PSI is the Foundation of your PSM Program

​If you have a process that contains highly hazardous chemicals, it’s likely that you are required to implement a Process Safety Management program at your facility.  If you have established your program, then you already know that it is everyone’s responsibility to protect people and the environment from exposure to highly hazardous chemicals.  And, having systems in place to prevent exposures and reduce the potential for catastrophic event like a significant release of toxic or flammable material is what Process Safety Management is all about.  So, how does Process Safety Information (PSI) fit into this system?

​The Basics
PSI is the second element within a PSM Program (29 CFR 1910.119(d)). This rule requires that an employer compile written PSI.  The information is divided into three distinct sections:

1.  Hazards of the chemicals in the process.
2. Technology of the process.
3. Equipment in the process.

​Each one of these sections contains a list of information that must be gathered.  It makes sense then, that information collected is “complete and accurate,” as noted in 29 CFR 1910.119 Appendix C.  

The rule doesn’t provide allot of guidance on how to gather the information, what form it should take or what to do with the information once you have it.  But we will get into these kinds of details later.  As time goes on, we will explore each of the PSI requirements in future posts.  Today we are going to focus on the purpose of PSI.

The Purpose of PSI

The regulation simply states that, “The compilation of written process safety information is to enable the employer and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals.” 

In our opinion, though, PSI is the backbone of the PSM Program.  PSI provides the building blocks for the rest of your PSM Program.  And we are in agreement with Appendix C in that having complete and accurate PSI is essential for an effective PSM program. 

PSI is a core requirement. It is a necessity.  Imagine, if accurate information is not maintained and something happens, how would you deal with the situation if you don’t know what kind of materials are in your process.  It’s kind of like following a recipe, if you don’t know what the ingredients are, how do you know that your cake will turn out?  If you don’t know what kind of gasoline your car runs on, how do you know what to put in it if you run out of gas?  If you don’t know what kind of equipment is in your refrigeration system, how will know what to do when something needs repair or replacement? 

It’s the same principle.  There is basic information you need to have on hand in order to run your process effectively and efficiently.

So, let’s repeat the mantra.  Complete and accurate PSI is imperative.  It is really, Really, REALLY important because it supports everything else you do. 
 
How Does PSI Inform the rest of your PSM Program?

PSI is the foundation of your entire PSM program. You use PSI to build your program.  It intersects and interacts with all the other PSM program elements.  We’ll keep it simple for now.  Here are a few examples of how PSI affects the rest of your program:

• Standard Operating Procedures (SOPs) include the safe operating limits of your system.  If your operators don’t know what the safe limits are or they are listed incorrectly in your SOPs, just think about what could go wrong if your process exceeds the limits.
• Training is completely dependent on accurate PSI.  If the information in PSI is reflected in the SOPs and training is conducted using the inaccurate SOPs, then the training conducted just taught your operators the wrong thing.
• Complete and accurate PSI has to be available to do a Process Hazard Analysis (PHA).  You can’t even begin a PHA if you don’t have a set of P&IDs that contains appropriate information (that’s a whole post by itself).  The very basis of the PHA is dependent upon accurate P&IDs.  If your P&IDs are wrong, all the time and energy conducting the hazard assessment will have been wasted.
• The ability to effectively evaluate a change to your process would be impaired.  The management of change (MOC) procedure would be ineffective.  If the PSI is inaccurate, then the change you are proposing would be based on erroneous information and it is likely that the change selected would be ineffective, costly and even dangerous.    If you don’t have PSI, then how would you evaluate a change in the first place? 
• Your Mechanical Integrity program will also be impaired.  If you don’t have information about your equipment, how do you set up a preventative maintenance program.  What standards or guidelines will you use?  How often do you need to replace a particular relief valve? 

We hope that these examples are useful in illustrating how PSI is used in the rest of a PSM program.  The data about your equipment, the chemicals and the technology of the process will guide you in making important decisions. 

Up Next – The details
​
Over the next several months we will be posting some details about each of the required PSI.  That is the information required by PSM and some guidance on what it should look like and how to use it.