OSHA Instruction CPL 2-2.45A CH-1 September 13, 1994 Directorate of Compliance Programs
Subject: 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals -- Compliance Guidelines and Enforcement Procedures
A. Purpose. This instruction transmits page changes to OSHA
Instruction CPL2-2.45A, which established uniform policies, procedures,
standard clarifications, and compliance guidance for enforcement of the
standard for Process Safety Management of Highly Hazardous Chemicals, 29 CFR
1910.119 ("PSM standard"), and amendments to the standard for Explosives and
Blasting Agents, 29 CFR 1910.109.
B. Scope. This instruction applies OSHA-wide.
C. Action.
1. Replace existing pages with the appropriate replacement pages, as follows:
Existing Pages |
Replacement Pages |
5 through 20 |
5 through 20 |
A-1 through A-61 |
A-1 through A-61 |
B-1 through B-8 |
B-1 through B-33 |
D-1 through D-3 |
D-1 through D-4 |
E-1 through E-2 |
E-1 through E-2 |
G-1 through G-2 |
G-1 through G-2 |
2. File a copy of this transmittal sheet with OSHA Instruction CPL 2-2.45A as a record of this change.
D. Federal Program Change. This instruction describes a Federal
program change which affects State programs. Each Regional Administrator
shall:
1. Ensure that a copy of this change is promptly forwarded to each
State designee, using a format consistent with the Plan Change Two-Way
Memorandum in Appendix P of OSHA Instruction STP 2.22A, CH-3.
2. Explain the technical content of this change to the State
designees as requested.
3. Ensure that State designees are asked to acknowledge receipt of
this Federal program change in writing to the Regional Administrator as soon
as the State's intention is known, but not later than 70 calendar days after
the date of issuance (10 days for mailing and 60 days for response). This
acknowledgment must include the State's intention to amend the policies and
procedures adopted in response to OSHA Instruction CPL 2-2.45A, in accordance
with OSHA's revised policies and procedures described in this change
instruction, or a description of the State's alternative policy and/or
procedure which is "at least as effective" as the Federal policy and/or
procedure.
4. Ensure that the State designees submit a plan supplement, in
accordance with OSHA Instruction STP 2.22A, CH-2, as appropriate, following
the established schedule that is agreed upon by the State and the Regional
Administrator to submit non-Field Operations Manual/Technical Manual Federal
Program Changes.
a. If the State intends to follow the revised inspection
procedures described in this instruction, the State must submit either a
revised version of this instruction, adapted as appropriate to reference
State law, regulations and administrative structure, or a cover sheet
describing how references in this instruction correspond to the State's
structure. The State's acknowledgment letter may fulfill the plan supplement
requirement if the appropriate documentation is provided.
b. If the State adopts an alternative to Federal enforcement
inspection procedures, the State's plan supplement must identify and provide
a rationale for all substantial differences from Federal procedures in order
for OSHA to judge whether a different State procedure is as effective as the
comparable procedure.
5. After Regional review of the State plan supplement and
resolution of any comments thereon, forward the State submission to the
National Office in accordance with established procedures. The Regional
Administrator shall provide a judgment on the relative effectiveness of each
substantial difference in the State plan change and an overall assessment
thereon with a recommendation for approval or disapproval by the Assistant
Secretary.
6. Review policies, instructions, and guidelines issued by the
States to determine that this change has been communicated to State program
personnel.
E. Discussion. These page changes contain additions and
corrections to the PSM compliance directive. Appendices A and B also reflect
clarifications and interpretations agreed to in a settlement dated April 5,
1993, between OSHA and the United Steelworkers of America, the Oil, Chemical
and Atomic Workers International Union, and the Building and Construction
Trades Department of the AFL-CIO. The settlement agreement clarifications
reflect modifications jointly and cooperatively agreed to by the above
parties and by the Chemical Manufacturers Association, the American Petroleum
Institute, the Dow Chemical Company, and the National Petroleum Refiners
Association. Individual text changes are denoted by a line in the left
margin, except in Appendix B, in which revisions were so extensive as to
require complete reprinting. The following significant changes should be
noted:
1. Pages 6-20. References to explosives manufacture have
been added, as well as technical clarifications regarding the inspection
scheduling process.
