OSHA 3908-03 2017

Process Safety 

Management for 

Small Businesses
Occupational Safety and Health Act of 1970

“To assure safe and healthful working conditions 

for working men and women; by authorizing 

enforcement of the standards developed under 

the Act; by assisting and encouraging the States 

in their efforts to assure safe and healthful 

working conditions; by providing for research, 

information, education, and training in the field of 

occupational safety and health.”

This guidance document is not a standard 

or regulation, and it creates no new legal 

obligations. It contains recommendations as well 

as descriptions of mandatory safety and health 

standards. The recommendations are advisory 

in nature, informational in content, and are 

intended to assist employers in providing a safe 

and healthful workplace. The Occupational Safety 

and Health Act requires employers to comply 

with safety and health standards and regulations 

promulgated by OSHA or by a state with an 

OSHA‐approved state plan. In addition, the Act’s 

General Duty Clause, Section 5(a)(1), requires 

employers to provide their employees with a 

workplace free from recognized hazards likely to 

cause death or serious physical harm.

Material contained in this publication is in the 

public domain and may be reproduced, fully or 

partially, without permission. Source credit is 

requested but not required.

This information will be made available to 

sensory-impaired individuals upon request.

Voice phone: (202) 693-1999; teletypewriter

(TTY) number: 1-877-889-562
Process Safety Management 

for Small Businesses

U.S. Department of Labor

Occupational Safety and Health Administration

OSHA 3908-03 201
Contents

Purpose . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Examples of Small Businesses with potential 

PSM-covered processes.

Process Safety Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Process Hazard Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

PHA Development Team. .

Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Mechanical Integrity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

Compliance Audit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

APPENDIX A: Frequently Asked Questions . . . . . . . . . . . . . . . 19

APPENDIX B: Examples of PHA Methodology . . . . . . . . . . . .  2

Workers’ Rights . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  2

OSHA Assistance, Services and Programs . . . . . . . . . . . . . .  2

Establishing a Safety and Health Program. .

Compliance Assistance Specialists. .

Free On-site Safety and Health Consultation Services

for Small Business. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

Cooperative Programs. .

Occupational Safety and Health Training Courses. .

OSHA Educational Materials. .

OSHA Regional Offices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

How to Contact OSHA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  3
PROCESS SAFETY MANAGEMENT FOR SMALL BUSINESSES

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Purpose

This guidance document does not cover the entire Process 

Safety Management standard (PSM), but only focuses on 

aspects of the standard that may be particularly helpful for 

small businesses. For a full compliance guide to PSM, please 

refer to OSHA’s Process Safety Management Guide (OSHA 

3132)

1

 or the full text of the standard at www.osha.gov.

2

Although all elements of the PSM standard apply to a PSM

covered small business, the following elements of the standard 

are most relevant to hazards associated with small businesses.

■ Process Safety Information (PSI)

■ Process Hazards Analysis (PHA)

■ Training

■ Mechanical Integrity (MI)

■ Compliance Audits

PSM is critically important to small businesses with highly 

hazardous chemicals. Implementing the required safety 

programs help prevent fires, explosions, large chemical 

spills, toxic gas releases, runaway chemical reactions, and 

other major incidents. Compliance with the PSM standard 

will help ensure that employees, contractors, facility visitors, 

and emergency responders are safe from these hazards. 

Compliance will also benefit employers by minimizing damage 

to facility equipment and neighboring structures in the event of 

an HHC release. 

Managing HHCs is required by OSHA standards and a good 

business practice.3 Catastrophic HHC release events continue 

to occur among smaller companies. One study estimates that 

employers with 1-25 employees are 47 times more likely to

have a release and 17 times more likely to suffer an injury, 

per employee, than facilities with 1500 or more employees.4

1. www.osha.gov/Publications/osha3132.pdf

2. www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9760

3. See “The Business Case for Process Safety”, downloadable from www.aiche.org/ccps/about/

business-cas

4. “Process Safety Issues For Small Businesses” M. Sam Mannan, Harry H. West, Nir Keren and T. 

Michael O’Connor, Mary Kay O’Connor Process Safety Center, 2004. IChemE
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

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In addition to presenting risk to workers these companies are 

often located in populated areas, and can pose a risk to the 

surrounding population and structures.

Many small companies have the potential to realize cost 

efficiencies and savings through improved safety practices, 

such as adopting more effective work practices, inventory 

controls, storage practices, and better handling, use and 

disposal procedures, and instituting targeted PSM training to 

improve and ensure employee competence. Where possible 

and practical, finding alternative materials will help reduce 

hazards and associated risks. The approaches in this guidance 

document can help small businesses meet PSM requirements 

without creating unnecessary or additional resource burdens, 

and will give both employees and employers a better 

understanding of the standard. 

Many industry organizations have materials that may contain 

guidance for specific industries and processes. Small 

businesses may find this guidance helpful in developing a PSM 

program. Such industries include, but are not limited to:

■ Refrigeration – International Institute of Ammonia 

Refrigeration (IIAR)

■ Compressed Gasses – Compressed Gas Association (CGA)

■ Petrochemical and Chemical Manufacturers – American 

Petroleum Institute (API)

■ Chemical Manufacturers – Society of Chemical 

Manufacturers and Affiliates (SOCMA)

■ Chemical Distribution/Supply-chain – National Association

of Chemical Distributors (NACD)

■ Agricultural Wholesalers – Agricultural Retailers 

Association (ARA) & The Fertilizer Institute (TFI)

■ Chlorine users (water/wastewater treatment and others) – 

The Chlorine Institute

■ Explosives Manufacturing – Institute of Makers of 

Explosives (IME)

