On August 23, 2016, the U.S. Occupational Safety and Health Administration (OSHA) issued three draft guidance documents1 associated with Process Safety Management (PSM); comments were accepted until September 23, 2016. The guidance documents describe compliance requirements for the following affected industry groups:
- Explosives and Pyrotechnics Manufacturing,
- Storage Facilities, and
- Small Businesses
The guidance documents do not introduce any significantly new broad interpretations or new requirements. Rather, they emphasize existing requirements, provide some insight into OSHA’s likely enforcement focus, and give some industry-specific examples of OSHA’s expectations for complying with the PSM standard. They also provide some useful reference materials for facilities currently subject to PSM requirements or evaluating PSM applicability.
Explosives and Pyrotechnics Manufacturing
In the guidance document related to the explosives and pyrotechnics manufacturing industry, OSHA summarizes requirements specifically related to Process Safety Information (PSI), Process Hazards Analysis (PHA), Operating Procedures, Training, and Mechanical Integrity (MI).
OSHA notes that several facilities have received citations for inadequate PSI. To improve PSI compliance, the guidance emphasizes the basic PSI requirements for particular explosives and pyrotechnics industry processes. For example, some facilities with purely mechanical processes may not have piping and thus have no need for process piping and instrument diagrams (P&IDs); however, all facilities with a fire suppression system must have a P&ID for that system. The guidance also points out that components or equipment of unknown origin cannot meet the Quality Assurance provisions and are prohibited in the explosives and pyrotechnics manufacturing industry.
When conducting PHAs, owners/operators must consider the inherent chemical and physical properties of explosive compounds, quantity-distance requirements, building design, human factors, and prior incident reports. The importance of thorough written operating procedures is also emphasized, with it noted that this is a common area for citations, especially for procedures related to emergency shutdown and raw material quality. Training expectations are also summarized, along with what OSHA considers to be acceptable standards to follow in developing a training program.
The guidance emphasizes the importance of design that is in accordance with recognized and generally accepted good engineering practices (RAGAGEP) and identifies acceptable sources of RAGAGEP for the industry. In describing minimum MI requirements and recommended MI practices in order to ensure that equipment is properly inspected and maintained, the guidance makes particular mention of documenting inspections and maintenance activities.
In the guidance related to storage facilities, OSHA summarizes requirements specifically related to Employee Participation, PSI, PHA, Operating Procedures, Training, MI, and Emergency Planning and Response. Several examples of storage facility incidents are presented, along with OSHA’s PSM expectations for the industry.
With respect to PSI, facilities are reminded that they must compile information on process technology, including block flow diagrams, maximum inventory levels, safe upper and lower process limits, and consequences of deviations. For information on process equipment, the guidance notes that, depending upon the classification of the stored contents, storage tanks must bear a marking indicating compliance with the applicable codes or standards under which it was constructed. Other required information includes the manufacturer, installation date, materials of construction, pressure rating, wall thickness, and volume. For tanks lacking such information, the facility must verify the fitness for operations. Operators must also collect data on transfer hoses, vapor control systems, pressure relief systems, level controls, and spill control and containment systems.
In addressing PHA requirements, the guidance cites specific priorities relative to storage tank facilities, including separation of incompatible materials, siting hazards, temperature hazards, toxic hazards, accidental releases, and fire zones.
Regarding operating procedures, the guidance emphasizes that procedures should be current and that an "operation must be placed on hold if an out-of-date procedure is discovered or an error affecting form, fit, or function in the process is noted." Examples of storage facility operating procedures are also provided, including container handling; location; signs of damaged containers; storage tank loading/unloading; administrative procedures to limit personnel access; and emergency operations, including loss of containment and fire response. The guidance also reinforces training requirements, with a special mention of training for loss of containment scenarios and hazard recognition.
With respect to MI, "any deficiencies identified during inspections and tests must be addressed immediately, or in a safe and timely manner when immediate shutdown might compromise process safety. When equipment is determined to be deficient, a management of change (MOC) procedure must be established (if not already in place) and implemented prior to continuing operation of the deficient equipment." In addressing emergency planning and response, the guidance pays particular attention to assessing worst-case scenarios, especially for employees who perform rescue or medical duties.
The guidance for small businesses summarizes requirements related to PSI, PHA, Training, MI, and Compliance Audits. OSHA notes the importance of PSM for smaller facilities, citing one study which estimates that "employers with 1-25 employees are 47 times more likely to have a release and 17 times more likely to suffer injuries, per employee, than facilities with 1500 or more employees." The guidance includes a list of businesses (by NAICS code) typically subject to PSM as well as a broad summary of PSM program elements, which can be a good resource for small facilities. The primary take-away is that small facilities should take a fresh look at their PSM programs because they can have the same hazards as larger facilities and will be held to the same standards.