2. Appendix A. Clarified audit guidelines and questions
have been added on compliance requirements relative to contractors. (Because
of a minor typographical change, the entire appendix has been
reprinted.)
3. Appendix B. Numerous additional clarifications and
interpretations of the standard have been added.
4. Appendix D. References regarding explosives manufacture
and training resources have been added.
Joseph A. Dear Assistant Secretary
DISTRIBUTION: National, Regional, and Area Offices All Compliance Officers
State Designees NIOSH Regional Program Directors 7(c)(1) Consultation Project
Managers OSHA Training Institute
NOTE: The text below includes only the revised pages 5 thru 20 of OSHA Instruction CPL 2-2.45A. For the full updated text of that directive, go to CPL 2-2.45A (REVISED)
an assessment of the employer's Hazard Communication
program.
b. If the establishment is found to be covered by the
standard:
(1) It shall be further determined if the establishment is
included in the universe of affected establishments from which PQV
inspections may be scheduled. (See J. of this
instruction.)
(2) The employer shall be provided:
(a) Copies of the OSHA publications "Process Safety
Management," OSHA Publication 3132, which also contains the full text of
1910.119; and "Process Safety Management -- Guidelines for Compliance;"
and
(b) A letter notifying the employer that the subject
establishment is covered by the PSM standard and may be inspected under the
standard. The letter shall also emphasize the employer's obligation to
comply with the standard. An example of such a letter is provided as
Appendix F of this instruction.
c. The Area Director shall ensure proper coding of the OSHA-1
(as described at Q. and Appendix H of this instruction) to identify the
establishment as either known to be covered by the PSM standard or known not
to be covered by the standard.
3. Unprogrammed PSM-related Inspections. In all
unprogrammed inspection activity relating to the PSM standard, a
determination shall be made as to whether the establishment is covered by 29
CFR 1910.119.
a. If a formal complaint or referral relating to the PSM
standard is received regarding any workplace classified in one of the SIC
codes listed at Appendix C of this instruction, the complaint or referral
item(s) shall be investigated and:
(1) All programs required by the PSM standard shall be
screened for obvious violations; and
(2) A CSHO referral for a PQV inspection shall be
considered if major deficiencies are indicated. This determination shall be
documented in the case file.
b. Investigations of formal, PSM-related complaints and
referrals in establishments in all other SIC codes shall normally be limited
to the complaint item(s) only, unless violations related to the complaint or
referral items are found.
4. Responses to Accidents and Catastrophes. Responses to
accidents and catastrophes involving PSM shall follow the guidelines
contained in Chapter VIII of the FOM and -- where appropriate -- in OSHA
Instruction CPL 2.94, "OSHA Response to Significant Events of Potentially
Catastrophic Consequence," in addition to the guidelines of this instruction.
If the workplace is classified in one of the SIC codes listed at Appendix C
of this instruction, a PQV inspection shall be considered; the reasons for
the determination shall be documented in the case file.
5. All Other Inspections. Normally, there shall be no
PSM-related activity on any inspection other than those described at H.1.
through H.4., above.
I. Inspection Resources. Appropriate levels of staff training and
preparation are essential for compliance activities relating to the PSM
standard. In particular, it is anticipated that PQV inspections will be
highly resource-intensive; they will therefore require careful planning and
coordination. The recommendations included as Appendix G of this instruction
may be used as a guide for such planning.
1. PQV Team Leaders ("Level One"). Only trained compliance
safety and health officers (CSHOs) with experience in the chemical industry
(and/or the explosives industry, as appropriate) shall be assigned to lead a
PQV inspection under this standard.
a. As a minimum, this training must include the OSHA Training
Institute's Course 330, "Safety and Health in the Chemical Processing
Industries," and Course 340, "Hazard Analysis in the Chemical Processing
Industries." A section of Course 340 will deal with explosives
manufacture.
NOTE: (1) Due to a significant change in course content,
completion of Course 330 prior to Fiscal Year 1991 does not meet this
requirement for PQV team leaders.
(2) All CSHOs who will serve as PQV team leaders should
have additional advanced training such as that offered by the National
Institute of Standards and Technology and the U.S. Bureau of
Mines.
b. Team leaders must have prior experience in the chemical
industry. This experience should include experience obtained from
accident/explosion investigations in chemical or petrochemical plants,
through previous chemical inspections involving process safety management
evaluation, or through previous chemical industry employment.
c. For PQV inspections of explosives manufacturers, team
leaders shall have had experience in the explosives industry.