■ Pyrotechnics – American Pyrotechnics Association
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■ Composite Manufacturers – American Composites 

Manufacturers Association (ACMA)

■ Petrochemical Manufacturing – American Fuel and 

Petrochemical Manufacturers (AFPM) 

■ Dairy Manufacturing – The International Dairy Foods 

Association (IDFA)

■ Paint Coating  American Coatings Association (ACA

Applicability

The Process Safety Management standard covers processes 

which involve threshold quantity (TQ) of chemicals listed in 

Appendix A of the PSM standard.5 The PSM standard also 

applies to processes containing 10,000 pounds (4535.9 kg) or 

more of either a Category 1 flammable gas (as defined in 29 

CFR 1910.1200(c)) or a flammable liquid with a flashpoint below 

100 °F (37.8 °C) on site in one location, and to the manufacture 

of explosives or pyrotechnics in any quantity, except for:

■ Retail facilities

■ Hydrocarbon fuels used solely for workplace consumption 

as a fuel (e.g., propane used for comfort heating, gasoline 

for vehicle refueling), if such fuels are not a part of a 

process containing another highly hazardous chemical 

(HHC) covered by the PSM standard 

■ Flammable liquids with a flashpoint below 100 °F (37.8 °C) 

stored in atmospheric tanks or transferred which are kept 

below their normal boiling point without benefit of chilling 

or refrigeration. (Note: Atmospheric tanks are storage tanks 

designed to operate at pressures from atmospheric through 

0.5 psig)

■ Oil or gas well drilling or servicing operations

■ Normally unoccupied remote facilities6

5. Calculation of TQ for mixtures is explained in an OSHA Letter of Interpretation at www.osha.gov/

pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=30848

6. Letter of Interpretation: www.osha.gov/pls/oshaweb/owadisp.show_document?p_

table=INTERPRETATIONS&p_id=22592
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Although OSHA believes PSM will have a positive effect on 

the safety and health of employees and will offer potential 

benefits to employers such as increased productivity, smaller 

businesses with limited resources might consider alternative 

approaches to decreasing HHC-associated risks at their

workplaces. One possible approach is reducing their HHC 

inventories to below the PSM TQ by improving inventory 

control and accepting smaller deliveries. Inventory reduction 

may help reduce the consequences of a catastrophic incident. 

When reduced inventory is not feasible, the employer might 

consider dispersing inventory among several on-site locations

such that a release/incident in one location will not cause a 

release in another. 

However, reducing inventories below the PSM TQs does 

not relieve employers of their responsibility under the 

OSH Act to provide safe and healthful working conditions 

for their employees. Simply reducing inventories has no 

effect on the properties of the HHCs, which, depending on 

their use in a process, may still present hazards to workers. 

OSHA encourages employers handling HHCs who are not 

subject to the PSM standard to implement safety and health 

management systems to protect their employees. 

Small businesses may contact OSHA’s free On-site Consultation

Program for help with identifying and mitigating workplace 

hazards. OSHA’s On-site Consultation Program offers free

and confidential occupational safety and health services to 

small and medium-sized businesses in all states and several

territories, with priority given to high-hazard worksites. To locate

the OSHA On-site Consultation Program nearest you, call 1-8

321-6742 (OSHA) or visit www.osha.gov/consultation.
PROCESS SAFETY MANAGEMENT FOR SMALL BUSINESSES

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Examples of Small Businesses with potential 

PSM-covered processes

The following list contains examples of businesses potentially 

affected by the PSM standard (NAICS codes are included for 

clarity, but they are not used to determine the PSM standard’s 

applicability):

■ Asphalt Paving/Roofing Materials (NAICS 32412)

■ Chemical and Allied Products (NAICS 4246)

■ Chemical Products-Misc (NAICS 42469

■ Drugs (NAICS 4242)

■ Fabricated Metal (NAICS 332)

■ Fabricated Rubber Products, (NAICS 32521)

■ Food and Kindred Products (NAICS 31199)

■ Industrial Organic Chemicals (NAICS 32519)

■ Inorganic Chemical Manufacturing (NAICS 32518)

■ Lumber, Wood Products (NAICS 321)

■ Natural Gas Liquids (NAICS 2212)

■ Paints, Varnishes, Enamels (NAICS 3255)

■ Paper and Allied Products (NAICS 32229)

■ Plastics Products-Miscellaneous (NAICS 3261

■ Plastics, Rubber, Cellulosics (NAICS 325211)

■ Petroleum & Coal Products-Misc (NAICS 32419

■ Petroleum Refining (NAICS 32411)

■ Primary Metals Industries (NAICS 331)

■ Stone, Glass & Concrete (NAICS 21232, 3272, 3273)

■ Textile Mill Products (NAICS 3131)

■ Wholesale Trade (NAICS 42)
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Process Safety Information

Employers are required to compile written process safety 

information (PSI) about highly hazardous chemicals and 

process equipment for all PSM covered processes. Complete 

and accurate compilation of PSI is critical to the effective 

implementation of all other aspects of the PSM standard and 

will help employers and employees involved in operating the 

process identify and understand the hazards involved in their 

processes. PSI must include information concerning the hazards 

of the highly hazardous materials used, produced, stored, or 

transported on-site by/for the process, the technology of the

process, and all the equipment used in the process.

The PSI compiled by the employer must include information on 

toxicity, permissible exposure limits, physical data, reactivity 

data, corrosivity data, thermal and chemical stability data, 

and hazardous effects associated with inadvertent mixing of 

materials that may occur. Facilities are required by OSHA’s 

Hazard Communication standard (29 CFR 1910.1200) to 

maintain Safety Data Sheets (SDSs) for hazardous chemicals 

in their workplaces, which often contain some of the required 

information. If an employer does not already have SDSs, it 

must obtain them from its chemical suppliers. Employers 

should confirm that the SDSs contain all of the information 

required under PSM. 

