Process Safety Management Audit

Use this Process Safety Management Audit checklist to evaluate compliance with OSHA PSM Standard, applicable to industries with highly hazardous chemicals.

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Process Safety Management Audit

Employee Participation â€“ 1910.119(c)(1)

Employee Participation â€“ 1910.119(c)(2)

Employee Participation â€“ 1910.119(c)(3)

Hazard Information Collection â€“ 1910.119(d)(1)

Technology Of The Process Information Collection â€“ 1910.119(d)(2)(i)(A)

Technology Of The Process Information Collection â€“ 1910.119(d)(2)(i)(B-D)

Technology Of The Process Information Collection â€“ 1910.119(d)(2)(i)(E)

Equipment Of The Process Information Collection â€“ 1910.119(d)(3)(i)(A-H)

Process Hazard Analysis â€“ 1910.119(e)(1)

Process Hazard Analysis â€“ 1910.119(e)(2)(i-vii)

Process Hazard Analysis â€“ 1910.119(e)(3)(i-vii)

Process Hazard Analysis â€“ 1910.119(e)(4)

Process Hazard Analysis â€“ 1910.119(e)(5)

Process Hazard Analysis â€“ 1910.119(e)(6)

Process Hazard Analysis â€“ 1910.119(e)(7)

Operating Procedures â€“ 1910.119(f)(1)

Employee Training â€“ 1910.119(g)(1)

Employee Training â€“ 1910.119(g)(2)

Employee Training â€“ 1910.119(g)(3)

Contractor Management â€“ 1910.119(h)(2)(i)

Contractor Management â€“ 1910.119(h)(2)(ii)

Contractor Management â€“ 1910.119(h)(2)(iii)

Contractor Management â€“ 1910.119(h)(2)(iv)

Contractor Management â€“ 1910.119(h)(2)(v)

Contractor Management â€“ 1910.119(h)(2)(vi)

Contractor Management â€“ 1910.119(h)(3)(i-iv)

3. Has the contractor employer documented that each contractor employee has received and understood the required training, including the identity of the employee, date of training, and the means used to verify the contractor employee understood the training?

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Pre-Startup Safety Review â€“ 1910.119(i)

Mechanical Integrity Of Process Equipment â€“ 1910.119(j)(2)

Mechanical Integrity Of Process Equipment â€“ 1910.119(j)(3)

1. Does the employer have documentation of training that each employee involved in the maintaining of the ongoing integrity of covered process equipment has been informed of the hazards of the process and the procedures applicable to the employee’s job task and how to perform the job task in a safe manner?

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Mechanical Integrity Of Process Equipment â€“ 1910.119(j)(4)

1. Does the employer have documentation that the employer has performed inspections and tests on the covered process equipment following generally accepted engineering practices or manufacturer’s recommendations on a frequency that is according to generally accepted engineering practices, manufacturer’s recommendations or more frequently if determined by prior experience? The documentation should include the date, name of the person performing the inspection or test, description of the inspection or test, and results of the inspection or test.

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Mechanical Integrity Of Process Equipment â€“ 1910.119(j)(5)

Mechanical Integrity Of Process Equipment â€“ 1910.119(j)(6)

1. Has the employer assured that fabricated equipment is suitable for the process application (applicable codes), has been inspected and checked for proper installation consistent with design specification and manufacturer’s recommendations, and all maintenance materials and spare parts are also suitable for the process application?

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Hot Work â€“ 1910.119(k)

Management Of Change â€“ 1910.119(l)(1-2)

Management Of Change â€“ 1910.119(l)(3)

Management Of Change â€“ 1910.119(l)(4-5)

Incident Investigation â€“ 1910.119(m)(1)

Incident Investigation â€“ 1910.119(m)(2)

Incident Investigation â€“ 1910.119(m)(3)

Incident Investigation â€“ 1910.119(m)(4)

Incident Investigation â€“ 1910.119(m)(5)

Incident Investigation â€“ 1910.119(m)(6)

Incident Investigation â€“ 1910.119(m)(7)

Emergency Planning And Response â€“ 1910.119(n)

Compliance Audit â€“ 1910.119(o)(1-3)

Compliance Audit â€“ 1910.119(o)(4)

Compliance Audit â€“ 1910.119(o)(5)

Trade Secrets â€“ 1910.119(p)

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Process Safety Management Audit

Use this Process Safety Management Audit checklist to evaluate compliance with OSHA PSM Standard, applicable to industries with highly hazardous chemicals.

