OSHA PSM Enforcement is Increasing: Are You Prepared?
By: James Junkin, Contributor
While the Occupational Safety and Health Administration Process Safety Management (OSHA PSM) standards have been in place for 30 years, enforcement of the existing rules often comes down to White House priorities — which change with each administration.
The current administration has increased fines, and the President’s budget proposal calls for hiring an additional 207 OSHA enforcement employees and 63 new whistleblower investigators in the near future.
These efforts have chemical and manufacturing plants concerned, causing a debate on whether you must comply, and how to create sound procedures to avoid hefty OSHA citations as well as keep your workers safe.
Is my facility covered by PSM?
PSM most directly applies to companies handling more than 130 reactive and toxic chemicals, or flammable gases and liquids of 10,000 pounds or more. Industrial plants that make organics and inorganics, paint manufacturers, large pharmaceutical companies, manufacturers of adhesives and sealants, paper mills, food processors — all may be covered under PSM. Coverage depends on chemical inventory and weight listed in OSHA’s Appendix A of 29 CFR 1910.119.
Develop a chemical inventory with quantities to determine if PSM coverage applies to you. Any chemicals handled by your facility must tick both boxes on Appendix A, type and weight. If they exceed the defined limits in one location, you’re covered under PSM.
If the chemical’s threshold quantity is stored in atmosphere tanks or without the benefit of chilling or refrigeration, or if you’re using fuels that aren’t part of the process of your facility (e.g., diesel fuel onsite used for refueling), then your facility may be excluded from PSM.
Eight things you need to do to avoid an OSHA PSM citation
Once you determine that the PSM standard applies to your facility, you need to follow the right protocols to avoid a citation and remain compliant. Here’s how:
- Form a PSM committee. Include process engineers, senior management, operators, safety and maintenance professionals, and outside consultants, if necessary to receive a well-rounded amount of perspective on safety procedures.
- Document everything. Make sure there’s adequate feedback and back-and-forth discussion between your working committee and those in higher management. Document all happenings and make sure there is a record.
- Have a written plan. Define committee members’ duties and responsibilities, who they report to, and how they’ll control PSM documentation. The latter is ripe for human error. Once an error is introduced, it can be replicated over and over and become difficult to find or undo, or worse, it can lead to a disaster.
- Track progress. Determine how often the committee will meet. Define a feedback loop between the committee and senior management.
- Update data. Use whatever methods are available to get the most current data in front of decision makers. Outdated and old data can lead to further mistakes and missteps down the line.
- Collect toxicity information. Use the National Institute for Occupational Safety Health (NIOSH) pocket guide or the American Conference of Government In Health Guide to Occupational Exposures Values to evaluate safety data and toxicity levels for each chemical listed on your inventory. Figure out permissible exposure limits for each chemical and think about the hazardous effects of inadvertently mixing different materials. For example, a person could die from just one drop of hydrogen fluoride.
- Create a block safety diagram or process flow diagram. A process flow diagram helps you analyze where danger might lurk. You’ll need individual diagrams showing how each chemical moves through a facility—the more chemicals you use the more difficult this task will be. Determine what the committee should be reviewing—piping materials, process and instrument drawings, electrical classifications, ventilation, mechanical processes. Use the information to brainstorm what-if scenarios. Can we ventilate the chemical if we have a release, so we don’t kill everyone in the safety plant?
- Do a Process Hazard Analysis (PHA). The key to process safety management. PHA helps identify, evaluate and control hazards involved in the process. As you develop PHA, you’ll run through many what-if scenarios: What if ‘X’ fails? What if we get hit by lightning? What if we’re along the coast and get a storm surge? Brainstorm responses and use that information to develop a checklist. Follow up with hazard and operability studies (haz opps) and failure mode and effects analysis (FMEA).
Chemicals are serious business – Do PSM right
Once you’ve made your determinations, it’s time to make changes. There will be inspections, testing, training and change management to deal with down the road. The latter is particularly difficult as the standard requires you to describe how you will manage change and all stakeholders must have input.
Chemicals are serious business. People die when things aren’t communicated correctly. Putting in place the aforementioned eight building blocks to the 14-element PSM standard will set you on a path to increased safety for your employees, your facilities and the environment. WMHS
James Junkin, CSP, SMS, CSHO is a master trainer for Veriforce. He holds a degree in Occupational Safety & Health and is a noted author and much sought-after trainer and speaker. As noted above, Junkin holds the Safety Management Specialist (SMS) and the Associate Safety Professional (ASP) designations from the Board of Certified Safety Professionals. For more information about Veriforce, visit www.veriforce.com.
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