Unexpected releases of toxic, reactive, or flammable liquids and gases in processes involving highly hazardous chemicals have been reported for many years, in various industries using chemicals with such properties. Regardless of the industry that uses these highly hazardous chemicals, there is a potential for an accidental release any time they are not properly controlled, creating the possibility of disaster.
To help ensure safe and healthful workplaces, OSHA has issued the Process Safety Management of Highly Hazardous Chemicals standard, which contains requirements for the management of hazards associated with processes using highly hazardous chemicals.
Process safety management (PSM) is addressed in specific standards for the general and construction industries. OSHA’s standard emphasizes the management of hazards associated with highly hazardous chemicals and establishes a comprehensive management program that integrates technologies, procedures, and management practices.
OSHA has been busy when it comes to monitoring facilities with highly hazardous chemicals (HHCs). Since 2010, OSHA has issued more than 69 enforcement cases regarding Process Safety Management (PSM). The problem is, many organizations don’t understand OSHA’s PSM standard or realize if it even applies to them.
Why Did OSHA Develop PSM?
In 1991, to help ensure safe and healthy workplaces, OSHA issued the Process Safety Management of Highly Hazardous Chemicals standard (29 CFR 1910.119). This rule contains requirements of the management of hazards associated with processes using HHCs. Additionally, in January 2017, OSHA issued a new National Emphasis Program to further protect workers’ health and safety in certain industries that pose high risks to people and the environment.
To help minimize toxic occurrences, PSM was created. PSM aims to prevent the release of toxic, reactic, flammable, and explosive chemicals into the environment.
What Facilities are covered?
OSHA states that the PSM standard applies to “a process that involves a chemical at or above the specified threshold quantities (TQs) listed in Appendix A of the standard. The Appendix contains a list of toxic and reactive HHCs, which present a potential for a catastrophic event at or above the TQ. When evaluating chemicals on the list, it’s important to look at the TQ as well as checking and verifying the chemical abstract service number (CAS). This involves the entire chemical inventory, making an appropriate chemical inventory process crutial.
One important interpretation to note is that OSHA uses the phrase “on site in one location” in the standard to mean that the standard applies when a TQ of a HHC exists within an area under the control of an employer or group of affiliated employers. It also applies to any group of vessels that are interconnected or in separate vessels that are close enough in proximity that the HHC could be involved in during a potential catastrophic release.
Types of Industries Included
Any industry that processes chemicals could be included in OSHA’s PSM standard. Some examples of these industries include:
• Industrial organics and inorganics
• Sealants and fibers
• Petrochemical facilities
• Paper mills
• Food processing with anhydrous ammonia over the TQ
A company is exempt from the requirements of PSM when:
• A TQ of flammable liquids is stored in atmospheric tanks or transferred without the benefit of chilling or refrigeration.
• Hydrocarbon fuels are used solely for workplace consumption as a fuel (e.g. propane used for comfort heating or gasoline for vehicle refueling).
• Fuels are not a part of a process containing another HHC covered by this standard.
Considering the severity of the consequences that HHCs pose to the environment and the past disasters that have occurred, we only see PSM continuing to become a stronger and stronger regulation.