Abstract The paper describes a Process Safety Management (PSM) Plan to satisfy the requirements of OSHA 1910.119 for onshore production facilities and proposed MMS requirements for offshore operations. The information presented will help operators better understand the requirements as they apply to producing facilities and gas plants, and develop a plan to meet these requirements.
Background In February 1992, OSHA 1910.119 was promulgated, requiring that a Process Safety Management (PSM) Plan be put in place by May 1992. This regulation applies to processes handling highly hazardous chemicals, including onshore production facilities and gas plants. Offshore, the MMS has requested that operators voluntarily comply with API RP 75, Recommended Practices for Development of a Safety and Environmental Management Program for Outer Continental Shelf (OCS) Operations and Facilities (SEMP). Many of the requirements for these two regulations are similar, and it is possible for an operator to develop a PSM/SEMP Plan which will meet the requirements of both 1910.119 and RP 75.
The bulk of the PSM/SEMP Plan contains general requirements which are not site-specific. These include procedures to assure employee participation, training for employees and contractors, a method for ensuring mechanical integrity of equipment, management of change procedures, incident investigation, emergency planning and response, and auditing for compliance. Once such procedures are developed, they can be applied to a number of facilities. Site-specific requirements include information on the chemicals, equipment, and technology of the process, hazards analysis, written operating procedures for the facility, and detailed documentation of data collected to assure mechanical integrity. Much of this information can be presented on process flow diagrams and P and IDs in a format that is familiar to operators.