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What can you expect if OSHA were to walk through the door today?

The first thing they will want to see is all of your PSM support documentation. The list below is directly from the OSHA inspectors guide book.

Is YOUR documentation up to code?


Documentation to be Requested--General and Process Related. At the conclusion of the opening conference, the Inspector  shall request access to or copies of the documents listed at L.5.a. through L.5.m. below. Initially, to expedite the inspection process, only access to documents should be requested. During the inspection, as potential violations of the standard are observed, copies of the written documentation described below shall be requested to substantiate citations.

a. OSHA 300 Logs for the past 3 years for both the employer and all process-related contractor employer(s).

b. Employer's written plan of action regarding the implementation of employee participation.

c. Written process safety information for the unit(s) selected (see L.7.), if available, such as flow diagrams, piping and instrumentation diagrams (P&ID's), and process narrative descriptions.

NOTE: The employer is required to compile process safety information on a schedule consistent with the employer's schedule for conducting the process hazard analyses (PHA).

d. Documented priority order and rationale for conducting process hazard analyses; copies of any process hazard analyses performed after May 25, 1987; team members; actions to promptly address findings; written schedules for actions to be completed; documentation of resolution of findings; documentation verifying communication to appropriate personnel; and 5-year revalidation of original PHA required by standard.

e. Written operating procedures for safely conducting activities in each selected unit; annual certification that operating procedures are current and accurate; written procedures describing safe work practices for potentially hazardous operations, including (but not limited to) lockout/tagout, confined space entry, lifting equipment over process lines, capping over ended valves, opening process equipment or piping, excavation, and control over entrance into a facility of maintenance, laboratory, or other support personnel.

f. Training records for initial and refresher training for all employees in the selected unit(s) whose duties involve operating a process; methods for determining the content of the training; methods for determining frequency of refresher training; certification of required knowledge, skills, and abilities to safely perform job for employees already involved in operating a process on May 26, 1992, who have not received initial training; and training material.

g. Pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information; documentation of employee training.

h. Written procedures and schedules to maintain the ongoing integrity of process equipment; the relevant portions of applicable manufacturers' instructions, codes, and standards; and inspection and tests performed on process equipment in the unit(s) selected.

i. Hot work permit program and active permits issued for the unit(s) selected.

j. Written procedures to manage change to process chemicals, technology, equipment and procedures; and changes to facilities that affect a covered process.

k. Incident investigation reports for the unit(s) selected, resolutions and corrective actions.

l. Written emergency action plan including procedures for handling small releases and evidence of compliance with 1910.120(a), (p), and (q), where applicable.

m. The two most recent compliance audit reports, appropriate responses to each of the findings, and verifications that deficiencies have been corrected.

6. Documentation to be Requested--Contractor-Related. The following information relating to contractor compliance shall be requested:

a. Documentation from Employer:

(1) Information relating to contract employers' safety performance and programs;

(2) Methods of informing contract employers of known potential hazards related to contractor's work and the process and applicable provisions of the emergency action plan;

(3) Safe work practices to control the entrance, presence and exit of contract employers and contract employees in covered process areas;

(4) Evaluation of contractor employer performance in fulfilling responsibilities required by the standard;

(5) Contract employee injury and illness logs related to work in process areas; and

(6) A list of unique hazards presented by contractors' work or hazards found in the workplace that have been reported to the employer.

b. Documentation from Contract Employer:

(1) Records showing employees receive training in and understand safe work practices related to the process on or near which they will be working to perform their jobs safely;

(2) Known potential fire, explosion or toxic release hazards related to job, and applicable provisions of emergency action plan; and

(3) A list of unique hazards presented by contractors' work or hazards found in the workplace that have been reported to the employer.

NOTE: The documentation described at L.5. and L.6.a. may also be required of the contract employer, depending on the scope of the contract employer's activities.






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