Chemical Hazards Process Safety Management
Specific OSHA Requirements
A detailed explanation of the requirements of the Process Safety Management Standard is beyond the scope of this adviser. The user is encouraged to consult the standard itself and other references listed below.
- 29 CFR 1910.119, Process safety management of highly hazardous chemicals. OSHA Standard. Also see the appendices.
- Process Safety Management (PDF). OSHA Publication 3132, (2000).
- Process Safety Management Guidelines for Compliance (PDF). OSHA Publication 3133, (1994).
- Process Safety Management of Highly Hazardous Chemicals -- Compliance Guidelines and Enforcement Procedures. OSHA Directive CPL 02-02-045 [CPL 2-2.45A CH-1], (September 1, 2015).
- Process Safety Management for the Poultry Industry - A Compliance Guide. The Safety, Health and Ergonomics Branch, Georgia Tech Research Institute, (1996).
The major objective of OSHA's Process Safety Management (PSM) Standard is to prevent unwanted releases of hazardous chemicals, especially into locations that could expose employees and others to serious hazards.
What chemicals are covered by the Process Safety Management Standard?
The standard covers specific listed highly hazardous chemicals when present in a process in quantities at or above the threshold quantities listed in Appendix A of the standard.
In addition, flammable liquids or gases in quantities of 10,000 pounds or more are covered unless they are used solely for heating or fuel.
What chemicals used in the poultry processing industry may be covered by the Process Safety Management Standard?
Chemicals used in the poultry processing industry that may be covered include:
- ammonia (anhydrous), used in standard mechanical refrigeration systems, if 10,000 pounds or more
- chlorine, used for disinfecting water treatment systems, if 1500 pounds or more
- hydrochloric acid, used in wastewater treatment systems, if 5000 pounds or more
Propane (LPG) is exempted from coverage if it is used strictly as a fuel and is not associated with any other process or system that uses any other "highly hazardous chemical" above the threshold quantity.
What must employers do to comply with the Process Safety Management Standard?
A brief listing of the steps and activities that employers must take includes the following (for each process, where applicable):
- Compile written process information, including information on
- the hazards of the highly hazardous chemicals used or produced by the process
- the technology of the process
- the equipment in the process.
- Perform a process hazard analysis using 1 or more of methods specified in the standard, and update and revalidate the analysis every 5 years. The process hazard analysis will review what could go wrong and what safeguards must be implemented to prevent releases of hazardous chemicals.
Process
Any activity involving a highly hazardous chemical including using, storing, manufacturing, handling, or moving such chemicals at the site, or any combination of these activities. For purposes of this definition, any group of vessels that are interconnected, and separate vessels located in a way that could involve a highly hazardous chemical in a potential release, are considered a single process.
- Develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process.
The procedures will address
- steps for each operating phase (startup, normal operation, emergency shutdown, etc.)
- operating limits
- safety and health considerations
- work activities such as lockout/tagout and entrance into a facility by contractor personnel.
- Develop a written plan of action to implement the employee participation required by the standard.
- Implement an effective training program
- initial training
- refresher training
- training documentation.
- Establish a program for evaluating a contract employer's safety performance and programs, informing the contract employer of information about the process and emergency procedures needed for safe work, and maintaining a contract employee injury and illness log.
- Perform a pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information.
- Establish and implement written procedures to maintain the ongoing mechanical integrity of process equipment.
- Require the issuance of a permit for hot work operation conducted on or near a covered process.
- Establish and implement written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process.
- Investigate within 48 hours or sooner each incident that resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical in the workplace and establish a system to promptly address and resolve the incident report findings and recommendations.
- Develop an emergency action plan in accordance with 29 CFR 1910.38(a) and include procedures for handling small releases of hazardous chemicals; 29 CFR 1910.120 - Hazardous Waste Operations and Emergency Response, may also apply.
- Conduct compliance audits at least every 3 years to verify that the procedures and practices developed under the standard are adequate and that they are being followed.
- Provide all required information for the above steps without regard to trade secret status; confidentiality agreements may be implemented to protect an employer's trade secrets.