PROCESS SAFETY MANAGEMENT ASSISTANCE

PENTA Engineering has extensive experience with 29 CFR 1910.119, the OSHA Process Safety Management (PSM) standard. PSM starts with a list of 137 chemicals deemed "highly hazardous, toxic, or reactive." If a site has more than a threshold quantity (which varies) of any of those materials, it is covered by PSM. In addition, many members of the American Chemistry Council (formerly the Chemical Manufacturers Association) have committed to adopting PSM-type documentation for other materials/processes not specifically covered by PSM as part of their Responsible Care program. In summary, we are familiar with the requirements and experienced in the implementation of PSM and can provide any assistance necessary to develop a compliance program ranging from making suggestions and coordinating the effort to actually developing most of the documentation. All PSM work performed by PENTA is under the supervision and direct charge of Registered Professional Engineers with expertise in this important area. When hired to provide design services, PENTA provides much of the baseline documentation required for compliance as part of our engineering services.

• Developing your overall compliance plan including Employee Participation.
• Compilation and development of Process Safety Information such as MSDSs, process descriptions, equipment information, applicable RAGAGEPs, and piping and instrumentation diagrams (P&IDs), which are crucial documents for PSM compliance.
• Conducting and documenting Process Hazards Analyses, such as What-If analyses and HAZOP reviews.
• Documentation of Operating Procedures that comply with PSM, including items such as startup, shutdown, operating parameters, high and low alarm limits, safety systems, and safety and health considerations.
• Developing and implementing operator Training, including items such as training on potential process hazards, training on process control systems, or training on how to conduct PHAs.
• Developing compliance requirements for Contractors, such as evaluating safety performance, documenting and informing contractors of plant safety standards and potential hazards, and developing plant safety orientations for contractors.
• Participation and documentation of Pre-Startup Safety Reviews (PSSRs), even if we were not involved in the original design.
• Development and implementation of a Mechanical Integrity program, including assembling equipment documentation, providing relief device calculations, performing suitability for service analyses, and recommending inspection and testing programs in accordance with RAGAGEPs.
• Development of a Hot Work Permit system.
• Development and implementation of a Management of Change system to review and document changes to the process.
• An Incident Investigation, to provide an impartial third-party assessment of the incident, along with documentation and recommendations for preventing future incidents.
• Development of Emergency Planning and Response plans for potential accidents and/or releases.
• An impartial third-party Compliance Audit of your compliance program along with recommendations for improvements.