The PSM Standard

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). 

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. 

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... 

The CSB analysis is limited by incomplete knowledge of chemical concentrations, quantities, or other covered chemicals in the same process-all of which are relevant in determining whether a process is regulated under the PSM Standard. 

The PSM Standard is a performance-oriented standard that requires the employer to prevent catastrophic releases from covered processes by executing a 14-element safety program. All processes with highly hazardous chemicals are required to have a management system that addresses each element of the standard. 

The PSM Standard requires that the following information be contained within the PSI element-physical data, reactivity data, corrosivity data, thermal and chemical stability data, and hazardous effects of potential inadvertent mixing of different materials. The standard does not specifically define what is to be included in any of these data categories, the level of detail required, or the method of compilation.41 It does, however, stipulate that an MSDS can be used to compile the data to the extent that it contains the information required. In 1996, OSHA issued a Hazard Information Bulletin cautioning that MSDSs do not always contain information about hazards from mixing or blending chemicals (OSHA, 1996). 

Another requirement of the PSM Standard is that the employer conduct process hazard analysis, which OSHA defines as an organized and systematic effort to identify and analyze the significance of potential hazards associated with the processing or handling of highly hazardous chemicals. The analysis must identify the hazards of the process and necessary safeguards however, the standard does not explicitly define requirements for addressing reactive hazards. 

It is evident that the 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. 

Following the Napp incident, six labor unions44 petitioned OSHA for emergency revision of the PSM Standard, stating that it failed to cover reactive chemicals. In a followup letter, the labor unions asked OSHA to consider the following issues in any revision of the standard ... 

In February 1996, the Chemical Manufacturers Association (now ACC) and API submitted a letter to OSHA responding to issues raised by the labor unions. The letter indicated ACC support of PSM as an effective standard. It also reflected the opinion that expanding PSM in the ways proposed would greatly increase compliance costs without substantial benefits and that a large amount of the additional cost would fall on small businesses. ACC and API identified several alternatives for regulating reactives, but concluded that each presented technical difficulties, significant cost, and minimal benefit. For these reasons, both trade groups opposed any revisions to the PSM Standard. 

OSHA did not undertake an emergency revision of the PSM Standard in response to the labor unions petition. In October 1997, OSHA and EPA issued a joint chemical accident investigation report on the Napp Technologies incident. Among the recommendations was that OSHA and EPA review the lists of substances subject to the PSM Standard and RMP regulation (40 CFR 68) to determine whether reactive substances should be added. 

Just when you think everything is going very well, try an audit. Audits are required by the PSM Standard and the first audit can be an eye opener. Check work order logs and engineering projects logs to see if some types of activities are slipping by the MOC procedure. Also emphasize complete authorizations prior to the introduction of highly hazardous chemicals into the area. 

The nonmandatory section of the PSM standard under Management of Change states that organizations must define what is meant by change. Each organization needs definitions that fit their circumstances. Note the definitions and examples. 

Regardless of the method of investigation used for any incident, there are some mandatory OSHA requirements. The OSHA Process Safety Management (PSM) standard focuses on incidents that could reasonably have resulted or actually had resulted in a catastrophic release of highly hazardous chemicals. A major requirement is having a procedure that the employer can quickly implement. Here are a few considerations for an incident investigation procedure that addresses the major points of the PSM standard. 

Contractor Safety programs have been in existence for many years, but the PSM Standard required that the program become formalized and more far-reaching than traditional contractor safety programs. The Contractors [29 CFR 1910.119 (h)] element requires that those considering the use of contractors must partially base their selection of a particular contractor on their safety performance. Covered process owners, once they select a contractor, must ensure that not only are the employees of the contractor qualified to do the... 

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. 

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