API / OSHA PSM — Process Safety Management Documentation

Example Conversation

You: We need our PSM programme documented for 29 CFR 1910.119: process safety information, PHA with scenarios and recommendations, operating procedures for all phases, MOC with technical basis, and incident investigation. Then validate coverage.

Agent: I’ll draft the PSM programme covering process safety information (PSI), process hazard analysis (HAZOP/what-if) with scenarios and recommendations, operating procedures for startup, normal, temporary, emergency, and shutdown, management of change (technical basis, safety impact), incident investigation (root cause, corrective actions, tracking), and mechanical integrity. Then I’ll run psm_element_coverage_check.

Agent: Created psm-programme.md. Running psm_element_coverage_check…

Agent: Check PASS — the document addresses the 14 PSM elements, PHA, operating phases, MOC, incident investigation, and mechanical integrity. Ready for PSM coordinator review.

What the Tools Validate

psm_element_coverage_check checks the PSM programme document for:

• 14 OSHA PSM elements — Coverage of 29 CFR 1910.119 (process safety information, PHA, operating procedures, MOC, incident investigation, mechanical integrity, etc.).
• PHA — Process hazard analysis with documented scenarios and recommendations (HAZOP, what-if, or checklist).
• Operating procedures — All phases: startup, normal operation, emergency, shutdown, with safety limits.
• MOC — Management of change with technical basis and safety impact.
• Incident investigation — Root cause, corrective actions, and tracking.
• Mechanical integrity — Programme for critical equipment (inspection, testing).

Output: PASS if all are present; otherwise FAIL with a short line per missing element. Run on the draft before finalizing; fix gaps and re-run until the check passes.

Output Excerpt

Excerpt from a generated PSM programme and sample checker report.

PSM programme (excerpt):

## Process Safety Information (PSI)

Chemical hazards: [data]. Technology of the process: P&IDs, design basis [references]. Equipment data: materials of construction, relief systems [references].

## Process Hazard Analysis (PHA)

HAZOP/what-if study completed. Scenarios: [list]. Consequences and safeguards: [summary]. Recommendations: [tracked to closure].

## Operating Procedures

Procedures cover: startup, normal operation, temporary operations, emergency shutdown, normal shutdown. Safety limits and consequences of deviation are documented for each phase.

## Management of Change (MOC)

MOC procedure requires technical basis, safety impact assessment, and required approvals. PSI and operating procedures are updated as part of MOC.

## Incident Investigation

Root cause methodology: [e.g. 5-Why, fishbone]. Corrective actions are assigned and tracked to completion.

## Mechanical Integrity

Critical equipment is identified. Inspection and testing programme: [frequency, criteria]. Documentation maintained per 29 CFR 1910.119.

psm_element_coverage_check report (excerpt):

=== PSM ELEMENT COVERAGE CHECK (29 CFR 1910.119) ===
Result: PASS

Document: psm-programme.md
PSM elements (29 CFR 1910.119) addressed.
PHA with scenarios and recommendations present.
Operating procedures covering operating phases (startup, normal, emergency, shutdown).
MOC with technical basis and safety impact.
Incident investigation with root cause and tracking.
Mechanical integrity programme for critical equipment.
PSM programme meets 29 CFR 1910.119 coverage expectations.

Getting Started

Add your source materials to the project workspace (P&IDs, PHA reports, existing procedures), then activate the API / OSHA PSM — Process Safety Management Documentation skill. The agent will guide you through drafting and validating with psm_element_coverage_check.