508 Access Fullbook Industrial PSM Training Ed. 2.0 January 2014 PDF

Industrial Process Safety
Management Training
Tony Mazzocchi Center

January 2014
Edition 2.0
© 2014
Tony Mazzocchi Center Industrial Process Safety Management Training Edition 2.0, January 2014 E-19
Industrial Process Safety
Management Training
Written and produced by the Tony Mazzocchi Center for
Health, Safety and Environmental Education, a project of the
United Steelworkers - USW, the Communications Workers of America
and The Labor Institute
January 2014
Edition 2.0
© 2014 Tony Mazzocchi Center
This book is written and produced in cooperation with the United Steelworkers - USW (Five Gateway
Center, Pittsburgh, PA 15222), the Communications Workers of America (501 3rd Street NW,
Washington, DC 20001) and The Labor Institute, a non-profit organization (817 Broadway, 6th Floor,
New York, NY 10003). The project is supported by grant number EPA 2 U45 ES06175 from the National
Institute of Environmental Health Sciences (NIEHS), NIH. Its contents are solely the responsibility of the
authors and do not necessarily represent the official views of the NIEHS, NIH.
i
“Never Forget”. . . . . . ”Never Again”
November 25, 1998, is a day that will not be forgotten by many in the chemical and refining
industry. For those working at the Equilon Refinery in Anacortes, WA, it is a day perman-
ently etched in their memories.
A catastrophic incident needlessly took the lives of six
people: Dave “Wiener” Dowe, 44; Ron J. Granfors, 49;
Warren “Woody” Fry, 50; Ted Cade, 23; Dave Murdzia, 30;
and Jim Berlin, 38.
The absence of procedures or a Management of Change
(MOC) was proven to be a significant factor in causing
the fire and needless fatalities. Still today, the company is
receiving OSHA citations for the same thing; not following
Process Safety Management (PSM) as it applies to procedures or MOCs.
USW Local 12-591 member, Paul Demmon, wrote about the events that surrounded that
unforgettable day in “Never Forget.”*
“I decided to write this story because people were starting to forget. Because the
company did not follow PSM as it relates to procedures or the application of MOCs,
six people needlessly lost their lives in 1998. People must have the fortitude to
influence decisions which could prevent something like this happening in their
workplace.
I hope someday people will never have to feel the pain which comes from losing your
friends and coworkers in a workplace tragedy. The pain is magnitudes worse when
you know it was completely preventable.
If we continue to demand proper attention be brought to all of the elements within
PSM and insist on having proper procedures and the execution of proper MOCs, only
then can we say ‘Never Again’.”
* The “Never Forget” story is 35 pages and you can receive it by sending an e-mail to safety@usw.org.
ii Industrial PSM Training

Tony Mazzocchi
(1926-2002)
Tony Mazzocchi is credited by many

with founding the modern health and
safety movement. As Vice-President
and Secretary-Treasurer of the Oil,
Chemical and Atomic Workers, he
also helped to create OSHA and was
the first to link worker safety and health
to the environmental movement. The
following passage from his biography,
The Man Who Hated Work and Loved
Labor, by Les Leopold, conveys some
of his vision and passion for the labor
movement:
“Tony Mazzocchi conjured up a labor movement that didn’t really exist, but
just might. This movement would be militant and green. It wouldn’t just fight
to protect the workforce from toxics — it would eliminate toxics. It would lead
the struggle to prevent global warming. It would give workers real control over
the quality and pace of work and over corporate investment decisions. It would
champion the fight against militarism and for justice and equality. It would demand
life-enhancing social programs like free higher education and free health care for all.
In short, it would make good on its potential to transform American capitalism into
something more humane.”
iii
iv Industrial PSM Training
Table of Contents
Note: The 6 Activities and 17 Tasks below constitute approximately 16 hours of training.
To use for an 8-hour class, the training must be tailored to satisfy the PSM elements which
are specific to the workplace being trained.
Factsheet Reading Method vi
Activity 1: An Introduction to the Process Safety Management
Standard (PSM) and Systems of Safety (3 Tasks) 1
Activity 2: Elements m, c and e of the PSM Standard 35
Tasks 1 and 2: Incident Investigation (m) 36
Task 3: Employee Participation (c) 57
Task 4: Process Hazard Analysis (e) 69
Activity 3: Elements n, i and o of the PSM Standard 83
Task 1: Emergency Response (n) 84
Task 2: Pre-startup Safety Review (i) 95
Task 3: Compliance Audits (o) 103
Activity 4: Elements l, d, f, and g of the PSM Standard 121
Task 1: Management of Change (l) 122
Task 2: Process Safety Information (d)
Operating Procedures (f) 135
Task 3: Training (g) 147
Activity 5: Elements h and p of the PSM Standard 161
Task 1: Contractors (h) 162
Task 2: Trade Secrets (p) 173
Activity 6: Elements k and j of the PSM Standard 189
Task 1: Hot Work (k) 190
Task 2: Mechanical Integrity (j) 201
Appendices: A-1
USW Policy on Sexual Harassment A-2
Tony Mazzocchi Center Worker-Trainers and
Worker-Centered Training A-3
Tony Mazzocchi Green Policy Statement A-4
Attendance Form A-5
Sign-in Sheet A-7
v
Example of the Factsheet Reading Method for
a Task Containing Seven Factsheets
The Small Group Activity Method places workers at the center of the learning
experience. It is designed to draw on two bodies of knowledge: The knowledge
and experiences workers bring into the room and the factsheets contained in your
workbooks.
Each of you will be assigned a small number of factsheets to read. You will then
share this new information with your table. The idea is for each of you to describe
your assigned factsheets to the others in your group.
Your trainer will assign your individual factsheets in the following way:
First, select a scribe for this task. Starting with the scribe and moving to his/her left,
count out loud from 1 to 7. Keep going around the table until all numbers (factsheets)
are distributed. For example, if there are four people at your table, the scribe will have
self-assigned Factsheets 1 and 5; the person to their left will be responsible for Factsheets
2 and 6, etc. The numbers that you have assigned yourselves correspond to Factsheets 1
through 7 on the following pages.
Once everyone has read their assigned factsheets individually, your scribe will go around
the table and ask each of you to explain to the rest of your group what you have learned.
No notes need to be taken during this discussion. The factsheets should be explained in
the order they were assigned (1 through 7), as many times factsheets build on previous
factsheets. Once this process is complete, your trainer will read the scenario and the task.
In this way we all start at the same place and with the same information.
Scribe 1
2 The method described
above is used several
times in this book.
Table 2 A note appears each
4 time the method is
to be used.
3
vi Industrial PSM Training

Tony Mazzocchi Center Proficiency Assessment
Industrial Process Safety Management Training
Complete this page BEFORE you begin your training.
Workbook Title: Industrial Process Safety Management Training
Workbook Version: Edition 2.0, January 2014
Today’s date: _ _ / _ _ / _ _ _ _
MM DD YYYY
As you complete the assessments at the end of each activity, please only mark one answer
choice per question. Make your marks dark and clear when selecting your choice. See
the following example:
O 
No Yes
vii
viii Industrial PSM Training
Activity 1
An Introduction to the Process Safety
Management Standard (PSM) and
Systems of Safety
Purposes
To understand the Process Safety Management (PSM) Standard and how it affects
workers.
To introduce the concepts of Systems of Safety.
This Activity has three tasks.
Activity 1: An Introduction to the PSM Standard and Systems of Safety 1

Task 1
Statement:
I came to work here immediately after being released from the service almost 30 years
ago. This was a good job, with good pay and benefits. I’ve seen a lot of changes —
some for the better, some for the worse. But the thing that scares me the most is that
there seems to be more and more government regulations on our jobs.
There are already plenty of regulations in our industry. So why do we need a Process
Safety Management Standard?
I think we have done a pretty good job running these plants, and the last thing we
need is the government looking over our shoulders.
Use the Factsheet Reading

Method for Task 1,
Factsheets 1 through 9.
The Factsheet Reading Method

is described on page vi.
2 Industrial PSM Training

Factsheet 1: Process Safety
Process safety incidents are the unexpected release of toxic, reactive or flammable
liquids and gases in processes, including highly hazardous chemicals. Incidents
continue to occur in various industries that use highly hazardous chemicals. There
is always a potential for a release if they are not properly controlled; this creates the
possibility for disaster.
Process Safety Management (PSM) focuses on major process-related events; such
as fires, explosions and the release of toxic chemicals. The OSHA Process Safety
Management Standard (29 CFR 1910.119) was published in the Federal Register in
February 1992. All compliance dates were to be finished by May 1997.
Source: OSHA Process Safety Management Standard, 29 CFR 1910.119, 57 FR 6356, February 24, 1992.

Factsheet 3: History of Events Leading to PSM
The first PSM regulations were developed in response to a number of serious
accidents.
1984 Toxic chemical release in Bhopal, India, kills over 4,000 people.
1985 Release from a chemical plant in Institute, West Virginia, injures 135.
American Institute of Chemical Engineers forms the Center for Chemical Process
Safety and publishes Guidelines for Hazard Evaluation Procedures.
1989 Phillips Chemical Plant explosion kills 23, injures 232.
1990 American Petroleum Institute (API) publishes Management of Process Hazards

voluntary guidelines.
Arco Chemical plant disaster kills 17 workers.
OSHA releases a Proposed Safety Standard based on the API Guidelines and
Recommendations.
Congress passes the Clean Air Act Amendment, which mandates that OSHA enact
Process Safety Rules covering 14 specific areas.
1991 OSHA releases study of the effects of using contract workers in the U.S.
petrochemical industry.
1992 The final OSHA PSM Standard is issued.
1997 May 26, 1997, was the deadline for 100 percent completion of all Process Hazard
Analysis.
Source: Learning from Hamlet: The Case for a National Safety and Health Board, New Solutions, Vol. 3,
No. 2, Winter 1993.

Factsheet 4: Features of PSM
PSM is not a management program that is handed down to workers and contractors.
PSM is a process that involves and includes everyone. Management must organize
and lead the initial effort; but the workers must be fully involved in its implementa-
tion and improvement, because they are the people who know the most about how
a process really operates.
The concept of process safety management can further be understood by its compon-
ent words:
 Process: PSM is concerned with process issues and the properties of chemicals
as distinct from occupational issues such as trips and falls.
 Safety: Although an effective PSM program improves all aspects of a facility’s
operation, the initial driving force for most PSM programs was the need to meet
safety regulations and to reduce safety incidents related to process upsets.
 Management: In this context, a manager is taken to be anyone who has some
degree of control over the process; including operators, engineers and mainten-
ance workers.
There must always be ways of improving safety and operability. Process safety
management cannot be viewed as being a one-time fix.
Source: “Process Safety Management (PSM), Managing Risk in Process Facilities,”

http=//knol.google.com/k/ian-sutton/process-safety_Management-psm/zvu500dgllb4m/1#.

Factsheet 5: The Expected Results of the
Standard
After extensive hearings and much resistance from some companies, the Standard
became effective in 1992, with OSHA making these remarks:
OSHA anticipates that full compliance with the PSM Standard will lead to
fewer catastrophic fires, explosions, releases of hazardous substances and other
types of serious accidents. It is expected that many minor incidents will be
prevented as well.
In addition to the health and safety benefits from preventing catastrophic inci-
dents, reductions in injuries and illnesses related to minor process disruptions
are anticipated, as well as reductions in the long-run risks posed by occasional
releases of toxic vapors and gases and by the physical hazards of poor process
design.

Factsheet 6: The PSM Standard is a
Performance-based Standard
Performance-based Standards
The PSM Standard is a performance-based standard. That means it is goal-oriented
and what you should judge is a program’s effectiveness. The specifications are not
spelled out, just the desired results.
The PSM Standard gives each facility the flexibility to design its own program to
match its needs, as long as the outcome prevents or minimizes spills, fires and
explosions.
There are no universally correct answers as to what needs to be done to achieve a safe
operation. What is appropriate at one location may not be appropriate at another.
Source: “Process Safety Management (PSM), Managing Risk in Process Facilities,”

http=//knol.google.com/k/ian-sutton/process-safety_Management-psm/zvu500dgllb4m/1#.

Factsheet 7: Application — Paragraph (a) of
OSHA’s PSM Standard
(a) Application
What is covered:
 A process that involves a chemical which is present at, or above, certain levels.
(See Appendix A of the Standard.)
 A process that involves flammable liquid or gas in excess of 10,000 pounds.
Except:
1. Hydrocarbons used for comfort heating, if not used elsewhere as part of a process;
2. Flammable liquids stored in atmospheric tanks below their boiling point, which
don’t need cooling (unless interconnected or involved in a process); and/or
3. Any flammable liquid or gas, provided it is consumed as a fuel and is not part of a
process containing another highly hazardous chemical.

Factsheet 8: Definitions — Paragraph (b) of
OSHA’s PSM Standard
(b) Definitions: (Some have been shortened.)
1. Atmospheric Tank means a storage tank which has been designed to operate at
pressures from atmospheric through 0.5 p.s.i.g. (pounds per square inch gauge,
3.45 Kpa).
2. Boiling Point. The boiling point of a liquid at a pressure of 14.7 pounds per
square inch absolute (p.s.i.a.) (7650 mm).
3. Catastrophic Release means a major uncontrolled emission, fire or explosion,
involving one or more highly hazardous chemicals, that presents serious danger
to workers in the workplace.
4. Facility means the buildings, containers or equipment which contain a process.
5. Highly Hazardous Chemical means a substance possessing toxic, reactive,
flammable or explosive properties and specified by paragraph (a)(1) of this
section.
6. Hot Work means work involving electric or gas welding, cutting, brazing or
similar flame- or spark-producing operations.
7. Normally Unoccupied Remote Facility means a facility which is operated,
maintained or serviced by workers who visit the facility only periodically to
check its operation and to perform necessary operating or maintenance tasks.
8. Process means any activity involving a highly hazardous chemical; including any
use, storage, manufacturing, handling or the onsite movement of such chemicals,
or combination of these activities.
9. Replacement in Kind means a replacement which satisfies the design
specification.
10. Trade Secret means any confidential formula, pattern, process, device, informa-
tion or compilation of information that is used in an employer’s business and that
gives the employer an opportunity to obtain an advantage over competitors who
do not know or use it.

Factsheet 9: 14 Elements — 29 CFR 1910.199 (c–p)
14 Required Elements
1 (c) Employee Participation
2 (d) Process Safety Information
3 (e) Process Hazard Analysis
4 (f) Safe Operating Procedures
5 (g) Training
6 (h) Contractors
7 (i) Pre-Startup Safety Review
8 (j) Mechanical Integrity
9 (k) Hot-work Permit
10 (l) Management of Change
11 (m) Incident Investigation
Emergency Planning and

12 (n)
Response
13 (o) Compliance Audits
14 (p) Trade Secrets

Task 1 (continued)
Please read the following statement. Then within your groups, develop a response to
the statement. One person within your group should be selected to keep a master list
of the discussion and be prepared to report-back to the workshop as a whole.
Statement (restated):
I came to work here immediately after being released from the service almost 30 years
ago. This was a good job, with good pay and benefits. I’ve seen a lot of changes —
some for the better, some worse. But the thing that scares me the most is that there
seems to be more and more government regulation on our jobs.
There are already plenty of regulations in our industry. So why do we need a Process
Safety Management Standard?
I think we have done a pretty good job running these plants, and the last thing we
need is the government looking over our shoulders.
Task:
List reasons for a Process Safety Management Standard.
Use the Factsheet

Reading Method for
Task 2, Factsheets
10 through 15.

Factsheet 10: What Are Systems of Safety?
Systems of Safety identify, control and/or eliminate workplace hazards.

Surprisingly, the same hazard often can be addressed in more than one system. Take
the low pipe in the doorway above. On the next three pages we’ll see how this same
problem could be handled by each of the major safety systems.
Which is the best approach? Well, if we examine the Systems of Safety fulcrum,
we’ll find the Systems of Safety arranged in order of strength: The most powerful —
Design — on down to the least powerful — Personal Protective Equipment.

Factsheet 11: Safety Systems — Personal
Protective Equipment, Procedures and Training
Personal Protective Equipment
Subsystems that include a broad

range of working conditions and
situations that affect workers.
 Weakest systems; and
 Controls the hazard directly

at the individual’s level.
Procedures
The instructions necessary to

maintain and operate equipment
or processes.
 Easier to affect groups of
workers.
Training
Educating and preparing workers

to perform their jobs.
 Dependent on individuals’
memories and lack of
distraction.
Factsheet 12: Safety Systems — Warning Devices

and Maintenance and Inspection
Warning System
Devices that warn of a dangerous,

or potentially dangerous, situation.
 Draws attention; and
 May be missed
or ignored.
Maintenance and Inspection
The system responsible for

maintaining, repairing and
inspecting equipment and
processes.
 Vital to make sure even
the best designed system
continues to function safely.

Factsheet 13: Safety Systems — Mitigation
Devices and Design
Mitigation System
Subsystems that automatically act
to control or reduce the effect of
hazards.
 Workers protected
automatically.
Design
The primary (highest level) system

that designs the hazard out of the
process.
 Strongest system; and
 Hazard eliminated.
Factsheet 14: Work Organization and Health

and Safety
Work organization is about management’s control of work and the way work is
divided. It includes:
 The tasks performed;
 Who performs them; and
 How they are performed.
Most workplaces are undergoing massive changes in the ways management organizes
work. Innovations in technology often make these changes possible. Work organiza-
tion must be evaluated as to how it potentially harms our health and safety.
Examples of work organization changes include:
 Combining jobs;
 Multi-tasking;
 Increasing the workload;
 Increasing the pace of work;
 Work intensification;
 Extending working hours, days or weeks;
 Alternative work schedules;
 Reducing staffing levels;
 Using temporary workers;
 Using contract workers; and
 Electronic performance monitoring.
A growing body of research links work organization with the increased risk of job
injury, illness, stress and death due to catastrophic events like explosions.
For example, the U.S. Chemical Safety Board (CSB) reports that excessive work
hours and extended shifts contributed to the BP, Texas City, refinery explosion that
killed 15 and injured 180.
Sources: Lessin, Nancy and Kojola, Bill, “Work Re-Organization: A Hazard to Workplace Health and Safety,”
AFL CIO Fact Sheet, January 2006; Landsbergis, P.A., Cahill, J., and Schnall, P., “The Impact of Lean
Production and Related New Systems of Work Organization on Worker Health,” Journal of Occupational
Health Psychology, 4(2): 108-130, 1999; and U.S. Chemical Safety and Hazard Identification Board (CSB),
“Investigation Report: Refinery Explosion and Fire (15 Killed, 180 Injured), BP, Texas City, Texas, March 23,
2005,” Washington, DC: U.S. CSB, 2007.

