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Process Safety Management and OSHA's National Emphasis

The Occupational Safety and Health Administration (OSHA) instituted a “National Emphasis Program” to conduct both targeted and random inspections of facilities subject to the Process Safety Management (PSM) regulations. OSHA has responded to several high profile incidents by initiating a program to help assure that facilities handling highly hazardous chemicals are meeting the PSM regulations in an effort to reduce incidents. OSHA is currently inspecting or auditing facilities believed to require PSM and will indeed issue citations if the facility does not meet all of the standard’s requirements. Below are the most common deficiencies at facilities inspected and information that can be used to make sure that a facility’s PSM program will indeed pass an OSHA inspection under the National Emphasis program.

OSHA initiated the “PSM Covered Chemical Facilities National Emphasis Program” in 2011. Since then, many facilities have undergone PSM compliance reviews. Industry has been able to learn not only where common deficiencies exist in their programs from these reviews, but also about what OSHA is looking for in terms of compliance and how to improve PSM efforts.

Will my facility be inspected?

• Focus is on Level 3 facilities designated by the EPA Risk Management Program (RMP) program.

• There is a 4 to 6% chance per year you will be audited if your facility is part of the RMP program.

What is OSHA’s dynamic list?

• OSHA will generate a list of protocols from its Directorate of Enforcement with the goal of attempting to shorten the length of these inspections. These audit protocols allow for easy one-word answers: Yes, No, or NA.

What are common deficiencies?

• Piping and Instrumentation Diagrams (P&IDs) are missing or do not reflect changes that have been made to the system

• Relief system design or design basis is not documented

• Compliance with recognized and generally-accepted good engineering practices is not documented

• Electrical area classifications and/or electrical distribution system are not documented

• Chemical reactivity hazard evaluations are not documented

Is it time for a review of PSM procedures at your facility?

OSHA’s PSM standard contains requirements for safely managing hazards associated with using, storing, manufacturing, handling, or moving highly hazardous chemicals on-site. It emphasizes an established, comprehensive program that integrates technologies, procedures, and management practices.

The standard addresses issues including the following:

Why is it necessary? There is a potential for an accidental release of highly hazardous chemicals any time the chemicals are not properly controlled. A release in turn creates the possibility of a disaster.

What industries are covered? PSM applies mainly to manufacturing industries, particularly those that address chemicals, transportation equipment, and fabricated metal products. Other affected sectors are those involving natural gas liquids; farm product warehousing; food processing; electric, gas, and sanitary services; and wholesale trade.

What is required? The key provision of the standard is a process hazard analysis (PHA) based on process safety information. The PHA is careful review of what can go wrong and what safeguards must be in place to prevent accidental releases. The standard also describes required written operating procedures, employee training and involvement, pre-startup safety reviews, evaluation of mechanical integrity, contractor requirements, and procedures for managing change. PSM requires a permit system for hot work, incident investigation, emergency action plans, regular compliance audits, and trade secret protection.

Penalties for deficiencies noted in OSHA PSM inspections are substantial and often require additional facility investment into the program. A NY facility was assessed over $65,000 in penalties last month.

Baron urges facilities that are covered by the PSM standard to review their compliance before an inspection occurs. Contact Maria Maciejewski for more information.

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