protocols regarding ventilation by management to proactively identify and address any emerging concerns or new understandings about the risk posed by a given material, etc. These systems have been developed in response to the knowledge that once a hazard and its risks are brought into an environment, the risk “remains, waiting for an opportunity to happen unless the management system is actively monitoring company operations for concerns and taking proactive actions to correct potential problems” (Amyotte et al., 2007).

Having an effective management system for process-related hazards—fire, explosion, and toxic release—is therefore considered by many in the chemical process industries to be a critical corporate objective. Formally, PSM is defined as the application of management principles to the identification, understanding, and control of process hazards to prevent process-related incidents OSHA’s PSM standard, 29 CFR § 1910.119. Various approaches exist for PSM. One example is the 1989 system developed by the Center for Chemical Process Safety (CCPS, 1989), which served as the basis for a 12-element system recommended by the Canadian Society for Chemical Engineering (CSChE, 2002). More recently, the CCPS has developed guidance on a 20-element, risk-based approach to managing process safety (CCPS, 2007); see Table 7.1. Within the United States, OSHA administers Process Safety Management of Highly Hazardous Chemicals standard 29 CFR § 1910.119, which defines requirements for handling of those materials. It consists of 16 elements, 14 of which are mandatory.


As most companies do, Bayer CropScience has its own PSM system. Bayer’s 14-element system is shown in Table 7.2, with noted similarities between this system and the CCPS-developed listing in Table 7.1.

For this discussion, Bayer’s element 4, Process hazard analysis., is most relevant. This analysis consists of the following steps (Patrick Ragan, Bayer CropScience unpublished material, August 8, 2011):

1. Hazard identification (using a variety of methods including preliminary safety analysis; hazard and operability study (HAZOP); what-if review; checklist review; what-if/checklist review; fault tree analysis; event tree analysis; and failure modes, effects and criticality analysis (FMECA);

2. Severity determination;

3. Probability determination;

4. Risk assessment (using a risk matrix); and

5. Risk management (including application of risk reduction measures).

Within step five, the list of preventive safety measures given includes passive, active, and procedural measures for hazard control, but there is no specific requirement to consider ISP measures.

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