OSHA created process safety management (PSM) standards to address the potentially catastrophic release of highly hazardous chemicals (HHCs) in the workplace. HHCs may be liquids or gases and are often highly reactive, toxic, corrosive, or flammable. Exposure to even small amounts of an HHC can result in serious injury, death, or health issues such as cancer, birth defects, miscarriage, and genetic damage.
Any facility storing or using HHC must comply with OSHA process safety management regulations. Chemical safety in the workplace is also regulated by the EPA, whose regulations are similar to OSHA.
Defining Process Safety Management
Different industries require very different types of chemical safety. OSHA recognizes this, and as a result process safety management regulations are written to cover all industries and any use, storage, manufacture, handling, or on-site movement of HHCs. The result is a set of fourteen interrelated PSM elements OSHA watches for when inspecting companies:
- Compliance Audits
- Emergency Planning and Response
- Employee Participation
- Hot Work Permit
- Incident Investigation
- Mechanical Integrity
- Management of Change
- Operating Procedures
- Pre-startup Safety Reviews
- Process Hazard Analysis
- Process Safety Information
In addition to employees, workplaces must keep all independent contractors informed of potential release hazards in the work environment and the steps required in the event of such a release.
Emergency Planning and Response
OSHA recognizes the risk of accident remains when dealing with HHCs no matter how well a company follows the process safety management standard. For this reason an emergency action plan is required. The plan must include emergency preplanning and training so all employees understand the plan, while remaining in accordance with other OSHA rules.
Even a small release of highly hazardous chemicals is dangerous, and can lead to more catastrophic releases. Emergency plans must include how to handle small releases.
The process safety management standard is most effectively implemented with full employee participation. This isn’t just a suggestion for increased chemical safety: OSHA requires employees be including in all aspects of PSM programs, including being represented in meetings related to PSM. A written formal employee participation plan is required.
Hot Work Permits
Any employee or contractor who welds or performs any other high temperature work on or near a covered process must be in possession of a relevant work permit. Employees and contractors alike should be trained to post and file such permits as the need arises.
All incidents that result in or could result in HHC release must be investigated. Such investigations must be initiated within 48 hours of the incident by a team with at least one person familiar with the processes involved. Investigation reports must include the following:
- Date of incident,
- Date investigation began,
- Incident description,
- Any factors contributing to incident,
- Recommendations resulting from investigation.
OSHA requires employers retain incident investigation reports for five years.
Mechanical Integrity and Chemical Safety
OSHA demands periodic documented inspections for all HHC systems, including pressure vessels, storage tanks, piping and ventilation system. Those performing inspections must be properly trained and follow engineering practices recognized by OSHA. For mechanical integrity documentation to be valid, documents must include the name of the person performing the inspection, the name/number identifying the equipment, the inspection date, the type of inspection used, and any recommendations resulting from the inspection.
Written procedures must be in place to deal with the potential release of HHCs during turnarounds and shutdowns as well as during normal or temporary operations.
Pre-Startup Safety Reviews
A process safety management program requires all safety procedures be reviewed whenever a worksite starts up, no matter how minor the interruption in work.
Process Hazard Analysis
The consequences of all possible HHC-related safety failures must be analysed by teams of engineers and maintenance leaders. To ensure chemical safety in the workplace, OSHA requires at least one person on each team understand the process hazard methodology used.
Process Safety Information
OSHA requires workers have access to all relevant information related to HCC-related risks. This includes, but is not limited to, toxicity and corrosivity information, permissible exposure limits, reactivity, thermal and chemical stability data, physical information, and a list of hazardous effects caused by mixing different chemicals.
Employers have argued in the past HHC processes represent property knowledge, and as such cannot be shared with employees. The trade secret element of process safety management states employees have the right to such information. The provision does not, however, prevent employers from requiring confidentiality or nondisclosure agreements regarding such processes.
Any employee working with HHCs must be trained in proper processes and chemical safety in the workplace. Training can be performed in-house or through third parties, but needs to be taught by competent sources and well-documented. Refresher training should be provided at least every three years. Check out our Chemical Hazards course for proper HHC training.
Employees must certify compliance with all process safety management requirements at least every three years. The audit must be performed by at least one person knowledgeable in relevant HHC processes, and document any deficiencies and problems that have been corrected. Employers must retain at least the last two audit reports on file.