Factsheet 15: Eliminate the Hazard with the
Design Safety System
You can design within any safety system; but a true Design fix is the one which
eliminates the hazard.
For example: A worker, wearing a leaky respirator, is exposed through inhalation
to a hazardous chemical used in a cleaning process. Suggested fixes could be:
1. Design a new respirator for the worker to wear. Is this an effort to eliminate
the hazard? No! It is a fix within the lowest safety system — Personal
Protective Equipment.
2. Design a new procedure which makes it less likely that the worker will be
exposed. Is this an effort to eliminate the hazard? No! It is a fix within the
Procedures safety system.
3. Design a training program which will address the selection and wearing of
respirators? No! It is a fix in the Training safety system.
4. Design a warning system to alert the worker when the concentration of the
chemical reaches a dangerous level. Is this an effort to eliminate the hazard?
No! It is a fix in the Warning Devices safety system.
5. Design a better maintenance and inspection program to maintain the ventila-
tion system. Is this an effort to eliminate the hazard? No! It is a fix in the
Maintenance and Inspection safety system.
6. Design a better ventilation system which will remove most of the dangerous
fumes. Is this an effort to eliminate the hazard? No! It is a fix in the
Mitigation safety system.
7. Design the cleaning process that uses a safe substance to replace the toxic
agent. Is this an effort to eliminate the hazard? Yes! It is a fix in the Design
safety system.

Task 2
Scenario:
Two workers on the night shift at U.S. Pipe were checking the status of three
3,500-pound totes of calcium carbide to determine if they needed to be replaced
before operations at midnight.
One operator, a Cleanup Operator, climbed the stairs to check to see if the totes on
the platform were empty or full. If empty, the other operator, a Crane Operator,
would lift the tote; place it on the lower floor; and replace it with a full tote.
All the totes were full, but the tote on the farthest end was out of place and twisted.
The Cleanup Operator hooked the tote up for lifting. He wanted the tote lifted a few
inches so that it could be straightened out and then lowered into the correct position.
Radios were not available for the operators.
The Crane Operator assumed the tote was empty, since it had been hooked up. He
lifted the tote and began to move it from the platform to the ground. Calcium carbide
began to flow out the bottom door of the tote. He quickly placed it back into position;
500-1,000 pounds of calcium carbide fell into a pool of water that had collected into a
pit just below the totes.
Calcium carbide creates acetylene gas when mixed with water. The gas was ignited
by a torch that was being used nearby. The gas exploded sending 11 workers to the
hospital.

The investigation uncovered the following facts:
 There was no light at the tote stationed on the platform. It was dark and the
crane windows are tinted.
 The operator had to move into light to signal the crane operator. Due to lack
of visibility, the crane operator can only see large motions.
 No other form of communication was available to the workers.
 There was no specific hand signal for the job of just lifting.
 There was no Standard Operating Procedure (SOP) about moving calcium
carbide over water. Even when a tote is empty, there is still falling product
when moving.
 There was no training or understanding on the hazards of calcium carbide.
 The water leak was due to a rupture in the pipe from cold weather. The rupture
had been repaired and the pipe wrapped again but not properly and water was
still leaking.
 The water pool was never cleaned up after the initial pipe rupture.
continued

Task 2 (continued)
Discuss the following questions with members of your group. Select a scribe to
report your answers back to the class.
Based on the eight facts, choose (circle) the Safety System that failed in each case.
Be sure to give your reasons.
Fact Failed Safety System
A. Design
1. No light on platform
B. Maintenance and Inspection
A. Procedures
2. Poor crane operator visibility B. Design
C. Mitigation Devices
A. Warning Devices
3. No communication B. Training
C. Procedures
A. Procedures
4. No written SOP B. Design
C. Training
A. Warning Devices
5. No training on calcium carbide B. Training
C. Procedures
A. Maintenance and Inspection

6. Pipe rupture B. Design
C. Mitigation Devices
A. Mitigation Devices
7. Wrapping pipe again B. Design
C. Maintenance and Inspection
A. Procedures
8. Water pool not cleaned up B. Maintenance and Inspection
C. Training

Notes
Task 3
Scenario:
The investigation team for U.S. Pipe made the following recommendations:
 Issue radios to all operators;
 Update lighting in calcium carbide storage area;
 Develop SOPs (Standard Operating Procedures) on the handling of calcium
carbide;
 Properly insulate and protect all water lines from freezing conditions; and
 Substitute calcium carbide with a less dangerous chemical.
Use the Factsheet

Reading Method for
Task 3, Factsheets
16 through 23.

Factsheet 16: Systems of Safety and Subsystems
Factsheet 17: OSHA and Systems of Safety

The Occupational Safety and Health Administration’s (OSHA) Process Safety
Management (PSM) Standard provides an example of how Systems of Safety are
used in other hazardous industries. For instance, the PSM Standard requires that, at
a minimum, companies formally establish certain Systems and Subsystems of Safety.
The chart below shows how some of OSHA’s PSM requirements fit into a System
of Safety framework.
Maintenance Design, Warning Devices

Training System and
and Inspection and Mitigation Devices
Procedures System
System Systems
Mechanical Integrity Operating Procedures Process Safety Information

Subcontractors Training Process Hazard Analysis
Hot Work Management of Change
Emergency Planning
and Response
Pre-startup Safety
Review

Factsheet 18: Systems vs. Symptoms
When we focus attention on worker injuries, we are only seeing the tip of the safety
iceberg. Changing the unsafe behaviors of an injured worker does not take us very
far down the road to prevention.
Unsafe acts, unsafe conditions and accidents are symptoms of something wrong in
management’s Systems of Safety.
The root causes of incidents are found in management system failures, such as faulty
design or inadequate training, which lead to unsafe acts and unsafe conditions.
Process Safety Management involves the use of management systems to control
hazards and reduce the number and seriousness of process-related incidents and
accidents.
Accident prevention requires making changes in the Systems of Safety.
Source: Center for Chemical Process Safety, Guidelines for Investigating Chemical Process Incidents, New
York: American Institute of Chemical Engineers, 1992.

Factsheet 19: Proactive vs. Reactive Systems
Corporations are re-engineering themselves and cutting costs. How often have
you heard the buzz words, “if it ain’t broke, don’t fix it?” Many corporate safety
programs have been based on this reactive model.
The reactive safety model is the least effective method for preventing chemical
releases and accidents.
This after-the-fact approach to safety creates a piecemeal safety program. Extensive
standards are created after a disaster to address prevention of that particular type of
event. If a disaster involving a particular process or chemical has not occurred yet,
there are often few, if any, industry, trade association or government safety guidelines.
Proactive Systems of Safety are the best way to prevent disasters and injuries.
Source: Roland, Harold and Moriarty, Brian, System Safety Engineering and Management, New York: John
Wiley and Sons, 1983, pp. 8-9.

Factsheet 20: Worker Involvement Creates
Strong Systems of Safety
Many worksites have Joint Health and Safety Committees. These committees often
concentrate their activity on handling worker complaints and on promoting injury rate
reduction goals. Workers and their union representatives are usually not involved in
creating or changing Safety Systems.
OSHA recognizes in their PSM Standard that active worker and union involvement in
the development and use of process Systems of Safety is essential for the prevention
of disasters. Workers have a unique understanding of the hazards of the processes
that they operate and maintain.
A report published by the U.S. Environmental Protection Agency (EPA) makes the
same point:
“. . . operators have traditionally been more aware than management of the
frequency, severity and nature of chemical incidents. Similarly, workers are
often more aware of the ineffectiveness of Personal Protective Equipment and
other mitigation devices. Were the company’s technological decision-making
to be informed by such worker insights, primary prevention would be signifi-
cantly encouraged.”
Source: Ashford, Nicholas, The Encouragement of Technological Change for Preventing Chemical Accidents,
MIT, EPA, 1993.

Factsheet 21: Finding the Root Cause
Safety professionals and government safety experts recognize the importance of
identifying root causes and preventing accidents.
For example, the Center for Chemical Process Safety defines “root causes” as:
“Management systems failures, such as faulty design or inadequate training,
that led to an unsafe act or condition that resulted in an accident; underlying
cause. If the root causes were removed, the particular incident would not have
occurred.”
The Environmental Protection Agency also emphasizes “root causes:”
“. . . an operator’s mistake may be the result of poor training, inappropriate
standard operating procedures (SOPs) or poor design of control systems.
Equipment failure may result from improper maintenance, misuse of
equipment (operating at too high a temperature) or use of incompatible
materials. Without a thorough investigation, facilities may miss the
opportunity to identify and solve the root problems.”
What we see is above ground, but what really matters is sometimes hidden from
initial view.
Sources: American Institute of Chemical Engineers, Guidelines for Auditing Process Safety Management
Systems, Environmental Protection Agency Proposed Rule, Risk Management Programs for Chemical
Accidental Release Prevention.

Factsheet 22: Profit-driven Decisions Can
Cause Accidents
Root causes do not necessarily have immediate effects. It takes time for problems to
take root. Corporate decisions made over the last decade in the name of profits are
often the root cause of current and future “accidents.”
Such decisions may include:
 Cutbacks in preventive maintenance;
 Less frequent equipment inspections;
 Inadequate training for workers and supervisors;
 The failure to report and investigate previous near-misses;
 Longer and longer intervals between preventive maintenance shutdowns;
 The use of skeleton crews for maintenance and operations;
 Increased use of untrained subcontractors; and
 Dangerous hot work on running units.
Accidents don’t just happen; they take time to mature.

Factsheet 23: What are Root Causes?
Root causes are sometimes referred to as “basic” causes because they are the prime
factors that cause an accident. There are almost always several root causes involved
in an incident, accident or near-miss. For example, the root causes of an electrocution
might include improperly designed or maintained equipment, poor lockout procedures
or inadequate training. Root causes are always found in management safety systems.
Effective prevention of similar incidents requires changing management systems.
Examples of Root Causes:
 Poor design of process units and equipment;
 Poor layout of control room indicators and controls;
 Difficult access to equipment;
 Unsafe siting and spacing of process units and equipment;
 Lack of preventive maintenance or inspection;
 Inadequate procedures or training for both normal and emergency situations;
 Excessive overtime; and
 Inadequate staffing levels.
Sources: Mine Safety and Health Administration, Accident Prevention, 1990, pp. 35-38; and Center for
Chemical Process Safety, Guidelines for Investigating Chemical Process Incidents, New York: American
Institute of Chemical Engineers, 1992, pp. 129-131.

Task 3 (continued)
1. Using the factsheets and your experience, choose the Safety System which was
used for each of the recommended fixes listed below. Be ready to give reasons
for your answers.
Recommended Fix Safety System
A. Procedures
1. Issue radios to all operators. B. Warning Devices
C. Design
A. Maintenance and Inspection

2. Update lighting in storage area. B. Design
C. Mitigation
A. Design
3. Develop SOPs on handling
B. Procedures
calcium carbide.
C. Mitigation
4. Properly insulate and protect all A. Mitigation

water lines from freezing conditions. B. Maintenance and Inspection
5. Substitute less dangerous chemical A. Design

for calcium carbide. B. Mitigation
2. Which fix would be the most effective?

Summary: An Introduction to the Process Safety
Management Standard (PSM) and Systems of
Safety
1. OSHA issued the Process Safety Management Standard in an attempt to prevent
the ever-increasing number of disasters from occurring.
2. This valuable tool gives workers more control over workplace safety by increasing
their participation.
3. Proactive Systems of Safety are the key to preventing disasters and injuries.
4. The Design System can provide primary prevention by eliminating the possibility
of a serious accident. The other safety systems provide secondary prevention by
reducing the probability or severity of an accident.
5. Active worker, union and community involvement in Systems of Safety are
essential for these systems to be effective.
6. Understanding the hierarchy of Systems of Safety (with Design as the primary
System) enables workers to become active participants in developing and
implementing safe work practices (Training and Procedures Systems).

Activity 1: An Introduction to the Process Safety Management
Standard (PSM) and Systems of Safety
Learning Objectives:
1. To understand the Process Safety Management (PSM) Standard and how it affects
workers. How much do you agree or disagree that the training met this learning
objective?
O O O O O
Strongly agree Agree Neither agree Disagree Strongly
nor disagree disagree
2. To introduce the concepts of Systems of Safety. How much do you agree or disagree
that the training met this learning objective?
O O O O O
3. OSHA issued the Process Safety Management Standard in an attempt to prevent

the ever-increasing number of disasters from occurring. How much do you agree or
disagree with the following statement? Understanding and applying this learning objective
will assist me in improving health and safety at my workplace.
O O O O O
4. Proactive Systems of Safety are the key to preventing disasters and injuries. How
much do you agree or disagree with the following statement? Understanding and applying
this learning objective will assist me in improving health and safety at my workplace.
O O O O O
5. Active worker, union and community involvement in Systems of Safety are essential
for these Systems to be effective. How much do you agree or disagree with the following
statement? Understanding and applying this learning objective will assist me in improv-
ing health and safety at my workplace.
O O O O O

Activity 2
Elements m, c and e of the PSM Standard
Purpose
To introduce and become familiar with the PSM elements below.
Tasks 1 and 2: Incident Investigation (m)
Task 3: Employee Participation (c)
Task 4: Process Hazard Analysis (e)

Task 1: Incident Investigation (m)
of the PSM Standard
Purpose:
To conduct accident, incident and near-miss investigations which involve workers in
the process, and focus on root causes.

Task 1
Scenario:
“What are you guys talking about?” asked Elaine, a Global Paper Operator, as she
entered the bleaching area.
“I almost got sprayed with acid,” replied Bill, a coworker. “A flange gasket on the
addition line leaked just as I walked under it. It just barely missed me.”
“The problem is that he wasn’t wearing his splash gear, and now he’s trying to decide
whether or not to report the hazard,” said Phil.
“After Sarah got sprayed last year, they made the PPE a requirement whenever you go
into the area,” said Elaine.
“It’s not leaking now, so maybe we just let the pressure get too high on the line,” said
Phil.
“Phil’s probably right. I’ve never seen that flange leak before. Maybe we should just
forget it,” said Bill.
“They have been telling us to report near-misses, but I’m not even sure that this would
qualify as one,” said Phil.
“Now that I think about it, maybe it wasn’t really that close; and I bet it never leaks
again,” said Bill.
“Others are not going to know about this unless it’s reported. It’s your decision Bill,”
said Elaine.
Use the Factsheet

Reading Method for
Task 1, Factsheets
1 through 7.

Factsheet 1: All Incidents Should Be
Investigated
What OSHA says:
“Each incident which resulted in, or could reasonably have resulted in, a
catastrophic release of highly hazardous chemicals in the workplace (should
be investigated).”
What the National Safety Council says:
“All accidents should be investigated, regardless of the extent of injury or
property damage.”
In everyday language:
If a small leak could have been worse, and even if no one or the environment was
hurt, it still needs to be investigated.
Sources: OSHA Process and Safety Management Standard, 29 CFR 1910.119(m), 57 FR 6356, February 24,
1992; National Safety Council, Accident Investigation, A New Approach, p. 2.

Factsheet 2: OSHA Requires a Comprehensive
Investigation
The Process Safety Management Standard requires the following:
1. An investigation shall be initiated as soon as possible, but no later than 48 hours
following the incident.
2. An incident investigation team shall be established and shall include:
 At least one person with knowledge about the process involved;
 A contract worker, if the incident involved work of the contractor; and
 Other persons with knowledge and experience to thoroughly investigate and
analyze the incident.
3. The employer is required to establish a system to promptly address the incident
report findings and recommendations, documenting all resolutions and corrective
actions.
4. Incident reports shall be reviewed with all affected personnel, whose job tasks
are relevant to the investigation, including contract workers, where applicable.
5. Reports shall be retained for five (5) years.
Source: OSHA Process Safety Management Standard, 29 CFR 1910.119(m), 57 FR 6356, February 24, 1992.

Factsheet 3: Investigate “Near-Misses” — Help
Avoid Disasters
Disasters are usually preceded by warnings.
These warnings are serious incidents or “near-misses” that tell us something is wrong.

Factsheet 4: The Best Investigation Team is at
the Site
OSHA states in the non-mandatory appendix that:
 Employers need to develop in-house capability to investigate incidents that
occur at their facility.
 A team needs to be assembled by the employer and trained in the techniques
of investigation, including how to conduct interviews of witnesses, needed
documentation and report writing.
 A multi-skilled team is better able to gather the facts of the event, analyze them
and develop plausible scenarios as to what happened and why.
 Team members should be selected on the basis of their training, knowledge
and ability to contribute to a team effort to fully investigate the incident.
 Workers in the process area where the incident occurred should be consulted,
interviewed or made members of the team.
Source: OSHA Process Safety Management Standard, 29 CFR 1910.119, 57 FR 6356, February 24, 1992,
Appendix, p. 6415.

Factsheet 5: Joint Health and Safety Committees
Are a Ready-Made Team
The Joint Health and Safety Committee can be a ready-made investigative team,
allowing the employer and union to substitute those with unit or specific knowledge
as prescribed in the Standard.
As a member of an investigation team you will need:
Training on:
 Investigation techniques;
 How to conduct interviews of witnesses;
 How to compile pertinent documentation; and
 Report writing.
Time:
Committee members will need the necessary time to fulfill their duties. Great pressure
is sometimes placed on committee members by their immediate supervisors and
coworkers.

Factsheet 6: Does Discipline Create a Safe
Workplace?
Trevor Kletz, in his book “What Went Wrong? Case Histories of Process Plant
Disasters,” offers us some insight into discipline associated with accidents:
“. . . accidents (may be) due to those aberrations that even well-trained and
well-motivated persons make from time to time. For example, they forget to
close a valve or close the wrong valve. They know what they should do; want
to do it; and are physically and mentally capable of doing it. But they forget
to do it. Exhortation, punishment or further training will have no effect. We
must either accept an occasional mistake or change the work situation so as
to remove the opportunities for error or make errors less likely.”
Sources: Kletz, T.A., What Went Wrong? Case Histories of Process Plant Disasters, Houston: Gulf, Coast
Publishing Company, November 1989; and Root Cause Network, November 1992, System Improvements, Inc.,
238 South Peters Road, Suite 301, Knoxville, TN 37923-5224.

Factsheet 7: Fact-Based Investigations Result in
Prevention
Incidents cannot be investigated if they are not reported. A common reason that
incidents go unreported is that, in some organizations, the incident investigations
tend to be searches for the “guilty” rather than searches for the facts.
“When incident investigations are handled as searches for facts, the entire
organization is more likely to work together to report incidents and to correct
deficiencies; be they procedural, training, human error, managerial or other.”
It must be realized that when this approach is adopted, there will likely be an increase
in the number of incidents reported. This is good. The objective is to get the situation
into the open so the entire organization can work to correct deficiencies and prevent
recurrence.
Appendix D.

Notes
Task 1 (continued)
For the questions below, let’s assume Bill reported the incident.
Using the scenario, your experience and the factsheets, answer the following
questions.
1. If Bill was a worker at your workplace, would he be safe in reporting this
near-miss? Give your reasons.
2. List reasons this incident will require an investigation.
3. According to the OSHA PSM Standard, is a worker representative required

to be a member of the investigation team?
In your opinion, what does a good investigation team look like?

4. How are incident investigations conducted in your workplace?
Who initiates the investigation?
When is it started?
Who is on the team?

