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OSHA Issues Two PSM Reports for Facilities Storing Highly Hazardous Chemicals

By Nickole C. Winnett at Jackson Lewis P.C.. June 1, 2017

The U.S. Occupational Safety and Health Administration (OSHA) has issued two reports on the safe management of hazards by small businesses and storage facilities that use highly hazardous chemicals in business processes.

In 1994, OSHA outlined the requirements for the management of hazards associated with processes using highly hazardous chemicals in its Process Safety Management of Highly Hazardous Chemicals (HHC) standard (29 CFR 1910.119). OSHA said the standard is intended to help prevent or minimize unexpected releases of toxic, reactive, or flammable liquids and gases associated with these processes. The agency said the standard emphasizes the establishment of a “comprehensive management program that integrates technologies, procedures, and best management practices.”

In its small businesses report, OSHA said, “Catastrophic HHC release events continue to occur among smaller companies.” It said one study estimated that employers with 1-25 employees are 47 times more likely to have a release and 17 times more likely to suffer an injury, per employee, than facilities with 1,500 or more employees. It said that the release of highly hazardous chemicals not only risks worker safety, but the safety of surrounding populations and structures because small businesses often are located in populated areas.

In its report for storage facilities, OSHA said that, between 1997 and 2013, “numerous” incidents at storage facilities have caused serious injuries and fatalities to employees. It said storage facilities typically have considerably less complex process safety issues than facilities with large chemical manufacturing operations, which may make compliance easier and less costly.

The reports spell out how the standard includes a compilation of process safety information, followed by a process hazard analysis (PHA). The analysis includes “a careful and thorough review of what could go wrong and what safeguards must be implemented to prevent releases of highly hazardous chemicals.

The standard also mandates development of written operating procedures, completion of relevant employee training, encouraging and ensuring employee participation, according to a written plan, pre-startup safety reviews, evaluation of the mechanical integrity of critical equipment, contractor requirements, and a written management of change process. It also requires a permit system for “hot work,” investigation of incidents involving releases of covered chemicals or “near-misses,” emergency action plans, compliance audits at least every three years, and allows for trade secret protection as long as the relevant information remains available to applicable parties.

© 2017 Jackson Lewis P.C. This Update is provided for informational purposes only. It is not intended as legal advice nor does it create an attorney/client relationship between Jackson Lewis and any readers or recipients. Readers should consult counsel of their own choosing to discuss how these matters relate to their individual circumstances. Reproduction in whole or in part is prohibited without the express written consent of Jackson Lewis.


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