(55bk) Applying OSHA PSM Elements at Non-Covered Facilities.

The Occupational Safety and Health Administration (OSHA) issued Process Safety Management (PSM) for Highly Hazardous Chemicals (29 CFR 1910.119) in 1992 as a response to several large chemical release incidents around the world.

The code provides 14 elements that facilities must document as a means to ensure safe operations. While OSHA requirements mandate that covered facilities operating with highly hazardous chemicals above the threshold quantity adhere to these regulations, non-covered facilities can still benefit from the implementation of a “PSM-lite” program based on the federal PSM guidance.

This paper will explore the purpose of PSM and its role in ensuring well informed and safe operation of processes involving highly hazardous chemicals. It will go on to explore how these concepts can be utilized by companies that do not fall under the PSM regulatory requirements but are still involve potentially hazardous chemicals or processes.

Additionally, the paper will describe how, and provide examples of when, a PSM program can be beneficial in ensuring standards that apply to non-PSM covered facilities are followed. For example, in 29 CFR 1910.119(k)(2) Hot work permit, it notes that “shall document that the fire prevention and protection requirements in 29 CFR 1910.252(a) have been implemented prior to beginning the hot work operations. In this paragraph of the PSM Standard, OSHA comes right out and says that it is simply restating the requirements they have provided in 29 CFR 1910.252(a), Welding, Cutting, and Brazing-General requirements.

While not all facilities handling highly hazardous chemicals are subject to the regulations provided in 29 CFR 1910.119 all of these facilities can benefit from implementing aspects of this standard.