2019 Spring Meeting and 15th Global Congress on Process Safety

(55v) Most Common Process Safety Management Gaps Based on Occupational Safety and Health Administration Process Safety Management of Highly Hazardous Chemicals Violation Trends

Author

The Occupational Safety and Health Administration (OSHA) administers violations for the 29 Code of Federal Regulation (CFR) 1910.119 Process Safety Management (PSM) of Highly Hazardous Chemicals. These violations can be tied to the specific element and sub-set of the particular element within the standard. Data is available to allow review of the violation trends and in turn can provide some indication of common gaps in the industry.

This paper will provide an overview of the OSHA PSM violation trends not only for current years, but going back decades. The information will be segmented by industry, state and other categories. Although regulatory compliance is not the only goal of adequate PSM programs, reviewing the gaps found by OSHA can bring awareness and attention to some common issues and can lead to focused solutions for safer and more reliable facilities. The paper also covers some high-level information on corrective action considerations for some of the most cited elements of PSM.