OSHA PROCESS SAFETY MANAGEMENT (PSM)
OF HIGHLY HAZARDOUS CHEMICALS
by Sandra Noble, President
Noble & Associates Consulting,
Disaster in the workplace is a
constant possibility for people working with dangerous chemical
compounds. OSHA’s Process Safety Management (PSM) program seeks to
minimize the impact of catastrophic release of chemicals that could cost
lives and cause serious destruction.
Industries using hazardous chemicals (“Dangerous Products” in
European parlance) in their processes are especially vulnerable to
accidents. These substances include the possibility of unforeseen and
even catastrophic release of toxic or inflammable liquids and gases.
Catastrophic release is defined as a major uncontrolled emission, fire,
or explosion, involving one or more highly hazardous chemicals, that
presents serious danger to employees in the workplace.
Recognizing these vulnerabilities, agencies such as the
Occupational Safety and Health Administration (OSHA), and the
Environmental Protection Agency (EPA),
have developed enforceable regulatory frameworks for workplace safety
and health, including penalties for non-compliance. This framework
includes documenting information pertaining to the hazards of the highly
hazardous chemicals used and/or produced and information pertaining to
the technology and equipment used in the manufacturing process. A
written plan of action detailing the safety measures being applied must
also be provided.
OSHA has the primary function and the authority to develop and implement
rules and regulations aimed at protecting workers in their workplaces.
One of the most important such initiatives is the standard for Process
Safety Management (PSM). The PSM is officially known as the 29 CFR
1910.119, Process Safety Management of Highly Hazardous Chemicals.
It lays down detailed criteria which have to be followed for the
prevention of any potential disaster due to catastrophic releases of
toxic, reactive, flammable, or explosive chemicals and for the
minimization of the consequences of such incidents.
While there are specific PSM Standards for the construction and general
industries, the OSHA Standard essentially applies to the management of
risks related to highly hazardous chemicals and is somewhat similar to
the EPA Risk Management Program (RMP) regulations (Title 40 CFR
Part 68). The PSM Standard of OSHA is not merely a set of specifications
but strives to provide a comprehensive safety management program that
can be implemented by industry and enforced by OSHA. These include
concise documentation of toxicity information, permissible exposure
limits, reactivity data, corrosivity data, as well as thermal and
chemical stability data. Also addressed is an examination of the
hazardous effects of inadvertently mixing different chemicals and the
ramifications that could occur.
These powers of enforcement arise from The Occupational Safety and
Health Act passed by Congress in 1970. The Act provided a legal and
constitutional framework for the development and enforcement of
workplace safety and Health related rules and regulations, including
provisions for penalties for non-compliance. Through the enactment
Congress also created OSHA as a division of the U.S. Department of
Labor, to oversee the administration of the Act and enforce its
standards throughout the United States.
The National Institute for Occupational Safety and Health (NIOSH)
was similarly created as a federal agency responsible for conducting
research and making recommendations for the prevention of work-related
injury and illness. Bearing in mind the need for balance, Congress also
created the Occupational Safety and Health Review Commission (OSHRC),
through the same act. OSHRC is an independent agency for mediation of
workplace safety and health disputes between the Department of Labor and
employers. It is not part of any other Federal department.
The enforcement powers enjoyed by OSHA include the power to carry- out
investigations and to inspect/audit organizations, to asses the level of
compliance to mandated health and safety standards. In cases of
violations, OSHA is empowered to issue citations to the erring entities
and also propose penalties.
The effective implementation of health and safety standards, which
requires multi-faceted inter-disciplinary efforts, is never easy in any
industry. However, the OSHA initiatives, including the PSM, (together
with similar efforts of other agencies in the field of industrial health
and safety), have succeeded in reducing work-related fatalities by 50
percent. OSHA initiatives have also helped reduce on-the-job injuries
and illnesses by over 40 percent since 1970. The development and
subsequent actions of OSHA in America can legitimately be considered a
major success story and a powerful inspiration for similar agencies
seeking to insure health and safety in the workplace.
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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