Process Safety Management (29 CFR 1910.119) - Training offered by Chemical Distributors, Incorporated

Unexpected releases of highly hazardous chemicals including toxic, reactive, or flammable liquids and gases from processes have been reported for many years. Incidents continue to occur in various industries that use highly hazardous chemicals that may be toxic, reactive, flammable, or explosive, or may exhibit a combination of these properties. Regardless of the industry using these highly hazardous chemicals, there is a potential for an accidental release any time they are not properly controlled. This, in turn, creates the possibility of a disaster.

OSHA Process Safety Management (PSM) was adopted to minimize the risk of an accidental release of certain highly hazardous chemicals and to protect workers and the public. Under the PSM standard, OSHA wants to prevent the unwanted releases of hazardous chemicals, especially into locations that could expose employees and others to serious hazards. Further, OSHA wants to eliminate having untrained workers in the workplace.

  • The standard covers specific listed highly hazardous chemicals when present in a process in quantities at or above the threshold quantities listed in Appendix A of the standard.
  • In addition, flammable liquids or gases in quantities of 10,000 pounds or more are covered unless they are used solely for heating or fuel.

Employers must develop a written plan that includes the following:

  • Compile written process information, including information on:
    • the hazards of the highly hazardous chemicals used or produced by the process
    • the technology of the process
    • the equipment in the process.
  • Perform a process hazard analysis. The process hazard analysis will review what could go wrong and what safeguards must be implemented to prevent releases of hazardous chemicals.
  • Develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process.The procedures will address:
    • steps for each operating phase (startup, normal operation, emergency shutdown, etc.)
    • operating limits
    • safety and health considerations
    • work activities such as lockout/tagout and entrance into a facility by contractor personnel.
  • Develop a written plan of action to implement the employee participation required by the standard.
  • Implement an effective training program
    • initial training
    • refresher training
    • training documentation
  • Establish a program for evaluating a contract employer's safety performance and programs, informing the contract employer of information about the process and emergency procedures needed for safe work, and maintaining a contract employee injury and illness log.
  • Perform a pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information.
  • Establish and implement written procedures to maintain the ongoing mechanical integrity of process equipment.
  • Require the issuance of a permit for hot work operation conducted on or near a covered process.
  • Establish and implement written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process.
  • Investigate within 48 hours or sooner each incident that resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical in the workplace and establish a system to promptly address and resolve the incident report findings and recommendations.
  • Develop an emergency action plan in accordance with 29 CFR 1910.38(a) and include procedures for handling small releases of hazardous chemicals; 29 CFR 1910.120 - Hazardous Waste Operations and Emergency Response, may also apply.
  • Conduct compliance audits at least every 3 years to verify that the procedures and practices developed under the standard are adequate and that they are being followed.
  • Provide all required information for the above steps without regard to trade secret status; confidentiality agreements may be implemented to protect an employer's trade secrets

The EH&S division of Chemical Distributors, Incorporated started with an internal need for training and compliance and has expanded with the following offering for all of our customers.

Please inquire about a program to match your specific needs.

All training materials will be provided

Give us a call, we've got you covered.

 

About our trainer:

Cindy Shelton is a certified Associate Safety Professional through the Board of Certified Safety Professionals, as well as a Registered Environmental Professional through the National Registry of Environmental Professionals. In addition she holds a Master's degree from Columbia Southern University in Occupational Safety and Health with a concentration in Environmental Management.