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Fact Sheets (Program Highlights)
01/01/1993 - Process Safety Management of Highly Hazardous Chemicals

Fact Sheets (Program Highlights) - Table of Contents Fact Sheets (Program Highlights) - Table of Contents

U.S. Department of Labor
Program Highlights

Fact Sheet No. OSHA 93-45

PROCESS SAFETY MANAGEMENT
OF HIGHLY HAZARDOUS CHEMICALS

Introduction-The Process Safety Management(PSM) of Highly Hazardous Chemicals(HHC's) standard, 29 CFR 1910.119 is intended to prevent or minimize the consequences of a catastrophic release of toxic, reactive, flammable or explosive HHC's from a process. A process is any activity or combination of activities including any use, storage, manufacturing, handling or the on-site movement of HHC's. A process includes any group of vessels which are interconnected and separate vessels which are located such that a HHC could be involved in a potential release.

Application-The standard applies to a process which contains a threshold quantity or greater amount of a toxic or reactive HHC as specified in Appendix A. Also, it applies to 10,000 pounds or greater amounts of flammable liquids and gases and to to the process activity of manufacturing explosives and protechnics.

Exceptions-The standard does not apply to retail facilities, normally unoccupied remote facilities and oil or gas well drilling or servicing activities. Hydrocarbon fuels used solely for work place consumption as a fuel are not covered, if such fuels are not part of a process containing another HHC covered by the standard. Atmospheric tank storage and associated transfer of flammable liquids which are kept below their normal boiling point without benefit of chilling or refrigeration are not covered by the PSM standard unless the atmospheric tank is connected to a process or is sited in close proximity to a covered process such that an incident in a covered process could involve the atmospheric tank.

Process Safety Information-Requires compilation of written process safety information (PSI) including hazard information on HHC's, technology information and equipment information on covered processes.

Employee Involvement-Requires developing a written plan of action regarding employee participation; consulting with employees and their representatives on the conduct and development of process hazard analyses and on the development of other elements of process safety management required under the rule; providing to employees and their representatives access to process hazard analyses and to all other information required to be developed under the rule. Employees include work site and contractor employees.

Process Hazard Analysis-Specifies that process hazard analyses (PHA's) must be conducted as soon as possible for each covered process using compiled PS in an order based on a set of required considerations. At least twenty-five percent of initial process hazard analyses must be completed by May 26, 1994; 50 percent by May 26, 1995; 75 percent by May 26, 1996; and 100 percent by May 26, 1997. Process hazard analyses must be updated and revalidated at least every five years and must be retained for the life of the process.

Operating Procedures-Must be in writing and provide clear instructions for safely conducting activities involving covered process consistent with PSI; must include steps for each operating phase, operating limits, safety and health considerations and safety systems and their functions; be readily accessible to employees who work on or maintain a covered process, and be reviewed as often as necessary to assure they reflect current operating practice; and must implement safe work practices to provide for special circumstances such as lockout/tagout and confined space entry.

Training-Employees operating a covered process must be trained in the overview of the process and in the operating procedures addressed previously. This training must emphasize specific safety and health hazards, emergency operations and safe work practices. Initial training must occur before assignment or employers may certify that employees involved in the process as of May 26, 1992, have required knowledge, skills and abilities. Documented refresher training is required at least every three years.

Contractors-Identifies responsibilities of work site employer and contract employers with respect to contract employees involved in maintenance, repair, turnaround, major renovation or specialty work, on or near covered processes. Contract employers are required to train their employees to safely perform their jobs, and document that employees received and understood training, and assure that contract employees know about potential process hazards and the work site employer's emergency action plan, assure that employees follow safety rules of the facility, and advise the work site employer of hazards contract work itself poses or hazards identified by contract employees.

Pre-startup Safety Review-Mandates a safety review for new facilities and significantly modified work sites to confirm that the construction and equipment of a process are in accordance with design specifications; to assure that adequate safety, operating, maintenance and emergency procedures are in place; and to assure process operator training has been completed. Also, for new facilities, the PHA must be performed and recommendations resolved and implemented before start up. Modified facilities must meet management of change requirement.

Mechanical Integrity-Requires the on-site employer to establish and implement written procedures for the ongoing integrity of process equipment particularly those components which contain and control a covered process.

Hot Work-Hot work permits must be issued for hot work operations conducted on or near a covered process.

Management of Change-The work site employer must establish and implement written procedures to manage changes except "replacements in kind" to facilities that effect a covered process. The standard requires the work site employer and contract employers to inform and train their affected employees on the changes prior to start-up. Process safety information and operating procedures must be updated as necessary.

Incident Investigation-Requires employers to investigate as soon as possible (but no later than 48 hours after) incidents which did result or could reasonably have resulted in catastrophic releases of covered chemicals. The standard calls for an investigation team, including at least one person knowledgeable in the process involved, (a contract employee when the incident involved contract work) and others with knowledge and experience to investigate and analyze the incident, and to develop a written report on the incident. Reports must be retained for five years.

Emergency Planning and Response-Requires employers to develop and implement an emergency action plan. The emergency action plan must include procedures for handling small releases.

Compliance Audits-Calls for employers to certify that they have evaluated compliance with process safety requirements at least every three years. Prompt response to audit findings and documentation that deficiencies are corrected is required. Employers must retain the two most recent audit reports.

Trade Secrets-Sets requirements similar to trade secret provisions of the 1910.1200 Hazard Communication standard requiring information required by the PSM standard to be available to employees (and employees representatives). Employers may enter into confidentiality agreement with employees to prevent disclosure of trade secrets.

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This is one of a series of fact sheets highlighting U.S. Department of Labor programs. It is intended as a general description only and does not carry the force of legal opinion. This information will be made available to sensory impaired individuals upon request. Voice phone: (202) 523-8151. TDD message referral phone: 1-800-326-2577.



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