Who must follow Process Safety Management regulations?
Companies processing “highly hazardous” chemicals must follow the Occupational Health and Safety Administration’s (OSHA) Process Safety Management (PSM) standard to assess the risks of processes and establish a series of controls to avoid catastrophic consequences.
Does OSHA consider common flammable materials “highly hazardous”?
Many chemical companies have assumed that PSM regulation does not apply to them because they do not process what they believe to be “highly hazardous” chemicals. For example, companies processing common solvents or other flammable materials may not consider them to be “highly hazardous,” due to their familiarity with the chemicals. However, when there are 10,000 pounds or more of flammable solvents such as acetone, methyl ethyl ketone, and methanol connected to a process, these are considered “highly hazardous” by OSHA
Does OSHA consider drums as “highly hazardous”?
Another misinterpretation of the PSM standard is that it does not apply when a drum of highly hazardous materials is connected to the process. A drum of common flammable solvent weighs about 600 pounds, which is well below the 10,000-pound threshold quantity that triggers the PSM standard. Although a single drum of flammable solvent does not surpass the PSM threshold quantity, OSHA requires employers to consider all of the flammable material in the area when calculating the threshold quantity. That consideration is driven by the potential for a catastrophic consequence triggered by an event with a single process drum. Therefore, even though a company may only connect one drum at a time to the process, storing 16 other drums in the vicinity of the process may reach the 10,000-pound threshold for application of the PSM standard.
What factors other than “highly hazardous” chemicals does OSHA consider?
Reaching the threshold quantity of a “highly hazardous” chemical is one of a few considerations to be made when determining applicability of the PSM standard. Other factors include:
- storage vs. processing
- atmospheric vs. pressurized vessels
- ambient temperature vs. refrigeration systems
Are there benefits to implementing PSM even if my operation isn’t subject to PSM regulations?
Even if the PSM standard does not apply to a process, there are elements of PSM which, if implemented properly, may reduce the potential for a catastrophic event regardless of the quantity of chemicals connected to the process.
If your company has questions about the applicability of PSM or how to assess and manage the risks of a chemical process, contact our PSM specialists today.