2. PQV Team Members ("Level Two"). CSHOs may be assigned
as PQV team members, or to conduct unprogrammed inspections in workplaces in
the targeted SIC codes listed in Appendix C of this instruction, if they have
2 years of OSHA inspection experience or the equivalent and have completed
Course 330, "Safety and Health in the Chemical Processing Industries"
(including offerings of this course prior to Fiscal Year 1991) and Course
340, "Hazard Analysis in the Chemical Processing Industries."
3. CSHOs With Less Training. Complaint and other
unprogrammed inspections pertaining to some sections of the standard may be
conducted by CSHOs who do not have the training and experience described at
I.1. or I.2., above, but who are experienced in evaluating other programmatic
standards such as hazard communication and lockout/tagout and in evaluating
respirator programs.
a. The following sections of 29 CFR 1910.119 may be appropriately evaluated by such CSHOs:
* (c) Employee participation.
* (g) Training.
* (h) Contractors.
* (k) Hot work permits.
* (m) Incident investigation.
* (n) Emergency planning and response.
b. Such CSHOs shall make full utilization of Technical Support
resources at the Regional Office and National Office levels in arriving at
decisions regarding compliance or noncompliance.
c. Nevertheless, to the extent possible, Area Directors shall
attempt to utilize CSHOs with experience and training in the chemical
industry to perform such unprogrammed inspections.
4. State Plan States. Each State shall have one or more
CSHOs trained to meet the requirements for PQV team leaders and an
appropriate number of qualified team members. OSHA will provide technical
assistance, as needed, through the Regional Office, Health Response Team, and
the Office of Construction and Engineering.
J. PQV Inspection Scheduling. Due to the resource-intensive nature
of inspections for compliance with the PSM standard, the Agency will be able
to perform only a limited number of PQV inspections (as described at K. and
L. of this instruction) each year. A special targeting and scheduling system
is therefore necessary to maximize the effective use of inspection resources.
1. Targeting. OSHA wishes to make the most effective use
of its limited resources, and therefore will use the factors listed below in
determining the SIC codes to be inspected. OSHA will select the SICs that
have experienced the greatest number of accidents/incidents as determined
from these three sources:
a. Published insurance industry reports of major accidents/incidents.
b. IMIS data, including the OSHA-170 Investigation Summary File.
c. EPA Accident Release Information Program (ARIP) data.
2. Current Targeted SICs. A list of targeted SIC codes
based on current data, as described at J.1., is included as Appendix C of
this instruction. This Appendix may be updated periodically.
3. Scheduling. PQV inspections shall be scheduled as follows:
a. Using the list of SICs determined as described at J.1.
above, the Office of Statistics shall annually create an initial list
including all known establishments within each of the identified SICs for
each Region. This list shall be organized by establishment, by establishment
size, by corporate identity (as determined through a commercially available
source), and by State.
b. The Directorate of Compliance Programs shall forward the
initial lists to the appropriate Regions. A Region may add to its initial
list establishments that are known to be in the identified SICs and to have
more than 10 employees.
c. Within 30 days of receipt of the initial list, each Region
shall select five candidates for a PQV inspection and shall forward the
resulting list, together with documentation supporting the selections, to the
Directorate of Compliance Programs. The Regions shall base their selection
on such factors as:
(1) Number of employees at the facility.
(2) Age of the facility.
(3) Known toxicity of chemicals used in the facility' s processes.
(4) Frequency of media reports of releases or other incidents at the facility.
(5) Local EPA information.
(6) Past OSHA history of the facility, including complaints received and/or followup inspections due.
(7) Information from local/municipal fire departments.
