DSS059: Overview of the Fourteen Pillars of Process Safety Management

In this episode of the DustSafetyScience Podcast, we discuss the 14 Pillars of Process Safety Management, or PSM, that appear in OSHA 1910.119. It’s a topic that generates a lot of questions and a certain amount of controversy in industries handling combustible dust.

In Canada, the CSAZ767 on process safety management was issued in 2017. The general perception of PSM is that it applies to oil and gas or chemical processing industries when in reality, it can improve facility safety in a wide range of sectors. The problem is that PSM adoption is encountering resistance in several quarters.

Many consultants and industry experts who do dust hazard analyses (DHAs) know process safety management and apply it when they do hazard identification or hazard analysis, but there are others in combustible dust handling industries who take the approach that, “this is what oil and gas do. It’s very complicated and very expensive. And we don’t really want any part of it.”

The NFPA guidance excludes the OSHA PSM guidelines from its standards for combustible dust, possibly so that it doesn’t make these guidelines mandatory for anyone governed by NFPA 652.

However, U.S. Chemical Safety Board reports routinely include lessons learned that fit under one of the 14 pillars from PSM, so this is not a new concept. It may be more expedient to adopt it as a way of thinking instead of building a new process from the ground up and adding a new element every time an incident occurs.

Why Is PSM Not Applied Across More Industries Handling Combustible Dust?

We already explained that there is a tactical reason why process safety management is excluded from certain standards: to avoid triggering very specific OSHA frameworks. There is also a general hesitation to adopt it as something to apply overall, and this appears to be due to a couple of issues.

The main one is that there are 14 pillars in PSM, which is a lot to address in an efficient and cost-effective manner. When Canada issued CSAZ767 in 2017, PSM was grouped into four elements, making it a more manageable concept. They are:

Process safety leadership
Understanding hazard and risk
Risk management
Review and improvement

The other elements are included in these four primary ones, which makes their adoption more palatable to companies concerned about complications and added expense. It’s a strategy that can encourage the use of PSM in facilities that can benefit from its framework.

An Overview Of OSHA 1910.119

Below are the 14 pillars of process management safety as per OSHA 1910.119.

1. Employee Involvement.
Employers must engage their workforces in process safety and make it a requirement for employees to be involved.

2. Safety Information.
This refers to the information about identifying hazards, characterizing materials, and evaluating the consequences of those potential hazards, all of which are steps in a DHA.

3. Process Hazard Analysis.
According to OSHA, hazard evaluation can include elements such as a ‘what if ‘checklist, HAZOP, failure mode and effects analysis, fault tree analysis, etc. These are the same tools being used in a dust hazard analysis but, for reasons already discussed, it isn’t called a process hazard analysis.

4. Operating Procedures.
This covers all operating procedures, including startup and shutdown. Chemical Safety Board reports often describe how restarting equipment after an emergency shutdown can trigger a flash fire or explosion.

5. Training.
Employers are responsible for training employees on the known potential fire, explosion, or toxic release hazards related to their work and the process.

6. Contractors.
Employers must inform contractors of the known potential fire, explosion, or toxic release hazards related to their work and the process.

7. Pre-startup Safety Review.
Jeff Mycroft mentioned this concept in Episode# 47. In Ontario, they are now doing a lot more of these pre-startup safety reviews and catching evidence of combustible dust noncompliance before it can endanger anyone.

8. Mechanical Integrity.
This step refers to equipment inspection: making sure that lubrication is applied correctly and that maintenance manuals are being used for bearing replacement and related adjustments.

9. Hot Work Permits.
Hot work is one of the leading causes of explosions, so having a permit system is a must-have in an industry handling combustible dust regardless of whether you’re following the PSM framework or not.

10. Management Of Change.
An example of the necessity of this step can be found from the Imperial Sugar Refinery explosion. Company management changed out the conveyor system and built housing around it. This was one of the contributing factors leading to the escalation of that explosion.

11. Incident investigation.
Investigating near-misses and fires and explosions that don’t cause loss makes it easier to avoid future tragedies.

12. Emergency Planning and Response.
This one is critical. An explosion can put out your emergency systems, cut power, cause sprinklers to malfunction, and block stairwells. Having some sort of emergency response planning is critical.

13. Compliance Audits.
Under NFPA, you have to redo your dust hazard analysis every five years. This PSM pillar is already in use in combustible dust safety protocols.

14. Trade Secrets.
This pertains to proprietary company information.

Conclusion

Combustible dust handling industries may not involve gas or chemical processing, but having wood dust build up in a lumber mill for 20 years and then igniting can be just as deadly as a gas or chemical leak. This is not to say that we need to adopt the OSHA PSM framework or that any one framework is better than another. We simply should not discount the historical information we’ve been collecting about how technical process safety happens. There are some things we can learn now, saving ourselves the tragedy of learning it the hard way.

If you would like to discuss further, leave your thoughts in the comments section below. If you have questions about the contents of this or any other podcast episode, you can go to our ‘Questions from the Community’ page and submit a text message or video recording. We will then bring someone on to answer these questions in a future episode.