Task 2
Petrolia, Pa. — On Saturday October 11, 2008, a corrosive liquid overflowed from
a tank at a chemical plant in western Pennsylvania, evaporating into a toxic cloud
that snaked along the ground and forced about 2,500 people to flee. At least three
residents were believed to suffer respiratory problems.
“A material called oleum, similar to sulfuric acid, leaked from a tank at the Indspec
Chemical Corp. plant in Petrolia, about 40 miles northeast of Pittsburgh,” Plant
Manager, Dave Dorko, said.
“The plant, about 60 miles north of Pittsburgh, has 260 workers and makes resorcinol,
an industrial adhesive used to manufacture tires. Oleum is used in the making of
resorcinol. When it leaks, it reacts with water vapor in the air to create a toxic cloud
of sulfuric acid gas,” Dorko said.
“Authorities were concerned about the potential for respiratory damage and skin
burns,” said Freda Tarbell, Spokeswoman for the State Department of Environmental
Protection.
Authorities went door to door to warn the 2,500 people living within three miles to
evacuate.
“About 3,300 pounds of oleum leaked when a transfer tank overflowed, because its
internal pumps were connected to an electrical outlet that was not equipped with an
automatic shutoff,” said OSHA Spokeswoman, Leni Fortson.
Based on its investigation of the accident, the U.S. Department of Labor’s Occupa-
tional Safety and Health Administration announced penalties for 27 serious violations
of safety laws. A few of the 27 are listed below in which the employer did not:
 Implement or develop written procedures;
 Develop or implement mechanical integrity procedures for testing and
maintenance;
 Test safety interlocks at Acid House;

 Review operating procedures;
 Correctly train liquid handlers;
 Develop clear instructions for the transfer of oleum;
 Use any process-experienced workers in developing the Process Hazard
Analysis;

 Address recommendations to improve the unloading system;
 Have a written plan to involve workers in development of all elements of
PSM; or
 Have an Emergency Response Plan which would have sounded an alarm
during the incident.
The employer was also deficient in more than a dozen more applications of the
Emergency Response Plan.
With 27 serious violations of safety laws to address, Indspec chose to fire the worker
who hooked up the transfer tank to the wrong electrical outlet. “Workers are trained
to use outlets that afford overflow protection,” Dorko said.
Use the Factsheet

Reading Method for
Task 2, Factsheets
8 through 11.
Sources: FoxNews.com, October 12, 2008; and Joe Mandak Associated,

www.philly.com/philly/wires/ap/news/state/pennsylvania; and US Department of Labor OSHA, Inspec
#311331615, Issue date: April 4, 2009.

Factsheet 8: Blame — The Easy Way Out
Finding and addressing root causes can be hard work. It’s much easier to pursue an
investigation just to the point where someone, or something, can be blamed (the bad
worker, the bad boss, the broken widget) instead of continuing on to find the flawed
system(s) involved.
A Systems Thinking approach teaches us that everyone shares responsibility for a
problem generated within a system; so there is no value in placing blame. It also
encourages everyone to work together to bring change.
When a person is blamed, instead of a root cause being corrected in a flawed system,
his or her replacement walks into the same trap. The hazards still wait, like time
bombs, to injure their next victim. Fixing flawed systems fosters a positive team
approach.
By demonstrating a real concern for each worker, leadership (both management and
union) helps to establish a mutual respect between all parties involved. Respect leads
to trust; and soon a foundation is laid for a solid safety effort.

Factsheet 9: The Lessons of Chernobyl
In 1986, operators at a nuclear power plant in Chernobyl (located in the former Soviet
Union) reduced power to low levels to conduct a test of their emergency systems.
 This unexpectedly caused an explosion and meltdown of the reactor core.
 Thousands of people were exposed to high levels of radiation and many died.
 Five of the operators and supervisors involved were blamed for the accident
and sent to jail.
continued
Factsheet 9: The Lessons of Chernobyl (continued)
Years later it was revealed:
 That the operating manuals did not warn of the hazards of running at low
power levels.
 More importantly, serious problems were discovered with the reactor.
Grigori Medvedev, a senior Soviet nuclear engineer, explains that:

“An exceedingly grave mistake by the reactor designers. . . proved to be the
main cause of the nuclear disaster.” He added that “the reactor was a nuclear
time bomb, whose explosion signaled the death throes of an entire historical
period.”
Blaming workers is the easiest way to explain away accidents. James Reston of the
University of Manchester points out that:
“Rather than being the main instigators of an accident, operators tend to be
the inheritors of system defects created by poor design, incorrect installation,
faulty maintenance and bad management decisions. Their part is usually that
of adding the final garnish to a lethal brew whose ingredients have already
been long in the cooking.”
Sources: Medvedev, Grigori, The Truth About Chernobyl, Basic Books, 1991, p. 90; and Meshkat, Najmedin,
“Preventing Accidents at Oil and Chemical Plants,” Chemical Safety, November 1990.

Factsheet 10: Workplace Design and Human
Error
The poor design of process units and equipment often promotes human error. For
example:
 Most workplaces have equipment and controls that are arranged in illogical
sequences; and
 Pump and vessel numbers and letters are not in order, or are similar to those
of other equipment, so that workers can easily become confused.
Another serious design problem is that equipment is difficult to access.
 Workers are told to be “responsible” and wear fall protection.
 Workers are urged to adapt their work behavior to fit the poorly designed
equipment.
 If something goes wrong, it is the worker’s fault.
 Unsafe piping and valve systems do not receive the discipline or blame.
Virtually any accident can be blamed on human error.
A well-designed safety system includes worker representatives in the conceptual
design and engineering phases of the project.
Sources: Guidelines for Investigating Chemical Process Incidents, Center for Chemical Process Safety, 1992,
pp. 146-147; and Norman, Donald, The Psychology of Everyday Things, Basic Books, 1988, p. 129.

Factsheet 11: Shifting Gears
Systems Thinking is the foundation of a powerful health and safety culture. We
realize that we can’t really make people change how they think. We can only “invite”
them to consider a new point of view. Have you begun to shift gears in analyzing
problems by:
1. Moving from a focus on worker behavior to one
that considers systems and how they work?
2. Digging for the root causes of incidents by going
beyond blame to real solutions?
3. Applying the most effective recommendations
possible (even when they are not the quickest
and easiest)?
4. Focusing on safe design before moving to other systems when considering

recommendations?
If you answered “yes” to these questions, congratulations! You are either a “systems
thinker” or well on your way to becoming one. If you answered “no,”. . . . well, we
just ask you to keep an open mind, your eyes on the road and your hand on the
gearshift. (You may want to shift at any time.)
Source: Barnett, Ralph L. and Poczynok, Peter J., “Safety Rules of Thumb,” Safety Bulletin, Vol. 2, #4,
February 1996.

Task 2 (continued)
Using your experience and the factsheet discussion, answer the questions below.
1. Do you agree with the decision made to fire the worker?
List your reasons below.
2. List reasons why you think many people jump to conclusions and blame
workers.
3. How can placing blame affect worker morale?

Notes

Task 3: Worker Participation (c) of the
PSM Standard
Purpose:
To understand that employee knowledge and participation is vital to an effective
Process Safety Management (PSM) organizational structure.

Task 3
Scenario:
Although not required by OSHA, Chem Co. has chosen to establish a PSM steering
committee to monitor and administer the employer’s compliance with the PSM
Standard.
The committee is comprised of four management and one hourly worker.
The Union is to be informed of all the steering committee’s activities on a regular
basis.
Use the Factsheet

Reading Method for
Task 3, Factsheets
12 through 18.

Factsheet 12: OSHA Requires Worker
Participation
OSHA requires that employers consult with workers and their representatives on the
development, implementation and effect of the Standard. This requirement is broken
down into three different segments. They are:
1. The Written Plan
Employers shall develop a written plan of action regarding the implementation of the
employee participation required by this paragraph.
2. Conduct and Development
Employers shall consult with employees and their representatives on the conduct and
development of the Process Hazard Analysis and on the development of the other
elements of process safety management in this Standard.
3. Access to Information
Employers shall provide to employees and their representatives access to the Process
Hazard Analysis and all other information required to be developed under this
Standard.
Source: OSHA 1910.119 Process Safety Management Standard, 29 CFR 1910.119, 57 FR 6356, at 6505,
February 24, 1992.

Factsheet 13: Who Are the “Employee
Representatives?”
The Standard requires consultation with employees and their representatives. The
term “employee representatives” is intended to mean union representatives where
a union exists or employee-designated representatives in the absence of a union.
The term is to be construed broadly, and may include:
 The local union;
 The international union; or
 An individual designated by the parties, such as the Safety and Health
Committee Representatives at the site or non-employee consultants.
In the absence of a union, employees have a right under the Standard to designate
representatives to participate in the consultation process.

Factsheet 14: Our Knowledge is Valuable
OSHA takes the consulting requirement very seriously. The Standard lays out, in
precise and exacting terms, the types of management/worker exchanges that must
take place.
The intent of consult:
 To exchange information;
 Solicit input;
 Get participation from the employees and their representatives; and
 Requires more than simply informing employees.
The employer needs:

 To consult with employees and employee representatives; and
 To develop information concerning the knowledge and expertise of individual
workers in various processes and aspects of the facility.
These steps must be done to ensure substantive input by employees and their
representatives in developing the written action plan, Process Hazard Analysis
and access to information required under the Standard.
Source: OSHA Instruction CPL 2-2.45A Directorate of Compliance Programs. [Emphasis added.]

Factsheet 15: Information is Power
Under the Standard, the employer must perform an analysis of the hazardous produc-
tion processes (Process Hazard Analysis or PHA). It is our responsibility to see that
these analyses are carried out. It is also our right to be made aware of the results.
OSHA says:
The intent of access under this Standard is for the information to be made
available for employees and their representatives in a reasonable manner.
Reasonable access may require providing copies or loaning documents.
The trade secret provision of the Standard permits the employer to require
confidentiality agreements before providing the information.
Source: OSHA Instruction CPL 2-2.45A Directorate of Compliance Programs. [Emphasis added.]

Factsheet 16: Jointness is a Must
Each facility must have a written plan for worker and union involvement. The plan
needs to address specifically how workers and the union will participate in each
element of the OSHA PSM Standard. This plan should be jointly written by workers
and management representatives.
If an employer has written or implemented its plan alone, it is not in compliance!
For example:
Today, Labor Secretary, Robert B. Reich, proposed penalties of $1,597,000
against a West Virginia fertilizer/pesticide manufacturer. The action against
Rhone-Poulenc AG Co. of Institute, West Virginia, follows an investigation
by the department’s Occupational Safety and Health Administration (OSHA)
into an explosion and fire last summer that killed one worker and seriously
injured two.
Source: Chemical Week, Vol. 154 Issue 7, p. 6, February 23, 1994.

Factsheet 17: Is Your Committee Legal?
The Process Safety Management Standard does not require the establishment of PSM
steering committees. Nor does it require that a union representative be included if a
committee is formed.*
Many employers, however, have found that the most effective way of fulfilling the
consult requirement of the Standard is to form such committees and to include union
representation. If worker participation is solicited, it is the union’s right to designate
who their representative will be.
In a December 1992 ruling, the National Labor Relations Board found that
the Electromation Corporation violated the law by not giving the workers the
opportunity to choose their own method of selecting committee members.
(Bureau of National Affairs, Labor Daily, Inc., June 7, 1993.)
When the employer decides who the hourly representative is on a
committee and/or what the committee should work on, it is illegal! It
is important for union employees to select their own representatives for
joint labor-management committees.
Not only is it important, but it is the only legal way.
* OSHA Process Safety Management Standard, R9 CFR 1910.119, Appendix C, 57 FR 6356, February 24,
1992.

Factsheet 18: A Look at an Effective Committee
Some workplaces have chosen to use contractually negotiated Joint Health and
Safety Committees to oversee the implementation of the PSM Standard. Others
have created a separate oversight committee and have used the Joint Health and
Safety Committee as a model.
Joint Health and Safety Committees have equal numbers of union and management
representatives. Representation is typically based on each major work area or work
group. A structure such as this is seen as very effective, especially when care is
exercised by union and management in choosing the members.
The following list was provided by USW sites who have effective committees:
1. We view each other as equals. We even have co-chairs of the committee.
2. Our members are very diverse. Each member has special skills: One for
paperwork; another for verbal communication; and some from the Laboratory,
Maintenance and Operations. They are the eyes, ears and voices of their
departments.
3. We ensure our members are thoroughly trained.
4. The workers have the necessary time for committee work; paid for by the
employer and encouraged by their immediate supervisor and work group.
5. We post the committee minutes, but we also make a formal report at the Union
meetings.
6. Our alternates to the committee are actually safety stewards. This maintains our
lines of communications.
Source: John Gray Institute, “Managing Workplace Safety and Health; The Case of Contract Labor in the U.S.
Petrochemical Industry,” Lamar University System, July 1991, pp. 202-3. [Emphasis added.]

Task 3 (continued)
Scenario (restated):
Although not required by OSHA, Chem Co. has chosen to establish a PSM steering
committee to monitor and administer the employer’s compliance with the PSM
Standard.
The committee is comprised of four management and one hourly worker.
The union is to be informed of all the steering committee’s activities on a regular
basis.
Scenario (continued):
Joe, a member of the Health and Safety Committee, is upset by the formation of this
committee. He’s had problems in the past with committees whose members were
hand-picked and controlled by management and suspects that this committee is more
of the same. He does not believe that it will give the union any say in the way the
PSM Standard is implemented. In fact, he’s afraid that if he doesn’t distance himself,
the union will get mouse-trapped down the road when something goes wrong.
Judy, the site Health and Safety Representative, agrees with Joe about the way the
current committee is structured; but she is concerned that by not including itself,
the union is missing an opportunity to influence the development of new Health and
Safety Systems at their workplace. Judy has read the PSM Standard and feels that the
union can convince management to reformulate the committee to be more inclusive.
Joe and Judy have asked the site Health and Safety Committee to study the situation
and to come up with a recommendation.

Task:
1. What position do you think the Health and Safety Committee should take?
Why?
2. What changes would you make to the PSM Steering Committee and how
would you support your argument? Please refer to at least one factsheet.
continued

Task 3 (continued)
3. Do you have a PSM Oversight Committee at your workplace?
If so, is there worker involvement on the committee, and to what degree?

Task 4: An Introduction to Process Hazard
Analysis (PHA) (e) of the PSM Standard
Purpose:
To use Process Hazard Analysis as a tool to prevent accidents.

Task 4
Scenario:
Jane and Bob work for Chem Co. The following situation took place while they were
on duty:
Jane was operating a forklift and moving 55-gallon drums of chemicals from one
storage area to another. The forklift did not have a drum-lifting attachment but was
the forklift that had been used in this area for the past few weeks. These storage areas
were outside, but covered. However, the metal cover had leaked for some time in the
area where the drums were being moved. Jane and Bob were the only two workers in
the immediate area but Jane had seen a couple of folks earlier in the shift. Bob was
helping by flagging and reading labels on the drums. Jane and Bob were also sorting
the drums by contents. One of the drums had a badly rusted spot, but it was not
evident because the paint still covered most of the rust. It was the next drum they
were planning to move and, as fate would have it, the rusted spot was at the same
elevation as the forks. One of the forks ruptured the drum and liquid gushed out.
Use the Factsheet

Reading Method for
Task 4, Factsheets
19 through 24.

Factsheet 19: What is a Process Hazard
Analysis?
A PHA is defined as:
 A systematic effort designed to identify and analyze hazards associated with
the processing or handling of highly hazardous materials; and
 A method to provide information which will help workers and employers in
making decisions that will improve safety.
A PHA analyzes:
 The potential causes and consequences of fires, explosions and releases of
toxic chemicals; and
 The equipment, instrumentation, human actions and other factors which might
affect the process.
A PHA attempts to determine:
 The failure points, methods of operations and other factors that can potentially
lead to accidents.
A PHA team:
 Should include engineers, operators, supervisors and other workers who have
knowledge of the standards, codes, specifications and regulations which apply
to the process being studied.
Source: Adapted from OSHA Process Safety Management Standard, 29 CFR 1910.119, 57 FR 6356,
February 24, 1992, Appendix C.

Factsheet 20: Common PHA Methods
The following is a list of some of the better common methods used to evaluate
process hazards. (All these methods should include workers.)
Hazard and Operability Study (HAZOP)
A structured, systematic review that identifies equipment that is being used in a way
that it was not designed to be and which might create hazards or operational problems.
HAZOPs are usually conducted by a multi-skilled team that studies piping and instru-
ment diagrams. Each pipeline and vessel is evaluated for certain limitations and
deviations in flow, temperature, pressure, etc.
Failure Mode and Effect Analysis (FMEA)
A systematic study of the consequences of failure (breakdown) of certain operational
hardware; such as transmitters, controllers, valves, pumps, rotometers, etc.
Fault-Tree Analysis
This method draws a picture (model) that shows what undesirable outcomes might
result from a specific initiating event (for example, a pipe rupture in a pipe rack). It
uses graphics and symbols to show the possible order of events which might result in
an accident. This method is sometimes used in accident investigations to determine
probable cause.
Source: The Workplace Health Fund, Blueprint for Prevention, Washington, D. C.

Factsheet 21: The Most Hazardous Processes
are First
OSHA requires workers to perform a PHA on each process covered by the law. The
purpose of the PHA is to identify and evaluate the hazards of the process and ways or
methods to control them.
PHA guidelines include:
 The most hazardous processes must be evaluated first;
 All PHAs must be completed as soon as possible; and
 All PHAs must be updated and revalidated at least every five years.

Factsheet 22: Process Experience is a Must
According to OSHA, Process Hazard Analyses must be performed by a team with
process and engineering knowledge and include at least one worker experienced in
running the process. Also, one member of the team must have experience with the
PHA method being used.
PHAs must address all of the following issues:
 The hazards of the process;
 Previous incidents which could have been catastrophic;
 Engineering and administrative controls;
 The consequences of failure of engineering and administrative controls;
 Facility siting;
 Human factors; and
 The range of possible safety and health effects caused by the failure of
controls.

Factsheet 23: Take Action and Follow-through
OSHA sets specific timelines for the completion of PHAs. However, OSHA has
no equivalent time requirements for the implementation of PHA recommendations.
Follow-up is a critical part of any PHA; yet this is usually the weakest link in the
process.
It is not enough for the employers to just conduct the PHAs. They should do some-
thing about their findings. The employer should establish a system, or set of
procedures, that will promptly deal with the findings and recommendations of the
PHA team. Any actions taken to correct hazards uncovered by the PHA team must
be communicated to the workers in the area and to any other workers who might be
affected.

Factsheet 24: New Guidelines for the PSM
Standard
After several unions, including OCAW (now USW), challenged OSHA’s guidelines
for following up on PHA recommendations in court, OSHA issued the following
revised guidelines for their PSM compliance directive:
“Where a recommendation is rejected, the employer must communicate this
to the team and expeditiously resolve any subsequent recommendation of the
team. An employer can justifiably decline to adopt a recommendation where
the employer can document in writing; and based upon adequate evidence, that
one or more of the following conditions exist:
1. The analysis upon which the recommendation is based contains material
factual errors.
2. The recommendation is not necessary to protect the health and safety of the
employer’s own employees or the employees of contractors.
3. An alternative measure would provide a sufficient level of protection.
4. The recommendation is infeasible.”
The Joint Health and Safety Committee is a ready-made body for reviewing the
resolution of recommendations.
Source: OSHA PSM Compliance Directive, September 13, 1994.

Notes
Task 4 (continued)
Your group has been appointed to the incident investigation team for the incident on
page 70. After reviewing the evidence, the team has split into two camps. One side
blames operator error for the disaster. The other side argues that the “root causes”
of the incident should have been identified and fixed prior to the incident.
Task:
Now that you have discussed Factsheets 19 through 24, in your groups, answer
the following questions.
1. List what the root causes would be for the potential incident in the scenario.
2. Would a PHA on the storage area have uncovered any of the root causes of
the potential incident?
If so, what PHA method, or combination of methods, should have been used
and what causes would they have exposed? (See Factsheet 20.)

