Process Safety Management Application to Oil and Gas Production: A Quick Primer

//Process Safety Management Application to Oil and Gas Production: A Quick Primer

Process Safety Management Application to Oil and Gas Production: A Quick Primer

Process Safety Management Application to Oil and Gas Production: A Quick Primer

By Russell Pinheiro

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This article highlights three process safety accidents at upstream production sites (Table 1) and summarizes the key requirements of the 14 Process Safety Management (PSM) elements under OSHA’s 29 CFR 1910.119 rules.

Following the Bhopal gas tragedy in India (1984), the Occupational Safety and Health Administration (OSHA) issued the PSM rules in 1992 to protect US workers, contractors, and the plant from the consequences of a catastrophic release of toxic, reactive, flammable, or explosive chemicals [1]. Those releases may occur due to a multitude of factors, including but not limited to loss of primary containment (LOPC), process upset, failure of a safety device, system, or layer of protection, and substandard maintenance. A LOPC event, for example, has the potential to cause environmental pollution from a leak, release, or spill to a valued ecosystem component; fire or explosion if flammable substances were involved; or acute and chronic health damage from exposure to toxic and poisonous substances. An average of 110 Tier 1 process safety events (or LOPC) occurred during the five year period ending 2017 according to the American Petroleum Institute [2]. The US Environmental Protection Agency (EPA) enacted legislation similar to PSM in 2006, also known as the Risk Management Program rules [3], whose key objective is to protect communities living beyond a plant boundary where highly hazardous chemicals are stored, used, or processed.

Although oil and gas well drilling and well servicing operations are currently exempt from OSHA’s PSM rules, production operations may not be exempt if:

  1. The process involves a chemical at or above the specified Threshold Quantity listed in appendix A of 29 CFR 1910.119, and

  2. The process involves a Category 1 flammable gas or a flammable liquid with a flashpoint below 100 °F on site in one location, in a quantity of 10,000 pounds or more. Note: A Category 1 flammable gas is one, which at 68°F and a standard pressure of 14.7 psi is ignitable when in a mixture of 13% or less by volume in air; or has a flammable range with air of at least 12 percentage points regardless of the lower flammable limit.

Natural gas, natural gas liquids (NGL), liquefied natural gas (LNG), liquid petroleum gases (LPG), compressed natural gas (CNG), and many crude oils will fall within this category if the process inventory or storage exceeds the 10,000 lb. threshold. In the Bakken field of N. Dakota, for example, portable CNG infrastructure is being deployed at production sites in areas lacking gas pipeline capacity to cap flaring and meet regulatory emission limits.

Exceptions to (b):

  • hydrocarbon fuels used solely for workplace consumption as a fuel unless it is part of a process containing another hazardous chemical covered by the rules

  • flammable liquids with a flashpoint below 100 °F stored in atmospheric tanks, or transferred, below their normal boiling point without chilling or refrigeration

Figure 1: Temporary LPG storage on a production site

Figure 2: CNG transportation skids being loaded at a production site

Figure 3: Production facility with crude oil and produced water tanks

The PSM elements and key requirements of each are summarized below:

  • Employee Participation

    • Develop a written plan of action for employee involvement in process safety

    • Involve employees in PHA and development of the PSM elements

    • Provide employees access to PHA and other process safety information

  • Process Safety Information

    • Gather written process safety information before conducting a process hazard analysis. At a minimum this includes: toxicity information, permissible exposure limits, physical data, reactivity data, corrosivity data, thermal and chemical stability data, and hazardous effects of inadvertently mixing incompatible materials

    • Compile information pertaining to the process technology. At a minimum this includes: a block flow diagram or process flow diagram, process chemistry, maximum intended inventory, safe upper and lower limits for process parameters (temperatures, pressures, flows, compositions, etc.)

    • Collect information on the process equipment, including: materials of construction, piping and instrument drawings, electrical classification, relief system design and design basis, ventilation system design, design codes and standards employed, material and energy balances, and safety systems

    • Document that equipment complies with recognized and generally accepted good engineering practice (RAGAGEP)

    • Determine and document if existing equipment is designed, maintained, inspected, tested and operated in a safe manner


  • Process Hazard Analysis

    • Perform a PHA and identify, evaluate, and control the hazards

    • Use a recognized methodology, such as: What-if, Checklist, Hazard and Operability Study (HAZOP), Failure Mode and Effects Analysis (FMEA), or Fault Tree Analysis (FTA)

    • Address: hazards of the process, previous process incidents, engineering and administrative controls and consequences of their failure, facility siting, human factors, and the likelihood and consequences on employee health and safety

    • Use a team approach, with at least one member knowledgeable of the methodology

    • Establish a system to address findings and recommendations of the PHA and ensure corrective actions are completed on time

