Both OSHA’s Process Safety Management (“PSM”) and EPA’s Chemical Accident Prevention regulations are regulatory programs developed to address process safety in the “Process Industry.” A “Process” is defined broadly and includes any activity that uses, stores, manufactures, handles or moves hazardous chemicals. Since the definition is broad, it includes much more than refineries and chemical

Both PSM and RMP require that the owner or operator have a system in place to promptly address the team’s PHA findings and recommendations to assure they are resolved in a timely matter. See 29 CFR 1910.119(e)(5) and 40 CFR 68.67(e). In accordance with Pre-startup review requirements, these PHA recommendations must be resolved or implemented

A PHA team must have the following expertise:

  • engineering and process operations;
  • experience and knowledge specific to the process being evaluated; and
  • a facilitator (knowledgeable in the specific PHA methodology being used)

Employers must have a written plan to include employees and their representatives on the conduct and development of PHAs. 29 CFR 1910.119(c) and