Document gbaE3kXjZqk0q3VMqOzDXVDeL

i ABDOO100732 Examples ofDocumentation to Support Compliance with OSHA's PSMRegulation Description of PSM Documentation General PSM Documentation 1. A written implementation plan, budget document, or memo outlining PSM compliance intentions 2. A manual describing the PSM program for the facility 3. A listing of general PSM training given to plant employees or seminar attendance to help prepare them to implement the rule 4. A plant organization chart that describes the PSM-related roles and responsibilites Required Practical Necessity Convenience X X X X Employee Participation 1. Written plan describing implementation ofthis provision 2. Minutes ofmeetings during which employees and their representatives were consulted about the development ofthe PSM program 3. Various PSM documents listed below dial name employees as authors, participants, reviewers, etc. Process Safety Information 1. MSDSs 2. Laboratory reports concerning tests ofthe thermal stability or reactivity associated with covered chemicals 3. Up-to-date information that describes the subject process, its operating limits, maximum intended inventories, safety systems, and consequences of deviations fe.e.. troubleshooting information} X X X X X X F:\DATA\COURSESU02\EXAMPLES\102-045.EXA 1 of 6 ABDOO100733 Description of PSM Documentation Required Process Safety Information (continued) 4. Updated P&IDs, interlock descriptions, electrical classification drawings 5. Design files for equipment including references to codes and standards used, technical basis for relief device design, etc. 6. Written documentation that asserts the plant's judgment that the associated equipment complies with generally recognized engineering practices, or documentation oftests, inspections, operating history, etc., that shows that the equipment is safe for its intended duty Process Hazard Analysis 1. Prioritization of covered processes for the purposes ofscheduling PHAs that list the factors considered in selecting the order 2. Descriptions ofhow the plant intends to plan, perform, document, use, and retain PHAs 3. Descriptions ofhow the plant uses particular PHA techniques 4. PHA reports 5. Memos or reports stating plant management's response to suggestions from PHA reports 6. Schedules for tracking progress and completing accepted PHA recommendations 7. Lists of "qualified" PHA team leaders. Lists of PHA-related training courses taken 8. Minutes of meetings or logbooks that provide evidence of communicating the results of PHA reports to affected employees Operating Procedures 1. Written instructions for operating the covered process in all anticipated modes of operation 2. Annual certifications that the procedures are current and accurate X X X X X X X X X Practical Necessity Convenience ' t* V> // >, s* s X X X X F:\DATA\CXWRSES\102\EXAMPLES\102-045.EXA 2 of 6 ^ABDUU1UU7 34 Description of PSM Documentation Required Practical Necessity Convenience Operating Procedures (continued) 3. Written description ofthe process the plant uses to create and update operating procedures, including the names of people and their responsibilities Training 1. Description ofthe initial training program. Lists oftopics covered in training courses or other methods used to provide initial training X 2. Checklists of operating tasks to be demonstrated bv employees that undergo on-the-job training 3. <&iemos>pecifically ''grandfathering" employees -- for certain operating jobs 4. Descriptions of refresher training plans, methods, and contents - v-flx LL 0U\J- dltiA ( 0 -T&/A X 5. Evidence ofhow employees were consulted about the appropriate frequency for their refresher training (e.g., training surveys) X 6. Records oftraining for eveiy person involved in - f\jb ,-tUtUL operating the process, including the means used ^/va to determine that the individual understood the training i t* Contractors 1. Copies of information that employer's have used during the contractor selection process to Wf ' / evaluate contractors' safety programs and performance * M* 2. Criteria or forms used to document how such a contractor safety review was used in the selection process X 3. Generic contractor safety manual provided to all contractors bidding on or performing work in a covered process area X 4. Lists of safe work practices that contractors are required to follow while performing work in the covered facility X 5. Examples of written information provided to contractors concerning the specific hazards associated with the covered process X X X cut F:\DATA\COURSES\l 02\EXAMPLES\102-045.EXA 3 of 6 ABDOO100735 Description of PSM Documentation Required Contractors (continued) 6. Booklets, badges, or cards that are used to help control the entrance and exit of contractors into covered process areas 7. Lists of emergency action plan information provided to each contractor employee so they will know what to do in the event of an emergency 8. Forms, criteria, or other means used to document the periodic auditing of contractor work practices to ensure that contractors are satisfying the regulatory requirements (e.g., training) 9. Log of contractor injuries/illnesses for covered process areas 10. Memos, data, or other records to indicate that appropriate action was taken when contractor safety infractions were discovered Pre-startup Safety Review (PSSR) 1. Procedures, forms, or checklists used to perform PSSRs 2. Examples of completed PSSR forms with plant management's authorization to start up, ensuring that the provisions ofthis paragraph are satisfied Mechanical Integrity 1. Written procedures for mechanical integrity activities 2. Description ofthe maintenance training program. Lists oftopics covered in training courses, apprenticeship program, or other methods used to provide training 3. Checklists ofmaintenance tasks to be demonstrated by employees that undergo on-theiob training 4. Memos specifically "grandfathering" maintenance employees 5. Descriptions of refresher training plans, methods, and contents Mechanical Integrity (continued) X X Practical Necessity X X X X X Convenience X X X X X F:\DATA\COURSES\102\EXAMPLES\102-045.EXA 4 of 6 "*55000100736 Description of PSM Documentation Required 6. Records oftraining for maintenance personnel, including the means used to determine whether the individuals understood the training 7. Inspection and testing records for equipment in the covered process 8. Quality assurance procedures and/or records for new equipment and for maintenance materials, spare parts, and equipment 9. Manufacturers' installation and repair manuals Hot Work Permit 1. Hot work permit procedures 2. Example hot work permit forms 3. Completed hot work permits Management of Change 1. Procedures for managing change 2. Completed "request for change" forms 3. Minutes of change review meetings or memos containing change review analyses 4. Minutes ofmeetings or other evidence of communicating the results of changes to affected employees Incident Investigation 1. Procedures for performing incident investigations 2. Completed incident investigation reports or data summaries 3. Procedures for resolving recommendations and tracking their implementation 4. Minutes of meetings or other evidence of communicating the results of incident reports to affected employees X X X X X Practical Necessity X X X X X X Convenience X X , X X F:\DATA\COURSES\102\EXAMPLES\102-045.EXA 5 of 6 ABDOO100737 Description of PSM Documentation Required Emergency Planning and Response 1. Emergency action plans 2. Records of emergency action plan training for plant employees Compliance Audits 1. Procedures, forms, and checklists for performing compliance audits 2. Compliance audit reports Trade Secrets 1. Policy for dealing with trade secrets 2. Completed confidentiality agreements X X Practical Necessity Convenience X X . X X F:\DATA\COURSES\102\EXAMPLES\102-045.EXA 6 of 6