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Management of Change [1910.119(l)]

Management must establish and implement written procedures to manage changes in or with the process technology, chemicals,

and equipment. These procedures should cover all modifications to the process (or facility if it affects the process) except for changes

“in kind.” Considerations such as health and safety, technical basis for the change, impact of modifications to the procedure or

process, training requirements, and authorization must be contemplated before the change is made. Some confusion surrounds

mechanical integrity and management of change. Mechanical integrity is intended to maintain the process "as is"; whereas

management of change is intended to control significant changes to the covered process.

Incident Investigation [1910.119(m)] - The standard also requires an “incident” investigation procedure. Each incident that has either

resulted in or “could have” resulted in a release of a highly hazardous material must be investigated promptly (no later than 48 hours

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after the event). The investigation team must include at least one person who is knowledgeable about the process and must include

a contract employee if the incident involved work with the contractor. At a minimum, the incident investigation team’s report must

include the date of the incident, the date that the investigation began, a description of the incident, a discussion of the factors that

led to the incident, and the team’s recommendations. Afterwards, management must address and “resolve” the issues raised by the

report and review the report with all affected process personnel, including contract employees. Incident reports must be retained for

five years.

The Process Safety Management Standard reaffirms OSHA’s existing

requirement of emergency response planning. Management must have a plan that conforms to the requirements of OSHA’s

Employee Emergency Planning provisions [29 C.F.R. 1910.038] and, where appropriate, the emergency planning provisions of the

Hazardous Waste Operations and Emergency Response Regulations [29 C.F.R. 1910.120]. Every employer subject to compliance with

PSM should carefully review the requirements and applicability of 29 CFR 1910.119 and 1910.120 to determine what their

obligations are under these standards.

A compliance audit must be completed at least every three years. The audit must be conducted

by at least one person who knows the process. Since management must be in a position to certify its compliance with the PSM

regulations, they would be well advised to also include at least one person who is well versed with the requirements of the regulation

itself. The two most recent audit reports must be retained. Again, some confusion exists regarding compliance audits and PSM

documentation. To summarize, the Standard requires annual certification of SOPs, a full compliance audit every three years, and a

formal process hazard analysis review every five years.

Trade Secret Documentation [1910.119(p)]

Zurich Services Corporation

Risk Engineering

1400 American Lane, Schaumburg, Illinois 60196-1056 800 982 5964 www.zurichna.com

The information in this publication was compiled by Zurich Services Corporation from sources

believed to be reliable for informational purposes only. All sample policies and procedures

herein should serve as a guideline, which you can use to create your own policies and

procedures. We trust that you will customize these samples to reflect your own operations

and believe that these samples may serve as a helpful platform for this endeavor. Any and all

information contained herein is not intended to constitute legal advice and accordingly, you

should consult with your own attorneys when developing programs and policies. We do not guarantee the accuracy of this information or any results and further assume no liability in

connection with this publication and sample policies and procedures, including any

information, methods or safety suggestions contained herein. Moreover, Zurich Services

Corporation reminds you that this cannot be assumed to contain every acceptable safety and

compliance procedure or that additional procedures might not be appropriate under the

circumstances The subject matter of this publication is not tied to any specific insurance

product nor will adopting these policies and procedures ensure coverage under any insurance

policy.

©2012 Zurich Services Corporation