OSHA listed chemicals

Regulatory Compliance Issues in the US Table 64.2 Examples of OSHA-listed chemicals... 

Process Hazard Analysis (PHA) (Dowell, 1994, pp. 30-34.) The OSHA rule for Process Safety Management (PSM) of Highly Toxic Hazardous Chemicals, 29 CFR 1910.119, part (e), reqmres an initial PHA and an update every five years for processes that handle listed chemicals or contain over 10,000 lb (4356 kg) of flammable material. The PHA must be done by a team, must include employees such as operators and mechanics, and must have at least one person skilled in the methodology employed. Suggested methodologies from Process Safety Management are listed in Table 26-1. 

De Minimis Limitation. A listed toxic chemical does not have to be considered if it Is present in a mixture at a concentration below a specified de nvnimis level. The de minimis level is 1.0%, or 0.1% if the chemical meets the OSHA carcinogen standard. See Table II for the de minimis value associated with each listed toxic chemical. For mixtures that contain more than one member of a listed chemical category, the de minimis level applies to the aggregate concentration of all such members and not to each individually. EPA included the de minimis exemption In the njle as a burden reducing step, primarily because facilities are not likely to have information on the presence of a chemical in a mixture or trade name product beyond that available in the product s MSDS. The de minimis levels are consistent with OSHA requirements lor development of MSDS information concerning composition. 

Most or the incidents described were the result or not rollowing good engineering practice. Some violated the law, and many more would if they occurred today. In the United States, they would violate OSHA 1910.147 (1990) on The Control of Hazardous Energy (Lock Out/Tag Out) and the Process Safety Management (PSM) Law (OSHA 1910.119, in force since 1992). which applies to listed chemicals above a threshold quantity. The PSM Law requires companies to follow good engineering practice, codes, industry consensus standards, and even the company s owm standards. OSHA could view failure to follow any of these as violations. 

In 1992, OSHA promulgated its Process Safety Management (PSM) Standard (29 CFR 1910.119). The standard covers processes containing individually listed chemicals that present a range of hazards, including reactivity, as well as a class of flammable chemicals. Reactive chemicals were selected from an existing list of chemicals identified and rated by the National Fire Protection Association (NFPA) because of their instability rating of "3" or "4" (on a scale of 0 to 4)4,5... 

As a result of the joint OSHA-EPA chemical accident investigation of the Napp Technologies incident in April 1995, a recommendation was made by EPA and OSHA to consider adding more reactive chemicals to their respective lists of chemicals covered by process safety regulations. To date, neither OSHA nor EPA process safety regulations have been modified to better cover reactive hazards. 

The Whitehall Leather case demonstrates that reactive hazards other than thermal runaways in reactors-such as inadvertent mixing of incompatible materials-can cause severe reactive incidents. Neither ferrous sulfate nor sodium hydrosulfide is rated by NFPA, and neither compound is an OSHA PSM-listed chemical. 

The OSHA PSM Standard lists 131 distinct chemicals with toxic or reactive properties.40 It includes 25 chemicals with an NFPA rating of 3 and 13 chemicals with an NFPA rating of 4. PSM applies to processes that involve listed chemicals at or above threshold quantities and to processes with flammable liquids or gases onsite in one location, in quantities of 10,000 pounds or more. Companies that manufacture explosives and pyrotechnics are also required to comply with the standard. 

The OSHA list has not been updated since the promulgation of PSM in 1992. It does not reflect changes in the list of chemicals and their ratings made by NFPA in 1991 and 1994. 

Regulations a. Air OSHA List of Highly Hazardous Chemicals Yes 29CFR 1910.119, App. A OSHA 1974... 

Actually, before the Oklahoma City bombing, the anthrax attacks, and 9/11, OSHA and USEPA had already taken the initial steps to ensure safety and security in chemical production facilities and in other facilities that use, produce, or store listed chemicals. These steps were listed in OSHA s Process Safety Management (PSM) Standard and USEPA s Risk Management Program (RMP). Based on personal experience, having conducted VAs and modified VAs (wastewater) on both water and wastewater systems and having implemented RMP in a major U.S. wastewater system, we have to concur that these initial safety/security steps were quite effective. 

What is an OSHA Hazardous Chemical Under HCS, each manufacturer or importer had to determine the hazards of the chemicals it manufactured or imported. These were broken down into many different physical and health hazards. If a substance possessed any of these properties, it was, by definition, a hazardous chemical and therefore had to have an MSDS created for it, listing certain properties and hazards in a loosely specified form. Even if, after testing, it was determined that the chemical did not fall into any of these 23 categories but was listed in certain other references, the standard said that it was also hazardous, by definition. 

In the United States, the OSHA standard 29 CFR 1910.119 Process Safety Management of Highly Hazardous Chemicals requires that a hazard analysis must be carried out for any process involving certain listed chemicals (see Appendix A of the standard) or involving more than 10,0001b (4535.9 kg) of flammable gas or liquid. Employers must involve employees in the hazard analysis, and it must be made available to employees and updated at least every 5 years. Employees and contractors must be trained in safe work practices associated with the identified process hazards. Eull details of these and other legal requirements as well as descriptions of the information that must be included in the analysis can be found in the standard. The most recent version of this standard and all other OSHA regulations are available at www.osha.gov. 

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