1. Has the employer developed a written plan of action for the implementation of employee participation?

1. Has the employer consulted with employees and their representatives on the conduct and development of process hazard analyses and on the development of all other elements of the PSM standard?

1. Do employees and their representatives have access to process hazard analyses and all other information required by the PSM standard?

1. Has the employer collected information pertaining to the toxicity hazards of the process?

2. Has the employer collected information on Permissible Exposure Limits (PELs) for the process?

3. Has the employer collected physical data related to the hazards of the process?

4. Has the employer collected information on the reactivity hazards of the process?

5. Has the employer collected information on the corrosivity hazards of the process?

6. Has the employer collected information on the thermal and chemical stability of the process?

7. Has the employer collected information on the hazards of mixing chemicals in the process?

8. Has the employer collected Material Safety Data Sheets (MSDSs) for the process?

1. Does the employer have block diagrams or simplified process flow diagrams for each covered process?

1. Does the employer have information on the process chemistry for the covered process, as required by 1910.119(d)(2)(i)(B)?

2. Does the employer have information on the maximum intended inventory for the covered process, as required by 1910.119(d)(2)(i)(C)?

3. Does the employer have information on the safe upper and lower limits for temperature, pressures, flows, levels, compositions, or other pertinent metrics for the covered process, as required by 1910.119(d)(2)(i)(D)?

1. Has the employer performed and documented an evaluation of the consequences of deviations in the covered process, including those affecting the health and safety of employees?

1. Does the employer have information on the materials of construction for the equipment of the covered process, as required by 1910.119(d)(3)(i)(A)?

2. Does the employer have piping and instrument diagrams (P&IDs) for the equipment of the covered process, as required by 1910.119(d)(3)(i)(B)?

3. Does the employer have information on the electrical classification for the equipment of the covered process, as required by 1910.119(d)(3)(i)(C)?

4. Does the employer have information on the relief system design and design basis for the equipment of the covered process, as required by 1910.119(d)(3)(i)(D)?

5. Does the employer have information on the ventilation system design for the equipment of the covered process, as required by 1910.119(d)(3)(i)(E)?

6. Does the employer have information on the design codes or standards used for the equipment of the covered process, as required by 1910.119(d)(3)(i)(F)?

7. Does the employer have information on the material and energy balances for processes related to the equipment of the covered process, as required by 1910.119(d)(3)(i)(G)?

8. Does the employer have information on the safety systems for the equipment of the covered process, as required by 1910.119(d)(3)(i)(H)?

9. Has the PSM documentation including all elements above been field verified and compared to the actual equipment and components in the covered process?

1. Has the employer performed an initial process hazard analysis on the covered processes?

1. Has the employer used the "What if" methodology to perform the process hazard analysis (PHA), as required by 1910.119(e)(2)(i)?

2. Has the employer used the checklist methodology to perform the process hazard analysis (PHA), as required by 1910.119(e)(2)(ii)?

3. Has the employer used the "What if/Checklist" combination methodology to perform the process hazard analysis (PHA), as required by 1910.119(e)(2)(iii)?

4. Has the employer used the Hazard and Operability Study (HAZOP) methodology to perform the process hazard analysis (PHA), as required by 1910.119(e)(2)(iv)?

5. Has the employer used the Failure Mode and Effects Analysis (FMEA) methodology to perform the process hazard analysis (PHA), as required by 1910.119(e)(2)(v)?

6. Has the employer used the fault tree analysis methodology to perform the process hazard analysis (PHA), as required by 1910.119(e)(2)(vi)?

7. Has the employer used an appropriate equivalent methodology to perform the process hazard analysis (PHA), as required by 1910.119(e)(2)(vii)?

