Gateway Consulting Group

What is Process Safety Management (PSM)?

OSHA 1910.119, the Process Safety Management regulations mandate that plant operators manage the hazards associated with processes using highly hazardous chemicals.

What is a Process Safety Management (PSM) Covered Process?

Covered processes involve either specified quantities of hazardous chemicals or significant quantities of flammable substances, with exemptions for retail, oil, gas, and remote facilities. The Process Safety Management (PSM) standard applies broadly to interconnected and closely located components that could contribute to or exacerbate a hazardous chemical release.

Why is Process Safety Management (PSM) so challenging?

The regulation requires a great deal of information be maintained and kept current such as process safety information hazards analyses operating procedures

What is Management of Change (MOC)?

A key element of OSHA Process Safety Management (PSM) is the requirement for, and adherence to, a Management of Change (MOC) procedure. Before change Implementation: document the technical basis for change assess the impact of the change acquire proper approvals After change Implementation: mechanical integrity inspections pre-startup safety review conduct training update process safety information

When is Management of Change (MOC) Required?

The OSHA Process Safety Management (PSM) regulation requires a Management of Change (MOC) procedure to be initiated for asset changes (process chemicals, technology of the process, equipment and facilities) as well as procedures. Furthermore, there is an evolving consensus that organizational changes are also changes that should be managed by MOC. The exception is when the change is a Replacement in Kind (RIK).

What is a Replacement in Kind (RIK)?

“Replacement in Kind” (RIK) in the context of OSHA’s Process Safety Management (PSM) regulation, allows certain replacements that meet original design specifications to bypass the formal Management of Change (MOC) process. There are three primary assumptions that guide Replacement in Kind (RIK) decisions. “Grandfathering” allows identical part replacements “Generic” permits parts from alternative manufacturers with the same operational criteria “Recognized and Generally Accepted Good Engineering Practices” (RAGAGEP)

Why is Management of Change (MOC) so challenging?

A Management of Change (MOC) procedure must accommodate a wide range of potential changes from low to high complexity, cost or risk Management of Change (MOC) requires rigorous document management controls for each Management of Change (MOC) project A Management of Change (MOC) project typically involves different participants, skills, authority, etc. to accomplish

What is Process Hazard Analysis (PHA)?

The OSHA Process Safety Management (PSM) standard, identifies Process Hazard Analysis (PHA) as a critical component for identifying, evaluating, and controlling potential hazards associated with processes that involve hazardous chemicals. The analysis involves a systematic review of potential failure points, human errors, and equipment malfunctions that could lead to releases or other hazardous events. <div class="elementor-element elementor-element-9915c1a elementor-widget elementor-widget-text-editor" data-id="9915c1a" data-element_type="widget"