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PROCESS SAFETY MANAGEMENT
Unexpected releases of toxic, reactive or flammable liquids and gases in processes involving highly hazardous chemicals have been reported for many years in various industries that use chemicals with such properties. Regardless of the industry that uses these highly hazardous chemicals, there is a potential for an accidental release any time they are not properly controlled, creating the possibility of disaster.
To help ensure safe and healthful workplaces, OSHA has issued the Process Safety Management of Highly Hazardous Chemicals standard (29 CFR 1910.119), which contains requirements for the management of hazards associated with processes using highly hazardous chemicals. EPA’s Risk Management Program (RMP) regulations (Title 40 CFR Part 68) is very similar in scope, however the EPA rules also require an evaluation of off-site consequences.
Process safety management (PSM) is addressed in specific performance-based standards for the general industry. OSHA’s standard establishes a systematic method to identify, prevent and mitigate the risks of catastrophic incidents from the loss of containment of highly hazardous chemicals. Therefore, an effective PSM program is a continuously improving program that, once established at a facility, provides mechanisms for examination and improvement through the use of key program elements, such as PHA Revalidation, Audits, Incident Investigation and Management of Change. Some industries can find themselves somewhat complacent, thinking that the safe operation of a process is assured by the existence of a PSM program. However, learning from near misses, involving your employees and ensuring that Process Safety is just not another safety program on the shelf, will go a long way to preventing a catastrophe in the workplace and possibly in the surrounding community.
The EI Group, Inc. (EI) can help by providing the following services:
- Process Hazard Analysis (HAZOP, What-If and other methods)
- PHA Revalidations (required every 5 years)
- Process Safety Management Audits (required every 3 years)
- Development/Revision of Program Elements
In 2014, the US Chemical Safety Board recommended that the PSM rules be modernized to capture the many process safety advances and improvements from the past 20 years. Changes are on the horizon and rules to make Process Safety Management programs more robust will be a reality.
EI’s Process Safety engineering team is supplemented by our Certified Safety Professionals and Certified Industrial Hygienists to provide services to support the enhancement and effectiveness of any safety program, including:
- Lockout/Tagout Program Development
- Hot Work Permit Program Development
- OSHA Audits
- Safety Training
“Great article Bill! Really enjoyed the read. Very important stuff for everyone that maintains an OSHA 300 Log to know. Even after 22 years of doing this type of recordkeeping, I even learned a couple of new things from this article.”
If you had a release of a hazardous air pollutant, you would have to notify your authorizing environmental agency under various rules, Federal RMP (112(r)), Title V, or maybe a State Air Toxics regulation. You might even be required to notify the National Response Center (NRC). As of March 23, 2021, you can now add the Chemical Safety Board (CSB) to your “must call” list.