NOTE: The Regions need not make a determination on each
of these factors for each establishment on their initial list; however, their
selections for candidates shall be thoroughly documented.
d. Beginning with Fiscal Year 1994, Regional Administrators
shall provide to each State designee a copy of the establishment list within
their State. Each State shall nominate one establishment for a PQV
inspection or provide an explanation of why a PQV inspection should not be
scheduled in their State. Regional Administrators shall include these
candidates with their regional submission (i.e., in addition to the five
candidates submitted by each Region) to the Directorate of Compliance
Programs, together with their assessment and recommendation as to whether the
State's candidate should be included in the national selection and as to the
State's degree of readiness to conduct the inspection
independently.
e. Within 60 days of the receipt of the candidate lists from
the Regions, the Directorate of Compliance Programs shall notify each Region
of the final list of establishments from which PQV inspections are to be
scheduled.
(1) The selections for the Regional lists shall be made by
the Directorate of Compliance Programs in coordination with the Office of
Field Programs. The selections shall be based on:
(a) Emphasis on a corporate approach, to give
inspection priority to the maximum number of different corporations, rather
than targeting multiple inspections in the same corporation;
and
(b) Regional resources and inspection goals; and
(c) Overall Agency resources.
(2) Inspection goals (actual numbers) are to be set in the
annual Field Operations Program Plan between Regions and the Office of Field
Programs.
(3) The number of establishments selected may vary from
Region to Region, because OSHA plans to focus more PQV inspections in Regions
with higher concentrations of high-hazard industries affected by the
standard.
(4) The selections from the States' list shall be
coordinated with the Office of State Programs. Regional Administrators shall
include full discussion and coordination with the affected
States.
4. Deletion Criteria. An establishment shall be deleted
from the list if it:
a. Has received a substantially complete systems safety
inspection or PQV inspection within the current or the preceding 5 calendar
years; or
b. Is included in a corporate settlement agreement requiring
appropriate management systems for process safety; or
c. Is a VPP participant; or
d. Is a corporate office/headquarters and is not engaged in
actual production or physical research operations; or
e. Has been identified in the wrong SIC code or is out of business; or
f. Is not covered because of exclusions in the PSM standard; or
g. Has been the subject of a PSM-related inspection (complaint
or referral) in the preceding year during which PSM programs were screened
and a referral for a PQV inspection was not made.
NOTE: Determination for deletion shall be made
initially, to the extent possible, at the National Office level when the list
is prepared; and/or subsequently, as necessary, at the Regional Office level
based on local knowledge (e.g., recent inspections, Area Office screening,
State Manufacturers' Guide).
5. Local Emphasis Programs. Some Regions may have
relatively few establishments in the targeted SIC codes listed in Appendix C.
Regional Administrators therefore may propose a Local Emphasis Program to
direct Regional PSM inspections resources to industry types that may not be
covered by the targeted SIC codes. Such Local Emphasis Programs shall be
submitted to the Directorate of Compliance Programs for approval in
accordance with the FOM, Chapter II.
K. Scope of PQV Inspection. Comprehensive inspections under the
PSM standard shall evaluate the procedures used by the employer and the
process-related contract employers to manage the hazards associated with
processes using highly hazardous chemicals. Normally, these inspections will
embody a three-fold approach, which for reference is termed
Program-Quality-Verification (PQV).
1. First, the employer's and the contract employers'
Program for complying with each of the listed elements of the PSM
standard shall be evaluated in accordance with the PSM Audit Guidelines
contained in Appendix A of this instruction. (See also M. of this
instruction.)
2. Second, the Quality of the employer's and the contract
employers' procedures shall be compared to acceptable industry practices as
described in the standard to determine compliance.
3. Third, Verification of the employer's and the contract
employers' effective implementation of the program can be made through review
of written programs and records of activity, interviews with employees at
different levels, and observation of site conditions. The team leader shall
select one or more processes as described at L.7. of this instruction to
perform the verification portion of the inspection.
L. PQV Inspection Procedures. The procedures given in the FOM,
Chapter III, shall be followed except as modified in the following sections:
1. Opening Conference. Where appropriate, the facility
safety and health director, Process Safety Manager, or other person capable
of explaining the company's Process Safety Management Program shall be
included in the opening conference.
a. During the opening conference, CSHOs shall familiarize
themselves with the establishment's emergency response procedures and
emergency alarms.
b. CSHOs shall also request that the management
representative(s) provide them with a reasonably detailed overview of the
chemical (and, where applicable, explosives) process and/or manufacturing
operations at the facility, including block flow and/or process flow diagrams
indicating chemicals and processes involved.
