Process Safety Management (PSM) is the OSHA standard that mandates employers identify, evaluate and control potentially hazardous activities, chemicals and components used in their processes.
While PSM audits are performed every three years, you should periodically perform self-audits to protect your facility from punitive measures from OSHA and, more importantly, to protect your employees from potentially catastrophic events that could lead to loss of life or property.
However, this isn’t a guide on performing self-audits (you can read more on that here).
Instead, we’re going to walk through a few PSM elements that you should pay special attention to while performing self-audits.
Management of change
- When any ingredient, material, piece of equipment or operating procedure within a process changes, the effect of that change must be evaluated for any impacts on the health and safety of employees. The Management of Change protocol should begin when the change is contemplated.
- If new ingredients/materials are used in a process, the existing equipment that the ingredients come in contact with must be capable of handling the ingredients/materials without malfunction.
- If production speed increases, line equipment must be checked to ensure it can handle the increased capacity, increased volume and higher rates of wear and tear.
- Process equipment must be designed and configured to handle the materials, production capacity and volume involved in a given process.
- Equipment should be in good operating condition and not in disrepair (e.g., leaking, chaffing, corroded, clogged).
- Lack of mechanical integrity inspections and testing can lead to equipment malfunction and/or failure, leading to loss of production time, increased equipment repair or replacement costs, and/or problems in adjacent equipment and/or processes.
Emergency planning and procedures
- Employees should be routinely educated and drilled on emergency procedures, including emergency procedures, evacuation routes, emergency exits and the location of emergency equipment.
A cautionary tale: 2008 Imperial Sugar plant explosion
In February 2008, a dust explosion killed 14 employees and injured 36 others at the Imperial Sugar refinery in Savannah, Georgia. A combination of improper management of change (MOC), lack of mechanical integrity and insufficient emergency planning led to the tragic, but avoidable, explosion.
Management of change
- Imperial Sugar modified conveyor lines used to move sugar through the plant by enclosing the conveyor to protect from contamination — however, the enclosure did not have a dust collection system.
- Had plant management followed proper MOC protocol, the enclosure’s dust levels would have been measured and found to be at dangerous levels, prompting the addition of a dust collection system.
- The overhead chutes used to deliver sugar to the conveyor line from storage silos would occasionally clog with clumps of sugar, leading to conveyor blockages that sent sugar spilling onto the floor and high concentrations of sugar dust into the air inside the conveyor enclosure.
- When concentrated sugar dust came in contact with an ignition source, which the U.S. Chemical Safety Board (UCSB) believes was an overheated bearing, it caused a percussive explosion that crumbled floors and knocked down walls, largely destroying the facility’s packing buildings.
Emergency planning and response
- Evacuation drills had not been performed, so employees weren’t familiar with the safest exit routes in the event of an emergency.
- The explosion knocked out power and many of the emergency lights within the plant, so workers trying to escape the ensuing fires had to find their way out of a maze of dark rooms and hallways.
By keeping a keen eye on these key PSM elements, you can protect your employees from a deadly mishap like the Imperial Sugar explosion while insulating your business from massive financial setbacks and years of bad PR.
If you would like to learn more about process safety management, check out our PSM Training e-book or email me at firstname.lastname@example.org.