In response to high-profile industrial accidents, such as the Richmond, California refinery fire
, the Chemical Safety and Hazard Investigation Board (CSB) has called for changes to accidental release prevention regulations in the US. The CSB is pressing the Occupational Safety and Health Administration (OSHA) and the Environmental Protection Agency (EPA) to incorporate "inherently safer technology" into their respective regulations, including process safety management improvements.
This month, Lion News will cover the existing accidental release prevention rules under OSHA and EPA jurisdiction (subscribe here
). These programs were implemented under the Clean Air Act §112(r) mandates included in the 1990 Clean Air Act Amendments.
This week, we'll look at OSHA's Process Safety Management (PSM) regulations at 29 CFR 1910.119. PSM Applicability
The OSHA PSM requirements apply to employers who exceed a designated threshold of a given chemical at any time in a single process. [29 CFR 1910.119(a)(1)] Substances covered under these requirements are broken into two categories:
- Highly hazardous chemicals: These substances include toxic and reactive chemical substances. OSHA has listed these substances in Appendix A, each with a designated threshold quantity.
- All other flammable liquids and gases: These substances are assigned a 10,000-pound threshold quantity.
The PSM rules consider all of the following activities to be regulated processes:
- Handling; and
- On-site movement.
OSHA considers all interconnected parts of equipment or "vessels" to be part of a single process, so the amount of a targeted substance in each interconnected vessel must be added towards the employer's applicability determination. OSHA also considers separated vessels to be part of a process when they are located in a way such that the contents could be involved in a release associated with other vessels containing the same substance. [29 CFR 1910.119(b)] Exclusions from the PSM Requirements
The PSM rules do not apply to:
- Retail facilities;
- Oil and gas well drilling or servicing operations; and
- Normally unoccupied remote facilities.
[29 CFR 1910.119(a)(2)]
In addition, hydrocarbon fuels used in the workplace solely for fuel consumption, and flammable liquids stored in atmospheric tanks that are kept below their normal boiling point without chilling are excluded from the PSM rules. [29 CFR 1910.119(a)(1)] PSM Requirements
Before employers can operate a covered process, they must:
- Develop written process safety information that describes:
- The hazardous characteristics of the chemicals involved in the process;
- Information on the process equipment; and
- How the covered process technology works.
- Perform a hazard analysis that:
- Addresses the consequences of failures of engineering and administrative controls, human factors, previous incidents and near misses; and
- A quantitative analysis of the safety of and health effects on employees due to the failure of controls.
- This analysis must be performed by a team with expertise in engineering and process operation, including one person knowledgeable in process hazard analysis methodology. The team must also include at least one employee with knowledge of the process.
- Develop written operating procedures as well as procedures for managing facility changes.
- Develop a system to inspect, test, and maintain the covered process.
- Develop emergency response procedures.
- Implement employee and contractor training.
Employers must update and revalidate their process hazard analysis at least every five years. In addition, detailed compliance audits of the process safety management program must be performed at least every three years. [29 CFR 1910.119(e) and (o)] For more information on OSHA's PSM program, visit the Agency's Website
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