2. PSM Overview. Prior to beginning the walkaround
inspection, the CSHOs shall request an explanation of the company's Process
Safety Management Program including, at a minimum:
a. How the elements of the standard are implemented;
b. Personnel designated as responsible for implementation of
the various elements of the standard; and
c. A description of company records used to verify compliance
with the standard.
3. Initial Walkaround. After this familiarization, the
inspection may begin with a brief walkaround inspection of those portions of
the facility within the scope of the standard. Additional walkaround
activity may be necessary after selection of the process unit(s). The
purpose of the initial walkaround is to:
a. Give CSHOs a basic overview of the facility operations;
b. Allow CSHOs to observe potential hazards such as pipework
in risk of impact, corroded or leaking equipment, unit or control room
siting, and location of relief devices; and
c. Solicit input from the employee representative concerning
potential PSM program deficiencies.
4. Personal Protective Equipment (PPE). In addition to
normal inspection protective equipment, CSHOs conducting these inspections
shall be provided with flame retardant coveralls for protection from flash
fires and with NIOSH-approved emergency escape respirators for use during any
emergency conditions. PPE shall be appropriate to the environment at the
workplace. Special equipment will be necessary in environments containing
explosive materials.
a. CSHOs shall wear flame-retardant coveralls in all areas of
the plant where there is potential for flash fires and as may be required by
company policy.
NOTE: Clothing made of hazardous synthetic fabrics
should not be worn underneath flame-retardant coveralls.
b. CSHOs shall carry emergency escape respirators, when
necessary, during the walkaround portion(s) of the inspection. CSHOs
conducting these inspections shall have received proper training in the use
of emergency escape respirators.
c. CSHOs shall be provided with appropriate alert monitors
approved for the environment where they will be used (e.g., HCN, Cl2) where
such devices are necessary.
d. CSHOs shall ensure that any still cameras and/or video
cameras are intrinsically safe for use in the process areas being
inspected.
NOTE: CSHOs may use video cameras equipped with a
telephoto lens from outside classified areas and/or still cameras without
batteries.
5. Documentation to be Requested -- General and Process
Related. At the conclusion of the opening conference, the CSHO shall
request access to or copies of the documents listed at L.5.a. through L.5.m.
below. Initially, to expedite the inspection process, only access to
documents should be requested. During the inspection, as potential
violations of the standard are observed, copies of the written documentation
described below shall be requested to substantiate citations.
a. OSHA 200 Logs for the past 3 years for both the employer
and all process-related contractor employer(s).
b. Employer's written plan of action regarding the
implementation of employee participation.
c. Written process safety information for the unit(s) selected
(see L.7.), if available, such as flow diagrams, piping and instrumentation
diagrams (P&ID's), and process narrative descriptions.
NOTE: The employer is required to compile process safety
information on a schedule consistent with the employer's schedule for
conducting the process hazard analyses (PHA).
d. Documented priority order and rationale for conducting
process hazard analyses; copies of any process hazard analyses performed
after May 25, 1987; team members; actions to promptly address findings;
written schedules for actions to be completed; documentation of resolution of
findings; documentation verifying communication to appropriate personnel; and
5-year revalidation of original PHA required by standard.
e. Written operating procedures for safely conducting
activities in each selected unit; annual certification that operating
procedures are current and accurate; written procedures describing safe work
practices for potentially hazardous operations, including (but not limited
to) lockout/tagout, confined space entry, lifting equipment over process
lines, capping over ended valves, opening process equipment or piping,
excavation, and control over entrance into a facility of maintenance,
laboratory, or other support personnel.
f. Training records for initial and refresher training for all
employees in the selected unit(s) whose duties involve operating a process;
methods for determining the content of the training; methods for determining
frequency of refresher training; certification of required knowledge, skills,
and abilities to safely perform job for employees already involved in
operating a process on May 26, 1992, who have not received initial training;
and training material.
g. Pre-startup safety review for new facilities and for
modified facilities when the modification is significant enough to require a
change in the process safety information; documentation of employee
training.
h. Written procedures and schedules to maintain the ongoing
integrity of process equipment; the relevant portions of applicable
manufacturers' instructions, codes, and standards; and inspection and tests
performed on process equipment in the unit(s) selected.
i. Hot work permit program and active permits issued for the
unit(s) selected.
j. Written procedures to manage change to process chemicals,
technology, equipment and procedures; and changes to facilities that affect a
covered process.
k. Incident investigation reports for the unit(s) selected,
resolutions and corrective actions.
l. Written emergency action plan including procedures for
handling small releases and evidence of compliance with 1910.120(a), (p), and
(q), where applicable.
m. The two most recent compliance audit reports, appropriate
responses to each of the findings, and verifications that deficiencies have
been corrected.
