Process Safety Management (PSM) is a regulatory framework designed to prevent catastrophic releases of toxic, reactive, flammable, or explosive chemicals in the workplace. This federal standard establishes stringent requirements for managing the hazards associated with these materials, protecting workers and the surrounding community. Businesses must understand the specific criteria that trigger compliance to determine if they must implement these demanding safety standards.
What is Process Safety Management?
Process Safety Management is an integrated management program established by the Occupational Safety and Health Administration (OSHA) under the regulation 29 CFR 1910.119. Its objective is to manage the hazards associated with highly hazardous chemicals to prevent or minimize the consequences of accidental releases. PSM is a systematic approach to evaluating and controlling the entire lifecycle of a chemical process, rather than just a list of safety rules.
The standard mandates the implementation of 14 distinct elements that create a continuous cycle of safety improvement and risk reduction. The program covers nearly every aspect of a chemical process, from design and engineering to maintenance and emergency response. This system protects employees, contractors, and the public from the risks posed by high-hazard chemical operations.
Determining Applicability: Highly Hazardous Chemicals and Threshold Quantities
Compliance with the PSM standard depends on two factors: the specific chemical involved and the quantity present at the facility. A process is covered if it involves a chemical defined as “highly hazardous” in excess of its established Threshold Quantity (TQ). A process is defined as any activity involving a highly hazardous chemical, including use, storage, manufacturing, or on-site movement.
The definitive list of regulated substances and their specific TQs is found in 29 CFR 1910.119 Appendix A. This appendix lists over 130 toxic and reactive chemicals, with TQs ranging from 100 pounds (e.g., chlorine) to 15,000 pounds. Facilities must consult this list to determine if their chemicals meet or exceed the listed threshold.
The standard also applies to any process involving 10,000 pounds or more of a Category 1 flammable gas or a flammable liquid with a flashpoint below 100°F (37.8°C). When calculating the total quantity of a Highly Hazardous Chemical (HHC), businesses must consider the chemical in all its forms across the entire process. This includes storage vessels, piping, reaction vessels, and any interconnected systems where a release from one could affect the others.
Specific Exemptions from PSM Coverage
Certain operations are specifically excluded from the PSM standard, even if a facility possesses a highly hazardous chemical above its threshold quantity. These exclusions are outlined in 29 CFR 1910.119(a)(2) and prevent unnecessary compliance burdens on low-risk operations.
Common exemptions include hydrocarbon fuels, such as propane or natural gas, when used solely for workplace consumption like comfort heating or vehicle refueling. This exemption applies only if the fuels are not part of a process containing another covered HHC.
Another exemption covers flammable liquids stored in atmospheric tanks or transferred below their normal boiling point without chilling or refrigeration. This exclusion is void if the liquid is refrigerated or if the tank is pressurized above 0.5 pounds per square inch gauge. Additionally, the regulation excludes retail facilities (defined by NAICS sectors 44 and 45) and oil or gas well drilling and servicing operations. This exclusion does not extend to oil and gas production facilities that contain a TQ of a covered HHC.
Industries and Operations Most Frequently Affected
Businesses most frequently affected by Process Safety Management handle large quantities of highly hazardous substances. Chemical manufacturing plants are primary examples, as their core business involves synthesizing and processing the toxic and reactive substances listed in Appendix A. Petroleum refineries are also consistently covered due to their extensive use and storage of flammable liquids and gases, which often exceed the 10,000-pound threshold.
PSM requirements also apply to pulp and paper mills, which utilize chemicals like chlorine dioxide or sulfur dioxide in their processes. Many food processing and cold storage facilities are covered because they rely on large, centralized refrigeration systems using anhydrous ammonia, which has a TQ of 10,000 pounds. Utilities, including power generation and water treatment plants, may also be affected if they store large quantities of flammable gases or toxic substances like chlorine for disinfection.
Related Regulatory Requirements
Businesses handling highly hazardous chemicals often face compliance requirements from both OSHA and the Environmental Protection Agency (EPA), specifically the EPA’s Risk Management Program (RMP) standard (40 CFR Part 68). Both regulations address the prevention of catastrophic chemical releases but maintain distinct jurisdictional focuses.
OSHA’s PSM standard focuses on protecting employees and contractors within the facility boundaries, establishing a workplace safety framework. The EPA’s RMP, mandated under the Clean Air Act, focuses on preventing accidental releases that could harm the public and the environment outside the facility fence line.
The RMP covers many of the same substances as PSM, including 77 toxic and 63 flammable substances. It also requires a risk management plan to be submitted to the EPA every five years. While PSM and RMP are separate legal mandates, compliance with the prevention program elements of one standard often provides a strong foundation for meeting the requirements of the other.
Consequences of Non-Compliance
Ignoring the PSM standard introduces significant business risk beyond simple regulatory violations. Non-compliance can lead to severe financial penalties imposed by OSHA, with fines for willful or repeated violations potentially reaching six figures per violation.
Following a catastrophic incident, financial consequences multiply, including costs associated with operational shutdowns, emergency response, property damage, and civil liability lawsuits. The most severe consequence is the potential for human tragedy, resulting in fatalities or serious injuries to employees and the surrounding community. A major incident also results in lasting reputational damage and intense regulatory scrutiny. Failure to implement a PSM program is fundamentally a failure to manage a high-consequence business hazard.
Initial Steps for Achieving PSM Compliance
Once a business determines its processes are covered by the PSM standard, foundational steps must be taken to initiate compliance. There are four primary requirements:
Compile comprehensive Process Safety Information (PSI), which involves gathering written documentation on the hazards of the chemicals, the technology of the process, and the equipment. This includes details like toxicity, reactivity data, process chemistry, safe operating limits, and engineering design codes.
Conduct a Process Hazard Analysis (PHA), which is a systematic review of the process to identify potential hazards and their consequences. The PHA team must use recognized methodologies, such as What-If, Checklist, or Hazard and Operability Study (HAZOP), to evaluate potential equipment failures or operational deviations. The initial PHA must be retained for the life of the process.
Develop a written plan for Employee Participation, ensuring workers are actively involved in the development and conduct of the PHA and other PSM elements. This integrates the practical knowledge of operators and maintenance personnel into the safety system.
Designate a PSM coordinator or team responsible for overseeing the development and implementation of the remaining PSM elements, including training, operating procedures, and mechanical integrity protocols.