Employers must also understand their reactive hazards, which 

can include runaway reactions, side reactions, and possible 

inadvertent interactions. For more information, the CCPS 

Reactive Material Hazards Alert7 and the NOAA/EPA/CCPS 

Chemical Reactivity Worksheet8 are excellent resources on 

chemical reactivity hazards.

Process technology information must include a block or 

simplified process flow diagram (as shown below and in 

Appendix B of the PSM standard). Block flow diagrams 

and process flow diagrams (PFDs) are used to show the 

7. www.aiche.org/sites/default/files/docs/pages/reactmat.pdf

8. www.aiche.org/ccps/resources/chemical-reactivity-worksheet
PROCESS SAFETY MANAGEMENT FOR SMALL BUSINESSES

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major process equipment and interconnecting process flow 

lines. PFDs may also show flow rates, stream composition, 

temperatures, pressures, heat exchanger duties, and the 

process heat and material balance. Employers must also 

compile information on the process chemistry, establish 

maximum intended inventory levels for process chemicals, 

safe upper and lower process limits beyond which would 

be considered upset conditions, and an evaluation of the 

consequences of deviation, including those affecting the safety 

and health of employees, that could occur if operating beyond 

the established process limits.

Figure 1. Block Flow Diagram and Process Flow Diagram,

1910.119 Appendix 

Process Flow Diagram (Sample)
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

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Block Flow Diagram (Sample)

Finally, employers must compile information on the equipment 

used in the process. This includes piping and instrument 

diagrams (P&IDs), materials of construction, electrical 

classification, relief system design and basis, ventilation 

system design, safety systems, and for processes built after 

May 26, 1992, material and energy balances.

Small businesses should find it easy to compile this information 

from existing sources and doing so will usually require minimal 

staff time. See Table 1 below for examples of potential existing 

PSI sources that may be used to fulfill requirements.
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Table 1. Existing PSI Sources and Applicabilit

Potential Existing PSI Sources Potential applicability to PSI requirements

Chemical shipping and receiving 

manifests, chemical delivery 

receipts, and associated SDSs

• Physical data;

• Reactivity data;

• Corrosivity data;

• Thermal and chemical stability data;

• Hazardous effects of inadvertent mixing of 

different materials that could foreseeably occur

Equipment design and 

operating documents

• Maximum intended inventory;

• Safe upper and lower limits for temperatures, 

pressures, flows or compositions

Manufacturer specifications • Materials of construction; 

• Equipment electrical classification (used for 

electrical classification);

• Relief device specifications ( used for relief 

system design and design basis); 

• Ventilation system design;

• Safety Systems

Job hazard analyses and 

associated SDSs

• Toxicity information;

• Permissible exposure limits;

• Hazardous effects of inadvertent mixing of 

different materials that could foreseeably occur;

• An evaluation of the consequences of 

deviations, including those affecting the safety 

and health of employees

Emergency planning information 

including assessments from, 

insurance audits, Fire Marshall 

inspections, local fire departments, 

or emergency responders

• An evaluation of the consequences of 

deviations, including those affecting the safety 

and health of employees;

• Safety Systems

Related process documents • Electrical classification; 

• Design codes and standards employed;

• Material and energy balances
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Employers must also document that all equipment complies 

with recognized and generally accepted good engineering 

practices (RAGAGEP). For more information on OSHA’s 

interpretation of RAGAGEP see OSHA Memorandum, 

RAGAGEP in Process Safety Management Enforcement.

9

 Below 

is a non-exhaustive list of institutions that publish standards

that may contain applicable process equipment RAGAGEP: 

■ American National Standards Institute (ANSI)

■ American Petroleum Institute (API)

■ American Society of Heating, Refrigeration and Air 

Conditioning Engineers (ASHRAE)

■ American Society for Testing and Materials (ASTM)

■ American Society of Mechanical Engineers (ASME)

■ American Welding Society (AWS)

■ Center for Chemical Process Safety (CCPS)

■ Compressed Gas Association (CGA)

■ Chlorine Institute (CI)

■ International Institute of Ammonia Refrigeration (IIAR)

■ International Code Council (ICC)

■ International Organization for Standardization (ISO)

■ National Association of Corrosion Engineers (NACE)

■ National Fire Protection Association (NFPA)

■ Society of Chemical Manufacturers and Affiliates (SOCMA)

Process Hazard Analysis 

A process hazard analysis (PHA) is an organized and 

systematic effort to identify and analyze the significance 

of potential hazards associated with the processing and 

handling of highly hazardous chemicals. The PHA analyzes 

the hazards of the process including potential causes and 

consequences of fires, explosions, and releases of toxic or 

flammable chemicals. The PHA must make recommendations 

for additional safeguards to adequately control identified 

hazards or to mitigate their effects, or these may be generated 

9. www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=30785
PROCESS SAFETY MANAGEMENT FOR SMALL BUSINESSES

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by post-PHA evaluations of the team’s findings. Safeguards

may include inherently safer or passive approaches to hazard 

control, new engineering controls (e.g., improved fire detection 

and suppression systems) or administrative controls (e.g., new 

operating procedures, inventory control measures, separation 

of highly hazardous chemicals into different storage areas).