6. Documentation to be Requested -- Contractor-Related. The
following information relating to contractor compliance shall be
requested:
a. Documentation from Employer:
(1) Information relating to contract employers' safety
performance and programs;
(2) Methods of informing contract employers of known
potential hazards related to contractor's work and the process and applicable
provisions of the emergency action plan;
(3) Safe work practices to control the entrance, presence
and exit of contract employers and contract employees in covered process
areas;
(4) Evaluation of contractor employer performance in
fulfilling responsibilities required by the standard;
(5) Contract employee injury and illness logs related to
work in process areas; and
(6) A list of unique hazards presented by contractors' work
or hazards found in the workplace that have been reported to the
employer.
b. Documentation from Contract Employer:
(1) Records showing employees receive training in and
understand safe work practices related to the process on or near which they
will be working to perform their jobs safely;
(2) Known potential fire, explosion or toxic release
hazards related to job, and applicable provisions of emergency action plan;
and
(3) A list of unique hazards presented by contractors' work
or hazards found in the workplace that have been reported to the
employer.
NOTE: The documentation described at L.5. and L.6.a. may
also be required of the contract employer, depending on the scope of the
contract employer's activities.
7. Selection of Process(es). The team leader shall select
one or more processes within which to evaluate compliance with the standard.
This selection shall be based on the factors listed below, and shall be
documented in the case file:
a. Factors observed during the walkthrough;.
b. Incident reports and other history;
c. Company priorities for or completed process hazard analyses (PHA);
d. Age of the process unit;
e. Nature and quantity of chemicals involved;
f. Employee representative input;
g. Current hot work, equipment replacement, or other maintenance activities; and
h. Number of employees present.
M. Compliance Guidelines for Specific Provisions of 29 CFR
1910.119. Guidelines for assessing compliance with the provisions of the
PSM standard are provided in Appendix A of this instruction.
1. CSHOs shall use the guidance contained in Appendix A during all
enforcement activities related to the PSM standard.
2. Clarifications and interpretations are provided in Appendix B
of this instruction. Appendix B (or a subsequent revision) shall normally be
the first point of reference in interpreting 29 CFR 1910.119.
NOTE: Appendix B will be updated on an ongoing basis through
page changes to this instruction, as more interpretations are developed.
CSHOs must therefore take care to ensure that their reference copies are
up-to-date.
N. Citations. Citations for violations of the PSM standard shall
be issued in accordance with the FOM, Chapters IV and V, with the following
additional directions:
1. Classification. The requirements of the PSM standard
are intended to eliminate or mitigate the consequences of releases of highly
hazardous chemicals. The provisions of the standard present closely
interrelated requirements, emphasizing the application of management controls
when addressing the risks associated with handling or working near hazardous
chemicals.
a. Any violation of the PSM standard, therefore, is a
condition which could result in death or serious physical harm to
employees.
b. Accordingly, violations of the PSM standard shall normally
not be classified as "other-than-serious."
2. Use of Appendix A. Appendix A, PSM Audit Guidelines, is
constructed as a series of questions relating to each of the pertinent
provisions of the standard.
a. The questions are designed to elicit a determination of
"Yes" or "No" by the CSHO as to whether compliance with the provision has
been met.
b. A determination of "No" for any provision indicates
noncompliance; thus, any "No" shall normally result in a citation for a
violation of that provision.
c. The CSHO shall thoroughly document each such determination in the case file.
O. Non-Mandatory Appendices to this Instruction. This instruction
contains two non-mandatory appendices that are designed to provide
additional compliance assistance.
1. Appendix E is still being developed and is designated as "Reserved."
2. Appendix G, Recommended Guidelines for PQV Inspection
Preparation, is intended as an aid to Regional and Area Offices in planning
resources for PQV and other PSM related inspections.
