Before OSHA Comes Knocking

The OSHA Process Safety Management National Emphasis Program will soon apply to the chemical industry, targeting compliance with safety standards associated with chemical hazards. The U.S. Occupational Safety and Health Administration's (OSHA) process safety management (PSM) standard sets requirements for the management of hazards associated with processes that use highly hazardous chemicals (HHC) - e.g., chemicals that are toxic, reactive, flammable or explosive. 

As part of its overall enforcement activities, OSHA routinely uses national emphasis programs (NEPs) to target establishments or industries that have known or suspected hazardous conditions, such as exposure to lead or silica, the potential for amputations or trench cave-ins, or the presence of combustible dust. In response to recommendations by the U.S. Chemical Safety and Hazard Investigation Board (CSB), in June 2007 OSHA launched a PSM NEP aimed at reducing or eliminating workplace hazards associated with the catastrophic release of HHCs at petroleum refineries. Over the past year and a half, the agency has conducted comprehensive regulatory-compliance inspections at dozens of refineries throughout the U.S., and it expects to be finished inspecting all 81 refineries under federal jurisdiction by the end of 2009.

Most recently, the agency announced its plan to expand the PSM NEP to include the chemical industry. This initiative will target chemical facilities' compliance and implementatin efforts related to PSM and other workplace-safety standards associated with chemical hazards. Although OSHA has not yet officially launched the program, it is in the process of developing protocols and procedures needed to roll out the program early this year.

In the meantime, chemical plants can begin to prepare for these anticipated inspections. This article outlines some of the lessons learned from the refinery inspections, offers insights into the PSM standard elements and compliance issues that OSHA will likely target at chemical plants, and provides guidance on how facilities can prepare for the inevitable visits.

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