An interesting look at OSHA’s perspective on the written documents needed for comply with PSM! The information is used by employers to ensure that processes using highly hazardous chemicals with the potential of a catastrophic release are operated as safely as possible. The employer must thoroughly consider all facets of a process, as well as the involvement of employees in that process. Employers analyze processes so that they can identify, evaluate and control problems that could lead to a major release, fire, or explosion. The major information collection requirements in the Process Safety Management Standard include:
- Consulting with workers and their representatives on and providing them access to process hazard analyses and the development of other elements of the standard;
- Developing a written action plan for implementation of employee participation in process hazard analyses and other elements of the standard;
- Completing a compilation of written process safety information;
- Performing a process hazard analysis;
- Documenting actions taken to resolve process hazard analysis team findings and recommendations;
- Updating, revalidating and retaining the process hazard analysis;
- Developing and implementing written operating procedures and making these procedures accessible to workers;
- Reviewing operating procedures as often as necessary and certifying the procedures annually;
- Developing and implementing safe work practices;
- Preparing training records;
- Informing contract employers of known hazards and applicable provisions of the emergency action plan;
- Maintaining a contract worker injury and illness log;
- Establishing written procedures to maintain the integrity of and documenting inspections and tests of process equipment;
- Providing information on permits issued for hot work operations;
- Establishing and implementing written procedures to manage changes;
- Preparing reports at the conclusion of incident investigations, documenting resolutions and corrective measures, and reviewing the reports with affected personnel;
- Establishing and implementing an emergency action plan;
- Developing a compliance audit report and certifying compliance; and
- Disclosing information necessary to comply with the Standard to persons responsible for compiling process safety information.