Process Safety Management (PSM) is a regulatory and management framework designed to prevent catastrophic releases of highly hazardous chemicals in the oil and gas, petrochemical, and chemical industries. OSHA's PSM standard, codified at 29 CFR 1910.119, defines 14 elements that covered facilities must implement and maintain. This checklist provides a structured approach to verifying compliance with each PSM element, helping facilities identify gaps before they become audit findings or, worse, the root cause of a major incident.
Why Process Safety Management Matters
Major industrial disasters such as the Texas City refinery explosion, the Bhopal gas tragedy, and countless smaller incidents trace their root causes back to failures in process safety management. PSM is not just a regulatory checkbox; it is a systematic approach to managing the hazards associated with processes that use, store, manufacture, or handle highly hazardous chemicals. Effective PSM programs reduce the frequency and severity of process safety events, protect workers and communities, and avoid the enormous financial and reputational costs of major incidents. The U.S. Chemical Safety Board (CSB) consistently identifies PSM deficiencies as contributing factors in their incident investigations, reinforcing the critical importance of maintaining a robust program.
Process Safety Information (PSI)
Process safety information is the foundation upon which all other PSM elements are built. Accurate and complete PSI ensures that hazard analyses, operating procedures, and training are based on correct data.
- Verify that Material Safety Data Sheets (SDS) are current and available for all highly hazardous chemicals on site
- Confirm that process flow diagrams (PFDs) and piping and instrumentation diagrams (P&IDs) accurately reflect the current configuration of the facility
- Ensure that equipment design data including maximum allowable working pressures, materials of construction, and relief device capacities are documented and accessible
- Validate that process chemistry information including safe operating limits, consequences of deviation, and reactivity data is documented
- Check that electrical classification drawings accurately reflect the current hazardous area designations
Process Hazard Analysis (PHA)
Process hazard analysis is the systematic evaluation of potential hazards associated with a process. PHAs identify what could go wrong, how likely it is, and what safeguards are in place to prevent or mitigate the consequences.
- Confirm that initial PHAs have been completed for all covered processes and revalidated at least every five years
- Verify that the appropriate PHA methodology (HAZOP, What-If, Checklist, FMEA, or combination) was used based on the process complexity
- Review PHA recommendations for completion status and verify that accepted recommendations have been implemented
- Ensure that PHA teams included members with expertise in engineering, operations, process chemistry, and safety
- Check that PHA documentation addresses previous incidents, near misses, and lessons learned from industry events
Operating Procedures
Written operating procedures provide step-by-step instructions for safely conducting activities involved in each covered process. They must be current, accessible, and clearly written.
- Verify that operating procedures exist for all phases of operation including startup, normal operation, temporary operations, emergency shutdown, and normal shutdown
- Confirm that procedures address safe operating limits and the consequences of deviating from those limits
- Check that procedures are reviewed and certified as current and accurate at least annually
- Ensure that procedures address safety and health considerations including hazardous chemical properties, exposure controls, and PPE requirements
Training
Training ensures that employees understand and can safely perform their job duties in accordance with operating procedures and safety requirements.
- Verify that initial training has been completed for all employees involved in operating a covered process before they begin independent work
- Confirm that refresher training is conducted at least every three years for all operating personnel
- Check that training records document the identity of the employee, the date of training, and the means used to verify comprehension
- Ensure that contract employees have received appropriate training on the specific hazards related to their work scope
Management of Change (MOC)
Management of change is the process for evaluating and controlling modifications to process chemicals, technology, equipment, and procedures to ensure that safety is maintained.
- Verify that a written MOC procedure exists and is followed for all changes to process chemicals, technology, equipment, and procedures
- Confirm that each MOC includes an evaluation of the technical basis, safety and health impact, modifications to operating procedures, and required training
- Check that affected employees are informed of and trained on changes before startup following the change
- Ensure that process safety information and P&IDs are updated to reflect implemented changes
- Verify that replacement-in-kind decisions are documented and criteria for determining replacement-in-kind are clearly defined
Pre-Startup Safety Review (PSSR)
Pre-startup safety reviews confirm that new or modified facilities are safe to operate before process chemicals are introduced.
- Confirm that PSSRs are conducted for all new facilities and for modified facilities when the modification triggers an MOC
- Verify that the PSSR confirms construction and equipment are in accordance with design specifications
- Check that safety, operating, maintenance, and emergency procedures are in place and adequate
- Ensure that PHA recommendations have been resolved or implemented before startup
- Confirm that training for operating and maintenance personnel has been completed before startup
Incident Investigation
Incident investigation identifies the root causes of incidents and near misses to prevent recurrence. Effective investigation programs are proactive and learn from every event.
- Verify that a written incident investigation procedure exists and defines the criteria for initiating an investigation
- Confirm that investigations are initiated within 48 hours of the incident and include a multidisciplinary team
- Check that investigation reports identify root causes, contributing factors, and corrective actions with assigned responsibilities and target dates
- Ensure that investigation findings are reviewed with all affected personnel and lessons learned are shared across the organization
Compliance Audits
Compliance audits provide an independent evaluation of the facility's adherence to all elements of the PSM standard. They are the mechanism for verifying that the PSM program is working as intended.
- Confirm that PSM compliance audits are conducted at least every three years by a team with appropriate knowledge and experience
- Verify that audit findings are documented, corrective actions are assigned, and deficiencies are corrected in a timely manner
- Check that the two most recent audit reports and associated corrective action documentation are retained
- Ensure that the audit scope covers all 14 elements of the PSM standard for each covered process
Best Practices
- Treat PSM as an integrated management system rather than 14 separate programs by establishing clear links between elements
- Engage front-line operators and maintenance technicians as active participants in PSM activities including PHAs, MOCs, and incident investigations
- Use leading indicators such as overdue PHA recommendations, open MOCs, and late training to monitor PSM program health
- Benchmark against the Center for Chemical Process Safety (CCPS) Risk-Based Process Safety framework for a more comprehensive approach
- Establish a PSM steering committee with senior management participation to demonstrate leadership commitment
- Integrate PSM requirements into contractor management processes to ensure third-party work activities do not introduce uncontrolled hazards
How Checksheets Helps
Checksheets provides a comprehensive digital platform for managing all 14 elements of your PSM program. From PHA tracking and MOC workflows to incident investigation templates and audit checklists, the platform centralizes your process safety documentation in one accessible location. Automated reminders ensure that PHA revalidations, procedure reviews, and compliance audits happen on schedule. The reporting dashboard gives PSM coordinators and plant managers real-time visibility into program compliance status, open action items, and trending metrics. With Checksheets, facilities can move from reactive compliance to proactive process safety excellence.