1. Does the process hazard analysis (PHA) address the hazards of the process, as required by 1910.119(e)(3)(i)?

2. Does the PHA address the equipment in the process, as required by 1910.119(e)(3)(i)?

3. Does the PHA address the identification of previous incidents, as required by 1910.119(e)(3)(ii)?

4. Does the PHA address engineering and administrative controls, as required by 1910.119(e)(3)(iii)?

5. Does the PHA address the consequences of failure for engineering or administrative controls, including consequences of deviation and steps required to correct or avoid deviation, as required by 1910.119(e)(3)(iv)?

6. Does the PHA address facility siting, as required by 1910.119(e)(3)(v)?

7. Does the PHA address human factors, as required by 1910.119(e)(3)(vi)?

8. Does the PHA include a qualitative evaluation of the safety and health effects of failure on employees in the workplace, as required by 1910.119(e)(3)(vii)?

1. Was the process hazard analysis (PHA) performed by a team that had expertise in engineering and process operations?

2. Did the PHA team include at least one employee with experience and knowledge specific to the covered process?

3. Did the PHA team include at least one member who was knowledgeable in the specific evaluation methodology used to perform the PHA?

1. Does the employer have a system to promptly address PHA findings and recommendations?

2. Does the system address findings and recommendations in a timely manner?

3. Are the resolutions to PHA findings and recommendations documented?

4. Are the actions taken in response to PHA findings and recommendations documented?

5. Is there a written schedule for the completion of recommended actions?

6. Have the actions taken or scheduled for resolution of recommendations been communicated to employees, contractors, or other persons possibly impacted by the recommendations or actions?

1. Have PHAs been updated and revalidated at least every five years?

1. Has the employer retained all documentation for PHAs, updates, revalidations, recommendations, and resolutions of recommendations?

1. Has the employer developed and implemented written safe operating procedures for each covered process; addressing the steps for each operating phase, the operational limits, safety and health considerations, and safety systems and their function?

1. Has the employer trained each employee involved in operating a covered process before the employee is involved in operating the process?

2. Has a PSM (Process Safety Management) training program been developed for affected employees who are not directly involved in the process operation but have jobs at the facility with a covered process?

3. Has a PSM training program been developed for authorized employees who are directly involved in the process operation?

4. Has a PSM training program been developed for contractors who may perform work on a covered process?

5. Has a PSM training program been developed for vendors or visitors who may visit the facility and potentially be exposed to the covered process, with a focus on emergency evacuation procedures and PPE requirements (if necessary)?

6. Does the training program include Lock-out/Tag-out (LOTO) procedures and practices?

7. Does the training cover safety protocols for performing Hot Work (e.g., welding, cutting)?

8. Are the procedures for Line & Equipment Opening clearly defined and included in the training?

9. If applicable, does the training address the risks and safety measures associated with Confined Space Entry?

10. Is there training on Emergency Response procedures, including fire safety, evacuation, and spill response?

11. Does the training include instruction on Operating Procedures for equipment and processes?

12. Are the principles and processes of Management of Change (MOC) included in the training program?

1. Has refresher training been provided for employees involved in operating a covered process at least every three years or as needed?

1. Has the identity of each employee been recorded?

2. Has the date of training for each employee been documented?

3. Has the method used to verify employee understanding of the training (such as a test, interview, or other assessment) been documented?

1. When selecting a contractor, has the employer obtained and evaluated information regarding the contractor’s safety and health performance and programs?

1. Has the employer informed the contract employer of the known potential fire, explosion, or toxic release hazards related to the contractor’s work and process?

1. Has the employer explained to the contractor employer the applicable provisions of the emergency action plan?

1. Has the employer developed and implemented safe work practices to control the entrance, presence, and exiting of contractors in covered process areas?

1. Has the employer periodically evaluated the performance of all contractors in fulfilling their obligations in regard to training and related documentation for contractor employees?

2. Has the contractor notified the employer of unique hazards presented by the contractor employer’s work in the covered process area?

1. Has the employer maintained an illness and injury log (OSHA form 300) for work performed by contract employees in the covered process area?

1. Has the contractor employer trained each contractor in the work practices necessary to safely perform the job?

2. Has the contractor employer instructed each contractor employee in the known potential fire, explosion, or toxic release hazards related to the job and process?