3. Is Chem Co. required by OSHA to fix faults in design or operating
procedures identified by a PHA? (See Factsheets 22, 23 and 24.)
What do you think an effective program for PHA recommendations should

include?

Summary: Activity 2: Elements m, c and e of the
PSM Standard
Incident Investigation (m)
1. The Joint Union and Management Safety Committee is a good team for
conducting investigations.
2. Workers are uniquely qualified to be on the investigation team.
3. Investigations should start immediately; seek root causes of incidents; and not be a
“place-the-blame” hunt.
Worker Participation (c)
4. If an employer has already established its PSM program and failed to involve the
union or workers, it is illegal and the union should request to bargain the issue.
5. As we have seen from NLRB rulings, the union must select its own representatives.
6. Joint Health and Safety Committees can serve as the PSM Oversight Committee or
as a model for establishing a separate PSM Committee.
Process Hazard Analysis (e)
7. PHAs are methods to systematically determine process hazards.
8. Most PHAs do not examine worst-case scenarios. Experience has shown that
these catastrophic events do happen and should be studied in a PHA.
9. The subjectivity and experience levels of PHA team members have a large impact
on the effectiveness of the team. Worker representatives on PHA teams play a
crucial role due to their unique knowledge of process facilities.

Activity 2: Elements m, c and e of the PSM Standard
6. To conduct accident, incident and near-miss investigations which involve workers in
the process, and focus on root causes. How much do you agree or disagree that the
training met this learning objective?
O O O O O
7. To understand that worker knowledge and participation is vital to an effective Process

Safety Management (PSM) organizational structure. How much do you agree or disagree
that the training met this learning objective?
O O O O O
8. The Joint Union and Management Safety Committee is a good team for conducting
investigations. How much do you agree or disagree with the following statement?
Understanding and applying this learning objective will assist me in improving health
and safety at my workplace.
O O O O O
9. If an employer has already established its PSM program and failed to involve the
union or workers, it is illegal and the union should request to bargain the issue. How
much do you agree or disagree with the following statement? Understanding and applying
this learning objective will assist me in improving health and safety at my workplace.
O O O O O
10. PHAs are methods to systematically determine process hazards. How much do you
agree or disagree with the following statement? Understanding and applying this learning
objective will assist me in improving health and safety at my workplace.
O O O O O

Activity 3
Elements n, i and o of the PSM Standard
Purpose
Task 1: Emergency Response (n)
Task 2: Pre-Startup Safety Review (i)
Task 3: Compliance Audits (o)

Task 1: Hazardous Waste and Emergency
Response Standard 1910.120 (n)
of the PSM Standard
Purpose:
To know that an emergency response is required; your role in emergency response;
and the training you need.

Task 1
Scenario (restated from Act. 2, Task 4):

Jane and Bob work for Chem Co. The following situation took place while they were
on duty:
Jane was operating a forklift and moving 55-gallon drums of chemicals from one
storage area to another. The forklift did not have a drum-lifting attachment, but was
the forklift that had been used in this area for the past few weeks. These storage areas
were outside, but covered. However, the metal cover had leaked for some time in the
area where the drums were being moved.
Jane and Bob were the only two workers in the immediate area, but Jane did see a
couple of folks earlier in the shift. Bob was helping by flagging and reading labels on
the drums. Jane and Bob were also sorting the drums by contents. One of the drums
had a badly rusted spot, which was not evident because the paint still covered most of
the rust. It was the next drum they were planning to move and, as fate would have it,
the rusted spot was at the same elevation as the forks.
One of the forks ruptured the drum. Liquid gushed out and the fumes overcame Jane.
She fell into the pool of liquid which is now spreading. Bob has a two-way radio.
Neither Jane nor Bob have PPE other than hard hats, gloves, steel-toe boots and
coveralls.
Use the Factsheet

Reading Method for
Task 1, Factsheets
1 through 5.

Factsheet 1: OSHA’s Emergency Response
Standard
If you are likely to witness and/or respond to an emergency situation at your facility,
then you are part of the employer’s emergency response activities. OSHA demands
that you be trained on OSHA Standard 1910.120.
When Congress passed the Superfund Amendments and Reauthorization Act (SARA)
in 1986, it directed OSHA to develop safety standards for dealing with hazardous
wastes and “Emergency Response” [Section 126(d)(4)]. From the broad language
of this bill, OSHA decided to include a standard that covers all hazardous emergency
situations involving toxic substances.
This Standard and its required training is needed because of the high risk
associated with emergency response by untrained and unprotected workers.
The Standard also calls for the use of proper equipment in emergency response.

Factsheet 2: The Emergency Response Plan
Emergency Response Plans must be developed and implemented by all employers.
Employers who will evacuate their workers from the worksite location when an
emergency occurs, and who do not permit any of their workers to assist in handling
the emergency, are exempt if they provide an emergency action plan complying with
[1910.120 (l)(ii), 1910.129 (p)(8)(i) and 1910.120 (q)(l)].
This plan must be in writing and available for inspection and copying by employees,
their representatives and OSHA personnel. Elements of an emergency response plan
include: (Note: These small Roman numerals correspond to paragraphs l and q
only. Paragraph p uses letters.)
[1910.120 (l)(ii), 1910.129 (p)(8)(i) and 1910.120 (q)(l)]
(i) Pre-emergency planning and coordination with outside parties;
(ii) Personnel roles, lines of authority, training (q only) and communication;
(iii) Emergency recognition and prevention;
(iv) Safe distances and places for refuge;
(v) Site security and control;
(vi) Evacuation routes and procedures;
(viii) Emergency medical treatment and first aid;
(ix) Emergency alerting and response procedures;
(x) Critique of response and follow-up; and
(xi) PPE and emergency equipment.

Factsheet 3: Many USW Members Are First
Responders
Many USW members are “first responders”* because we work in situations where we
are likely to be the first to spot an emergency. The five levels of responders, in order
of increasing responsibility, are:
 First Responder, Awareness Level;
 First Responder, Operations Level;
 Hazardous Materials Technician (HAZMAT);
 Hazardous Materials Specialist; and
 On-Scene Incident Commander (IC).
Training First
According to OSHA, you have to be properly trained and equipped before your
employer can expect you to respond at your designated level. Contractors must
be trained too.
Check Your Plan
Your workplace’s emergency response plan should describe in detail which of the
five levels everyone in the workplace fits. A good plan should also clearly describe
contractor duties during an emergency.
*Note: The term “first responder” is widely used by professional firefighters and emergency response
organizations, such as the National Fire Protection Association (NFPA). NFPA Standard 472 spells out
in detail just what a first responder is and OSHA largely incorporated their definition in the HAZWOPER
Standard.

Notes
Factsheet 4: Know Your Role

First Responder, Awareness Level: Sound the Alarm and Get Out
You need to know how to notify and where to go. This typically applies to
administrative and office staff, most contract workers and some maintenance
workers (see also Operations Level below).
OSHA:
“First responders at the awareness level are individuals who are likely to
witness or discover a hazardous substance release and who notify the proper
authorities of the release. They would take no further action beyond notifying
authorities of the release.”
First Responder, Operations Level: The Defense Team
They act defensively from a safe distance. Typically first line supervisors, operators
and some maintenance workers are designated “Operations Level.” If you are asked
to assist in an emergency outside your area of expertise, you must be trained at the
“Operations Level.”
OSHA:
“First responders at the operations level are individuals who respond to
releases, or potential releases, of hazardous substances as part of the initial
response to the site for the purpose of protecting nearby persons, property or
the environment from the effects of the release. They are trained to respond in
a defensive fashion without actually trying to stop the release. Their function
is to contain the release from a safe distance, keeping it from spreading and
preventing exposures.”
Hazardous Materials Technicians: The Offense Team
They take offensive actions to stop the release and wear specialized protective
equipment. Extensive training is required, far beyond fire brigade training.

OSHA:
“Hazardous Material Technicians are individuals who respond to releases,
or potential releases, for the purpose of stopping the release. They assume a
more aggressive role than a first responder at the operations level in that they
will approach the point of the release in order to plug, patch or otherwise stop
the release of a hazardous substance.”
Hazardous Materials Specialist: The Experts
These people are special assistants to the HAZMAT team.
OSHA:
“Hazardous Materials Specialists are individuals who respond with, and
provide support to, hazardous materials technicians. Their duties. . . require
a more directed or specific knowledge of the various hazardous substances
they may be called upon to contain. The hazardous materials specialist would
also act as the site liaison with Federal, state, local and other governmental
authorities in regard to site activities.”
Safety Officer
The Safety Officer should conduct most release air monitoring, determine proper
levels of Personal Protective Equipment and selection of chemical protective clothing.
OSHA:
“ICS shall designate a safety official, who is knowledgeable in the operations
being implemented at the emergency response site, with specific responsibility
to identify and evaluate hazards and to provide direction with respect to the
safety of operations for the emergency at hand.”
On Scene Incident Commander: The Emergency Boss
The one person authorized to make key decisions
during emergencies and who controls all response
activity. An Incident Command System (ICS) must
be used if personnel in your workplace respond to
emergencies.

Factsheet 5: How Much Training Is Required by
OSHA?
All five levels of emergency responders need training. The amount of training OSHA
requires depends on the role assigned to you by your employer. The following chart
shows OSHA’s minimum training requirements.
* Based on USW’s assessment of the amount of time needed to cover the OSHA-mandated required subject
matter.
** USW offers a 24-to-40-hour course for this purpose.
Source: OSHA Publication 3114: “Hazardous Waste and Emergency Response,” 1989.

Task 1 (continued)
Below is a list of possible actions Bob could take in this situation. Using your
experience and the factsheets you just reviewed, put in order the actions Bob
should take, beginning with the first, by placing numbers in the blocks to the left
of the possible action. Bob is trained at the First Operations Awareness level.
Put an “X” by the ones Bob should not do at all. Be ready to give your reasons.
You can add actions not listed.
A. Move closer to make sure Jane’s face is not in the liquid.
B. Alert any others in area.
C. Determine wind direction and move upwind before attempting a rescue.
D. Move close enough to grab Jane by the heels and pull her out of the liquid.
E. Use the forklift to move the barrel away from Jane.
F. Use the radio while still on the forklift to call for help.
G. Direct the Response Team when they arrive.
H. Leave area immediately to a safe zone.
I. Use radio to call for help or pull alarm if one is available.

Notes

Task 2: Pre-Startup Safety Review (i)
of the PSM Standard
Purpose:
To introduce Pre-Startup Safety Review (PSSR) and to explore how it should be used
in the workplace.

Task 2
Scenario:
Chem Co. has hired contractors to construct a new boiler. Construction is scheduled
to be completed tomorrow afternoon. Management has notified workers that a large
contract is dependent upon the completion and startup of the new boiler by tomorrow
evening. Local news reports have led workers to believe that, without the new
contract, Chem Co. may be forced to eliminate jobs.
Use the Factsheet

Reading Method for
Task 2, Factsheets
6 through 9.

Factsheet 6: Pre-Startup Safety Review
— CFR 1910.119 (i)
(i)(1) The employer shall perform a pre-startup safety review for new facilities and
for modified facilities when the modification is significant enough to require
a change in the process safety information.
(i)(2) The pre-startup safety review shall confirm that prior to the introduction of
highly hazardous chemicals to a process:
(i)(2)(i) Construction and equipment are in accordance with design
specifications;
(i)(2)(ii) Safety, operating, maintenance and emergency procedures are in
place and are adequate;
(i)(2)(iii) For new facilities, a process hazard analysis has been performed and
recommendations have been resolved or implemented before startup;
and modified facilities meet the requirements contained in manage-
ment of change, paragraph (l); and
(i)(2)(iv) Training of each employee involved in operating a process has been
completed.

Factsheet 7: Purpose and History of PSSR
The purpose of a Pre-Startup Safety Review (PSSR) is to ensure that any changes
that are made to a facility or item of equipment meet the original design or operating
intent before that facility is started up (or restarted).
PSSRs cover not only workplaces and equipment, but also “soft” items such as
operating procedures and training.
The term Pre-startup Safety Review first received prominence in the process indus-
tries with the introduction of the Process Safety Management (PSM) regulations in
the early 1990s.
In the United States, two Federal agencies, the Occupational Safety and Health
Administration (OSHA) and the Environmental Protection Agency (EPA), now
require that companies conduct pre-startup safety reviews for process facilities,
such as oil refineries and chemical plants. The wording of the two Standards
regarding PSSRs is virtually identical, although the industries covered and the
reporting requirements differ slightly.
Source: Sutton Technical Books, PSSR 2007-08.

Factsheet 8: Large Project and a Time Crunch
PSSRs play a particularly important role on large projects because such projects all
too often fall behind schedule and/or run over budget, thus creating pressure on the
project team to eliminate or postpone the installation of any items or systems that are
not absolutely necessary for the startup. In effect, a pre-startup safety review provides
breathing space for everyone to make sure that the facility that they are about to start
is safe and operable.
If the facility is not ready to go, then the regulations from OSHA, the EPA and
other agencies allow the operations team to refuse to run the unit until they are
satisfied that it is safe.

Factsheet 9: PSSR — A Team Project
A PSSR is generally conducted by a team.
 The leader represents the operations group because it is he/she who is usually
the ultimate customer for the modified facility;
 Supporting the leader are technical specialists; and
 Representatives (including workers) from the process safety team.
The leader should have sufficient authority to delay the startup if he or she
identifies a significant deficiency.
Given that such a delay could lead to a serious financial loss, the leader may come
under very strong pressure to let things go ahead as they are. He or she must have
the personality and the organizational authority to resist such pressures.

Task 2 (continued)
Chem Co. has hired contractors to construct a new boiler. Construction is scheduled
to be completed tomorrow afternoon. Management has notified workers that a large
contract is dependent upon the completion and startup of the new boiler by tomorrow
evening. Local news reports have led workers to believe that, without the new
contract, Chem Co. may be forced to eliminate jobs.
At this point, Maintenance and Operations have not received training on the new
boiler, although it is similar to one currently in operation. Also, a thorough inspection
has not been conducted to determine whether the boiler met design specifications.
Task:
Using your experience and the factsheet discussion, answer the following
questions.
1. If the boiler is put into operation as scheduled, what violations of the PSSR
element of the PSM Standard will have occurred?
continued

Task 2 (continued)
2. If this situation occurred at your workplace, what would be your response

and/or action?
3. Have you experienced a similar situation at your workplace? If yes, please

explain.

Task 3: Compliance Audits (o)
of the PSM Standard
Purpose:
To understand the employer’s responsibilities to comply with PSM through auditing.

Task 3
Review Factsheet 10 and the sample PSM Compliance Audit on pages 106 to
117 and then complete the chart below. The sample audit of a facility gives the
results of an audit and identifies where the employer was cited in 11 of the 14
elements of PSM. The three elements at the bottom of the chart on this page
were not cited.
Review the shortcomings of the workplace audited and discuss them with your
group. Then identify possible shortcomings of each element at your workplace.
Put an “X” (in the second column of the chart below) next to each element in
which there may be a shortcoming at your workplace. Then in the third column,
make a note which would help you explain the “X” during report-back.
Give reasons why you put

PSM Element X
an “X” by this element.
1. Employee Participation
2. Process Safety Information
3. Process Hazard Analysis
4. Operating Procedures
5. Training
6. Contractors
7. Pre-Startup Safety Review
8. Mechanical Integrity
9. Management of Change
10. Incident Investigation

11. Compliance Audits
Emergency Response
Trade Secrets
Hot Work

Factsheet 10: Compliance Audits — The
Regulation
1910.119(o)(1)
Employers shall certify that they have evaluated compliance with the provisions
of this section at least every three years to verify that the procedures and practices
developed under the Standard are adequate and are being followed.
1910.119(o)(2)
The compliance audit shall be conducted by at least one person knowledgeable in
the process.
1910.119(o)(3)
A report of the findings of the audit shall be developed.
1910.119(o)(4)
The employer shall promptly determine and document an appropriate response to
each of the findings of the compliance audit and document that deficiencies have
been corrected.
1910.119(o)(5)
Employers shall retain the two (2) most recent compliance audit reports.

Sample PSM Compliance Audit
Area of Citation # Items Cited
Employee Participation 2
Process Safety Information 3
Process Hazard Analysis 3
Operating Procedures 7
Training 2
Contractors 2
Pre-Startup Safety Reviews 4
Mechanical Integrity 7
Management of Change 4
Incident Investigation 3
Compliance Audits 3
Total PSM 40

1. Employee Participation (c) (Finding)
The facility’s Employee Participation Guidelines did not:
 Address employee consultations during PSM program development;
 Assign responsibility or authority for implementing PSM; or
 Establish methods for soliciting input from contract employees regarding PSM.
The facility did not consult with employees on various elements of PSM.

2. Process Safety Information (d) (Finding)
The facility’s PSI Information did not include:
 A block flow or simplified process flow diagram;
 The expected maximum inventory of site vessels;
 Safe upper and lower operating limits for temperature, pressure, etc.;
 Expected results of deviations from safe upper and lower operating limits;
 Design codes and standards, materials of construction, etc., used in system
design;
 Complete Process and Instrumentation Diagrams (P&IDs);
 Electrical classification of machine rooms;
 Information regarding ventilation system design;
 Information regarding safety systems (e.g. interlocks, cutouts, detection
systems);
 Verification of good engineering practices in ammonia system including:
o Location of the discharge of pressure relief valves (PRVs) for new system;
o The size of common vent header for PRVs;
o Suitability of pipe and vessel insulation materials;
o Installation of PRVs on appropriate devices (Nos. 3 and 25 accumulators);
and
o Location of king valves (not operable from floor and no access platform).
Demonstration of good engineering practice for of electrical classification:
 Engine room not classified; and
 No remote emergency stop switches in engine rooms.

3. Process Hazard Analysis (e) (Finding)
The facility’s initial (1994) Process Hazards Analysis (PHA) did not:
 Identify, evaluate and establish controls for the hazards associated with the
process;
 Address previous PSM incidents;
 Address engineering and administrative controls for the following:
o Detection methodologies for neither ammonia nor emergency ventilation;
o PRVs or their vent header sizing;
o Emergency isolation (king) valves or compressor emergency cut-off
switches; and
o Mechanical integrity procedures.
 Address the consequences of failure of engineering and/or administrative
controls;
 Address facility siting or human factors; and
 The facility’s initial (1994) Process Hazards Analysis (PHA) did not:
o Promptly address all recommendations; or

o Discuss recommendations with refrigeration operators.

4. Operating Procedures (f) (Finding)
 The facility did not have compete (SOPs) for the ammonia system.
 The facility’s written SOPs did not address:
o Normal operating procedures;

o Temporary operations;
o Emergency shutdown conditions;
o Procedures for isolation and control of engine room leaks, including PPE;
o Operating limits (i.e., flow rates, pressure limits, temperature ranges, etc.);
o Hazards of the chemicals used in the process; and
o Safety systems and their functions (i.e., emergency stop switches, king
valves, etc.).
 The facility did not perform annual certification of their SOPs.
 The facility had not developed and implemented safe work practices for:
o Contractors entering the facility; and
o Entering process equipment or piping.

5. Training (g) (Finding)
The facility’s PSM training program did not:
 Require refresher training at least once every three years;
 Require consultation with workers regarding the frequency of refresher
training;
 Document employee training on specific SOPs; and
 Require verification of worker understanding of SOPs.

