OSHA PROCESS SAFETY MANAGEMENT (PSM)
OF HIGHLY HAZARDOUS CHEMICALS
by Sandra Noble, President
Noble & Associates Consulting,
How can industry prevent 6,000 fatalities and 4 million accidents?
These were the shocking workplace statistics for 2005. OSHA and its
Process Safety Management (PSM) program strive to improve upon these
The US Department of Labor's Bureau of Labor Statistics reported
5,702 workplace related fatalities (around 4 deaths per 100,000 workers)
and approximately 4.2 million incidents of workplace related non-fatal
injuries and illnesses. This demonstrates the continuing need for OSHA
programs and initiatives to ensure safety and health in the workplace.
Available data from the US Bureau of Labor Statistics (BLS)
highlights the fact that non-fatal workplace injuries and illnesses have
been progressively reduced from 5.3 to 4.6 cases/ 100 equivalent full
time workers, during the period 2002 to 2005. Stringent regulations for
workplace safety and the dedication of agencies enforcing the same have
made this remarkable feat a reality.
The Occupational Safety and Health Administration (OSHA), an
agency under the Department of Labor, has the primary responsibility of
developing and enforcing worker and workplace related health and safety
regulations. OSHA promotes workplace safety through a variety of ways,
including the 29 CFR 1910.119 PSM standard and the 29 CFR 1910.120
HAZWOPER standard. The essentials of the OSHA Workplace Injury and
Illness Prevention Program emanate from the provisions of these
All employers are required to implement and maintain (a) a workplace
Injury and Illness Prevention Program (IIPP), (b) an OSHA mandated
Hazard Communication Program (as per 29 CFR 1910.1200), (c) an Emergency
Action Plan (EAP) in accordance with provisions of 29 CFR 1910.38 and
(d) a Fire Protection Plan.
The EAP, orientated towards disaster management, and the IIPP, designed
for minimizing incidents, are not mutually exclusive. The two programs
complement each other and have certain common requirements. An example
of this is the recommended use of Material Safety Data Sheets (MSDS) to
identify potential hazards that may arise from the different types of
chemicals in use at the workplace. The 1910.119 PSM standard mandates
the use of MSDS, meeting the requirements of 29 CFR 1910.1200, section
An IIPP is a mechanism for reviewing and eliminating/reducing potential
hazards in the workplace. An effective IIPP can not only protect workers
but also benefit employers by reducing lost man-days and workers’
The workplace Injury and Illness Prevention Program (IIPP) can be
conveniently discussed in terms of the California-OSHA adopted IIPP.
Applicable categories of employers in California are required by law,
Title 8 (T8), of the California Code of Regulations (CCR) to have an
effective, documented Injury and Illness Prevention Program.
The Cal-OSHA mandated IIPP essentially has seven basic components. These
are: (1) identification of program implementing personnel, (2) a written
outline of the company’s system of evaluating and combating safety and
health hazards, (3) a schedule of periodic inspections, (4)
investigation procedures for workplace injuries and illnesses, (5) a
description of employee training program(s) on safe work practices and
specific job-related safety information, (6) a system for communicating
with employees on occupational health and safety matters and for
enforcing safe working practices, and (7) a retention policy for record
Records and reports (29 CFR 1904) are integral and important parts of
any effective OSHA workplace Injury and Illness Prevention Program.
Records help to identify causes of incidents and develop future
strategies for improving workplace safety. Records typically include
work-related accidents, fatalities, injuries and illnesses, incidents of
exposure to toxic or hazardous materials, Material Safety Data Sheets,
health and safety related training imparted to employees, inspections,
audits and other statutory records required for worker’s compensation,
The OSHA workplace Injury and Illness Prevention program, admittedly,
imposes meticulous requirements on employers. However the benefits that
an effective IIPP can provide far outweigh its inconveniences.
OSHA Regulation Explained
Owners & Managers
OSHA Regulation Explained For Business Owners &
Sandra Noble MBA, CPIM, Six
CDP, is president of
Noble & Associates Consulting which specializes in I.T. Needs /
Strategy Assessments, unbiased Software Selection assistance, and curing
Post Implementation Distress™. We also have full life cycle
implementation expertise in SAP, Oracle and other enterprise-wide
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Noble & Associates Consulting, Inc.