Small businesses will often have processes that have fewer 

quantities of HHCs, and may be less complicated than processes 

at a large facility. Therefore, OSHA anticipates that often less 

complex PHA methodologies could be used to meet the process 

hazard analysis requirement in the standard. These process 

hazard analyses methodologies can be applied in less time 

than more complex approaches. For example, a less complex 

process could mean that less process data, fewer P&IDs, and 

less equipment information are needed to perform a process 

hazard analysis. As a result, simpler methodologies, such as 

What-if/Checklist, may be appropriate for these processes

However, some small businesses have complex processes. 

In these instances, employers must use a PHA methodology 

appropriate to the process, such as a Hazard Operability Study 

(HAZOP), or Failure Mode and Effects Analysis (FMEA). In 

such instances, small businesses may find that PHA contractor 

assistance is beneficial. 

OSHA has provided examples of two different PHA methodologies 

that small businesses can review for information and potential use. 

These two PHA examples are contained in an OSHA February 1, 

2005 letter of interpretation10 and in APPENDIX B: Examples of PHA 

Methodology of this document.

Many small businesses have processes that are not unique, 

such as ammonia refrigeration systems or water treatment 

facilities. Industry associations have developed template PHAs 

for common processes used by their membership that can be 

made site-specific for a particular facility’s process. However,

any template PHA must be customized to accurately identify 

and address the hazards of the process.

10. www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25051
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

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Moreover, small employers who use batch processes may be 

able to use a generic approach for the PHA that may help to 

further reduce the cost of compliance. For example, a generic 

PHA based on a representative batch might be used for other 

similar batches where there are only small changes in the 

process chemistry and this is documented for the range of 

batch processes. Specifically, a paint mixing batch process may 

differ only in pigment being used or slight variations in solvents 

used for each pigment. In this case, the employer may not need 

a separate PHA for every different pigment/color batch, but 

only one generic PHA that considers the overall paint mixing 

process, including all the potential amounts of solvent used, and 

potential chemical hazards of the different pigments (which may 

be similar, if not the same). However, if the batch processes are 

dissimilar, or use chemicals with substantially different hazards, 

a separate PHA would be required. Furthermore, reactive batch 

processes can be very sensitive to small changes in quantities, 

compositions, or operating conditions and may require highly 

individualized evaluations.

Employers must develop systems to promptly address hazards 

identified and the process hazard analyses’ findings and 

recommendations, document how each item was resolved, 

and inform affected employees of any process changes made.

PHAs must be updated and revalidated at least every five years 

to assure that the process hazard analysis is consistent with 

the current process.

PHA Development Team

An effective and comprehensive process hazard analysis shall 

be performed by a team with expertise in engineering and 

process operations, and the team shall include at least one 

employee who has experience and knowledge specific to the 

process being evaluated. Also, one member of the team must 

be knowledgeable in the specific process hazard analysis 

methodology being used.
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Some companies, particularly smaller ones, may not 

have the staff expertise to perform such an analysis. The 

employer, therefore, may need to hire an engineering or 

consulting company to perform and augment the analysis. 

Employers may also want to sponsor their employees in taking 

appropriate training courses or provide opportunities for 

acquiring professional experience.

Training

Employers must provide initial and refresher training to every 

employee involved in operating a PSM-covered process.

Training must cover process-specific safety and health hazards,

operating procedures, safe work practices, and emergency 

shutdown procedures. The level of training may vary for each 

employee. For example, those who work in the area or operate 

the equipment will receive more extensive training than visitors 

or other non-operational personnel who are in the general area,

who would require awareness training. Employers must also 

train contractors or temporary employees on known potential 

fire, explosion, or toxic release hazards associated with their 

work and the processes. Additional training in subjects such as 

emergency evacuation and response, routine and nonroutine 

work authorization activities, and other areas pertinent to 

process safety and health should be covered by an employer’s 

training program. Training must also be conducted in 

compliance with 1910.1200, the Hazard Communication standard 

to help employees to become more knowledgeable about the 

hazardous properties of the chemicals they work with and better 

able to read and understand SDSs. 

As most small business owners already regularly train their 

employees, OSHA does not expect that employers will need 

substantial additional effort to come into compliance with the 

PSM training requirements. All employers (both operator and 

contractor) are required to document the training given to their 

employees and document that each employee has completed 

and understood that training.
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In the training program documentation, employers should 

clearly identify the employees to be trained and the subjects to 

be covered. One non-mandatory best practice to consider is to

determine clear and measurable learning goals or objectives 

before the training begins. The employer shall ascertain that 

each employee involved in operating a process has received 

and understands the training required by this paragraph. The 

employer shall prepare a record which contains the identity 

of the employee, the date of training, and the means used 

to verify that the employee understood the training. These 

goals and objectives should be tailored to each of the specific 

training modules or segments. Employers should describe how 

the employee will demonstrate competence and knowledge as 

well as what is acceptable performance.

Employers should periodically evaluate their training programs 

to ensure the necessary skills, knowledge, and procedures 

are properly understood and implemented. Training program 

evaluation will help employers to determine the amount of 

training their employees understood, and whether the desired 

results were obtained. If, after the evaluation, it appears that 

the trained employees are not at the level of knowledge and 

skill that was expected, the employer will need to revise the 

training program, provide retraining, or provide more frequent 

refresher training sessions until the deficiency is resolved. 

Those who conducted the training and those who received 

the training should also be consulted as to how to improve the 

training process. If there is a language barrier, the language 

known to the trainees should be used.

Mechanical Integrity

The Mechanical Integrity (MI) element of the PSM standard 

requires employers to implement rigorous and systematic 

written procedures to ensure that all critical process 

equipment are properly designed, tested, inspected, repaired, 

and maintained. Mechanical integrity programs must address 

pressure vessels, storage tanks, piping systems (including 

piping components such as valves), pumps, relief and vent 

systems and devices, emergency shutdown systems, and 
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controls (including monitoring devices and sensors, alarms, 

and interlocks). While large chemical manufacturing facilities 

and petroleum refineries sometimes have hundreds—or even 

thousands—of such components, small businesses with PSM

covered processes typically have less equipment to maintain, 

making compliance easier. 

