Process Safety Management: Are you covered by OSHA's standard?

OSHA is increasingly focused on enforcement of its Process Safety Management (PSM) of Highly Hazardous Chemicals (HHC) standard (29 CFR 1910.119), with recent emphasis programs addressing the issue. But, how do you know if your operations are covered under this standard? The answer is not always easy to determine.

For many types of operations, for example chemical facilities, it may be obvious that OSHA’s PSM standard applies. But, there are numerous other types of operations, such as food manufacturers, that can also fall under the PSM requirements.

It is important for all establishments who have chemical processes to assess their operations for coverage under the PSM standard. Employers who are covered must implement very strict controls and adhere to a rigorous set of operating procedures.

Who is covered under PSM?

The OSHA PSM standard applies to establishments having a “process” that involves either of the following:

[pullquote]
• A 1910.119 Appendix A-listed chemical at or above the specified “threshold” quantities (i.e., the amount, in pounds, necessary at any one point in time for coverage under the PSM standard) — There are over 130 chemicals in Appendix A, with threshold quantities ranging from 50 pounds to 15,000 pounds depending on the substance.
• 10,000 pounds or more of any flammable liquid or gas on site in one location. Note: If an Appendix A-listed HHC is a flammable liquid or gas, the coverage threshold is the lower of the following amounts: the threshold quantity specified in Appendix A or 10,000 pounds.

Under PSM, a “process” includes almost any activity involving a highly hazardous chemical, including any use, storage, manufacturing, handling or the on-site movement of these chemicals, or combination of these activities.

The definition of “process” also extends beyond a simple tank and includes interconnected vessels, as well as separate vessels that could impact each other if a release were to occur.

Exemptions

There are some exemptions for certain processes and facilities that otherwise would fall under the PSM standard. These exemptions are:

• Covered flammable liquid/gas process involving hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling), if the fuels are not a part of a process containing another HHC;
• Flammable liquids that are transferred or stored in “atmospheric tanks,” including 55-gallon drums, and that are kept below their normal boiling point without benefit of chilling or refrigeration;
• Retail facilities; 
• Oil or gas well drilling or servicing operations; or
• Normally unoccupied remote facilities.

If a facility is covered…

If a facility does fall under PSM there are numerous requirements that have to be met. This includes:

• Implementing a written plan for employee participation,
• Compiling Process Safety Information (PSI),
• Performing Process Hazard Analyses (PHA) using prescribed methodologies,
• Establishing operating procedures,
• Training employees,
• Evaluating contractors and sharing information,
• Performing pre-start up safety reviews,
• Developing written procedures to maintain the ongoing integrity of process equipment,
• Issuing hot work permits for work around processes,
• Establishing written procedures for managing changes to processes,
• Investigating incidents,
• Implementing emergency procedures, and
• Conducting triennial compliance audits.

Employers should take a look at any operations involving highly hazardous chemicals to determine applicability under the PSM standard. Complying with the PSM standard takes time and many resources. Start by asking: Do we have a covered process?