6. Contractors (h) (Finding)
The facility’s PSM Contractor Safety Program did not require:
 Evaluation of contractor safety performance and programs prior to contract
initiation;
 Periodic review of contractor safety performance;
 Periodic evaluation of contractor safety training programs; or
 Periodic evaluation of contractor employees understanding safety training.

7. Pre-Startup Safety Review (PSSR) (i)
(Finding)
The Pre-Startup Safety Review for the new ammonia system failed to confirm
that:
 The construction of the process equipment was in accordance with design
specifications;
 P&IDs were complete and verified as accurate;
 Acceptance tests were performed on computer hardware and software,
protection devices including alarms, interlocks, cutouts and level controls;
 Safety, operating, maintenance and emergency procedures were complete;
 A PHA had been performed; and
 Employee training had been performed and understood.

8. Mechanical Integrity (j) (Finding)
The facility’s Mechanical Integrity Program contained the following deficiencies:
 No procedures for repair of process equipment;
 No procedures for replacement of PRVs;
 Inspection and tests were not performed on vessels, piping, PRVs, emergency
shutdown systems, control systems, pumps and compressors;

 No documentation of inspection and tests on process equipment;
 The facility did not correct known deficiencies in a safe and timely manner;
 No procedures ensuring that new refrigeration plant was installed to design
specifications and manufacturer’s instructions; and
 No procedures to ensure that maintenance materials, spare parts and equipment
were suitable for the process applications.

9. Management of Change (l) (Finding)
 No requirement to establish and implement written MOC procedures;
 Numerous changes were implemented without performing MOCs; and
 Written MOC procedures did not assure that the following issues were
addressed:
o Technical basis for proposed changes;
o Safety and health considerations;
o Modifications to operating procedures; and
o Failure to update process information and operating procedures after
implementing MOCs.

10. Incident Investigation (m) (Finding)
 Failure to develop an incident investigation procedure that met the
requirements of PSM;
 Failure to investigate numerous PSM-related incidents;

 Failure to train investigation teams in incident investigation techniques;
 Failure to include at least one member with process knowledge on
investigation team; and
 Failure to establish a system to promptly address and resolve investigation

report findings.

11. Compliance Audits (o) (Finding)
 Failure to verify that procedures and practices developed under the Standard
were being following (i.e., failure to correct PSI issues identified in earlier
compliance audits);
 Failure to include at least one member with process knowledge on the audit
team;
 Failure to develop a plan for resolution of compliance audit findings; and
 Failure to resolve compliance audit findings in a timely manner.

Summary: Activity 3: Elements n, i and o of the
PSM Standard
Emergency Response (n)
1. We need to know the limits of our role as first responders. Our first priority is to
protect ourselves and others from being injured. If we don’t have the appropriate
training and the right equipment, we should run away!
2. We should never try to be heroes or heroines. Instead, we should initiate the
Emergency Response Plan.
3. An Emergency Response Plan must be reviewed and updated to cover any
incident, intentional or accidental, that might occur despite our efforts to prevent
it. This review and update must include the worker, so that every aspect of the
operation can be covered.
Pre-Startup Safety Review (i)
4. A Pre-Startup Safety Review (PSSR) must be performed for new and modified
equipment, processes or facilities.
5. Recommendations that come from a PSSR must be addressed and/or corrected
prior to startup.
6. Safety, operating, maintenance and emergency procedures must be adequate and
in place as a component of a completed PSSR.
Compliance Audits (o)
7. The employer must certify that they have evaluated compliance with the PSM
Standard at least every three years.
8. The employer must certify that procedures and practices are adequate and are
being followed.
9. The employer must document any deficiencies found during the Compliance
Audit and document corrections made.

Activity 3: Elements n, I and o of the PSM Standard
11. To know that an emergency response is required, your role in emergency response
and the training you need. How much do you agree or disagree that the training met
this learning objective?
O O O O O
12. To understand the employer’s responsibilities to comply with PSM through auditing.
How much do you agree or disagree that the training met this learning objective?
O O O O O
13. We need to know the limits of our role as first responders. Our first priority is to
protect ourselves and others from being injured. How much do you agree or disagree
with the following statement? Understanding and applying this learning objective will assist
me in improving health and safety at my workplace.
O O O O O
14. A Pre-Startup Safety Review (PSSR) must be performed for new and modified equip-
ment, processes or facilities. How much do you agree or disagree with the following
statement? Understanding and applying this learning objective will assist me in improving
health and safety at my workplace.
O O O O O
15. The employer must certify that they have evaluated compliance with the PSM
Standard at least every three years. How much do you agree or disagree with the
following statement? Understanding and applying this learning objective will assist
me in improving health and safety at my workplace.
O O O O O

Activity 4
Elements l, d, f and g of the PSM Standard
Purpose
Task 1: Management of Change (l)
Operating Procedures (f)
Task 3: Training (g)
Activity 4: Elements l, d, f and g of the PSM Standard 121

Task 1: Management of Change (l)
of the PSM Standard
Purpose:
To understand how to manage change safely.

Task 1
Scenario:
During the last shutdown on the treating unit at the XYZ Facility, gravel and sediment
were found in the pump upstream on the gas compressor. Engineers designed a
temporary filter to be installed in the line to catch the debris.
The filter would require changing out on a regular basis to keep the pump free from
debris.
Use the Factsheet

Reading Method for
Task 1, Factsheets
1 through 8.

Factsheet 1: Process Safety Elements
Many of the Process Safety Elements link to one another. For example, if a change to
the operating conditions was made:
 A Management of Change System must be used;
 This then requires the need for an update in the Process Safety Information;
 Then the Operating Procedures must be updated; and
 Training must be conducted on all the new conditions.

Factsheet 2: Management of Change —
Paragraph (l) of OSHA’s PSM Standard
(l) Management of Change
Requirements:
 Establish written procedures to manage
changes to:
1. Process chemicals;
2. Technology;
3. Equipment;
4. Procedures; and
5. Facilities.
 Assess the impact of change on safety and operating procedures.
 Provide updated training to workers and contract workers prior to startup.
 If change is significant, then a pre-startup review is required.
 Update process safety information.
 Update operating procedures.

Factsheet 3: Maintenance and Change
Management of Change issues most often come into play during maintenance work
of some kind. It can happen in a variety of ways:
 Equipment/parts replacement
What happens when a part isn’t available? The tendency is to substitute
whatever is on hand to keep a workplace running.
 Changes made to isolate, protect, clean or clear equipment
Temporary changes are often made when preparing equipment for mainten-
ance. Temporary changes must be analyzed for unseen hazards. When work
is complete, equipment must be returned to a safe condition.
 Startups
This is a time of intense pressure in time and capital. Focus is often on these
issues and not on safety.
 Changes to design
Maintenance workers often perform most of the engineering changes in the
workplace. MOCs are often overlooked in this process.
Managing change during maintenance work means using good communications and
good planning with approved procedures, proper materials and qualified workers.
Sources: Sanders, R.E., Management of Change in Chemical Plants: Problems and Case Histories,
Butterworth-Heinemann, LTD., 1993; “Management of Process Hazards,” API recommended practice 750,
1990; and “Management of Change,” a presentation to the Oil, Chemical and Atomic Workers International
Union, AFL-CIO Process Safety Management School by Richard Budler, Manager of Process Safety, 76
Products Company, Denver, CO, 1996.

Factsheet 4: The Quick Change
Sometimes the hardest changes to manage are those that are the easiest to make.
They are inexpensive and don’t receive the same detailed consideration a larger,
more expensive change might get.
They are usually simple in nature so they don’t receive a review by the Engineering
Department. In fact, a work order may not even be generated.
Quick changes might include using a different lubricant in a compressor; using a
different gasket in an unloading hose; or perhaps changing a hose connection on an
airline to temporarily purge it with air.
New policies or procedures are not very effective in eliminating this problem. Opera-
tors, supervisors, mechanics and, in fact every worker in the workplace, must be
retrained to be aware of the potential hazards involved in making even small changes
to their worksites. Nor should this be a one-time thing. It must become a way of life
— a new part of the workplace’s culture — as commonly discussed at safety meetings
as any other important item.
Source: Sanders, R.E., Management of Change in Chemical Plants: Problems and Case Histories,
Butterworth-Heinemann, LTD., 1993.

Factsheet 5: “Other” Changes
When beginning a MOC program, it’s common to focus primarily on strictly
mechanical changes at first (i.e., swapping equipment parts; switching hose gaskets;
using a different type of valve). But other types of changes also have a significant
impact on safety and are often some of the more difficult ones to track. These can
include:
 Changes in Process Technology
Production rates, raw materials, new product development, operating
conditions and specifications such as pressure, temperature and flow rate;
 Changes in Equipment
Programming on a computer-controlled unit; changes in alarms; interlocks and
mitigation devices (i.e., pressure relief valve settings or piping, auto-shutdown
device set points); and increasing the load on a control system, such as adding
one more heat exchanger to an already overloaded cooling system;
 Changes in Procedures
Most changes in a process will cause a necessary change in procedures for
both operators and maintenance workers. Additional training on the changes
process will be required; and
 Changes in Human Factors
Staffing levels, physical conditions (i.e., lighting, temperature, etc.), work
schedules, system of supervision, etc. The potential effects of such changes
should be studied carefully before implementing.
Sources: Sanders, R.E., Management of Change in Chemical Plants: Problems and Case Histories,
Butterworth-Heinemann, LTD., 1993; “Management of Process Hazards,” API recommended practice 750,
1990; and “Management of Change,” a presentation to the Oil, Chemical and Atomic Workers International
Union, AFL-CIO Process Safety Management School by Richard Budler, Manager of Process Safety, 76
Products Company, Denver, CO, 1996.

Factsheet 6: Evaluation Team
One way to ensure that MOC concerns are not overlooked is to establish an evaluation
team. This team should be made up of members with a wide variety of backgrounds.
Engineers, safety professionals, operators, production supervisors, mechanics, etc.,
bring their own knowledge and/or expertise to an MOC Evaluation Team.
The team’s duties will include:
Evaluation
 Proposed changes are analyzed and a determination is made as to whether or
not the change is feasible.
 The team determines the degree of response that will be required (i.e., will a
checklist filled out by the operator/supervisor suffice or is a PHA called for,
etc.).
Follow-up
Team member(s) are assigned to follow a project and report-back to the full team on
its progress until completed. (Note: A large-scale project may be broken into smaller
tasks and assigned to several members.)
Auditing
Prior to completion of the project, the team (or sub-groups of the team, if the change
is determined to be small) will audit the change. This will include making sure that
updates and changes to written procedures and process safety information documents
have been made and training for operations and maintenance employees on the
change has been completed or scheduled.
Sign off
When the project is completed, team members will ensure that all tasks have been
completed. Startup of the process will not be permitted until each member signs off
on it.
Source: Jadubowski, Jake A., “Lessons Learned: Management of Change,” Professional Safety Magazine,
November 1996.

Factsheet 7: MOC Tools
Analyzing changes for potential problems is not an easy task. Ideally, a MOC
Evaluation Team would receive extensive training in this area. There are, however,
tools that can help to make the job a little easier and systematic.
A MOC checklist is a tool often used in MOC programs. The checklist is made up
of questions designed to help the user evaluate a change without overlooking any
important questions. No checklist is ever complete in itself; it is just a guide through
the evaluation process.
Even more common (and the focal point of most Management of Change programs)
is the MOC Change Request Form or permit. This form is basically used to gather
information about the change and may also include a brief checklist of MOC.
What goes into a checklist? That will vary widely from site to site. But at a mini-
mum, the questions or guidelines should cover possible effects of change to each
Safety System.
Sources: Jadubowski, Jake A., “Lessons Learned: Management of Change,” Professional Safety Magazine,
November 1996; and Process Safety Management Guidelines for Compliance, OSHA Publication 3133, 1994.

Factsheet 8: Sample Checklist
Source: Process Safety Management Guidelines for Compliance; OSHA Publication 3133, 1994.

Task 1 (continued)
The filter would require changing out on a regular basis to keep the pump free from
debris.
The workers on that unit were told that changing the filters would be added to their
regular job assignments when the unit was brought back on line.
The workers went to their Joint Health and Safety Committee because they did not
know how to change the filters.
Task:
You and your table are members of the Joint Health and Safety Committee.
Using the factsheets and your experience, answer the following questions.
1. How would you and your committee handle this situation?

2. Has this type of event ever happened at your workplace? If yes, please
explain.
3. Does your workplace have an MOC plan in place? If yes, please explain.

Notes

of the PSM Standard
of the PSM Standard
Purposes:
To understand how Process Safety Information protects workers.
To understand the need for and limitations of Standard Operating Procedures.

Task 2
Scenario:
XYZ Management, after action by the Union Health and Safety Committee, finally
issued an MOC on the pump. When you came into work that day, a copy of the MOC
was laying on the table in the satellite building. All workers were asked to sign off
stating they were trained and understood the new process.
Use the Factsheet

Reading Method for
Task 2, Factsheets
9 through 16.

Factsheet 9: Process Safety Information —
Paragraph (d) of OSHA’s PSM Standard
(d) Process Safety Information
Requirements:
 Compile specific information before starting a Process Hazard Analysis that
covers:
1. The hazards of highly hazardous chemicals in the process (MSDSs/SDSs
are sufficient if they contain all required information);
2. The technology of the process (block flow diagrams, chemistry of process);
and
3. Information pertaining to the equipment in the process.

Factsheet 10: What is Process Safety
Information?
Process Safety Information has many aspects.
Information about the hazards of the highly hazardous chemicals found in the process
are:
 Toxicity;
 Permissible exposure limits;
 Physical data;
 Reactivity data;
 Corrosivity data; and
 Thermal and chemical stability data and hazardous effects of accidental mixing
of different materials.
Process Safety Information provides the basis for identifying and understanding the
hazards of a process and is necessary in developing the Process Hazard Analysis.

Factsheet 11: Process Safety Information and
Technology
Information concerning the technology of the process must include at least the
following:
 A block flow diagram or simplified process flow diagram;
 Process chemistry;
 Maximum intended inventory;
 Safe upper and lower limits for such items as temperatures, pressures, flows or
compositions; and
 An evaluation of the consequences of deviations, including those affecting the
safety and health of workers.

Factsheet 12: Process Safety Information and
Equipment
Information on the equipment in the process must include the following:
 Materials of construction;
 Piping and instrument diagrams (P&IDs);
 Electrical classification;
 Relief system design and design basis;
 Ventilation system design;
 Design codes and standards employed;
 Material and energy balances for processes built after May 26, 1992; and
 Safety systems (e.g., interlocks, detection or suppression systems).
The employer shall document that equipment complies with recognized and generally
accepted, good engineering practices.
For existing equipment designed and constructed in accordance with codes, standards
or practices that are no longer in general use, the employer shall determine and
document that the equipment is designed, maintained, inspected, tested and operated
in a safe manner.
The employer shall perform a Pre-Startup Safety Review for new facilities and for
modified facilities when the modification is significant enough to require a change
in the Process Safety Information.

Factsheet 13: Necessary Resource
Process Safety Information is a necessary resource to a variety of users
including:
 The team performing the Process Hazard Analysis, as required by the PSM
Standard;
 Those developing the training programs and the operating procedures;
 Contractors whose workers will be working with the process;
 Those conducting the Pre-Startup Reviews;
 Local emergency preparedness planners; and
 Insurance and enforcement officials.
The information to be compiled about the chemicals, including process intermediates,
needs to be comprehensive enough for an accurate assessment of the fire and explo-
sion characteristics, reactivity hazards, the safety and health hazards to workers and
the corrosion and erosion effects on the process equipment and monitoring tools.
Current material safety data sheet (MSDS and SDS) information can be used to
help meet this, but must be supplemented with process chemistry information,
including runaway reaction and over-pressure hazards, if applicable.
Source: http://www.osha.gov/Publications/osha3133.html.

Factsheet 14: Safe Operating Procedures —
Paragraph (f) of OSHA’s PSM Standard
(f) Safe Operating Procedures
Requirements:
Develop and implement written procedures covering:
1. Each operating phase:
 Startup;
 Normal operations; and
 Emergency shutdown.
2. Conditions which require emergency shutdown;

3. Operating limits;
4. Safety and health considerations; and
5. Safety systems.
Keep these procedures current and update once a year.

Factsheet 15: Procedures
Operating procedures should:
 Be prepared and reviewed with worker input;
 Undergo review and approval by the safety authority;
 Be field-validated (walkdown of operating procedure prior to release for work,
or re-release for work; such as when modifications to the procedure or system

have been made);
 Specify that modifications to the procedure or system must be documented and
verified;
 Be made accessible and available to all workers;
 Be reviewed and updated periodically;
 Identify who is authorized to operate and/or maintain the equipment; and
 Define what Personal Protective Equipment (PPE) must be worn.

Factsheet 16: Written Hazards in Procedures
We use procedures to help us eliminate the risk of hazards, but many times procedures
have risks and hazards written into them. We can identify these cautions and warnings
in the following three ways:
 First and easiest is when the words “caution,” “alert” or “be careful” are used
with a step in the procedure.
 Second is when the worker is asked to use Personal Protective Equipment.
This often indicates there is a hazard that should be eliminated or reduced.
 Third is when there is a step in the procedure in which the worker clearly
identifies a danger. Workplace rules stress following procedures exactly.
Including the worker in writing and reviewing all procedures would help eliminate
many of the risks and dangers.
Source: “Identifying Hazards through Procedures and Eliminating Them with Systems of Safety,” DOE Annual
Refresher Training for Hazardous Waste Operations, Edition 121, May 2006, Tony Mazzocchi Center.

Task 2 (continued)
were found in the pump upstream on the gas compressor. Engineers designed a tem-
porary filter to be installed in the line to catch the debris. XYZ Management finally
issued an MOC on the pump. When you came into work that day, a copy of the MOC
was laying on the table in the satellite building. All workers were asked to sign off
stating they were trained and understood the new process.
Task:
Using your experience and the factsheets, answer the following questions.
1. Should you and the other workers sign this form?
Please explain your answer.
2. How should new information pertaining to equipment and procedures be

handled?

Notes

Task 3: Training (g) of the PSM Standard
Purpose:
To familiarize ourselves with the requirements for training within the PSM Standard.
Task 3
Scenario:
“The other night I passed the hot oil turbine when I was making my rounds and
saw the bearings were hot because they were not getting enough cooling. I tried to
get more flow but I couldn’t do it. I thought there was another way to get more flow,
but I hadn’t received all the training on this process. They said I just needed enough
to do my job. I called the control room and notified them of the problem. If I had
shut down the turbine (the backup was offline for repairs), it would have stopped
production.”
Use the Factsheet

Reading Method for
Task 3, Factsheets
17 through 23.

Factsheet 17: PSM Standard Section (g) —
Training
1. Initial Training
(i) Each employee presently involved in operating a process, and each employee
before being involved in operating a newly assigned process, shall be trained
in an overview of the process and in the operating procedures as specified in
paragraph (f) of this section.
The training shall include emphasis on the specific safety and health
hazards and emergency operations, including shutdown and safe work
practices applicable to the employee’s job tasks.
(ii) In lieu of initial training for those employees already involved in operating
a process on May 26, 1992, an employer may certify in writing that the
employee has the required knowledge, skills and abilities to safely carry
out the duties and responsibilities as specified in the operating procedures.
2. Refresher Training
Refresher training shall be provided at least every three years, and more often if
necessary, to each employee involved in operating a process to assure that the
employee understands and adheres to the current procedures of the process. The
employer, in consultation with the employees involved in operating the process,
shall determine the appropriate frequency of refresher training.
3. Training Documentation
The employer shall ascertain that each employee involved in operating a process
has received and understood the training required by the paragraph. The employer
shall prepare a record which contains the identity of the employee, the date of the
training and the means used to verify that the employee understood the training.