For some small businesses, the mechanical integrity section of 

the PSM standard may appear daunting. MI is often the most 

resource intensive PSM element once the PSM program is up 

and running, as components of a successful MI program may 

include tracking inspections, tests, repairs, and controlling 

spare parts and materials. In some cases, a small employer 

may already have a maintenance/inspection program for 

PSM covered equipment. These employers will simply need 

to ensure that their existing maintenance program and 

inspection frequencies are appropriate under PSM. Employers 

who do not have an MI program will first need to identify all 

critical equipment that is part of the covered process. This 

list would include pressure vessels, storage tanks, process 

piping, relief and vent systems controls, monitoring devices, 

interlocks, pumps, alarms, and emergency shutdown systems. 

In addition, some utility piping and equipment, e.g., cooling 

required to prevent run-away reactions, may be subject to MI

requirements. Employers should also consider including loss 

of containment mitigation equipment, such as fire protection 

system components, in their mechanical integrity provisions. 

In many cases, the equipment that is part of the MI program 

will have inspection and testing recommendations from the 

manufacturer. If the covered equipment does not have any MI 

related manufacturers recommendations, then employers should 

look for applicable codes/standards or industry best practices. 

Inspections and tests must follow Recognized and Generally 

Accepted Good Engineering Practices (RAGAGEP), and 

inspection and test frequency must be consistent with 

manufacturer’s recommendations and good engineering 

practices, or more frequently if indicated by operating 

experience. Applicable codes and standards such as those 
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from the American Society for Testing and Materials, 

American Petroleum Institute, National Fire Protection 

Association, American National Standards Institute, American 

Society of Mechanical Engineers, and other groups provide 

information to help establish an effective testing and 

inspection frequency, as well as appropriate methodologies. 

Employers must document each inspection and test it 

performs on critical process equipment, including the date, 

the name of the person performing the test, the serial number 

or other identifier of the equipment, a description of the test or 

inspection, and its results.

Employers must train each employee involved in the 

maintenance of the integrity of equipment used in an ongoing 

process. These employees must be provided an overview of 

the process, its hazards, and the procedures they must follow 

in their assigned tasks to ensure they can perform the tasks 

in a safe manner. This training may be covered in conjunction 

with other training required by the standard.

Equipment deficiencies outside the acceptable limits defined 

by the PSI must be corrected before further use. In some 

cases, however, it may not be necessary that deficiencies be 

corrected before further use, as long as the deficiencies are 

corrected in a safe and timely manner, when other necessary 

steps are taken to ensure safe operation. When equipment is 

determined to be deficient, a management of change (MOC) 

procedure must be established and implemented prior to 

continuing operation of the deficient equipment outside of 

established operating limits. The MOC procedure must include 

a determination of the safety and health impacts of continued 

operation of the deficient equipment.

Employers must have a quality assurance system to ensure 

that equipment, maintenance materials, and spare parts 

are suitable for the process applications in which they 

are used. Employers must make appropriate checks and 

inspections to insure that equipment is installed property and 

consistent with design specifications and the manufacturer’s 

instructions. “As built” drawings, together with documents 
PROCESS SAFETY MANAGEMENT FOR SMALL BUSINESSES

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containing testing, certification, construction, materials and 

other pertinent information should be retained in the quality 

assurance documentation. 

Compliance Audit

PSM compliance audits are used to gather sufficient facts 

and information to verify compliance with the requirements 

specified in the PSM standard. A PSM compliance audit must 

be conducted at least every three years. 

Employers must select at least one individual who is 

knowledgeable about the process to be audited. For some 

complex and/or larger processes, OSHA believes that a 

team of individuals would be beneficial for conducting an 

audit. However, for less complex and/or smaller processes 

an employer may need only one knowledgeable person to 

conduct an audit. 

The audit must include an evaluation of the compliance with 

the provisions of PSM and to verify that the procedures and 

practices developed are adequate and are being followed. The 

audit should be conducted or lead by a person knowledgeable 

in audit techniques and who can be impartial towards the area 

being audited. The essential elements of an audit program 

include planning, staffing, conducting the audit, evaluation and 

corrective action, follow-up and documentation

Planning is essential to the success of the auditing process. 

It is helpful to establish the format, staffing, scheduling and 

audit methods prior to conducting the audit. The format should 

be designed to provide the lead auditor with a procedure or 

checklist that details the requirements of each section of the 

PSM standard. The checklist, if properly designed, should 

provide the auditor with the necessary information to expedite 

the review and ensure that no requirements of the standard are 

omitted. This checklist would also identify PSM elements that 

will require evaluation or a response to correct deficiencies. 

This checklist could also be used for developing the follow-up

and documentation requirements.
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An effective audit includes a review of the relevant 

documentation and process safety information, inspection 

of the process, and interviews with employees. Using the 

audit procedure and checklist developed in the planning 

stage, the auditor can systematically analyze compliance 

with the provisions of the PSM standard. For example, the 

auditor will review operator training as part of the overall 

audit. The auditor will typically review the employer’s training 

program for adequacy of content, frequency of training, and 

effectiveness of training in terms of its goals and objectives as 

well as to how it fits into meeting the standard’s requirements. 

