Reducing the STRESS  of Software Implementations Worldwide  


Oracle Applications Users Group



by Sandra Noble, President
Noble & Associates Consulting, Inc.

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 
For Business Owners & Managers


Get OSHA Regulation Explained For Business Owners & Managers

Sandra Noble MBA, CPIM, Six Sigma, DCFS, 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 software solutions. Reducing the STRESS of Software Implementations Worldwide!

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