What Process Safety Management is

OSHA's Process Safety Management of Highly Hazardous Chemicals standard, 29 CFR 1910.119, requires employers to manage the hazards of processes that involve listed toxic or reactive chemicals or large quantities of flammable liquids and gases. It was issued in 1992 after a series of catastrophic accidents, and it remains the backbone of process safety regulation in the United States.

PSM is a performance-oriented standard. It tells employers what their programs must achieve — accurate process information, systematic hazard analysis, sound procedures, trained people, maintained equipment, controlled change — but leaves much of the "how" to the employer and to recognized and generally accepted good engineering practices (RAGAGEP). That flexibility is a strength, and also why programs vary so widely in effectiveness.

When PSM applies

In broad terms, a process is covered when it involves:

A chemical listed in Appendix A of the standard at or above its threshold quantity (for example, anhydrous ammonia or chlorine); or
10,000 pounds or more of a flammable liquid or gas on site in one location, subject to specific exceptions.

The standard also defines exemptions — including retail facilities, oil and gas well drilling or servicing, and normally unoccupied remote facilities — and exceptions for certain fuels and atmospheric storage. Applicability turns on precise definitions such as "process" and "one location," so it deserves a careful, documented determination. Our article Does OSHA PSM apply to your facility? walks through the tests.

Note

This summary is general information, not a regulatory determination. Applicability should be evaluated against the current text of 29 CFR 1910.119, OSHA interpretations and the specifics of your facility.

The 14 elements of PSM

Select an element to see what it requires and the gaps we most often find. Paragraph references are to 29 CFR 1910.119.

PSM element explorer

Select an element

29 CFR 1910.119(c)

Employee participation

What it requires: A written plan of action for consulting employees and their representatives on conducting and developing PHAs and other elements, and access to PHAs and other PSM information.
Gaps we commonly find: Participation limited to signatures on attendance sheets; operators not genuinely involved in PHAs or MOC reviews.

29 CFR 1910.119(d)

Process safety information

What it requires: Written information on chemical hazards, process technology and equipment — including P&IDs, relief system design and design basis, materials of construction, safety systems and the codes used — compiled before the PHA.
Gaps we commonly find: Out-of-date P&IDs; missing relief design basis; no documentation that equipment complies with RAGAGEP.

29 CFR 1910.119(e)

Process hazard analysis

What it requires: An initial PHA using an appropriate methodology, addressing hazards, previous incidents, controls, consequences of control failure, facility siting and human factors; revalidated at least every five years.
Gaps we commonly find: Revalidations that do not test the prior study; recommendations not resolved promptly or documented.

29 CFR 1910.119(f)

Operating procedures

What it requires: Written procedures for each operating phase (startup, normal, temporary, emergency shutdown, emergency operations, normal shutdown, startup after turnaround), operating limits, safety and health considerations; certified annually as current.
Gaps we commonly find: Procedures that do not match field practice; consequences of deviation and steps to avoid them missing.

29 CFR 1910.119(g)

Training

What it requires: Initial training in the process and procedures, refresher training at least every three years, and documentation that each employee understood the training.
Gaps we commonly find: Training records without evidence of understanding; refresher content not updated after changes.

29 CFR 1910.119(h)

Contractors

What it requires: Evaluation of contractor safety performance, informing contractors of hazards, controlling entry, and contractor obligations to train their employees.
Gaps we commonly find: Contractor evaluation limited to pre-qualification; no periodic evaluation of performance on site.

29 CFR 1910.119(i)

Pre-startup safety review

What it requires: A PSSR for new facilities and for modified facilities when the change is significant enough to require a change in process safety information, confirming construction, procedures, training and PHA/MOC requirements before hazardous chemicals are introduced.
Gaps we commonly find: PSSRs signed off with open items that affect safety; scope inconsistently applied to MOCs.