Factsheet 18: Who Is “Involved in Operating the
Process?”
When OSHA proposed this section of the Standard, there was a lot of debate about
who should be covered. Some workplaces contend that managers and supervisors
only require training in supervisory skills, since they have completed college.
Others question how a college education prepares a person for a specific petrochemical
process. They further argue that a person could not possibly be able to instruct or give
direction to workers if they do not have at least the same training and that they should
have more training than the workers.
So OSHA gives us their definition:
“To apply to only those employees, including managers and supervisors, who
are actually involved in ‘operating’ the process.”
p. 6381.

Factsheet 19: Maintenance Personnel Must
Receive Training Too!
There are also training requirements for maintenance workers listed within the
Mechanical Integrity (j) portion of the Standard:
“The employer shall train each employee involved in maintaining the ongoing
integrity of process equipment in an overview of that process and its hazards
and in the procedures applicable to the employee’s job tasks to assure that the
employee can perform the job task in a safe manner.”
This means skills training is required along with an overview of the process.

Factsheet 20: Even Contractors Have to Be
Trained!
There are also requirements for contractors [see PSM Standard, Section (h) —
Contractors]:
“The contract employer shall assure that each contract employee is trained in
the work practices necessary to safely perform his/her job.”
It is the responsibility of the employer to ensure that the contractor is training their
workers. A complete history of the training and verification of the contractor’s
understanding of the training must be kept on file.
More than a Process Safety Overview is needed to fulfill this requirement. It requires
a history to verify the skills necessary to be considered a machinist, electrician or any
other craftsperson.

Factsheet 21: Training for Production is Not
Enough; Health and Safety Must Be Included
As a result of an investigation by OSHA of an explosion at Shell Chemical, the
company was issued several citations. The citation for failure to properly train
workers is as follows:
Citation:
The initial training program for workers involved in operating a process did not
include emphasis on:
1. Specific safety and health hazards of the process;
2. Emergency operations, including shutdown; and
3. Safe work practices.
The employer did not train all K-l technicians and shift supervisors on the potential
hazards, equipment and system limitations and associated safeguards of the K-l
polymerization unit.
In settlement of the training issue, the employer agreed to train each worker involved
in the process in:
1. An overview of the process;
2. Operating procedures; and
3. Actions taken pursuant to:
a. Process Hazard Analysis; and
b. Incident Investigation Reports.
The training will emphasize the specific safety and health hazards of the process.

Factsheet 22: The Myth of “Safety First”
Training for production is the number one reason that workplaces implement training
programs.
In a survey, manufacturing firms were asked directly why they had decided to
implement their programs. Their answers are listed in the chart below:
Reasons Manufacturing Firms Implement Training Programs
To reduce errors and waste 54%
As a benefit to workers 46%
Because a subsidy became available 46%
Because of pressure from customers 43%
Because it was needed as a result of changes in production 40%
As a part of a transformation of corporate culture 29%
Because it was needed as a result of new technology 29%
Because it was required by customers 29%
Because training became available 26%
Because of changes in the available work force 26%
To attract new workers 23%
To attract new customers 23%
To meet new health and safety requirements 23%
To meet new certification 20%
To meet increased competition 20%
Because of an agreement with labor 20%
Because workers identified the need 17%
Source: “Workplace Education for Hourly Workers,” Journal of Policy Analysis and Management, Winter
1994.

Factsheet 23: Some Have Reasons for Not
Training
Firms without education programs were asked to indicate the most important reasons
for not having training programs.
Reasons Manufacturing Firms Don’t Have Training Programs
Do not feel the need for such a program 52%
Believe that the program would cost too much 41%
Don’t have the personnel infrastructure to deal with it 33%
Too busy to deal with training 22%
Don’t know what skills their workers need or how to arrange for those skills
40%
to be taught
Philosophically opposed to such a program 29%
Believe the turnover is too high to enable the firm to recoup its investment
29%
in the program
But the bottom line is . . . money!
Source: “Workplace Education for Hourly Workers,” Journal of Policy Analysis and Management, Winter
1994.

Task 3 (continued)
“The other night I passed the hot oil turbine when I was making my rounds and
saw the bearings were hot because they were not getting enough cooling. I tried to
get more flow but I couldn’t do it. I thought there was another way to get more flow,
but I hadn’t received all the training on this process. They said I just needed enough
to do my job. I called the control room and notified them of the problem. If I had
shut down the turbine (the backup was offline for repairs), it would have stopped
production.”
The foreman told me to wait while he talked to the night superintendent. I stood there
while the night superintendent called the unit supervisor and woke him up to get his
permission. I watched that turbine wipe its bearing out and ruin the shaft. Then I got
the OK to shut it down.
Task:
1. Who should be process trained and how much training should be given?
2. Could this scenario happen at your workplace?
Please give your explanation.

3. Do you believe a worker should have the authority to correct unsafe
conditions in your workplace?
4. What are the pros and cons of workers having the authority to correct
unsafe processes and other conditions at your workplace?
Pros Cons

Summary: Activity 4: Elements l, d, f and g of
the PSM Standard
Management of Change (l)
1. A written Management of Change (MOC) policy should be developed with full
worker participation.
2. Updated training for operators, mechanics and contractors must be given before
the startup of a modified process.
3. A dedicated MOC Review Team made up of individuals with widely diverse
backgrounds and including both management and hourly members, is an important
part of any effective MOC program.
4. Operating procedures must be rewritten to reflect the changes.
5. A MOC will only be effective if everyone in the workplace believes it to be
necessary.
Process Safety Information (d)
6. Process Safety Information provides the basis for identifying and understanding
the hazards of a process and is necessary in developing the Process Hazard
Analysis.
7. Procedures help us eliminate risks, but many times procedures have risks and
hazards written into them.
8. SOPs should be prepared and reviewed with worker input.
Training (g)
9. The PSM Standard tries to ensure that all workers involved with the process are
trained.
10. All maintenance personnel must be trained. Direct-hire and contractors must be
trained before they repair equipment.
11. Workers must be allowed to use their training and education to make decisions.
Who better to act than the one who does the work?
12. All training should focus on health and safety skills, not just production skills.

Activity 4: Elements l, d f and g of the PSM Standard
16. To gain an understanding of how to manage change safely. How much do you agree or
disagree that the training met this learning objective?
O O O O O
17. To understand how Process Safety Information protects workers. How much do you
agree or disagree that the training met this learning objective?
O O O O O
18. To understand the need for and limitations of Standard Operating Procedures. How
much do you agree or disagree that the training met this learning objective?
O O O O O
19. To familiarize ourselves with the requirements for training within the PSM Standard.
O O O O O
20. A written Management of Change policy should be developed with full worker partici-
pation. How much do you agree or disagree with the following statement? Understanding
and applying this learning objective will assist me in improving health and safety at my
workplace.
O O O O O

Activity 5
Elements h and p of the PSM Standard
Purpose
To introduce and become familiar with the elements below.
Task 1: Contractors (h)
Task 2: Trade Secrets (p)

Task 1: Contractors (h)
of the PSM Standard
Purpose:
To understand the health and safety consequences of the contractor/temporary worker
system.

Task 1
Scenario:
Joe Brown, a chemical worker, was walking to the job after punching in on Monday
morning. He was surprised to find Ron, a friend of his 20 year old son, Mark, at the
coffee machine.
“Mornin’ Ron. Are you lost? What brings you out to the plant?” asked Joe.
Ron answered, “Hey Mr. Brown. Didn’t Mark tell you? I start my new job today.
I’m a pipefitter for ACME Construction!”
“A pipefitter? If I remember right, you were flipping hamburgers just a week ago.
How’d this happen?” Joe replied.
Use the Factsheet

Reading Method for
Task 1, Factsheets
1 through 7.

Factsheet 1: The Contractor PSM Element (h)
Workplace Employer Requirements:
When selecting a contractor, the employer must:
1. Evaluate its safety performance and programs.
2. Maintain a log of contractor injuries and illnesses.
3. Inform the contractor employers of potential fire, explosion or toxic release
hazards related to the contractor’s work.
4. Develop and implement safe work practices to control the entrance, presence
and exit of contract workers.
5. Periodically evaluate the onsite performance of the contractor to ensure
compliance with the PSM Standard.
6. Explain the employer’s Emergency Action Plan to the contractor.

Contract Employer Requirements:
1. Train its workers to perform work safely.
2. Inform all of its workers of potential fire, explosion or toxic release hazards and
what to do if they occur.
3. Document that workers have been trained and understand the training.
4. Assure that workers follow workplace safety rules.
5. Inform workplace employer of any hazards introduced by contractor’s work, or
of any hazards discovered by the contractor.

Factsheet 2: The Day “It” Hit the Fan in Texas
On October 23, 1989, the largest industrial accident in the U.S. (outside of construc-
tion) since the passage of the 1970 Occupational Safety and Health Act occurred in
Pasadena, Texas. When the smoke cleared, 23 workers lay dead and 232 were injured.
This infamous explosion at Phillips 66 occurred while workers employed by Fish
Engineering and Construction, Inc., were performing maintenance work on equipment
from which highly flammable gases escaped.
The tragedy followed a smaller explosion just two months earlier that killed two
workers at the same plant involving the same contractor!
The Phillips disaster finally forced Congress and OSHA into action.
A study was ordered to determine whether the use of contract workers posed a threat to
worker and community safety. The eventual result was the Process Safety Management
Standard.
Ironically, contractor safety, the issue that started it all, was practically ignored by
the Standard.

Factsheet 3: Who’s John Gray?
OSHA chose the John Gray Institute of Lamar University in Beaumont, Texas, to
research the impact of contractor safety after the Phillips disaster in 1989. OSHA
also created a Steering Committee made up of industry and union labor leaders (the
Oil, Chemical and Atomic Workers International Union, the International Chemical
Workers Union and United Steelworkers Union) to help in the study.
The report gave detailed recommendations for improving the safety of the Contractor
System:
 A comprehensive, proactive database should be set up to collect and analyze
workplace injury data.
 OSHA should establish and implement safety and health training standards for
all petrochemical industry workers.
 OSHA should require workplace management to assume responsibility for the
safety and health of all workers (direct-hire and contract) at the worksite.
 OSHA should require effective Labor-Management Safety and Health Commit-
tees that include contract workers at each site and provide resources to train
committee members.
 Workplace managers should engage their workforce and labor representatives in
open discussion of the contract decision-making process.
 OSHA should continue the research and evaluation process.
Because of heavy opposition by industry and by corporate lobbyists in Congress,

the study and its recommendations were never adopted by OSHA in its formula-
tion of the PSM Standard.
But, the information uncovered by the study cannot be ignored; especially if the
unionist movement is to survive and our workplaces and communities made safe!

Factsheet 4: Contract Labor — A Failed System
The Disposable Workforce
Testifying before the House Government Operations Subcommittee on Employment
and Housing, Sandra Davis, a widow, said:
“I am concerned about the fact that there is not enough training or awareness
of safety hazards; and I am not referring to just those normal daily hazards
addressed in the safety video, but the hazards that occur due to the problems
at the plant that these men don’t know about.”
Three weeks earlier, a wastewater tank exploded just before midnight on July 4, 1990,
killing 17 workers at Arco Chemical in Channelview, Texas. They included Sandra’s
husband, Greg Davis, one of 11 contract workers for Austin Industries, Inc.
Representative Tom Lantos, Subcommittee Chairman, said in his opening remarks of
the hearing:
“We cannot permit companies focused on the bottom line to off-load their risks
onto contract workers; often:
 Less trained;
 Less skilled;
 Lower-paid workers who lack experience due to a high rate of turnover;
and
 Who often are non-English-speaking, which complicates the process of
communicating hazards and worksite risks.”
Source: Victor, Kirk, “Explosions on the Job,” National Journal, August 11, 1990.

Factsheet 5: The Contractor System in a Nutshell
Contract workers are victims in this system, not villains.
They are forced to work in hazardous situations they do not understand and with
hazardous substances they know little about. They are used as cheap replacements
for direct-hire workers but receive only a fraction of the training and compensation
that a direct-hire worker would get.
“Contract workers are, on average, younger, less educated, less experienced in
the petrochemical industry and with their employer, lower paid and more likely
to be of Hispanic origin. [Contract workers] . . . are more likely to have English
language or communications difficulties . . . receive less safety training . . . are
less likely to be unionized or covered by a Labor-Management Safety and Health
Committee and less likely to participate in safety discussions with others on their
worksite.”
Job too dirty? Too dangerous? Call a contractor. That’s the bottom line of the
contractor system.
Source: Wells, John C., Kochan, Thomas A. and Smith, Michael, “Managing Workplace Safety and Health:
The Case of Contract Labor in the US Petrochemical Industry,” the John Gray Institute, Lamar University.

Factsheet 6: The Role of the Law in the Contractor
System
“. . . Contract employees were generally treated as a separate and distinct workforce.
It was observed that contract workforces:
 Dressed differently;
 Used separate entrances;
 Relied upon workplace medical support in emergencies only;
 Reported and responded first to contract supervisors; and
 Depended principally upon the contractor to prepare them for work in a
petrochemical facility.”
The U.S. legal system actually encourages host employers to avoid training and
supervising contractors because of legal liabilities. If a contractor injures a third
party (someone not working for the contractor or host), then usually the contract
employer alone is held liable. So long as the court agrees that the contractor was
truly an independent contractor, the host employer escapes liability. Also, by avoid-
ing most contact with the contract employer, the host employer isn’t held liable in
worker’s compensation claims filed by contract workers.

Factsheet 7: The Role of Government in the
Contractor System
The Chemical Manufacturer’s Association (CMA) paints a rosy picture of safety in our
industry. According to Gordon D. Strickland, CMA Assistant Vice-President:
“If you look at the chemical industry’s safety record, it is always at the top
one, two or three of the industries in this nation; even though (its jobs include)
making explosives and dealing with high pressures, strong acids and poisons.”
That claim is based on data from the Federal Bureau of Labor Statistics (BLS) which
maintains records of worker accidents throughout the country. But. . . wait a minute:
They don’t include injuries to contract workers in that data! Contract workers who, as
we have seen, represent at least 30 percent of the total workforce in the petrochemical
industry!
“Since contract workers are more accident-prone than regular workers who
have learned the ropes during years spent at a workplace, the BLS database
substantially under-reports workplace injuries in petrochemical plants.”
Don’t contractor injuries show up anywhere? Sure; but only on the contract employer’s
OSHA 300 Log, not the host employer’s. A host employer is nearly unaccountable for
injuries on the job to contract workers. This further demonstrates that an OSHA inci-
dent rate number is just that, a number — not a real measure of workplace safety.
The government actually rewards employers for using contractors by making them less
accountable than direct-hire workers.
Sources: Kirk, Victor, “Explosions on the Job,” National Journal, August 11, 1990; and ”Chemical Accidents,”
Rachel’s Environment & Health Weekly, #408, September 22, 1994.

Task 1 (continued)
Joe Brown, a chemical worker, was walking to the job after punching in on Monday
morning. He was surprised to find Ron, a friend of his 20 year old son, Mark, at the
coffee machine.
“Mornin’ Ron. Are you lost? What brings you out to the plant?” asked Joe.
Ron answered, “Hey Mr. Brown; didn’t Mark tell you? I start my new job today. I’m
a pipefitter for ACME Construction!”
“A pipefitter? If I remember right, you were flipping hamburgers just a week ago.
How’d this happen?” Joe replied.
“I just answered an ad in the paper for ACME last week and here I am,” answered Ron.
Joe exclaimed, “Here you are! Have you ever even been inside a chemical plant
before?”
“Well no,” answered Ron.
“Do you have any idea what kind of stuff we work with here?” asked Joe.
“Hey, no problem Mr. Brown. All of us new guys went to the contractor safety council
class and sat through a whole bunch of videos about procedures, safety and all that
stuff. Must have lasted two or three hours. See, I got my certificate. It says ‘Safety
Trained’ right there above my name. Besides, the guys at ACME said I’d learn what I
need on the job,” said Ron.
continued

Task 1 (continued)
Working in your groups, answer the following questions using the information
you discussed in Factsheets 1 through 7 and your own experiences.
1. Does Joe really have any reason to be upset? Why? Formulate a list of
concerns.
a. Health and Safety:
b. Other:
2. What problems are you experiencing at your own workplace because of the
contractor system? Please list.

Task 2: Trade Secrets (p)
of the PSM Standard
Purpose:
To understand that workers have the right to know about their workplace hazards
regardless of the employer’s trade secrets.

Task 2
Scenario:
While working the night shift at Chem Co., Emily and her crew members were told
they would be working with a new chemical that would improve the durability of the
rubber they made.
Emily asked her foreman for the name of the chemical. He told her that he did not
know, but that she should not worry. He had been informed by his superiors that the
chemical was safer than the one it replaced.
Emily was not comfortable working with and around a chemical without information
about it. She routinely checked on the internet for updated MSDSs on the chemicals
with which she worked.
Use the Factsheet

Reading Method for
Task 2, Factsheets
8 through 14.

Factsheet 8: 1910.119(p) Trade Secrets
1910.119(p) — Trade Secrets
1910.119(p)(1)
Employers shall make all information necessary to comply with the section available to:
 Those persons responsible for compiling the Process Safety Information
[required by paragraph (d) of this section];
 Those assisting in the development of the Process Hazard Analysis [required by

paragraph (e) of this section];
 Those responsible for developing the operating procedures [required by
paragraph (f) of this section]; and
 Those involved in:
o Incident investigations [required by paragraph (m) of this section];

o Emergency planning and response [paragraph (n) of this section]; and
o Compliance audits [paragraph (o) of this section] without regard to possible
trade secret status of such information.
1910.119(p)(2)
Nothing in this paragraph shall preclude the employer from requiring the persons to
whom the information is made available, under paragraph (p)(1) of this section, to enter
into confidentiality agreements not to disclose the information as set forth in 29 CFR
1910.1200.
1910.119(p)(3)
Subject to the rules and procedures set forth in 29 CFR 1910.1200(i)(1) through
1910.1200(i)(12), employees and their designated representatives shall have access
to trade secret information contained within the Process Hazard Analysis and other
documents required to be developed by this Standard.

Factsheet 9: Trade Secrets — The Definition
The precise language by which a trade secret is defined varies by jurisdiction (as do
the particular types of information that are subject to trade secret protection). However,
there are three factors that, although subject to differing interpretations, are common to
all such definitions. A trade secret is information that:
 Is not generally known to the public;
 Confers some sort of economic benefit on its holder (where this benefit must
derive from specifically is not generally known; not just from the value of the
information itself); and
 Is the subject of reasonable efforts to maintain its secrecy.

Factsheet 10: Trade Secrets — Keep Your Rights
The employer is required to inform workers of the hazards associated with the
equipment, processes and facilities with which they work.
However, it is at the discretion of the employer whether or not to have workers sign
a confidentiality agreement prior to receiving information concerning hazards related
to work which the employer deems a trade secret.
Confidentiality agreements should not compel workers to give up rights outside of
those revealing information directly associated with trade secrets.