Through interviews, the auditor can determine the operator’s 

knowledge and awareness of the safety procedures, duties, 

rules, and emergency response assignments. During the 

inspection, the auditor can observe the operator’s actual 

implementation of practices such as safety and health policies, 

procedures, and work authorization practices. This approach 

enables the auditor to identify deficiencies and determine 

where corrective actions or improvements are needed.

The auditor must document the areas that require corrective 

action. This provides a record of the audit procedures and findings, 

and serves as a baseline for future audits. It will help future auditors 

determine changes or trends from previous audits.

Corrective action is one of the most important parts of the 

audit. The corrective action process normally begins with a 

management review of the audit findings. The purpose of 

this review is to determine what actions are appropriate, and 

to establish priorities, timetables, resource allocations and 

requirements and responsibilities. In some cases, corrective 

action may involve a simple change in procedure or minor 

maintenance effort to remedy the concern. Management of 

change procedures must be used, when required, even for 

what may seem to be a minor change. There may be instances 

where no action is necessary and this can be a valid resolution 

to an audit finding. However, all findings and corrective 

actions taken, including an explanation where no action is 
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taken, must be documented. Many employers have found that 

establishing a common system for addressing findings and 

recommendations from PHAs, Incident Investigations, and 

Compliance Audits is a cost-effective approach

APPENDIX A: Frequently Asked Questions

This appendix documents many PSM-related questions that

small businesses commonly ask of OSHA. These questions 

are meant to provide small business owners with helpful 

responses that can be used in your workplace.

“What is the Process Safety Management standard?” OSHA 

issued the Process Safety Management of Highly Hazardous 

Chemicals standard (29 CFR 1910.119), which contains 

requirements for the management of hazards associated with 

processes using highly hazardous chemicals. The standard 

is intended to help prevent or minimize unexpected releases 

of toxic, reactive, or flammable liquids and gases associated 

with these processes by emphasizing the establishment 

of a comprehensive management program that integrates 

technologies, procedures, and best management practices.

“Why is the PSM standard necessary?” Regardless of the 

industry using highly hazardous chemicals, there is a potential 

for a release of these chemicals any time the processes is not 

properly controlled. Properties of these chemicals may be 

toxic, reactive, flammable, or explosive, or they may exhibit 

a combination of these properties. These releases have the 

potential to cause significant damage to property and to 

severely or fatally injure individuals in the workplace.

“How do I know if my worksite is covered by the PSM 

standard?” You are required to comply with the PSM if you 

use, manufacture/produce, store, handle, or are involved in 

the on-site movement of chemicals that are on the List of

Highly Hazardous Chemicals (29 CFR 1910.119 Appendix A) 

at or above the threshold quantity set by OSHA; have a 

process which involves a flammable liquid or gas in a quantity 
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of 10,000 pounds or more; or manufacture explosives or 

pyrotechnics in any quantity. However, OSHA exempts three 

types of facilities from the PSM standard: retail facilities; oil 

or gas well drilling or servicing, and normally unoccupied 

remote facilities. Additionally, hydrocarbon fuels used solely 

for workplace consumption as a fuel (e.g., propane used for 

comfort heating, gasoline for vehicle refueling); and flammable 

liquids with a flashpoint below 100 °F (37.8 °C) stored in 

atmospheric tanks or transferred and kept below their normal 

boiling point without benefit of chilling or refrigeration, are 

also exempt from PSM if such fuels are not a part of a process 

containing another highly hazardous chemical (HHC) covered 

by the PSM standard. 

“What industries does the rule cover?” OSHA’s standard applies 

to a wide range of industries–particularly those pertaining to 

chemicals, transportation equipment, and fabricated metal 

products. Other affected sectors include those involved with 

natural gas liquids, chemical warehousing, food processing, 

electric, gas, sanitary services, and wholesale trade. The standard 

also applies to pyrotechnics and explosives manufacturers.

“Does PSM apply to non-manufacturing facilities?” Yes, the 

PSM standard can apply to non-manufacturing processes

such as in the refrigeration industry, and services industries 

such as food and sanitation, and chemical warehousing and 

distribution industries. In fact, many PSM-covered processes

involve a non-manufacturing application of HHCs

“What does the PSM standard require?” The PSM standard 

starts with a compilation of process safety information, 

followed by a process hazard analysis (PHA). A PHA consists 

of a careful and thorough review of what could go wrong and 

what safeguards must be implemented to prevent releases of 

highly hazardous chemicals. In addition to the PHA, the standard 

also mandates development of written operating procedures, 

completion of relevant employee training, encouraging and 

ensuring employee participation (according to a written plan), 

pre-startup safety reviews, evaluation of the mechanical

integrity of critical equipment, contractor requirements, and 
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a written management of change process. It also requires a 

permit system for hot work, investigation of incidents involving 

releases of covered chemicals or “near-misses,” emergency

action plans, compliance audits at least every three years, 

and allows for trade secret protection as long as the relevant 

information remains available to applicable parties.

“Why do I need a written Process Safety Management 

program?” A written PSM program assists employers and 

their workers in the development and uniform implementation 

of PSM activities across their organization. EPA’s Risk 

Management Program rule also mandates that covered 

employers submit a “Risk Management Plan” to their agency. 

OSHA’s PSM standard requires written documentation for a 

number of elements, including employee participation, process 

safety information, process hazards analysis, operating 

procedures, operator training, contractor training, hot work 

permits, mechanical integrity, management of change, incident 

investigations, emergency planning and response, and 

compliance audit elements. 

“What are the design and maintenance standards I will 

have to follow at my facility?” The PSM standard references 

recognized and generally accepted good engineering Practices 

(RAGAGEP). Businesses must be able to demonstrate that their 

PSM-covered processes are designed and constructed to meet

requirements of the applicable engineering standards (e.g., 

ASME, API, ANSI). The facility is responsible for selecting the 

RAGAGEP, and demonstrating how its processes are built to 

the appropriate design standards and have been maintained 

in accordance with those standards. See OSHA’s Regional 

Administrators Memorandum on RAGAGEP enforcement.

