The Occupational Safety and Health Administration (“OSHA”) published a Request for Information (“RFI”) on December 9, 2013 concerning possible changes to the Process Safety Management (“PSM”) program codified at 29 C.F.R. 1910.119. See 78 Fed. Reg. 73756 (Dec. 9, 2013). Likewise, the Environmental Protection Agency (“EPA”) published an RFI on July 31, 2014 relating
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
Safe upper and lower limits are intended to relate to the equipment itself. For example, a process circuit will have multiple pieces of equipment within the circuit with varying design maximum pressure ratings. Whereas each piece of equipment will have different pressure rating, the safe upper limit for the circuit should be something less than
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
RAGAGEP is an acronym for the term “Recognized and Generally Accepted Good Engineering Practice.” Although this term is not defined in the PSM or RMP regulations, it is found within the Process Safety Information (PSI) and Mechanical Integrity sections. Significant controversy exists around the term and its meaning resulting, in part, in recent
Both PSM and Program 3 of RMP require compliance with similar elements which include the:
After the team makes a recommendation, the first step is to resolve the team’s finding. If the resolution is to accept the recommendation, the employer must complete the actions as soon as possible. See 29 CFR 1910.119(e)(5).
OSHA expects that accepted recommendation be completed as soon as possible which usually means with one to
There is only one level of PSM applicability; either you are in or out. Processes are subject to PSM if they contain the threshold amount of a Chemical found in Appendix A to the rule, or if it has more than 10,000 pounds of a flammable gas or liquid. See 29 CFR 1910.119(a). PSM applicability