OSHA 29 CFR 1910.119 · EPA RMP · PHA/HAZOP · MOC
OSHA PSM software that keeps PHA, MOC and mechanical integrity in one covered-process file.
29 CFR 1910.119 puts fourteen management-system elements on the operator of a Highly Hazardous Chemical process — PSI, PHA, operating procedures, training, contractors, PSSR, mechanical integrity, hot work, MOC, incident investigation, emergency planning, compliance audits, trade secrets and employee participation. V5 replaces the PSM binder plus the MOC log plus the mechanical-integrity spreadsheet with one covered-process file the OSHA compliance officer can navigate.
PHA / HAZOP with revalidation clock
Management of Change (MOC)
Pre-Startup Safety Review (PSSR)
Mechanical Integrity programme
Full product detailCommon problems, what's included, why teams choose it, and where commercial meets regulated.
You're shopping because the last OSHA National Emphasis Program inspection cited overdue PHA revalidations and unclosed MOC actions.
PHA (HAZOP / What-If) reports live as PDFs and revalidation slips past the 5-year clock
MOC is a paper form that stalls between engineering, operations and safety
PSSR (pre-startup safety review) is a checklist nobody signs before commissioning
Mechanical integrity inspection intervals for pressure vessels, piping and PRDs live in a spreadsheet
Incident investigation actions from a near-miss last year are still open
The 3-year compliance audit turns into a paper hunt each cycle
OSHA PSM, run as one covered-process file.
PHA / HAZOP with revalidation clock
PHA (HAZOP, What-If, Checklist, FMEA, LOPA) as a live study with nodes, deviations, causes, consequences, safeguards and recommendations.
Management of Change (MOC)
MOC for technology, equipment, procedures, personnel and facilities per §1910.119(l). Impact on PHA, operating procedures, training, MI and PSI captured up front. No change closes until the training obligations are met.
Pre-Startup Safety Review (PSSR)
PSSR checklist per §1910.119(i) tied to the MOC — construction and equipment as designed, safety/operating/maintenance/emergency procedures in place, PHA recommendations resolved, training complete — with named accountability and electronic signature.
Mechanical Integrity programme
Equipment register (pressure vessels, storage tanks, piping systems, PRDs, ESD systems, pumps) with inspection/test intervals per RAGAGEP (API 510/570/653/579, NBIC), findings-to-repair workflow, and deficiency deferral with risk-based justification.
Incident investigation (§1910.119(m))
Root cause with linked recommendations, review with the workforce, resolution tracking, and 5-year record retention.
Hot work + contractors + training
Hot work permits per §1910.119(k), contractor pre-qualification and injury/illness log per §1910.119(h), operator training per §1910.119(g) with refresher every 3 years and documented competency for each covered process.
What changes the day this goes live.
- PHA revalidation stops slipping past the 5-year clock
- MOC closes with PSSR signed and training done — or it doesn't close
- Mechanical integrity intervals fire on the equipment record, not a spreadsheet
- Incident actions are tracked to closure and reviewed with the workforce
- The 3-year compliance audit is a report, not a paper hunt
The frameworks a PSM coordinator owns.
OSHA PSM — 29 CFR 1910.119
All 14 elements: employee participation, PSI, PHA, operating procedures, training, contractors, PSSR, mechanical integrity, hot work, MOC, incident investigation, emergency planning and response, compliance audits, trade secrets.
EPA RMP — 40 CFR Part 68
Risk Management Program for facilities with more than a threshold quantity of a listed regulated substance — Program 1/2/3 requirements, 5-year RMP resubmission, and the Safer Communities by Chemical Accident Prevention amendments (2024).
RAGAGEP
Recognized And Generally Accepted Good Engineering Practice — API 510 (pressure vessels), 570 (piping), 653 (tanks), 579 (FFS), NBIC, ASME B31.3 — as the inspection interval and repair basis referenced from mechanical integrity records.
OSHA PSM software, answered.
How does V5 track the PHA 5-year revalidation clock?
Every PHA study is a versioned object with an execution date, a revalidation-due date (default execution + 5 years per §1910.119(e)(6)), and a change-triggered re-open path — any MOC that touches the covered process opens the affected PHA nodes for review, so revalidation is event-driven, not just calendar-driven.
Does V5 cover EPA RMP alongside PSM?
Yes. The 14 PSM elements and the RMP Program 3 prevention programme are largely aligned. V5 lets you run one covered-process record that satisfies both, with the RMP-specific pieces (offsite consequence analysis, five-year accident history, emergency response coordination with LEPC) added on top. RMP resubmission every 5 years is tracked as a workflow.
How are Mechanical Integrity intervals decided?
Each MI-covered item references its RAGAGEP basis (API 510 for pressure vessels, API 570 for process piping, API 653 for storage tanks, API 579 for fitness-for-service, NBIC for repairs). Intervals are computed from the last inspection date, remaining life and risk classification (RBI where used), and any deferral requires a documented risk-based justification with signed approval.
What does the 3-year compliance audit produce?
A signed report per §1910.119(o) certifying the employer has evaluated compliance with each of the 14 PSM elements, with findings, promptly-addressed responses, and the two most recent audits retained. V5 assembles the evidence pack from the linked records — no separate audit binder.
Capabilities vary by plan and setup. Confirm specifics with our team before relying on them.
Run OSHA PSM on one covered-process file.
Free trial. Real PHA revalidation, real MOC / PSSR, real mechanical integrity.