PSM Program Development and Implementation

	If your PSM program has been sitting on the shelf for several years and no one at your facility quite understands what it says, much less how to implement it, then your not alone. We can help you through the process of developing a practical and straight forward PSM program that will make compliance doable.

PHA Team Leader Services 

The PHA Team Leader qualifications under PSM regulations require a trained and experienced Team Leader to perform Process Hazard Analysis. The qualifications of the Team Leader are often called into question by OSHA inspectors. We offer experienced and certified Team Leaders to lead your team through the labyrinth of a PHA . PHA revalidation is required every 5-years. PHA's are often required when a change to the process occurs.

Develop Site Specific Training Documentation

	Training requirements under PSM are far reaching and impact every person at your facility, including outside contractors. The scope of training needed to meet PSM requirements will include:
	New hire orientation -  Evacuation procedures as defined in EAP.   Hazards of ammonia as outline in MSDS .  Procedure for reporting an ammonia release. Overview of what PSM is and why its exists at this facility.   Overview of what a PHA is and why its perform.   Employees right of reasonable access to the above mention documents, the location of those documents, and their right to question those things they do not understand.   OSHA requires that employees not only be trained, but also requires that the employer can verify that employees understanding, this can be accomplished through testing. Either written or verbal is acceptable, as long as the questions and format follow a formalized format to assure consistency regardless of who is performing the training or conducting the test. Proof of compliance and can only be supported through documentation.
	Current employees –   Training updates and refresher training equal to New hire orientation training. Develop a written plan for regular refresher training. Develop a written plan for informing employees of changes to the PSM program that is conducted in a forum which solicits employee input. Develop a written plan for informing employees of the results of PHA’s and the companies plan to resolve any hazardous issues noted during the study, this must be conducted in a forum which allows employees to question those things which may concern them.   Overview of what a PHA is and why its perform.   Employees right of reasonable access to the above mention documents and their right to question those things they do not understand .
	Ammonia system operators Basic evacuation procedures as defined in EAP. Hazards of ammonia as outline in MSDS.   Procedure for reporting an ammonia release   Comprehensive understanding of PSM and the direct impact their job performance has on implementing and maintaining the PSM program. Initial training requirements to certify ammonia system operators.   Site specific on the job training (How much? How long? Scope? Formalized training in basic ammonia refrigeration (IIAR, RETA, etc.).  Trained, tested and certified on Operating Procedures. Read, understand and follow piping and instrumentation diagrams and block flow diagrams.  Previous related experience could be included .
	First Responders  Typically certified ammonia system operators. Proper response for handling small releases.  Proper procedures for responding to reported ammonia releases of unknown origin or concentration. Training on how and when to use of all safety and emergency related personal protective equipment and monitoring devices. Responsibilities during an emergency evacuation must be clearly defined. Responsibilities and procedures during an emergency system shutdown must be clearly defined, prioritized, and supported through documented training.  Limitation of responsibility: when to take a fall back position and when to retreat.
	Supervisors Personal responsibilities during evacuations.  Evacuation procedures as defined in EAP. Hazards of ammonia as outline in MSDS.  Procedure for reporting an ammonia release.  Overview of what PSM is and why its exists at this facility.  Overview of what a PHA is and why its perform.  Employees right of reasonable access to the above mention documents and their right to question those things they do not understand.

Three Year Compliance Audit

The three year compliance Audit is a regulatory requirement designed to verify that the procedures, practices, and documentation required under the PSM standard are adequate and being followed at your facility. Audits that are attempted in-house are very often challenged by OSHA, creditability and the potential for biases are red flags to OSHA inspectors.

PSM Needs Assessment (for more information check HERE)

A needs assessment is a thorough and detailed inspection and review process of your entire PSM program. Every element of PSM at your facility is scrutinized to assure compliance issues have been addressed, documented, and meets regulatory compliance. You don't know where you need to go until know where you are. Find out today.

Development of Operating Procedure

Developing concise, practical, and compliant SOP's is difficult and time consuming. Don't waste time and make the process more difficult then it has be. Let our experienced consultants guide you through the development process. We will work onsite with your operators and engineering staff during the development phase and follow-up with a comprehensive review/recommendation process.

Development and Implementation Guidance of Emergency Response Program 

Guide facilities through the process of developing and implementing a workable and compliant Emergency Action Plan.

Training Seminars (for more information check HERE)

	Onsite 3-day PSM Seminar This comprehensive 3-day seminar is specifically designed to give those with responsibility for developing, implementing and maintaining PSM a plain English, how to get it done, understanding of OSHA 1910.119.
	1-day PSM Seminar This 1-day orientation of PSM will help those with limited responsibilities under PSM to have a working understanding of compliance objectives. This course in not recommended for those with hands-on responsibly for PSM at their facility.    .
	1-day Ammonia Refrigeration refresher training This training course meets PSM 3-year refresher training requirements for system operators utilizing the IIAR training formula.
	Management of Change Process This far reaching element of PSM is difficult to master without hands on experience. We offer onsite training with a hands on approach. If you have a major expansion planned soon we can guide you through the MOC process and train your personnel by experience.
	Developing Operating Procedures This area of PSM is by far the most misunderstood and most often cited element of PSM. Developing concise, practical, and compliant SOP's is difficult and time consuming task. Don't waste time and make the process more difficult then it has be, let our experienced consultants show you how.
	Annual MI inspection Our inspectors will assist and train your personnel in the proper inspection techniques needed to achieve a thorough and compliant Mechanical Integrity inspection, which is required annually by OSHA.

Risk Management Plan Filing (RMP)

The 5-year RMP refiling is due this year for nearly everyone in the ammonia industry. The RMP program is built directly upon the PSM program. You must be PSM compliant to meet criteria outlined in your RMP submission. Filing an RMP with incorrect or false information is a federal crime. Section29 USC 666.(g): states that whoever knowingly makes any false statements, representation or certification in any application, record, plan or other documents filed or required to be maintained pursuant to the Act shall, upon conviction, be punished by a fine of not more that $10,000, or by imprisonment for not more than six months or both.

Annual Mechanical Integrity Inspection

This comprehensive annual inspection is an OSHA requirement which follows IIAR Bulletin 109 and 110 guidelines for inspections. We not only offer qualified inspectors to assure a comprehensive and thorough inspection, but we offer onsite training of your personnel in proper inspection procedures so this inspection process can properly completed by your own personnel.

Five Year Independent Mechanical Integrity Inspection 

	OSHA requires a full independent  Mechanical Integrity inspection every five years, including the evaluation for potential corrosion and stress cracking in vessels and piping .
	If your process has changed or expanded, trained field personnel will walk down and update your existing drawings.
	Ultrasonic testing as indicated.

P&ID's and Process Flow Diagrams

We offer AutoCAD services for updating existing drawings, new construction, removal of old equipment and process flow diagrams. P&ID's should be updated at least annually and must accurately reflect your system.

Quality Assurance (QA) 

We offer a full range of PSM services to guide to through expansion projects and new construction processes.

Fit for Service Vessel Inspection

OSHA requires all vessels have U1A data reports to validate that they were constructed to code. Where those data reports are no longer available we may be able to document them fit-for-service in accordance with the API-510 standard.