QEHSProcess safety
Process Safety Management — a QEHS primer
The 14 PSM elements, how they map to QEHS modules, and where they overlap with OSHA 1910.119 and EPA 112(r).
QEHS safety desk
Safety practitioners on staff
16 min read · 3 sections
Coverage
OSHA 29 CFR 1910.119 (PSM) applies to processes that contain a threshold quantity of a highly hazardous chemical. EPA 40 CFR Part 68 (RMP) layers on top for the same chemical list but with community-impact reporting. If you are PSM-regulated, you are almost always RMP-regulated.
The 14 elements
- Employee participation — written plan, workforce consulted on PSM activities.
- Process safety information — chemical, technology, equipment documentation.
- Process hazard analysis (PHA) — HAZOP / What-If / FMEA every 5 years.
- Operating procedures — written, current, accessible.
- Training — initial + refresher on process and procedures.
- Contractors — selection, training, audit.
- Pre-startup safety review (PSSR).
- Mechanical integrity — equipment inspection and testing.
- Hot work permit.
- Management of change (MoC).
- Incident investigation — recordable process-safety incidents.
- Emergency planning and response.
- Compliance audits — every 3 years.
- Trade secrets — protected but disclosable to those who need it.
PSM and QEHS modules
| PSM element | QEHS module |
|---|---|
| PHA | Risk register + HAZOP template |
| Operating procedures | Documents module, version-controlled |
| MoC | Change management module |
| Mechanical integrity | Inspections + Asset module |
| Incident investigation | Incidents + CAPA |
| Contractors | Contractor management + permits |
| Compliance audits | Audits module |