PSM standard

Operating procedures written, complete, meeting requirements of PSM Standard or RMP Rule, if covered... 

Many flame arrester mannfactnrers provide training conrses on inspection and maintenance of flame arresters, either at their facilities or a client s plant. It is recommended that snch conrses be schednled for operating and maintenance personnel. Also, the OSPLA PSM standard, 29 CFR 1910.119 (j)(3), shonld be consnlted for reqnirements for training for process maintenance activities. 

To meet this challenge, we have adopted a comprehensive approach to the management of process safety throughout our operations, which builds on our existing strengths. The goal of this approach is to assure that, in all of our businesses, we maintain PSM standards and practices that ... 

Materials—which include chemicals, process equipment, transport containers, protective equipment, and replacement parts—need to conform to quality (ESH/PSM) standards and specifications before being placed in use. Different materials will need varying levels of test and/or inspection as well as controls on their storage and handling. 

This element addresses the quality (adherence to ESH/PSM standards and specifications) of purchased materials and equipment, in-process inspections, and final product verification. Methodologies, frequencies, and sample size or scope of inspections are all expected to be specified. 

This element ensures that activities such as installation, operation, handling, and servicing also meet quality (ESH/PSM) standards and practices. Feedback systems on product performance are also addressed. 

The mechanical integrity section of the PSM standard ensures that the equipment, piping, relief systems, controls, and alarms are mechanically sound and operational. The requirements include (1) written procedures to maintain functioning systems, (2) training regarding preventive maintenance, (3) periodic inspections and testing based on vendor recommendations, (4) a process to correct deficiencies, and (5) a process to ensure that all equipment and spare parts are suitable. 

Under the management of change section of the PSM standard employees are required to develop and implement documented procedures to manage changes in the process chemistry, process equipment, and operating procedures. Before a change occurs (except for replacement-in-kind), it must be reviewed to ascertain that it will not affect the safety of the operation. After the change has been made, all the affected employees are trained, and a pre-startup review is conducted. 

Under the audits section of the PSM standard employers are required to certify that they have evaluated their compliance with the standard at least every three years. The recommendations from the audit must be followed. The audit reports need to be retained as long as the process exists. 

The trade secrets section of the PSM standard ensures that all contractors are given all the information relevant to operating in the plant safely. Some personnel may need to sign secrecy agreements before they receive this information. 

The second requirement of the RMP is a prevention program. The prevention program has 11 elements, compared to the 14 elements of the PSM standard. As shown in Table 3-4, many of these elements are duplicated. Fortunately, the EPA made a deliberate attempt to retain the same requirements wherever possible, although differences exist because the EPA and OSHA have different responsibilities. The first column in Table 3-4 lists each element of the PSM program, and the second column shows the corresponding element of the prevention program (some elements have no equivalence). 

The information in this publication is applicable to many industrial facilities not covered by process safety regulations such as the OSHA PSM Standard and the Seveso II Directive. Many reactive chemicals are not listed as regulated materials, and chemical reactivity hazards include uncontrolled chemical reactions between materials not considered as highly hazardous, or under conditions not typically encountered in storage and shipping. 

CCPS Elements OSHA PSM Standard and EPA RMP Rule Seveso II... 

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... 

For the purpose of the OSHA PSM Standard, NFPA instability ratings have the following limitations with respect to identifying reactive hazards ... 

The OSHA PSM Standard lists 137 highly hazardous chemi-cals-only 38 of which are considered highly reactive based on NFPA instability ratings of "3" or "4."... 

OSHA PSM Standard (29 CFR 1910.119) and EPA Accidental Release Prevention Requirements Risk Management Programs (RMP) Under the Clean Air Act, Section 112(r)(7) (40 CFR 68). 

The OSHA PSM Standard has significant gaps in coverage of reactive hazards because it is based on a limited list of individual chemicals with inherently reactive properties. 

NFPA instability ratings are insufficient as the sole basis for determining coverage of reactive hazards in the OSHA PSM Standard. 

The OSHA PSM Standard and the EPA RMP regulation do not explicitly require the use of multiple sources when compiling process safety information. 

Amend the Process Safety Management (PSM) Standard, 29 CFR 1910.119, to achieve more comprehensive control of reactive hazards that could have catastrophic consequences. 

Neither the OSHA PSM Standard nor the EPA RMP regulation explicitly requires specific hazards, such as reactive hazards, to be examined when performing a process hazard analysis. 

Is there a need to improve coverage of potentially catastrophic reactive hazards under the OSHA Process Safety Management (PSM) Standard If so, what approaches should be pursued ... 

For processes already covered under the OSHA PSM Standard, do the safety management requirements of the standard adequately address reactive hazards If not, what should be added or changed ... 

There are OSHA standards designed to protect employees from acute chemical hazards resulting lfom reactive incidents-including fires, explosions, and toxic releases. The Hazard Communication Standard (29 CFR 1910.1200) requires chemical manufacturers to evaluate chemicals produced or handled in their workplace and to communicate the hazards associated with the products they produce via labels and MSDSs. The standard also requires all employers to provide information to employees about the hazardous chemicals to which they could be exposed. The PSM Standard (29 CFR 1910.119) requires employers to prevent or minimize the consequences of catastrophic releases of highly hazardous chemicals, including highly reactive chemicals. 

The CSB incident data were analyzed to determine whether the chemicals involved were considered highly hazardous under the OSHA PSM Standard. For the purposes of analyzing the data, CSB determined if a chemical was covered by OSHA PSM by identifying whether it was listed in PSM or was covered as a flammable chemical by OSHA definition.38... 

Following a series of very serious chemical accidents in the 1980s, OSHA began to develop the PSM Standard. The proposed standard was published in 1990, the same year that Congress enacted the Clean Air Act Amendments (CAAA). Section 304 of CAAA required OSHA to promulgate a chemical process safety standard to protect employees from hazards associated with accidental releases of highly hazardous chemicals in the workplace. It further required that OSHA develop and apply the standard to a list of... 

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