Process Safety Management — PSM Elements
OSHA PSM's 14 elements explained — from Process Hazard Analysis to Management of Change and Mechanical Integrity.
What is PSM?
Process Safety Management (PSM) is the systematic set of programs designed to prevent or mitigate catastrophic releases of toxic, reactive, flammable, or explosive chemicals. OSHA's PSM Standard (29 CFR 1910.119) applies to facilities handling threshold quantities of highly hazardous chemicals. PSM focuses on major accident hazards — scenarios that can cause mass casualties and catastrophic environmental releases.
The 14 PSM Elements
- Employee Participation
- Process Safety Information (PSI)
- Process Hazard Analysis (HAZOP, FMEA, Fault Tree)
- Operating Procedures
- Training
- Contractors
- Pre-Startup Safety Review (PSSR)
- Mechanical Integrity (MI) — equipment inspection/testing
- Hot Work Permits
- Management of Change (MOC)
- Incident Investigation
- Emergency Planning and Response
- Compliance Audits (every 3 years)
- Trade Secrets
Management of Change — The Most Critical Element
Most major process incidents trace to inadequately controlled changes. Texas City 2005, Piper Alpha 1988 — both involved change management failures.
Any modification to process chemistry, technology, equipment, procedures, or facilities (except replacement-in-kind) must go through MOC review. MOC must assess: technical basis; safety implications; procedure modifications; authorization requirements.
Key Takeaways
OSHA PSM has 14 elements — gaps in any element create regulatory liability and safety risk
Management of Change is the most critical element — the majority of major incidents trace to change management failures
Mechanical Integrity (Element 8) requires written procedures, trained personnel, and documented inspection/testing
PHAs (HAZOP, FMEA) must be revalidated every 5 years or after major changes
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