Safety and Health Program- Process Safety Management

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Process Safety Management

(1) PURPOSE: This instruction establishes uniform policies, procedures, standard clarifications, and compliance guidance for enforcement of the standard for Process Safety Management of Highly Hazardous Chemicals, 1910.119 ("PSM standard"), and amendments to the standard for Explosives and Blasting Agents, 1910.109.

(2) SCOPE: This instruction applies Company wide.

(3) REFERENCES:

A. 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals; Final Rule; February 24, 1992, Federal Register Vol. 57, No. 36, pp. 6356-6417.

B. OSHA Instruction CPL 2.45B, June 15, 1989, the Field Operations Manual (FOM).

C. OSHA Instruction STP 2.22A, CH-2, January 29, 1990, State Plan Policies and Procedures Manual.

D. OSHA Instruction CPL 2.94, July 22, 1991, OSHA Response to Significant Events of Potentially Catastrophic Consequence.

E. OSHA Instruction ADM 1-1.12B, December 29, 1989, Integrated Management Information System (IMIS) Forms Manual.

(4) ACTION: All compliance and enforcement activities related to the PSM standard conducted by the Company shall adhere to the guidelines of this instruction.

(5) BACKGROUND: On February 24, 1992, OSHA promulgated the Final Rule for Process Safety Management of Highly Hazardous Chemicals. This standard originally became effective on May 26, 1992. An administrative stay delayed the effective date of paragraphs (f), (h), (j), and (l) until August 26, 1992 when the stay expired and the stayed provisions became fully effective. The Company adopted the rules on _______________ with an effective date of _____________________ .

A. In recent years, a number of catastrophic accidents in the chemical industry have drawn attention to the safety of processes involving highly hazardous chemicals. OSHA determined that employees have been and continue to be exposed in their workplaces to the hazards of releases of highly hazardous chemicals which may be toxic, reactive, flammable, or explosive.

B. The requirements of the PSM standard are intended to eliminate or mitigate the consequences of such releases. The standard emphasizes the application of management controls when addressing the risks associated with handling or working near hazardous chemicals.

C. In addition, the PSM standard has been developed in fulfillment of OSHA's obligation under the Clean Air Act Amendments (CAAA) of 1990, section 304(a). The final rule is consistent with the mandate of the CAAA.

D. It is anticipated that joint inspection activities related to the PSM standard will arise between the Company, OSHA, the Environmental Protection Agency, and the Chemical Safety and Hazard Investigation Board, which was mandated by the CAAA.

(6) ENFORCEMENT ACTIVITY RE LATED TO THE PSM STANDARD TYPES OF INSPECTIONS: 1910.119 has broad applicability to potentially hazardous processes that may exist in a wide variety of industries. Accordingly, enforcement activities related to the PSM standard--either to determine if an employer is covered by the standard or to assess the Company's compliance with it--may take place in any of the inspection types described below. The following guidelines shall apply to PSM-related compliance activity:

A. Program-Quality-Verification (PQV) Inspections. The primary enforcement model for the PSM standard shall be the PQV inspection and programmed PQV inspections shall be scheduled as described per this instruction.

B. Other Programmed Inspections: Screening for PSM Coverage. In all programmed safety and health inspections in general industry, a determination shall be made as to whether the Company is covered by the PSM standard.

1. This determination shall follow the criteria presented at 1910.119(a), including appropriate reference to Appendix A of §1910.119. The determination may be made in conjunction with an assessment of the employer's Hazard Communication program.

2. If the Company is found to be covered by the standard:

a. It shall be further determined if the Company is included in the universe of affected establishments from which PQV inspections may be scheduled.

b. The Company shall obtain copies of the OSHA publications "Process Safety Management," OSHA Publication 3132, which also contains the full text of §1910.119; and "Process Safety Management--Guidelines for Compliance;" and