11

“Who should receive PSM training?” The PSM standard 

requires specific training for all employees involved in 

operating a PSM-covered process. Operating employees

must complete initial training followed by refresher training 

at least every three years. Training of operators and contract 

11. www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=29414
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

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employees must be documented to demonstrate that the 

employee has received and understood the applicable 

information. Maintenance personnel and contractors also must 

receive training under the standard.

“I am a contractor on a PSM-covered worksite. Do I need 

PSM training?” Yes. Contract employees and their employers 

must meet the applicable requirements under the PSM 

standard, including training. The standard outlines specific 

responsibilities for both the employer and contract employer 

to ensure the safety of the contract employees and the proper 

operation of the process.

“Can small businesses receive help developing, initiating and 

instituting a PSM program?” Yes. OSHA’s On-site Consultation

Program offers free and confidential occupational safety and 

health services to small and medium-sized businesses in

all states and several territories, with priority given to high

hazard worksites. On-site Consultation services are separate

from enforcement and do not result in penalties or citations. 

Consultants from state agencies or universities work with 

employers to identify workplace hazards, provide advice on 

compliance with OSHA standards, and assist in establishing 

and improving safety and health programs. To locate the 

OSHA On-site Consultation Program nearest you, call 1-8

321-6742 (OSHA) or visit www.osha.gov/consultation.

“Where can I learn more about the PSM standard and its 

requirements?” In addition to this publication, you may refer to 

29 CFR 1910.119 for specific requirements of the PSM standard, 

which is available on the OSHA website (osha.gov). OSHA 

offers two other publications that provide information about the 

PSM standard and its application: Process Safety Management 

(OSHA 3132) and Process Safety Management–Guidelines 

for Compliance (OSHA 3133); both are available, on the OSHA 

web site. Small businesses may contact OSHA’s free On-site

Consultation Program for help with identifying and mitigating 

workplace hazards. OSHA’s On-site Consultation Program offers

free and confidential occupational safety and health services 
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to small and medium-sized businesses in all states and several

territories, with priority given to high-hazard worksites. To locate

the OSHA On-site Consultation Program nearest you, call 1-8

321-6742 (OSHA) or visit www.osha.gov/consultation

“What are a few key safety management practices all 

employees should know?” All potentially affected employees 

should know the hazards related to storing, mixing or 

processing chemicals. Employees should know how each of 

their processes work. They should also know when equipment 

is operating improperly or outside safe limits. If equipment is 

not operating properly or an emergency occurs, they should 

know how to respond and who to contact.

“What is the EPA Risk Management Plan (RMP)?” EPA 

regulations and guidance for chemical incident prevention at 

facilities that use certain hazardous substances are contained 

in the RMP rule (40 CFR Part 68). The information required from 

facilities under RMP helps local fire, police, and emergency 

response personnel prepare for and respond to chemical 

emergencies. Making RMPs available to the public also fosters 

communication and awareness to improve incident prevention 

and emergency response at the local level.

“Who must submit an RMP and how often?” Facilities using 

more than a threshold quantity of any chemical found in the 

List of Regulated Substances (40 CFR 68.130) in a process 

are required to comply with EPA’s Risk Management Plan 

regulations. The regulations require owners or operators of 

covered facilities to implement a risk management program 

and to submit an RMP to EPA. RMPs must be revised and 

resubmitted to EPA every five years.

“How is RMP different from PSM?” The requirement for 

development of RMPs is established by the Clean Air Act (as is 

the requirement for PSM), and is primarily intended to protect 

the population outside a facility. PSM is intended to protect 

employees at the facility. The RMP rule is administered and 

enforced by the EPA, while PSM is administered and enforced 
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by OSHA. The RMP rule requires facilities to submit plans to the 

EPA and local emergency responders so that they are aware of 

potential environmental and exposure risks when responding to 

an incident. Otherwise, the standards are nearly identical. 

“What chemicals must be reported under RMP?” Any 

chemical identified by EPA’s RMP List of Regulated Substances 

(40 CFR 68.130) that is present in more than a threshold 

quantity must be reported under RMP. Many of the chemicals 

on this list are also found on OSHA’s List of Highly Hazardous 

Chemicals (29 CFR 1910.119 Appendix A).
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APPENDIX B: Examples of PHA 

Methodology
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OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

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Workers’ Rights

Under federal law, workers are entitled to working conditions 

that do not pose a risk of serious harm. 

For more information on how to assure a safe and healthful 

workplace, see OSHA’s Workers page.

OSHA Assistance, Services and Programs 

OSHA has a great deal of information to assist employers 

in complying with their responsibilities under OSHA law. 

Several OSHA programs and services can help employers 

identify and correct job hazards, as well as improve their 

safety and health program.

Establishing a Safety and Health Program

Safety and health programs are systems that can substantially 

reduce the number and severity of workplace injuries and 

illnesses, while reducing costs to employers. 

Visit www.osha.gov/shpguidelines for more information.

Compliance Assistance Specialists

OSHA Compliance assistance specialists can provide 

information to employers and workers about OSHA standards, 

short educational programs on specific hazards or OSHA rights 

and responsibilities, and information on additional compliance 

assistance resources. 

