Common Process Safety Management Gaps Based on Occupational Safety and Health Administration Process Safety Management of Highly Hazardous Chemicals Violation Trends

摘要

On July 17, 1990 the U.S. Occupational Safety and Health Administration (OSHA) published in the Federal Register the proposed standard Process Safety Management (PSM) of Highly Hazardous Chemicals (HHCs). Approximately four months later it was enacted into law via Clean Air Act Amendments (CAAA). These amendments require that the U.S. Secretary of Labor, in coordination with the U.S. Administrator of the Environmental Protection Agency, promulgate, pursuant to the Occupational Safety and Health Act of 1970, a chemical process safety standard to prevent accidental releases of chemicals that could pose a threat to employees [1]. The full text of the final standard was issued in the Federal Register on February 24, 1992. The OSHA standard is listed under Title 29 (Department of Labor) of the Code of Federal Regulations (CFR) as 1910.119. This standard leans towards a performancebased guidance document that outlines methods and programs to decrease the likelihood of flammable, toxic, reactive and explosive chemical releases. The intent is to reduce the risk to employees, visitors and contractors that may enter or work at chemical processing facilities. Facilities are subject to the PSM regulation if they hold a threshold quantity of any HHC that is listed in Appendix A of the standard, with some exceptions. The violations that OSHA issues for the 1910.119 standard will cite the specific element and its relevant subsection. Published data allows for review of the violations, and based on that information an indication of common PSM program gaps can be assessed. A ten-year span of OSHA PSM violation data was examined (2007-2017). The data shows the top four OSHA cited PSM sections (often referred to as elements) are (highest to lowest): 1) Process Safety Information 2) Mechanical Integrity 3) Operating Procedures 4) Process Hazard Analysis Each of these elements have known solutions, and specific corrective actions can be easily implemented given the lessons learned, the current level of expertise that exists in the process safety industry and the cost-effective software tools that are now available. Regulatory compliance is not the only goal of adequate PSM programs, nor is it the goal of this review. The purpose of reviewing the OSHA violation information is not meant to help facilities avoid OSHA citations, but to uncover gaps found by OSHA and bring awareness and attention to some common issues, hopefully leading to focused solutions for safer, more reliable facilities.