Factsheet 11: Trade Secrets — The Problem
The chemical revolution of the past 50 years has altered nearly every aspect of our
lives.
 Many of the products we rely upon every day, from plastic bags to computers,
would not exist without synthetic chemicals.
 Most of us believe the chemicals in consumer products have been tested and
approved by some government agency.
In fact, until they are proven harmful, most chemicals are presumed safe.
Source: “Trade Secrets: A Moyers Report,” http://www.pbs.org/tradesecrets/evidence/evidence.html.

Factsheet 12: Few Chemicals are Tested
Of the more than 75,000 chemicals registered with the Environmental Protection
Agency, only a fraction have gone through complete testing to find out whether
they might cause problems for human health. Many that are produced in enormous
quantities have never been tested at all.
It usually takes dramatic episodes of workplace injuries or wildlife poisonings,
combined with rigorous scientific proof of harm and public outcry, before the
government will act to restrict or ban any chemical.
That is no accident. The current regulatory system allows synthetic chemicals
into our lives, unless one is proven beyond a doubt to be dangerous.

Factsheet 13: Trade Secrets — The Evidence
The “precautionary principle,” adopted by the European Union in 1992 as the basis
for regulation of toxic chemicals, holds that, in the face of scientific uncertainty,
government should err on the side of protecting public health and safety. In other
words, if scientific evidence indicates there is a good chance that a chemical may pose
a risk of irreversible harm, regulators should not wait for absolute proof before acting.
One of the major themes running through the internal chemical industry
documents investigated in “Trade Secrets: A Moyers Report,” is the industry’s
opposition to the precautionary principle.

Factsheet 14: Trade Secrets — The Options
The system is far from perfect.
 Only about 600 chemicals must be reported on EPA’s Toxic Release Inventory,
out of an estimated 75,000 chemicals registered.
 Information about potentially harmful chemicals in consumer goods is even
sketchier.
 Labels do not always list every ingredient. (Employers often claim trade-secrecy
exemptions on exact formulations.)
But available sources do make educated choices possible, and also help citizens to ask
the right questions of the government and the chemical industry.

Task 2 (continued)
While working the night shift at Chem Co., Emily and her crew members were told
they would be working with a new chemical that would improve the durability of the
rubber they made.
Emily asked her foreman for the name of the chemical. He told her that he did not
know, but that she should not worry. He had been informed by his superiors that the
chemical was safer than the one it replaced.
Emily was not comfortable working with and around a chemical without information
about it. She routinely checked on the internet for updated MSDSs on the chemicals
with which she worked.
Emily asked her foreman if there was any way he could get her the name of the
chemical so that she could find an MSDS for it before she began working with it.
He responded by saying, “This chemical is ‘top secret.’ The employer doesn’t want
anyone leaking information about it to our competitors. Emily, I would advise you to
just leave this alone and go back to the production line.”

1. In this scenario, Emily is presented with a problem. Should she take the
advice of her foreman and return to work without receiving the information
she requested?
Why or why not?
2. What can Emily expect her employer to make her agree to before the
information is granted?
continued

Task 2 (continued)
3. Have you, or anyone you have worked with, been faced with a problem similar
to Emily’s?
If so, how did you handle the situation?
4. How might you handle this situation, or possible future situations, differently
now that you’ve completed this task and know what the law says about “Trade
Secrets?”

Notes
Summary: Activity 5: Elements h and p of the

PSM Standard
Contractors (h)
1. OSHA requires training at two levels: First, to safely perform job skills and second,
to understand the hazards of the process.
2. Employers are increasingly moving to the contractor system because of:
 Cheaper labor/benefits;
 Less responsibility for worker training;
 Less liability under the law; and
 Ease of hiring/ease of firing.
3. The contractor system is flawed because:

 Contract workers are less experienced with hazards;
 Contract workers are inadequately trained; and
 Incidents involving contractors are on the rise.
Trade Secrets (p)

4. Workers have the right to know about the hazards to which they are being exposed.
5. Employers have the right to protect their business interests with “trade secrets.”
6. Employers do not have the right to use “trade secrets” as a method of preventing
workers from knowing the hazards with which they work.

Activity 5: Elements h and p of the PSM Standard
21. To understand why industry is moving into a system of contract or temporary labor.
O O O O O
22. To understand the health and safety consequences of the contractor/temporary worker
system. How much do you agree or disagree that the training met this learning objective?
O O O O O
23. OSHA requires training at two levels: First, to safely perform job skills and second,
to understand the hazards of the process. How much do you agree or disagree with the
following statement? Understanding and applying this learning objective will assist me in
improving health and safety at my workplace.
O O O O O
24. The contractor system is flawed: Contract workers are less experienced with hazards;
contract workers are inadequately trained; and incidents involving contractors are on
the rise. How much do you agree or disagree with the following statement? Understanding
and applying this learning objective will assist me in improving health and safety at my
workplace.
O O O O O

Activity 6
Elements k and j of the PSM Standard
Purpose
To introduce and become familiar with the elements below.
Task 1: Hot Work (k)
Task 2: Mechanical Integrity (j)

Task 1: Hot Work (k) of the
PSM Standard
Purpose:
To understand hot work and identify the elements of a good program.

Task 1
Scenario:
Art and Ray were sent to the Tank Farm to replace bearings on an isopropenyl pump
located on the alcohol pad. They found the bearings “frozen” in place.
When Art told his supervisor they would have to pull the pump, he said, “Let’s see
if we can’t pull those bearings in place; we’ve got too much downtime in that area
already.”
First they tried to loosen the bearings with a bearing heater (a powerful electric heat
gun) but without success. Ray then called a welder who heated the casing with her
torch until the bearings came free. While the welder was there, the supervisor had
her weld brackets on an I-beam.
Use the Factsheet

Reading Method for
Task 1, Factsheets
1 through 6.

Factsheet 1: What Is Hot Work and Why Is It
Hazardous?
OSHA defines hot work as “work involving electric or gas welding, cutting, brazing or
similar flame- or spark-producing operations.” We should be concerned about hot work
because:
 In most of our workplaces (especially in PSM-covered areas) a spark invites
disaster because of the tremendous potential for flammable vapors, gases or
dusts to be present.
 When we cut, weld or grind in our facilities, literally thousands of ignition
sources, in the form of sparks and hot slag, are created.
 Sparks and slag can sometimes scatter up to 35 feet or more throughout an
area where hot work is going on.
 Sparks and slag can also pass through cracks, gratings, doors, drains, open
hatches and other openings in walls, floors or vessels creating fire/explosion
hazards in sometimes distant areas.
Source: NFPA 51B, “Fire Prevention in Use of Cutting and Welding Processes,” 1989.

Factsheet 2: Hot Work May Be More Than You
Expect
Anything combustible or flammable can be ignited by hot work. Welding, cutting
and brazing are pretty obvious; but what about those other “flame- or spark-producing
operations” that OSHA talks about?
 Grinding, sanding and sand blasting;
 Metal-on-metal contact, metal-on-concrete contact;
 Internal combustion engines;
 Electric- and battery-powered tools, such as drills or saws;
 Cameras, battery-powered instruments, radios, etc.; and
 Even your clothing can cause static sparks.
If your Hot Work Permit System does not address these sources, it is not giving
you the protection the law requires.
Before doing hot work, it’s natural to focus on the hazards of the process (solvent
vapors, flammable gases, explosive dust-in-air mixtures, etc.). But it’s possible to
overlook other combustible materials; so check the area out thoroughly.
Move combustible materials at least 35 feet from the hot work area. If they can’t be
moved, they must at least be protected with flame-proof covers or shielded with metal
or asbestos guards or curtains. Edges of covers at the floor should be tight to prevent
sparks from going under them. Combustible flooring should be hosed down or
protected by fire resistant shields. Cover floor drains, trenches, sewer boxes, etc.
But remember, it is almost always safer to move that piece of equipment out of the
process area to a safe place before doing hot work on it.
Hot work should be your last resort.
Sources: OSHA 1910.252(a); and NFPA 51B — Fire Prevention in Use of Cutting and Welding Processes, 1989.

Factsheet 3: Where There’s Smoke, There Should
Be a Fire Watch!
When hot work is being performed the sparks fly — literally!
Sparks produced by hot work operations (like grinding, cutting or welding) are often
spread over a large area. This makes it impossible for grinders, welders or torch
operators to do their work and watch for fires too. OSHA says a fire watcher must
be assigned to the job if there is a chance of more than just a minor fire. In our
workplaces, no fire is minor. Consider the following real-life examples:
 Tennessee: A welder on the third floor of a construction project unknowingly
started a fire on the floor below. He did not realize how far the globules of
molten metal from his operation were traveling until another worker spotted a
fire in some combustible material on the second floor. The wind had carried the
molten metal to the lower east wing and ignited several wooden and cardboard
crates. There was no fire watch.
 Austin, Texas: Workmen were using an acetylene torch to remove old heating
ducts in a utility shaft between the 20th and 21st stories of the tower of a 27-story
building. Flying sparks fell through a vent and ignited papers stacked against the
vent in a storage room on the 20th floor. The fire burned 20 to 30 minutes before
being discovered. Damage extended to four stories.
Source: NFPA 51B — Fire Prevention in Use of Cutting and Welding Processes, 1989.

Factsheet 4: What’s a Fire Watcher?
A fire watcher is someone who. . . umm. . . well. . . er. . .
watches!
He or she continuously monitors the hot work area for fires
that may be caused by flying sparks and any changes in the
surrounding conditions that may make the hot work unsafe.
This is not a job to be given to an operator or mechanic who
already has another job to do.
A fire watcher is well-trained.
Fire watchers must be trained in using fire-extinguishing equipment, including “hands
on” practice with training fires. They must also be trained in the facility’s emergency
procedures (i.e., sounding an alarm, evacuation routes, etc.) as outlined in the work
places’ written Emergency Response Plan.
A fire watcher knows what to do and when to do it.
If a fire occurs, the fire watcher must warn the hot work crew and sound the plant
alarm. The fire watcher may try to extinguish a fire only when it is obviously within
the capacity of the fire extinguishing equipment available and only if the fire watcher
has been properly trained.
A fire watch must cover all areas where sparks might travel.
If there are floor or wall openings, open ductwork, gratings, open doors or windows or
any other way a spark may travel to another room or level, more personnel need to be
assigned as fire watchers.
It’s not over even when it’s over.
A trained fire watch attendant (more than one if necessary) must be on duty at the hot
work site until at least 30 minutes after the hot work is completed.
Source: OSHA 1910.252 (a)(III)(4)(8).

Factsheet 5: Hot Work Permits: No Guarantee
of Safety
A hot work permit is only as good as the information included on it and the skills of the
person issuing it. Always consider the following:
 Explosive atmospheres
Hot work obviously can’t be done near explosive atmospheres. The area should
be checked with a combustible gas analyzer at different levels. Continuous
monitoring should be standard practice to assure the air remains clear.
 Fire protection equipment
Inspect all fire equipment and do not allow hot work in sprinklered buildings if
that protection is impaired.
 Safe condition of surrounding areas
If something is going on near a hot work area that could create a hazardous
condition, those operations must be made safe until the hot work is finished. If
there are floor openings, gratings, wall openings or open ductwork or conveyors
that could allow sparks from the hot work to be carried into another area, they
must be covered or blocked.
 Notification of all persons involved
Operators on nearby units, supervisors, maintenance or other workers nearby and
contractors must be aware of the hot work going on and of the related hazards.
Posting a notice or sign is also recommended.
A hot work permit must include the date and time the work is authorized and
identify the equipment to be worked on. The permit must be kept on file until
the hot work operation is completed.
If the nature of the job changes (e.g., another craft becomes involved, new
equipment is used or conditions surrounding the job change) a new hot work
permit should be issued.
Sources: OSHA 1910.119; and NFPA 51B — “Fire Prevention in Use of Cutting and Welding Processes,” 1989.

Factsheet 6: Combustible Gas Analyzers
Most workplaces use combustible gas analyzers, often small hand-held units, to tell if
an area is clear of flammable gases or vapors. These analyzers test the air and give a
reading expressed in percent of lower explosion limit (LEL).
Percent Lower Explosion Limit (LEL)
Flammable gas will ignite only when the mixture of gas and air is in the right ratio.
Too little gas and the mixture is too lean to burn; too much gas and the mixture is too
rich.
What concentration is safe?
OSHA is unfortunately silent on this issue under PSM. But in the Confined Space
Standard they specify a maximum percent LEL of 10 percent for work inside a con
fined space. Employers can establish levels more protective than 10 percent, such as
0–3 percent.
How often is enough?
Most workplaces only sample when the permit is issued; yet the best protection is
offered by continuous monitoring. This can be done by area monitors with noticeable
alarms or by equipping fire watchers (after proper training) with analyzers during the
hot work.
Monitoring results are only as good as the equipment being used and the training
and experience of those using it. So be sure that:
 Only experienced, trained workers use combustible gas monitors. These
workers should fully understand the monitor’s limitations. Be sure to test
at different levels in the work area.
 The analyzer is intrinsically safe (explosion-proof).
 Units are calibrated on a regular basis and that calibration is checked daily.
Sources: OSHA 1910.146; and National Safety Council, Accident Prevention Manual for Business and Industry,
10th Edition, Itasca, IL: The National Safety Council, 1992.

Task 1 (continued)
Art and Ray were sent to the Tank Farm to replace bearings on an isopropenyl pump
located on the alcohol pad. They found the bearings “frozen” in place.
When Art told his supervisor they would have to pull the pump, he said, “Let’s see
if we can’t pull those bearings in place; we’ve got too much downtime in that area
already.”
First they tried to loosen the bearings with a bearing heater, a powerful electric heat
gun, but without success. Ray then called a welder who heated the casing with her
torch until the bearings came free. While the welder was there, the supervisor had
her weld brackets on an I-beam.
A piece of slag from the welding rolled into a nearby pile of damp wooden shims.
After the mechanics and the welder left the area, the wood began to smolder and then
burst into flames. At the same time, an operator began to charge ethanol to his unit
by remote computer control. The ethanol transfer pump started to leak around its
mechanical seal, creating a pool of alcohol on the pad. The vapors from the pool
traveled towards the fire, which then ignited them.
The fire spread instantly to the pump and grew in intensity as the heat increased the
size of the leak. The tank farm operator saw the fire, sounded the alarm and attacked
the fire with an extinguisher. She was overcome by vapors and fell unconscious.
Quick response by the in-plant emergency response team saved her life and stopped
a potentially disastrous fire.

Task:
Your group is the OilChem Joint Safety Committee. Discuss the incident, and
based upon your experience and the factsheets you just reviewed, answer the
questions below.
1. Make a list of what you think could have been done to prevent this fire.
Explain why.
2. Are there any changes or improvements that should be made to the Hot Work
Program in your workplace?
Please list and explain.

Notes

Task 2: Mechanical Integrity (j)
of the PSM Standard
Purposes:
To become familiar with the OSHA performance-based requirements for a workplace
“mechanical integrity” program.
To examine the causes and solutions of “breakdown” maintenance.

Task 2
Scenario:
During the night shift on unit “A” at Chem Co., the process operator, Debbie, noticed a
severe vibration on E-101 “G” air-cooled exchanger. She radioed the control room and
asked the Board Operator, Jim, to write a work order to get the bearings replaced. Jim
filled out the work order and gave it to his Foreman, Bob.
Bob made a notation in the unit log book that the bearings were bad and forwarded the
work order to the unit supervisor for approval. Bob and his crew were finishing up
their night rotation and were starting their days off.
When Ernest, the Unit Supervisor, arrived on the day shift, he assigned it a priority “2”
(complete within a week) because it was cool outside and he knew they could run with
out it. Besides, the maintenance crew was already busy repairing the centrifuge which
was a priority “1” (overtime authorized).
Use the Factsheet

Reading Method for
Task 2, Factsheets
7 through 12.

Factsheet 7: The Goal or Desired Results of the
Mechanical Integrity (MI) Element of OSHA’s
PSM Standard
The goal is to prevent accidents through the proper maintenance of equipment.
Common sense and experience are the tools that we use when determining whether
or not an MI system is fulfilling the intent of the PSM Standard.
OSHA’s Elements for an MI Program
According to OSHA, the necessary elements of a good mechanical integrity (MI)
program are:
 Establish and implement written procedures to maintain the integrity of process
equipment.
 Train workers and contractors involved in maintaining the integrity of
equipment.
 Perform periodic inspection and testing following “generally accepted good

engineering practices” and document that inspections have been done.
 Correct equipment deficiencies before further use or in a safe and timely manner.
 Develop a Quality Assurance Program to ensure that:
o Equipment for new workplaces is suitable for use in the process and is
properly installed; and
o All maintenance materials, spare parts and equipment are suitable for
intended use.

Factsheet 8: Why Preventive Maintenance?
It’ s the Law!
OSHA: The recent OSHA law is fully enforceable and violators are subject to fines
and jail time.
EPA: The Environmental Protection Agency has proposed rules to cover preventive
maintenance programs within its Risk Management Plan proposal.
If You Don’t, It Costs $$$.
A good example of the cost was noted in testimony before Congress:
“A 1978 fire and explosion at a Texas City, Texas, facility that led to almost
$100 million in property damage was attributed to instrument failure and a faulty
relief valve.”
If You Do, It Pays.
According to some corporate managers, there are some very positive benefits from
Process Safety Management:
“Process Safety Management is intended to help you recognize, understand and
control all your process hazards. If you do that, you’re going to understand and
control your business; it runs better. . . it’s more efficient and your quality’s
higher.”

Factsheet 9: Maintenance Myths Most Often Heard
Here are some commonly used excuses for not following safe mechanical integrity
practices and examples of the consequences of not doing so.
 It’s only temporary.
A leak developed on one of the six in-line reactors. All six were connected
with 28-inch diameter pipes and expansion bellows. The leaking reactor was
removed and replaced with a 20-inch pipe with two elbows and the expansion
bellows were left intact.
The pipe was not supported properly; it was resting on scaffolding. Because of
the bellows, it was free to rotate or “squirm;” and in the process it failed, killing
28 people and destroying the plant.
 It’s ready to go.
A pump was being removed for repair. When the case bolts were being removed,
benzene started spraying and an explosion followed, killing one new worker and
burning others. There were no blinds installed; they were relying on block valves
to hold.
 It’s factory set; no need to test it.
In an automatic fire fighting system, a small explosive charge cut a rupture disc
and released the firefighting agent, Halon. The manufacturer said it was not
necessary to test. To test would require the loss of the Halon, which was very
expensive.
The buyer insisted on the test even with the added expense. The smoke detectors
worked; but when the explosive charge was activated, the rupture disc was not
activated. The manufacturer was in error.
continued

Factsheet 9: Maintenance Myths Most Often
Heard (continued)
Go ahead and use this one; it’ll work.
 A carbon steel valve was painted with aluminum paint instead of using a
stainless steel valve. It corroded rapidly.
 Checks carried out on the materials delivered for a new ammonia plant showed
that 5,480 items (1.8 percent of the total) were delivered in the wrong material.
 The wrong electrodes had been used for 72 welds on the tubes of a fired heater.
I don’t need an operator, I’m just going to look.