29 CFR 1910.119(j)

Mechanical integrity

What it requires: Written procedures, training, inspection and testing per RAGAGEP, and correction of deficiencies for pressure vessels and storage tanks, piping, relief and vent systems, emergency shutdown systems, controls and pumps.
Gaps we commonly find: Incomplete equipment lists; inspection intervals not justified; deficiencies operated past without assessment.

29 CFR 1910.119(k)

Hot work permit

What it requires: Permits for hot work on or near covered processes, documenting that fire prevention and protection requirements of 29 CFR 1910.252(a) are implemented.
Gaps we commonly find: Gas testing and fire watch requirements unclear; permits not closed out.

29 CFR 1910.119(l)

Management of change

What it requires: Written procedures to manage changes (except replacement in kind) to chemicals, technology, equipment, procedures and facilities that affect a covered process.
Gaps we commonly find: Organizational and temporary changes not captured; "replacement in kind" interpreted too broadly.

29 CFR 1910.119(m)

Incident investigation

What it requires: Investigation of each incident that resulted in, or could reasonably have resulted in, a catastrophic release, initiated within 48 hours, with findings resolved and reports retained for five years.
Gaps we commonly find: Near misses not reported or investigated; root causes stop at "operator error."

29 CFR 1910.119(n)

Emergency planning & response

What it requires: An emergency action plan for the entire plant meeting 29 CFR 1910.38, including procedures for handling small releases.
Gaps we commonly find: Plans not coordinated with local responders; drills do not exercise realistic scenarios.

29 CFR 1910.119(o)

Compliance audits

What it requires: Certification at least every three years that the employer has evaluated compliance, by at least one person knowledgeable in the process, with deficiencies promptly addressed; the two most recent reports retained.
Gaps we commonly find: Audit findings carried over from audit to audit; auditors not independent of the program.

29 CFR 1910.119(p)

Trade secrets

What it requires: Information needed to comply with PSM must be made available to those who need it, regardless of trade secret status, subject to appropriate confidentiality agreements.
Gaps we commonly find: Process information withheld from PHA teams or maintenance staff.

How we help

Program development

Written programs, procedures and forms for new or newly covered processes, scaled to your organization and integrated with existing management systems.

Gap assessments

An element-by-element review of documentation and field implementation, with prioritized findings and a practical improvement roadmap.

Element support

PHA facilitation, PSI development, MOC and PSSR support, mechanical integrity planning, procedure writing and training.

Program effectiveness

Process safety metrics, management review, and alignment with CCPS Risk Based Process Safety to move beyond minimum compliance.

Signs your program needs attention

Audit findings repeat from one cycle to the next.
PHA recommendations remain open well beyond their target dates.
P&IDs and procedures lag behind field changes.
Near misses are rarely reported, or always attributed to individuals.
Knowledge of the program rests with one or two people.
You have acquired a facility, added a process, or crossed a threshold quantity.

Typical deliverables

Documented PSM applicability determination
Gap assessment report with risk-prioritized action plan
Written program and element procedures
PSI packages and P&ID verification support
Templates for MOC, PSSR, hot work and incident investigation
Process safety performance indicators and dashboards

Frequently asked questions

What is the relationship between OSHA PSM and EPA RMP?

They overlap substantially. EPA's Program 3 prevention program closely mirrors PSM, but RMP adds off-site consequence analysis, a five-year accident history, an emergency response program and registration of a Risk Management Plan with EPA. Many facilities are subject to both.

Does PSM apply to ammonia refrigeration?

Anhydrous ammonia is listed in Appendix A with a threshold quantity of 10,000 pounds. Many refrigeration systems in food processing and cold storage exceed it and are covered by both PSM and RMP.

What does RAGAGEP mean?

Recognized and generally accepted good engineering practices — the codes, standards and published practices (for example, from API, ASME, NFPA, ISA or IIAR) that PSM relies on for design, inspection and testing.

Is Risk Based Process Safety a regulation?

No. CCPS's Risk Based Process Safety framework is voluntary guidance. Many companies use it to structure programs that go beyond the regulatory minimum.

Process Safety Management (PSM)