Inspection process.OSHA

Acqnire an understanding of the OSHA compliance inspection processes. 

These inspections will include checking company records, reviewing compliance with hazard communication standards, evaluating fire protection and personal protective equipment, and reviewing the company s health and safety plan. This inspection will include conditions, structures, equipment, machinery, materials, chemicals, procedures, and processes. OSHA s priorities for scheduling an inspection are as follows ... 

VPP status removes the site from the OSHA random inspection process for three years. Because of OSHA s limited resources, the VPP program allows OSHA to focus on employers whose sites are most likely not in con liance. 

Safety culture, for nuclear power facilities, 17 538 Safety data, developing, 21 844 Safety factors, See also Process safety Safety inspections, OSHA, 21 829 Safety issues/considerations for heated and cryogenic tanks, 24 303 teaching related to, 24 184 Safety issues, emulsion-related, 10 128 Safety measures, improved, 24 184 Safety performance indexes, nuclear power facility, 17 539 Safety regulation(s)... 

Government Institutes, Inc., 1993, ISBN 0-86587-336-4, 120 pages, 49. This OSHA Inspection manual covers process safety management (PSM) compliance guidelines, PSM audit guidelines, clarifications and interpretations of the PSM standard, and SIC codes targeted for the program quality verification inspections. 

Figure 2.2 shows that a goal-driven approach can be managed with either an internal or a formal plan that can be evaluated and reviewed by external parties. OSHA s process safety standard is an example of an internal plan. Companies are not required to submit anything to OSHA. Only if they are inspected, they will have to share their plans with the regulators. 

Programmed inspections are planned at the beginning of the year by the OSHA regional offices. OSHA attempts to develop objective criteria for its choice of facilities to inspect so as to justify the warrant-application process. 

In designing the Process Safety Management standard (PSM), OSHA looked at overall process safety from a broad system s view and identified 14 key elements that industry should address to minimize catastrophic accidents. The 14 elements cover the things that can cause a process failure and accidents. Some of the major causes of process accidents are a lack of training, lack of information about process equipment, lack of equipment inspections, poor coordination with contractors, and lack of employee participation in process planning and implementation. The program is triggered by above-threshold quantities of any of 136 chemicals. The purpose of the standard is to minimize the consequences of a catastrophic release of a toxic, flammable, reactive, or explosive chemical. The importance of this standard is that it requires safety analysis and names certain analytic techniques to use or their equivalent. 

C. Non-Fatality/Catastrophe Criterion for Hazards Due to the Potential Release of a Highly Hazardous Chemical (Process Safety Management). An inspection in which OSHA finds three or more willful or repeated violations or failure-to-abate notices (or any combination of these violations/notices), based on high gravity serious violations related to hazards due to the potential release of a highly hazardous chemical, as defined in the PSM standard. 

Risk-Based vs. Compliance-Based Requirements. Prior to the 1990s, OSHA regulations were almost exclusively compliance-based. Very specific rules were promulgated and inspections were made to ensure that the rules were followed. With the advent of the process safety regulation, a portion of it required that the risk associated with a manufacturing or other chemical site be assessed and appropriate actions be taken to mitigate the results of an accident to protect the workers. 

The checklist in the OSHA Inspection Manual (see Chapter 24) is probably the best comprehensive tool that can be used to evaluate the process for compliance. Use of the checklist is probably the best way of assuring that initial and subsequent implementation of PSM has been accomplished. The process of assessing each provision of the rule with the checklist will yield findings regarding the adequacy of implementation. Each of the formal audit findings must be promptly responded to by the employer and correction of deficiencies must be documented. 

Implementation. The owner/operator must certify on the basis of the compliance audit every three years that the process meets the requirements of the PSM rule and retain that certification for OSHA inspection as an official record. External audits by OSHA in the United States are occasionally performed and are prompted principally by a reported problem or problems at a plant location. More information about the internal and external audits is provided in Chapter 24 that follows later in this part of the book. 

Both the PSM and RMP rules state that employers must certify that they have evaluated compliance to verify that the procedures and practices developed under the standard are adequate and are being followed. This chapter provided information about the relationship of audits to QA, the audits themselves, audit conduct, lessons learned, and some related information about the Chemical Safety and Hazard Investigation Board. It was stressed that the OSHA Inspection Manual is an essential reference at any site with process safety responsibilities. 

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