Within the past year, the Occupational Safety and Health Administration (OSHA) has completed some of its process safety management (PSM) “action items,” including clarifying parts of the PSM standard and revising its working definition of “retail facilities.”

Keep reading to find out what other changes employers can expect to see as OSHA continues to revise its enforcement policies.

Five Principles

OSHA has outlined five principles that guide the Agency in updating and clarifying its PSM enforcement. The Agency intends to:

  • Strengthen community planning and preparedness.
  • Enhance federal, state, and local coordination.
  • Improve data management.
  • Modernize policies and regulations.
  • Incorporate stakeholder feedback and develop best practices.

What is OSHA Actually Doing to Improve Chemical Safety?

According to OSHA chief administrator David Michaels, PhD, OSHA’s actions are aimed at better protecting workers from chemical plant incidents dating from 1984, such as the disastrous chemical release in Bhopal, India.

In 1992, the agency issued its PSM standard. It sets requirements for the management of highly hazardous substances and covers manufacturing of explosives and processes involving threshold quantities of flammable liquids and flammable gases, as well as 137 other highly hazardous chemicals.

Michaels noted that while the PSM standard has been effective, incidents continue to occur. In 2007, the agency launched a Petroleum Refinery PSM National Emphasis Program that enabled the agency to conduct a greater number of refinery inspections. The program ended in 2012 with 74 refinery inspections completed.

The inspections revealed “a widespread and deeply troubling failure to comply with basic process safety management principles in many refineries,” according to Michaels. OSHA responded with another National Emphasis Program in 2011 covering chemical facilities. Since then, the agency has conducted 645 inspections and has identified more than 3,100 violations of OSHA standards.

OSHA is exploring other possible means to improve safety at chemical facilities. These include:

  • Changes to emergency response standards;
  • Regulatory changes to improve ammonium nitrate safety;
  • Modernizing and updating the PSM standard and policies;
  • Increasing Occupational Safety and Health Act penalties; and
  • Developing targeted outreach and guidance.

With its RAGAGEP enforcement memorandum and its policy change on retail facilities, OSHA is well on the way to modernizing and updating its policies, even without changes to the standard. In addition, OSHA is focusing on whether affected workers know what they should about PSM.

Do Your Employees Know What OSHA Wants Them to Know About PSM?

OSHA says it’s essential for employees to know their role, the risks, and the proper procedures in order to protect themselves and others. If your business is covered by PSM regulations, you should be able to answer “Yes” to each of the following:

  • Employees know the hazards associated with mixing, separating, or storing process materials, including which chemicals are reactive or can cause a runaway reaction.
  • Employees are aware of equipment operation and maintenance requirements, including signs of corrosion or other problems, and they know which individuals to alert when they see a problem.
  • Employees know the processes and follow operating, safety, and emergency procedures.
  • Employees are made aware of changes.
  • Employees provide feedback to management.

For more information or assistance with your Environmental and Health & Safety regulatory compliance needs, contact Ralph Carito at Total Environmental & Safety, LLC (Total) at rcarito@TotalEnviron.com or 908-442-8599.