P. Evaluation. Each Region shall develop a preliminary evaluation
of the effectiveness of this program and submit it to the Directorate of
Compliance Programs no later than September 30, 1995. The report shall
include, at a minimum, the following items:
1. The utility of the PSM audit guidelines used in Appendix A.
2. An assessment of the accuracy of targeting information.
3. An estimate of total resources (CSHO, supervisory,
administrative and legal) that were required to conduct each
inspection.
Q. Recording in IMIS. Information about PSM-related inspections
shall be recorded in IMIS following current instructions given in the IMIS
manual. Refer to Appendix H of this instruction for additional guidance.
Joseph A. Dear Assistant Secretary
DISTRIBUTION: National, Regional, and Area Offices All Compliance Officers
State Designees NIOSH Regional Program Directors 7(c)(1) Consultation Project
Managers OSHA Training Institute
APPENDIX A
PSI AUDIT GUIDELINES
Purpose.
This appendix contains audit guidelines intended to assist the CSHO in
investigating an employer's compliance with the PSM standard. It shall be
used in conjunction with Appendix B, Clarifications and Interpretations of
the PSM Standard, as the primary source of compliance guidance on 29 CFR
1910.119.
Structure.
The guidelines present a Program Summary, Quality Criteria References, and a
Verification checklist for each of the PSM elements.
1. Guidelines for paragraphs c, g, h, k, m, and n are
designed so that CSHOs who may not be specifically trained in chemical
process plants or in the PSM standard can make a preliminary review of the
required elements.
2. Guidelines for elements d, e, f, i, j, l, o, and p are
oriented toward more detailed investigations.
Use of the Verification Checklist.
The verification of each program element is divided into three parts:
Records Review, On-Site Conditions and Interviews.
1. The Records Review section describes the documentation of the programs
as required by the PSM standard. During a preliminary inspection, the CSHO
shall review the documentation for the entire PSM program to ascertain that
all of the elements are developed.
2. Sections labeled On-Site Conditions and Interviews guide the CSHO in
confirming that the programs are implemented. This confirmation involves
observing conditions and procedures, and interviewing the operators,
maintenance personnel, engineering support staff, contractors and contractor
employees, as appropriate, to determine whether the implemented program
matches the program outlined by the documentation.
NOTE: Several questions in the "Interviews" sections refer to
interviewing engineers. The PSM standard does not require an employer to
employ engineers, and these questions should not be construed as imposing a
new requirement that an employer do so. All questions in this appendix that
refer to interviews of engineers shall be understood to mean "engineers, if
any, or other qualified persons capable of providing the information
requested."
3. The CSHO shall initially perform a representative number of
observations and interviews for elements c, g, h, k, m, and n. A more
detailed investigation will cover all 14 elements. During these detailed
assessments, the CSHO shall review components from a representative number of
processes, if multiple processes exist. To confirm implementation, the CSHO
shall compare the conditions and the interview results with both the minimum
requirements of the PSM standard and the program outlined by the employer's
documents.
Audit Guideline Documentation.
As noted at P.2. of the body of this instruction, the Audit Guidelines are
constructed as a series of questions relating to each of the pertinent
provisions of the standard.
1. The questions are designed to elicit a determination of "Yes" or "No"
by the CSHO as to whether compliance with the provision has been met. This
shall be indicated in the column labeled Met Y/N. A "Y" or "Yes" in this
column indicates the subsection meets requirements. An "N" or "No" indicates
the employer does not meet the standard and an "NA" signifies that the
subsection does not apply.
2. A determination of "No" for any provision indicates noncompliance;
thus, any "No" shall normally result in a citation for a violation of that
provision.
3. The CSHO shall thoroughly document each such determination in the case
file.
The Field Note Reference(s) space is used to cross-reference the PSM
subsection with the CSHO's field notes. Field notes need not be rewritten
when using these guidelines. The CSHO may record field note page numbers,
videotape frame identification, photograph identification, and other
documentation that refers to the requirements of the standard's elements.
Basic Audit Information.
In order to gather the information needed to audit the program, the CSHO
shall answer the following questions for each element:
Who? What? When? Where? Why? and How?
1. Who are the officials responsible for developing and implementing each
of the program elements?
2. What are the requirements and the contents of each program element?
3. When are the required actions for each element completed and when are
they required to be completed?
