: Process chemical Technology Equipment Procedures Facilities that affect a covered process.	1910.119(a)	The Ecesis MOC Solution makes it easy to submit, review and track change requests.
Incident Investigation	If an incident occurs, it is important that it be investigated so we can learn from it and prevent similar incidents from happening in the future.	Employers must investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemical in the workplace.	1910.119(m)	The Ecesis Incident Management solution lets you easily: Report and track incidents that occur within the workplace Complete incident investigations Track resulting corrective actions to completion.
Emergency Planning and Response	Knowing how to respond in the event of an emergency helps keep responders safe and minimizes the impacts of the emergency.	Employers must: Establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38. Include procedures for handling small releases. Comply with OSHA's HAZWOPER standard (if applicable)	1910.119(n) 1910.38 1910.120	The Ecesis Emergency Planning Solution centrally manages your emergency procedures without the need to keep paper copies floating around the office, or in your vehicles. Our mobile app also allows for anyone to access emergency information while they are on-the-go.
Compliance Audits	Auditing your programs helps ensure they are current and effective. After putting countless hours into developing your PSM program, it only makes sense to periodically verify it is effectively protecting your employees and processes.	Employers must certify that they have evaluated compliance with PSM requirements at least every three years to verify that the procedures and practices developed are adequate and are being followed. Compliance audits must be conducted by a subject matter expert and result in a report of findings that the employer must then correct.	1910.119(o)	With the Ecesis Compliance Management Solution, you can: Maintain any materials needed to pass an audit in one centralized location. Manage the audit reports and findings. Track resulting corrective actions to completion.
Trade Secrets	The individuals responsible for developing and upkeeping your PSM program must possess knowledge and comprehension of all hazards involved, even if some of these hazards are considered trade secrets. Without this critical understanding, it becomes exceedingly challenging to establish and maintain appropriate safety controls.	Without regard to trade secret status, employers must make information necessary to comply with PSM requirements available to persons: Responsible for compiling process safety information Assisting in development of PHAs Responsible for developing operating procedures Involved in incident investigations Involved in emergency planning and response Involved in compliance audits	1910.119(p)	With Ecesis EHS Software Solutions you can: Limit access to information to only those with a need to know Maintain PSM information and records in one centralized location