Visit www.osha.gov/dcsp/compliance_assistance/cas.html or 

call 1-800-321-OSHA (6742) to contact your local OSHA offi

Free On-site Safety and Health Consultation 

Services for Small Business

OSHA’s On-site Consultation Program offers free and confidential

advice to small and medium-sized businesses in all states across

the country, with priority given to high-hazard worksites. On-sit

consultation services are separate from enforcement and do not 

result in penalties or citations. 
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For more information or to find the local On-site Consultation

office in your state, visit www.osha.gov/consultation, or call 

1-800-321-OSHA (674

Under the consultation program, certain exemplary 

employers may request participation in OSHA’s Safety 

and Health Achievement Recognition Program (SHARP). 

Worksites that receive SHARP recognition are exempt from 

programmed inspections during the period that the SHARP 

certification is valid.

Cooperative Programs

OSHA offers cooperative programs under which businesses, 

labor groups and other organizations can work cooperatively 

with OSHA. To find out more about any of the following 

programs, visit www.osha.gov/cooperativeprograms.

Strategic Partnerships and Alliances

The OSHA Strategic Partnerships (OSP) provide the opportunity 

for OSHA to partner with employers, workers, professional or 

trade associations, labor organizations, and/or other interested 

stakeholders. Through the Alliance Program, OSHA works with 

groups to develop compliance assistance tools and resources 

to share with workers and employers, and educate workers and 

employers about their rights and responsibilities.

Voluntary Protection Programs (VPP)

The VPP recognize employers and workers in private industry 

and federal agencies who have implemented effective safety and 

health management programs and maintain injury and illness 

rates below the national average for their respective industries.

Occupational Safety and Health Training Courses

The OSHA Training Institute partners with 27 OSHA Training 

Institute Education Centers at 42 locations throughout the United 

States to deliver courses on OSHA standards and occupational 

safety and health topics to thousands of students a year. For more 

information on training courses, visit www.osha.gov/otiec.
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

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OSHA Educational Materials

OSHA has many types of educational materials to assist employers 

and workers in finding and preventing workplace hazards. 

All OSHA publications are free at www.osha.gov/publications and 

www.osha.gov/ebooks. You can also call 1-800-321-OSHA (674

to order publications.

Employers and safety and health professionals can sign-up for

QuickTakes, OSHA’s free, twice-monthly online newsletter with

the latest news about OSHA initiatives and products to assist 

in finding and preventing workplace hazards. To sign up visit 

www.osha.gov/quicktakes. 
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OSHA Regional Offices

Region I

Boston Regional Office

(CT*, ME, MA, NH, RI, VT*) 

JFK Federal Building, Room E340

Boston, MA 02203

(617) 565-9860 (617) 565-9827 Fa

Region II

New York Regional Office

(NJ*, NY*, PR*, VI*)

201 Varick Street, Room 670

New York, NY 10014

(212) 337-2378 (212) 337-2371 F

Region III

Philadelphia Regional Office

(DE, DC, MD*, PA, VA*, WV)

The Curtis Center

170 S. Independence Mall West

Suite 740 West

Philadelphia, PA 19106-330

(215) 861-4900 (215) 861-4904 F

Region IV 

Atlanta Regional Office

(AL, FL, GA, KY*, MS, NC*, SC*, TN*)

61 Forsyth Street, SW, Room 6T50

Atlanta, GA 30303

(678) 237-0400 (678) 237-0447 F

 

Region V

Chicago Regional Office

(IL*, IN*, MI*, MN*, OH, WI)

230 South Dearborn Street 

Room 3244

Chicago, IL 60604

(312) 353-2220 (312) 353-7774 F
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

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Region VI

Dallas Regional Office

(AR, LA, NM*, OK, TX)

525 Griffin Street, Room 602

Dallas, TX 75202

(972) 850-4145 (972) 850-4149 F

(972) 850-4150 FSO Fa

Region VII

Kansas City Regional Office

(IA*, KS, MO, NE)

Two Pershing Square Building

2300 Main Street, Suite 1010

Kansas City, MO 64108-241

(816) 283-8745 (816) 283-0547 F

Region VIII

Denver Regional Office

(CO, MT, ND, SD, UT*, WY*)

Cesar Chavez Memorial Building

1244 Speer Boulevard, Suite 551

Denver, CO 80204

(720) 264-6550 (720) 264-6585 F

Region IX 

San Francisco Regional Office

(AZ*, CA*, HI*, NV*, and American Samoa, 

Guam and the Northern Mariana Islands)

90 7th Street, Suite 18100

San Francisco, CA 94103

(415) 625-2547 (415) 625-2534 F

Region X

Seattle Regional Office

(AK*, ID, OR*, WA*)

300 Fifth Avenue, Suite 1280

Seattle, WA 98104

(206) 757-6700 (206) 757-6705 F
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* These states and territories operate their own OSHA

approved job safety and health plans and cover state and local 

government employees as well as private sector employees. 

The Connecticut, Illinois, New Jersey, New York and Virgin 

Islands programs cover public employees only. (Private sector 

workers in these states are covered by Federal OSHA). States 

with approved programs must have standards that are identical 

to, or at least as effective as, the Federal OSHA standards.

Note: To get contact information for OSHA area offices, OSHA

approved state plans and OSHA consultation projects, please visit 

us online at www.osha.gov or call us at 1-800-321-OSHA (674

How to Contact OSHA

For questions or to get information or advice, to report an 

emergency, fatality, inpatient hospitalization, amputation, 

or loss of an eye, or to file a confidential complaint, contact 

your nearest OSHA office, visit www.osha.gov or call OSHA 

at 1-800-321-OSHA (6742), TTY 1-877-889

For assistance, contact us

We are OSHA. We can help
For more information:

Occupational

Safety and Health

Administration

www.osha.gov (800) 321-OSHA (6742)

U.S. Department of Lab