Screen Shot 2017 09 08 at 6.32.18 PMOSHA has just released a new PSM Booklet titled "Process Safety Management for Petroleum Refineries", which contains "Lessons Learned" from their Petroleum Refinery Process Safety Management National Emphasis Program (NEP).  This publication is a MUST READ for any practicing process safety professional, regardless if your process(s) is a refinery or not!  The publication focuses on five (5) PSM elements: 1) Process Safety Information, 2) Process Hazards Analysis, 3) Operating Procedures, 4) Mechanical Integrity, 5) Management of Change.  The publication discusses the trends OSHA found in their Refinery NEP inspection, but let's not fool ourselves into thinking these problems are only in refining!  The publication offers suggested RAGAGEPs for these five (5) PSM areas, as well as provides some really great discussions on some of the RAGAGEPs finer points, such as:

  • intervening valves in relief systems (NOTE:  SAFTENG members should read my 2011 article on Car Seal Program and Relief Valves)
  • P&IDs and equipment identifiers in the field
  • PHAs overlooking human factors issues
  • SOPs not accurate or implemented as written
    • Operators deviating from written SOPs
  • Safe Work Practices deficient in the following areas:
    • Controlling entry of motorized equipment into ignition source controlled areas,
    • Controlling personnel access to process units,
    • Line breaking and equipment opening practices,
    • Hot work permitting,
    • Lock-out and tag-out (LOTO) practices,
    • Vehicle collision control, and
    • Housekeeping

The publication breaks down these five (5) focus areas in the following manner:

Process Safety Information (PSI)


A. Relief Systems RAGAGEP

B. Facility Siting RAGAGEP

2. Piping and Instrumentation Diagrams

3. Relief System Design and Design Basis


Process Hazards Analysis

1. Recommendation Resolution

2. Facility Siting

3. Human Factors


Operating Procedures

1. Emergency Shutdown Procedures

2. Safe Work Practices


Mechanical Integrity

1. Equipment Deficiencies

2. Inspection, Testing, and Maintenance Procedures

A. Thickness Measurements RAGAGEP

B. Inspection Frequency RAGAGEP

3. Resolve Anomalous Data

4. Ensure Proper “Site-Specific” Inspections and Tests


Management of Change

1. Changes in Equipment Design

2. Changes in Operating Procedures

3. Changes in Inspection and Test and Maintenance Procedures

4. Changes in Facilities

5. Time Limitations on Temporary Changes


Related Standards

OSHA often cites multiple standards during inspections. The following standards were also cited during the NEP (the list below is not exclusive).

  • Flammable and Combustible Liquids (29 CFR 1910.106)
  • The Hazard Communication (HazCom) standard (29 CFR 1910.1200)
  • Permit-Required Confined Spaces (29 CFR 1910.146)
  • Hazardous (Classified) Locations (29 CFR 1910.307)
  • The Personal Protective Equipment (PPE) standard (29 CFR 1910.132)
  • The Control of Hazardous Energy (Lockout/Tagout) standard (29 CFR 1910.147)


CLICK HERE for OSHA 3918 Process Safety Management for Petroleum Refineries

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