Safety Tidbit #2.24 – What falls under Process Safety Management
OSHA’s Process Safety Management of highly hazardous chemicals standard (1910.119) applies to all processes involving chemicals in Appendix A of the standard and for flammable materials (flashpoint less than 100 degrees Fahrenheit) in excess of the 10,000 pounds. Appendix A lists about 150 chemicals with applicable reportable quantities at which point the Standard kicks in. So how do you know if the employer has a chemical that falls under OSHA’s Process Safety Management standard?
First, the most common chemical from the list is ammonia as this is used for industrial refrigeration. If your client has a refrigerated facility or warehouse always ask about the refrigerant. If they use ammonia, ask how much their system uses. I have found facilities that started with one unit and did not fall under the standard but after they grew they added a second system and now exceed the 10,000-pound threshold onsite. Also, I have had clients that use diesel fuel in their product (e.g. roofing products) and have in large tanks to feed their process. They exceed the 10,000-pound threshold however the flashpoint of diesel fuel is greater than 100 degrees Fahrenheit.
A couple of good rules of thumb are, as you drive up to the facility, if you see tanks outside with process materials ask what the contents are and verify against Appendix A. If they have large tanks outside they may have enough chemical to exceed the threshold limits. Second, once inside the facility, if there is piping inside moving process chemicals around the facility ask what is in the piping and again verify against the list. Most likely if the employer is piping the chemical around they do not wish to handle it any more than necessary which is a good indicator that the chemical is not very nice.
Ultimately, use of the principles of PSM is just a robust hazard assessment so following the requirements of PSM is never a bad idea. So whether required or not everyone should:
· understand the hazards of the chemicals that are used,
· how to maintain the engineering controls to ensure proper functioning.
· how to safely handle the chemicals
· how to protect themselves from exposure
· how to render aid if exposure happens
· how to respond if a spill occurs
Hope this was helpful and thanks for reading my Safety Tidbits ~ Bryan
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