    • Revalidate the PHA every 5 years and maintain records

  • Operating Procedures

    • Implement written operating procedures for: initial startup, normal operations, temporary operations, emergency shutdown and operations, normal shutdown, startup following a turnaround or emergency shutdown

    • Ensure procedures address operating limits, safety and health, and safety systems

    • Make procedures readily available for reference

    • Develop safe work practices for: control of hazardous energy, confined space entry, opening process equipment and piping, control of access, and changes to facilities

    • Annually review, update as needed, and certify the procedures

  • Training

    • Provide a process overview, and initial training and testing of each employee on the operating procedures

    • Provide refresher training every three years and maintain records of training

  • Contractors

    • Evaluate the contractor’s safety programs and performance prior to selection

    • Inform contractor of known potential fire, explosion, or toxic release hazards

    • Explain the emergency response plan and procedure to the contractor’s employees

    • Implement a security/access control procedure for the covered process area

    • Monitor contractor’s safety performance and maintain an injury and illness log

    • Ensure the contractor has provided its employees the required training to safely perform their duties, has briefed them on unique hazards of the facility and their scope of work, and monitors their adherence to safety rules of the facility

  • Pre Startup Safety Review (PSSR)

    • Perform a PSSR prior to introducing oil and gas/chemicals to the process

    • Verify the PSSR addresses: construction and equipment is in accordance with design specifications; safety, operating, maintenance, and emergency procedures are in place; employee training on process operation; and closure of actions from applicable PHAs

  • Mechanical Integrity

    • Develop and implement a planned maintenance system for the following: pressure vessels, storage tanks, piping systems, relief and vent systems and devices, emergency shutdown systems, controls, and pumps

    • Develop written procedures for maintenance and train the relevant personnel

    • Perform inspection and testing of process equipment following manufacturer’s instructions and RAGAGEP, and maintain records

    • Correct deficiencies and ensure equipment is safe to operate within acceptable limits

  • Hot Work Permit

    • Issue a hot work permit for hot work (e.g. welding, cutting, grinding) operations conducted on or near the covered process

    • Maintain a record of the hot work permit for the duration of the work


  • Management of Change

    • Establish a written process to manage changes to chemicals, technology, equipment, procedures, and changes to a facility that affect a covered process

    • Ensure the management of change procedure addresses technical basis for change, impact on safety and health, modifications to procedures, time period for the change, authorization of the change

    • Prior to process startup, communicate and train personnel affected by the change

    • Update operating procedures as needed

  • Incident Investigation

    • Initiate an investigation of a catastrophic process safety event or near miss within 48 hours of the event by a person who is familiar with the covered process and has been trained in formal incident investigation

    • Ensure the investigation report includes date of incident, date of investigation, event description, contributing factors, and recommendations

    • Review findings and corrective actions with the affected employees and track each to closure

    • Retain investigation reports on file for five years

  • Emergency Planning and Response

    • Implement an Emergency Action Plan for the plant, including procedures for handling small releases and hazardous waste operations, if applicable

  • Compliance Audits

    • Perform a compliance audit to verify the adequacy of the PSM program and document the findings for each element

    • Respond to each finding and document that deficiencies have been corrected

    • Retain copies of the last two audits on file


  • Trade Secrets

    • Make available any proprietary information (trade secrets) pertaining to the covered process to those involved in compiling process safety information, performing PHAs, developing operating procedures, investigating process incidents, and emergency planning and response



            Oil and gas and production is an inherently hazardous operation that requires a systematic approach to manage the health, safety and environmental risks. The consequences of a process safety event can be catastrophic not only to workers and plant, but also to the surrounding community and the business enterprise. A formal process safety management program can help to prevent or mitigate the consequences of an incident and assure operations continuity and sustainable development.


[1] Occupational Safety and Health Administration (1992). Process Safety Management rules 29 CFR 1910.119. Source Retrieved from on December 21, 2018.

[2] API Process Safety Event Public Reporting (2018). American Petroleum Institute. Retrieved from on December 21, 2018.

[3] US Environmental Protection Agency (1994), General guidance on Risk Management Programs for Chemical Accident Prevention. Retrieved from on December 21, 2018.

[4] Cullen (1990). The public inquiry into the Piper Alpha disaster. United Kingdom Department of Energy. Retrieved from on December 21, 2018.

[5] Daley, Jenine (2013). Mumbai High North platform disaster. Journal of Undergraduate Engineering, Research and Scholarship. Retrieved from on December 21, 2018.

[6] US Chemical Safety and Hazard Investigation Board (2006).  Partridge Raleigh LLC Case Study: Hot Work control and safe work practices at oil and gas production wells. Retrieved from on December 21, 2018.


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