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November 28, 2005
Highly Hazardous Chemicals and the PSM Standard

The goal is to prevent a catastrophic release. The management of highly hazardous chemicals is regulated by OSHA in 29 CFR 1910.119, the Process Safety Management (PSM) Standard. The Standard is intended to prevent or minimize the consequences of a catastrophic release of toxic, reactive, flammable, or explosive, highly hazardous chemicals from a process. A "process" is defined by OSHA as "any activity or combination of activities including any use, storage, manufacturing, handling, or the on-site movement of highly hazardous chemicals." A process includes "any group of vessels that are interconnected and separate vessels that are located so that a highly hazardous chemical could be involved in a potential release."

Which chemicals are highly hazardous? The Standard applies to any process that contains a threshold quantity or greater amount of a large number of toxic or reactive hazardous chemicals, which are specified in Appendix A of the Standard. This list gives the chemical name, Chemical Abstract Service (CAS) number, and threshold quantity (TQ) in pounds for each substance. The Standard also applies to 10,000 pounds or greater amounts of flammable liquids and gases and to the process activity of manufacturing explosives and pyrotechnics.

Process safety management--the basics. OSHA recognizes that each company and process is different. Therefore, the Standard is performance oriented. However, all companies are required to follow certain basic steps. For example, the Standard requires you to compile detailed information about the chemicals, technology, and equipment used in regulated processes and conduct a process hazard analysis for each regulated process. Process hazard analyses must be updated and revalidated at least every 5 years. In addition, you must develop a written plan for involving employees (both your own and contractor employees) in the management of regulated processes and provide clear written instructions for safely conducting activities involving regulated processes. You also have to inspect and test process equipment regularly, conduct full compliance audits at least every 3 years, develop a written emergency action plan, and investigate within 48 hours any incidents that result or could reasonably have resulted in catastrophic releases of highly hazardous chemicals.

Employees have to be well trained.

Why It Matters...
  • When 40 metric tons of toxic methyl isocyanate were released from a Union Carbide pesticide plant in Bhopal, India, in 1984, 3,000 people died; 100,000 were injured; and 50,000 were left partially or totally disabled.
  • In the 20 years since, there have been nearly 200 serious incidents involving highly hazardous chemicals in the United States, according to the Chemical Safety Board.
  • On average, six of these incidents per year have resulted in injuries and there have been an average of five fatalities annually.
  • Nearly 50 of these incidents affected the public.

Training for employees operating a process regulated by the Standard must include:

  • Overview of the process
  • Operating procedures
  • Specific safety and health hazards
  • Emergency operations
  • Safe work practices

Refresher training is required at least every 3 years (and more often if necessary) to ensure that employees understand and follow the current operating procedures of the process. Whenever there are changes in the process, employees must be trained in those changes before start-up of the new or modified process. Employees responsible for maintaining process equipment must be trained in the process and its hazards. Although OSHA generally holds contractors responsible for training their own employees, you are responsible for taking your contractors' safety performance and programs into account when selecting a contractor. And you are responsible for informing your contractors about worksite hazards as well as workplace safety rules and emergency procedures.

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