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OSHA Process Safety Management (29 CFR 1910.119)

Process Safety Information (PSI)

The chemistry, technology, and equipment information for your process kept current and accessible to the people who need it

Strategic context

What this element is and why it matters

OSHA PSM at 1910.119(d) is the foundational documentation element. It is the compiled body of written process safety information that the employer has to complete before conducting any process hazard analysis. The information falls into three groups. Paragraph (d)(1) covers chemical hazard information such as toxicity, permissible exposure limits, physical data, reactivity, and corrosivity. Paragraph (d)(2) covers technology information including the block flow diagram, process chemistry, maximum intended inventory, safe operating limits, and the consequences of deviation. Paragraph (d)(3) covers equipment information such as materials of construction, P&IDs, electrical area classification, relief device sizing, and design codes. Our team assembles this so it is complete, accurate, and genuinely usable.

Process Safety Information (PSI)

Individual significance for organisations

The quality of this information directly sets the quality of every downstream PSM decision your facility makes. With accurate and current information your team runs hazard analyses that catch real scenarios, manages change in a way that captures the real implications, and investigates incidents in a way that reaches the real causes. When the information goes stale it acts like a slow leak that empties the management system over time, and keeping it current is one of the most valuable things we help you do.

Contribution to OSHA Process Safety Management (29 CFR 1910.119)

Paragraph (d) is the prerequisite that process hazard analysis in (e), operating procedures in (f), mechanical integrity in (j), and management of change in (l) all depend on. OSHA explicitly requires this information to be complete before any hazard analysis is run. It is also the single most cited PSM finding in OSHA enforcement actions, because stale P&IDs, missing relief calculations, and incomplete chemical hazard data are the silent enablers of failure in every other element.

Key requirements

What compliant execution looks like

Chemical hazard information under (d)(1) covering safety data sheets, GHS classification, reactivity, and toxicity
Process technology information under (d)(2) covering the block flow diagram, chemistry, inventory, and operating limits
Equipment information under (d)(3) covering materials of construction, P&IDs, area classification, relief sizing, and codes
Completion of this information before any hazard analysis as the (d) preamble requires
Integration with management of change so the information stays current
Accessibility of the information to the workforce and to contractors
Implementation methodology

How we implement this element

A focused six step methodology calibrated to deliver process safety information (psi) as a working capability rather than a documented compliance artefact.

Information Inventory Baseline

We catalogue the information required under (d)(1), (d)(2), and (d)(3) and identify gaps, version control issues, and any constraints on access.

Chemical Hazard Information

To meet (d)(1) we compile safety data sheets, GHS classification, toxicity data, physical properties, and reactivity assessed against CHETAH and Bretherick.

Technology Information

To meet (d)(2) we assemble the block flow diagram, process chemistry, maximum intended inventory, safe upper and lower limits, and the consequences of deviation.

Equipment Information

To meet (d)(3) we compile materials of construction, P&IDs, electrical classification, relief device sizing to API 520 and 521, ventilation, and design codes.

Change and Update Discipline

We specify the management of change trigger for updating the information, enforce the update before change closure, and track currency as a leading indicator.

Operator Access Provision

We make sure operating teams can reach the information relevant to their unit and integrate it with your document system and shift handover.

Implementation flow

Element implementation flow chart

A decision gated workflow that shows the actual sequence of activities from initiation through steady state operation, with key decision points highlighted.

Start
Baseline review of the process safety information initiated
Chemical Information (d)(1)
Safety data sheets, GHS, toxicity, and reactivity for each compound
Technology Information (d)(2)
Block flow diagram, chemistry, inventory, operating limits, and consequence of deviation
Equipment Information (d)(3)
Materials of construction, P&IDs, area classification, relief sizing, and codes
P&ID Walk Down
Field verification and as built markup
Decision
Gap Identified?
Decision gate
Gap Closure
Engineering work to close the missing information
Change Trigger Specification
Information update enforced before any change is closed out
Access Mechanism Verification
Operator and contractor access tested
Currency Dashboard
Monthly tracking that signals readiness for hazard analysis
Deliverables

What we produce

  • A chemical hazard information dossier meeting (d)(1)
  • A technology information pack meeting (d)(2)
  • An equipment information register meeting (d)(3)
  • A P&ID and process flow diagram set verified by field walk down
  • Relief device sizing calculations
  • An update procedure for the information with a management of change trigger
Common pitfalls

Where execution fails

  • P&IDs marked as built while the field reality has already drifted further
  • Relief calculations done at original design and never recalculated after a change
  • Chemical hazard data missing for newer materials
  • Operator access blocked by document classification
Standards & references

Codes this element is built on

OSHA 29 CFR 1910.119(d) (Process Safety Information, US)API RP 520, 521, and 2000 (Relief Device and Tank Venting)API RP 584 (Integrity Operating Windows)IEC 60079 and API RP 500 (Hazardous Area Classification)MSIHC Rules 1989 Schedule 1 (India)ISO 45001 2018 Clause 7.5 (Documented Information)
Implement this element

Talk to us about implementing Process Safety Information (PSI)

We can scope this element implementation against your facility, regulatory context, and existing management system maturity, then integrate it with the other OSHA Process Safety Management (29 CFR 1910.119) elements you already operate.