Following are the Process Safety Management (PSM) related records your facility must have available for a review by an OSHA inspector:
- OSHA 300 logs for the past 3 years for both the employer and all process-related contractor employer(s).
- Written process safety information for the unit(s) selected, if available, such as flow diagrams, piping and instrumentation diagrams (P&IDs), and process narrative descriptions. Note: The employer is required to compile process safety information on a schedule consistent with the employer’s schedule for conducting the process hazard analyses (PHAs).
- Process hazard analysis documents documenting priority order and rationale for conducting the analyses, copies of process hazard analyses, team members, actions to promptly address findings, written schedules for actions to be completed, documentation of resolution of findings, documentation verifying communication to appropriate personnel, and 5-year revalidation of original PHA required by standard.
- Written operating procedures for safely conducting activities in each selected unit, annual certification that operating procedures are current and accurate, written procedures describing safe work practices for potentially hazardous operations including (but not limited to) lockout/tagout, confined space entry, lifting equipment over process lines, capping over ended valves, opening process equipment or piping, excavation, and control over entrance into a facility of maintenance, laboratory, or other support personnel.
- Written plan of action regarding the implementation of employee participation.
- Training records for initial and refresher training for all employees in the selected unit(s) whose duties involve operating a process, methods for determining the content of the training, methods for determining frequency of refresher training, certification of required knowledge, skills, and abilities to safely perform job for employees already involved in operating a process on May 26, 1992, who have not received initial training, and training material.
- Prestart-up safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information, and documentation of employee training.
- Mechanical integrity procedures and schedules to maintain the ongoing integrity of process equipment, the relevant portions of applicable manufacturers’ instructions, codes and standards, and inspection and tests performed on process equipment in the unit(s) selected.
- Hot work permit program and active permits issued for the unit(s) selected.
- Management of change procedures to manage change to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process.
- Incident investigation reports for the unit(s) selected, resolutions, and corrective actions.
- Written emergency action plan, including procedures for handling small releases and evidence of compliance with 29 CFR 1910.120(a), (p), and (q), where applicable.
- The two most recent compliance audit reports, appropriate responses to each of the findings, and verifications that deficiencies have been corrected.
For assistance with your Environmental and Health & Safety (EHS) regulatory compliance needs, contact Ralph Carito at Total Environmental & Safety, LLC (Total) at 908-442-8599 or rcarito@TotalEnviron.com.