OSHA’s Process Safety Management – Is This Process Covered?

Author

Jennifer Morningstar

Expertise Includes:

    • Chemical Release & Exposure
    • Confined Space Entry - Lockout/Tagout
    • Environmental Regulatory Compliance
    • Fires & Explosions
    • Industrial Accident Investigation
    • OSHA Process Safety Management (PSM)

In February of 1992, the OSHA Process Safety Management (PSM) standard was issued. The official title is: ‘Process Safety Management of Highly Hazardous Chemicals.’ As its title implies, not every facility is covered by this rigorous standard. A process must contain highly hazardous, as defined by OSHA, chemicals above a certain weight threshold, again defined by OSHA. Notice that this is a process by process determination, so there could be certain processes at a manufacturing facility that are not covered by this standard situated beside other processes that are.

In the ‘Application’ section, OSHA has two means to determine the chemical and its quantity to trigger PSM coverage. The first is simply a table.  It is Appendix A of the standard and it is an alphabetical listing of those chemicals deemed highly hazardous. The threshold quantity varies by chemical from as little as 100lbs for phosgene, to 10,000lbs for anhydrous ammonia, to 15,000lbs for methyl chloride. The other determination is flammability.  Obviously, flammability is a hazard, so any process that involves flammable liquids or gases (as defined in 1910.1200) in a quantity of 10,000lbs or greater is also covered.

As with all rules and regulations, there are some exceptions to these coverage rules. If the flammable hydrocarbons are solely for consumption onsite (e.g. heating, vehicle fuel), the storage tanks are not covered. Likewise, retail facilities are not covered nor any oil or gas well drilling or servicing operations. Lastly, any facilities that are located remotely AND are normally unoccupied

An example of a process flow diagram

An example of a process flow diagram

It is the manufacturer’s responsibility to review their processes and determine where any highly hazardous chemicals can be found above the threshold quantities. In the example process flow diagram above, it’s possible that the feed chemical may not be on the list, but the product from the reactor is (and is present above the threshold quantity). In that case, the reactor and storage tank are considered to be covered processes.

Now the manufacturer knows what is and isn’t covered…now what? There are 14 elements of the PSM standard that must be applied to every covered process. Since this is blog and not a book, we’ll just list them below

All of the elements of PSM.

All of the elements of PSM.

As you can see, some of these elements are focused more on the physical plant, others focused on the people in and around the plant, and the remainder focus on the interface between the two. In this way, the process safety management standard helps to prevent injury to workers and damage to the plant and its surroundings.

Jennifer Morningstar, PE, CFEI, has more than 20 years of industrial experience. Her areas of emphasis include chemical release & exposure, OSHA process safety management, industrial accident investigation, fires & explosions, and scope of damage/cost to repair analyses. She spent 16 years working at a polyethylene terephthalate (PET) manufacturer.  She is an OSHA-trained Process Hazard Analysis study leader and completed Root Cause Failure Analysis training to become an Incident Investigator. Jennifer authored procedures for lockout/tagout and confined space entry. She has experience as an energy management consultant in a variety of industries including mineral extraction, pulp & paper, animal harvesting & packaging (including rendering) and grain milling. Jennifer holds a Bachelor of Science Degree in Chemical Engineering from Virginia Polytechnic Institute and State University as well as a Masters of Business Administration from the University of South Carolina.

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