A maintenance foreman was asked to look at a faulty cooling water pump. He decided
that, to prevent damage to the machine, it was essential to reduce its speed immediately.
He did so, but did not tell any of the operators. The cooling water rate fell; the process
was upset; and a leak developed on a cooler.
Sources: Accident at Amoco Chemicals related by Glenn Erwin, Health and Safety Coordinator, PACE (now
USW); and Kletz, Trevor A., What Went Wrong? Case Histories of Process Plant Disasters, Houston: Gulf
Coast Publishing Company, Second Edition, November 1989.

Factsheet 10: Work Order Backlog: #1 Warning
Sign
Most workplaces have, in writing, very good Preventive Maintenance (PM) plans on
equipment. But in reality, as the work orders pile up, they are unable to keep their PMs
caught up.
According to a spot survey of a typical chemical plant employing approximately 100
maintenance workers, there was a backlog of 1,045 work orders.
To make matters worse, preventive maintenance work orders are usually treated as
having a lower priority than most work orders. The problem is compounded by the
fact that most employers do not employ enough maintenance workers to stay on top
of the regular work orders, much less the PMs.
A huge backlog of work orders is a sign that the MI program is not doing what it
is intended to and it may be considered a violation of the performance-based PSM
Standard.

Factsheet 11: If It Ain’t Broke . . .
Many organizations consciously decide to Run To Failure (RTF). RTF is rarely less
costly than preventing failure. An organization that manages using RTF twists the
old cliché, “If it ain’t broke, don’t fix it.” Unfortunately, this approach can lead to
catastrophe.
“An ounce of prevention is worth a pound of cure” is a better maxim.
 A ten-dollar seal may wind up costing thousands of dollars, not to mention death
and injury.
 The normal rule of thumb is that corrective (breakdown) costs are four to five
times more expensive than preventive costs.
Source: “Total Productive Maintenance,” Marshall Institute, Inc. (2900 Yonkers Road, Raleigh, NC).

Factsheet 12: Understaffing Leads to Problems:
A Case Study
During testimony on the PSM Standard, one PACE (now USW) member described
some of the effects that the reduction of maintenance workers had at his plant.
Maintenance staff cut in half:
“The staffing of the Mobil Beaumont refinery has steadily decreased in the past
ten years. The Beaumont refinery had over 2,000 hourly employees, of which
1,200 were permanent maintenance employees, when I went to work there
20 years ago. We now have less than 600 maintenance workers.
The effects don’t hit you overnight:
“Maintenance workforce reductions are not something that hit you overnight.
The effects are gradual. But as time marches on, the reductions become more
and more obvious.”
“Running maintenance today in both quality and quantity is much worse than
10–15 years ago. Pumps and compressors are not maintained, cannot be
properly maintained, when the people are not there to do the work.”
The potential for disaster is present:
“Leaks of all sorts (oil, chemicals, etc., which include toluene, ketone, etc.),
are not addressed in a timely manner. The limited amount of maintenance
people are kept busy doing work necessary to maintain production; and the
less important problems, in the company’s judgment, are left unattended.”
Source: Testimony given before OSHA from PACE (now USW) member Jimmy Herrington, Local 4-243,
February 24, 1991. [Emphasis added.]

Task 2 (continued)
During the night shift on unit “A” at Chem Co., the process operator, Debbie, noticed a
severe vibration on E-101 “G” air-cooled exchanger. She radioed the control room and
asked the Board Operator, Jim, to write a work order to get the bearings replaced.
Jim filled out the work order and gave it to his Foreman, Bob.
Bob made a notation in the unit log book that the bearings were bad and forwarded the
work order to the unit supervisor for approval. Bob and his crew were finishing up
their night rotation and were starting their days off.
When Ernest, the Unit Supervisor, arrived on the day shift, he assigned it a priority
“2” (complete within a week) because it was cool outside and he knew they could run
without it. Besides, the maintenance crew was already busy repairing the centrifuge
which was a priority “1” (overtime authorized).
At 3:00 a.m. on the following day, the bearing failed on E-101 “G,” causing such a
vibration that a pressure gauge leaked, causing a fire.
During the investigation that followed, it was found that the vibration switch had failed to
trip the fan off the line. It had been wired wrong, probably since the time of installation.

Task:
List some ways this fire could have been prevented.
Summary: Activity 6: Elements k and j of the

PSM Standard
Hot Work (k)
1. A permit must be issued before the hot work (any job that can cause a fire) begins.
2. The worker performing the hot work cannot do his job and watch the area too. At
least one well-trained fire watcher should be posted in each hot work area.
3. Hot work areas should always be monitored for flammable gases before hot work is
performed. But the highest level of protection is given by continuously monitoring
the hot work area.
4. Any time you do hot work in a process area, you take a risk. Remove the job to a
safe site whenever possible.
Mechanical Integrity (j)
5. Preventive Maintenance Programs should be established, funded and staffed to
sufficient levels to avoid the need for “breakdown” maintenance.
6. All maintenance work must be done by trained craftsmen using proper equipment,
installation procedures, safety devices and according to applicable codes and
standards.
7. The consequences of not having a good Mechanical Integrity Program can be
devastating to us and our fellow workers.
8. Having a comprehensive written Mechanical Integrity Program which is not
followed is the equivalent of having no program at all.

Activity 6: Elements k and j of the PSM Standard
25. To understand hot work and identify the elements of a good program. How much do you
O O O O O
26. To become familiar with the OSHA performance-based requirements for a workplace
“mechanical integrity” program. How much do you agree or disagree that the training
met this learning objective?
O O O O O
27. To examine the causes and solutions of “breakdown” maintenance. How much do you
O O O O O
28. A permit must be issued before the hot work (any job that can cause a fire) begins.
How much do you agree or disagree with the following statement? Understanding and
applying this learning objective will assist me in improving health and safety at my
workplace.
O O O O O
29. All maintenance work must be done by trained craftsmen using proper equipment,
installation procedures, safety devices and according to applicable codes and
standards. How much do you agree or disagree with the following statement? Under-
standing and applying this learning objective will assist me in improving health and
safety at my workplace.
O O O O O

Class Name _______________________
Date _____________________________
Location __________________________
End of Class Evaluation Form

1. Overall, how would you rate this training session? (Check one)
 Excellent  Good  Fair  Poor
What about the training led you to rate it this way?
2. Thinking about the materials used in the training, how would you rate them
for being easy to understand? (Check one)
 Excellent  Good  Fair  Poor
What about the materials led you to rate them this way?
3. To what degree will you be able to apply what you learned in this training to
your work? (Check one)
 Will apply a lot  Will apply somewhat Will not apply
What about the training led you to rate it this way?
4. What would make this training more effective?
5. Additional Comments:
End of Class Evaluation Form 215

Tony Mazzocchi Center
Final Proficiency Assessment
Industrial Process Safety Management Training

Trainee Name _____________________________________________________
Print
Trainee’s ID No. ___ ___ ___ ___ - ___ ___ ___ ___ (The two-digit month and two-digit
day of trainee’s birth date and the last four numbers of the trainee’s social security number.
(For example, someone born September 22nd and whose last four digits of their social security
number are 1234 would enter 0922-1234.)
Trainer Name _____________________________________________

Print
By initialing below, I (the trainee), have assessed that I have successfully achieved the minimum levels of
knowledge and skills communicated in activities in which I have participated.
Activity Trainee’s Initials
Activity 1: An Introduction to the Process Safety Management Standard (PSM)

and Systems of Safety
Activity 2: Tasks 1 and 2, Incident Investigation (m)

Task 3, Employee Participation (c)
Task 4, Process Hazard Analysis (e)
Activity 3: Task 1, Emergency Response (n)

Task 2, Pre-startup Safety Review (i)
Task 3, Compliance Audits (o)
Activity 4: Task 1, Management of Change (l)

Task 2, Process Safety Information (d)
Task 3, Training (g)
Activity 5: Task 1, Contractors (h)

Task 2, Trade Secrets (p)
Activity 6: Task 1, Hot Work (k)

Task 2, Mechanical Integrity (j)
Number of Course Hours completed _____________________
Please turn page over to finish completing this form.
Final Proficiency Assessment 217

To be completed by the Trainee:
1. I, the trainee, agree that I have successfully completed the Industrial Process
Safety Management Training.
Trainee signature __________________________ Date: _________
2. I, the trainee, agree that the trainers have effectively facilitated the Industrial
Process Safety Management Training.
Trainee signature _________________________ Date: _________
To be completed by the Trainer:
3. I, a member of the team of trainers, confirm that this trainee has successfully
completed _____ hours of the Industrial Process Safety Management Training.
Trainer signature ___________________________ Date: __________
4. I, a member of the team of trainers, agree that our team has successfully facilitated
the Industrial Process Safety Management Training.
Trainer signature ___________________________ Date: _________

Appendices:
USW Policy on Sexual Harassment: A-2
Worker-Centered Training A-3
Tony Mazzocchi Center Green Policy Statement A-4
Attendance Form A-5
Sign-in Sheet A-7
Appendices A-1
USW POLICY
on
SEXUAL HARASSMENT
The Steelworkers want to effectively educate all our members about the harm done to everyone when sexual harassment is
tolerated in our workplaces. We also want to make sure we provide and maintain a harassment-free environment at all USW
workplaces and activities.
We have passed tough anti-harassment policies for all USW Conferences and Conventions, and we have negotiated policies
to protect our members. These are not just words. We take them seriously.
Cooperation, understanding and mutual respect must be the foundation of all interaction among trade unionists.
The USW will not tolerate and will not condone behavior by its employees, or by others doing business on our property,
such as vendors, if that behavior is likely to undermine the dignity or self-esteem of any individual, or if it creates a hostile
or offensive environment.
Sexual harassment is particularly demeaning and the following policy shall apply to allegations of such harassment.
SEXUAL HARASSMENT POLICY1
Sexual harassment is not a joke. It creates feelings of This policy is based upon a desire to mediate resolutions
uneasiness, humiliation and discomfort. It is an expression of complaints in an amicable and non-adversarial manner.
of perceived power and superiority by the harasser over Because, in most cases, the individuals involved are both
another person. There are two principles fundamental to members of our union, emphasis will be placed on resolving
complaints informally in the first instance. Where such
the trade union movement: human rights and solidarity. resolution is not possible, a formal complaint can be
Sexual harassment strikes at the heart of both. processed. A substantiated complaint will result in
Sexual harassment is illegal discrimination in both the United appropriate action, up to and including termination of
employment for USW employees. All complaints will be
States and Canada. It is commonly defined as: handled in a confidential manner and all formal complaints
(1) unwanted sexual attention of a persistent or abusive should be directed to the International President.
nature, made by a person who knows or ought reasonably
In addition to the contractual complaint and grievance
to know that such attention is unwanted; or provisions governing USW employees, the International
(2) implied or expressed promise of reward for complying has established a Committee on Sexual Harassment
with a sexually oriented request; or composed of representatives from the International, exempt
employees, SRU, USW Local 3657 and OPEIU Local 343.
(3) implied or expressed threat or reprisal, in the form This Committee will be responsible for developing an
either of actual reprisal or the denial of opportunity, for educational program on sexual harassment for all USW
refusal to comply with a sexually oriented request; employees and for recommending procedures for responding
to informal complaints under this policy.
(4) sexually oriented remarks and behavior which may
reasonably be perceived to create a negative, intimidating, The Committee will also provide for the investigation of any
hostile or offensive environment. complaints referred to it by the International President.
Unwanted sexually directed behavior can include:

Adopted this 17th day of June, 1992,by the USWA International Executive
 assault Board.
 physical abuse (touching, pinching, cornering) ¹This policy covers USW International employees in the United States and
 verbal abuse (propositions, lewd comments, Canada. It does not apply to USW members generally since they are covered
by policies established by their employers. However, USW members can
sexual insults)
request investigation of a claim of sexual harassment by a USW employee under
 visual abuse (display of pornographic material this policy. The policy also does not cover Local Union officers and Local Union
designed to embarrass or intimidate). employees. However, Local Unions are encouraged to adopt similar policies.
The policy does apply to the conduct of others doing business on USW property,
Some forms of harassment may not violate the law. such as vendors.
For example, harassment allegations concerning an ²This includes complaints about conduct by Local Union officers or members
International employee and a Local Union member would against other members where that conduct takes place at International USW
normally not affect the member's employment or working Junctions. In such cases, the Local Union will be notified of the results of the
environment. But such harassment does violate the basic investigation so that appropriate action can be taken by the Local Union.
principles of the union. The USW considers sexual
harassment of any kind a serious offense. Complaints of
harassment in the workplace and at USW activities will be United Steelworkers
Five Gateway Center
investigated.²
Pittsburgh, PA 15222
A-2 Industrial PSM Training

Worker-Centered Training
USW International Union, with its long Part of the task often includes
history of environmental safety and looking at factsheets and reading
health activism, believes that workers short handouts.
are really the best resource for making 2. Report-Back: For each task, the
our facilities safe and for protecting the group selects a scribe whose job it
community from harm. To put that is to take notes on the small group
belief into practice: discussion and report back to the
 The training is designed to be workshop as a whole. During the
conducted by USW rank and report-back, the scribe informs the
file worker-trainers. entire workshop about how his or
 Workers are the center of the her group tackled the particular
learning process. problem. The trainer records these
reports on large pads of paper in
 Experience and knowledge front of the workshop so that all can
of the workers in class is refer to it. After the scribe’s report,
considered one of the most the workshop is opened to general
important resources for discussion about the problem at
education in the class. hand.
Trainers, acting as facilitators and 3. Summary: Here the trainer
using the current workbook as a highlights the key points and brings
resource and guide, lead the class up any problems and points that
through activities which refresh may have been overlooked in the
and reinforce topics dictated by report-back. Good summaries tend
the regulations. to be short and to the point.
Worker-Centered Training is based Worker-centered training is based on
on Activities. An Activity can take the idea that every workshop is a place
from 30 minutes to an hour. Each where learning is shared. Learning is
Activity has a common basic structure: not a one-way street, running from
1. Small Group Tasks: The trainer to worker. Rather, worker-
workshop always operates with centered training is a structured
people working in groups at tables. procedure that allows us to share
(Round tables are preferable.) Each information. It is based on three
Activity has a task, or set of tasks, learning exchanges:
for the groups to work on. The idea  Worker to worker;
is to work together, not to compete.
 Worker to trainer; and
Very often there is no one right
answer. The tasks require that the  Trainer to worker.
groups use their experience to
tackle problems and to make
judgments on key issues.
Appendices A-3
Tony Mazzocchi Center Green Policy Statement
The environmental and health and safety movements were born together during
the 1960s. The very first health and safety training programs in the country were
called “Hazards in the Workplace Environment.” The TMC believes that the only
difference between worker health and safety and the environment is the facility
fence. Therefore, it is the policy of the TMC to integrate environmental concerns
in all of our programs and in the ways in which we carry out our training.
The TMC strives to:
 Connect environmental and health and safety issues as much as possible in
our training;
 Look for workplace solutions that improve the environment outside of our
facilities;
 Work extensively to reduce the use of hazardous substances;
 Encourage our employers to reduce energy use and reduce the emission of
greenhouse gases that cause global warming;
 Use recycled paper (at least 50 percent post-consumer content) when
producing our training materials;
 Encourage workbook reuse and recycling;
 Promote the use of (union-made) non-chlorine paper products and
environment-friendly toners and inks; and
 Conserve paper by reducing the length of our texts.

Attendance Form
Please print clearly
Name: ________________________________ Home Number: ________________
Cell Phone #: _________________
Address: _____________________________ Work Number: _________________
_____________________________ Email: ________________________
_____________________________ Union/Mgt. ____________________
Employer: ____________________________ District # ____ Local # _________
Workplace Location: _____________________________________________________
Name of Class: _______________________________ Completion Date: __________
Instructors: _____________________________________________________________
Would you like to be contacted at a later date to participate in an evaluation of this

training’s effectiveness? (Circle one)
Yes No
Would you like to participate in additional trainings and programs offered by the
Union and the TMC? (Circle one)
Yes No
Your Signature: _________________________________________________________
Appendices A-5
SIGN-IN SHEET (PLEASE PRINT CLEARLY)
Class Title: ____________________________ Completion Date: ___________
Location (City, State)/Facility: _________________________________________
Grant Program: _____________________ Dist. & LU#: ___________________
Instructors: 1) __________________________ 2) _________________________
3) ______________________ 4) ___________________ 5) __________________
Name (print first and last) Hourly Management
10
11
12
13
14
Appendices A-7

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Industrial Process Safety

Tony Mazzocchi Center

Written and produced by the Tony Mazzocchi Center for

Health, Safety and Environmental Education, a project of the

United Steelworkers - USW, the Communications Workers of America

and The Labor Institute

© 2014 Tony Mazzocchi Center

ii Industrial PSM Training

Tony Mazzocchi is credited by many

are specific to the workplace being trained.

Factsheet Reading Method vi

Activity 1: An Introduction to the Process Safety Management

Standard (PSM) and Systems of Safety (3 Tasks) 1

Activity 2: Elements m, c and e of the PSM Standard 35

Tasks 1 and 2: Incident Investigation (m) 36

Task 3: Employee Participation (c) 57

Task 4: Process Hazard Analysis (e) 69

Activity 3: Elements n, i and o of the PSM Standard 83

Task 1: Emergency Response (n) 84

Task 2: Pre-startup Safety Review (i) 95

Task 3: Compliance Audits (o) 103

Activity 4: Elements l, d, f, and g of the PSM Standard 121

Task 1: Management of Change (l) 122

Task 2: Process Safety Information (d)

Operating Procedures (f) 135

Task 3: Training (g) 147

Activity 5: Elements h and p of the PSM Standard 161

Task 1: Contractors (h) 162

Task 2: Trade Secrets (p) 173

Activity 6: Elements k and j of the PSM Standard 189

Task 1: Hot Work (k) 190

Task 2: Mechanical Integrity (j) 201

USW Policy on Sexual Harassment A-2

Tony Mazzocchi Center Worker-Trainers and

Worker-Centered Training A-3

Tony Mazzocchi Green Policy Statement A-4

Attendance Form A-5

Sign-in Sheet A-7

vi Industrial PSM Training

Workbook Title: Industrial Process Safety Management Training

Workbook Version: Edition 2.0, January 2014

To introduce the concepts of Systems of Safety.

This Activity has three tasks.

Activity 1: An Introduction to the PSM Standard and Systems of Safety 1

Use the Factsheet Reading

The Factsheet Reading Method

2 Industrial PSM Training

Activity 1: An Introduction to the PSM Standard and Systems of Safety 3

1989 Phillips Chemical Plant explosion kills 23, injures 232.

1990 American Petroleum Institute (API) publishes Management of Process Hazards

1992 The final OSHA PSM Standard is issued.

4 Industrial PSM Training

Source: “Process Safety Management (PSM), Managing Risk in Process Facilities,”

Activity 1: An Introduction to the PSM Standard and Systems of Safety 5

6 Industrial PSM Training

Source: “Process Safety Management (PSM), Managing Risk in Process Facilities,”

Activity 1: An Introduction to the PSM Standard and Systems of Safety 7

8 Industrial PSM Training

Activity 1: An Introduction to the PSM Standard and Systems of Safety 9

1 (c) Employee Participation

2 (d) Process Safety Information

3 (e) Process Hazard Analysis

4 (f) Safe Operating Procedures