4. Where have actions been implemented or changed?
5. Why have the implementation decisions and priorities been made as
recorded in the PSM documentation?
6. How is the program implemented and how is the program's effectiveness
evaluated and improved (monitoring performance, followup and closure of
outstanding items, etc.)?
Interrelationship of Elements.
An essential part of verifying program implementation is to audit the flow
of information and activities among the elements. When information in one
element is changed or when action takes place in one element that affects
other elements, the CSHO shall review a sample of the related elements to see
if the appropriate changes and followup actions have taken place.
The following example demonstrates the interrelationship among the elements:
During a routine inspection of equipment (Mechanical
Integrity), the maintenance worker discovers a valve that no longer meets
the applicable code and must be changed. Because the type of valve is no
longer made, a different type of valve must be selected and installed
(Management of Change). The type of valve selected may mandate
different steps for the operators (Operating Procedures) who will
require training and verification in the new procedures (Training).
The rationale for selecting the type of valve must be made available for
review by employees and their representatives (Employee
Participation).
When the new valve is installed by the supplier
(Contractors), it will involve shutting down part of the process
(Pre-startup Safety Review) as well as brazing some of the lines
(Hot Work Permit). The employer must review the response plan
(Emergency Planning) to ensure that procedures are adequate for the
installation hazards.
Although Management of Change provisions cover interim
changes, after the new valve is in place the Process Safety
Information will have to be updated before the Process Hazard
Analysis is updated or revalidated, to account for potential hazards
associated with the new equipment. Also, inspection and maintenance
procedures and training will need to be updated (Mechanical
Integrity).
In summary, 11 PSM elements can be affected by changing one valve. A CSHO
would check a representative number of these 11 elements to confirm that the
required followup activities have been implemented for the new valve.
Three key elements shall be routinely reviewed to verify that changes have
been implemented. They are:
* Operating Procedures;
* Process Hazard Analysis; and
* Training.
These elements shall be crosschecked to see if they show that the changes
have been followed through to completion.
1910.119(c): EMPLOYEE PARTICIPATION
I. PROGRAM SUMMARY
The intent of this paragraph is to require employers to involve employees at
an elemental level of the PSM program. Minimum requirements for an Employee
Participation Program for PMS must include a written plan of action for
implementing employee consultation on the development of process hazard
analyses and other elements of process hazard management contained within
1910.119. The employer must also provide ready access to all the information
required to be developed under the standard.
II. QUALITY CRITERIA REFERENCES
A. 1910.119(c): Employee Participation
III. VERIFICATION OF PROGRAM ELEMENTS
A. Records Review
1. Does a written program exist regarding employee participation?
[Criteria Reference .119(c)(1)]
2. Does the written program include consultation with employees and their
representatives on the conduct and development of process hazard analyses and
on the development of other elements in the PSM standard? [Criteria
Reference .119(c)(2)]
3. Does the written program provide employees (including contractor
employees) and their representatives access to process hazard analyses and
all other information developed as required by the PSM standard? [Criteria
Reference .119(c)(3)]
B. On-site Conditions
Not applicable.
C. Interviews
1. Based on interviews with a representative number of employees and their
representatives, have they been consulted on the conduct and development of
the process hazard analyses? [Criteria Reference .119(c)(2)]
2. Based on interviews with a representative number of employees and their
representatives, have they been consulted on the development of other
elements of the Process Safety Management program? [Criteria Reference
.119(c)(2)]
3. Based on interviews with a representative number of employees
(including contractor employees) and their representatives, have they been
informed of their rights of access and provided access to process hazard
analyses and to all other information required to be developed by the PSM
standard? [Criteria Reference .119(c)(3)]
(Ask about unreasonable delays in access to information and whether time is
given during the working hours to access information required by the PSM
standard.)
1910.119(d): PROCESS SAFETY INFORMATION
I. PROGRAM SUMMARY
The intent of this paragraph is to provide complete and accurate information
concerning the process which is essential for an effective process safety
management program and for conducting process hazard analyses. Therefore in
accordance with the schedule set forth in paragraph (e)(1) the employer is
required to compile written process safety information on process chemicals,
process technology, and process equipment before conducting any process
hazard analysis.
II. QUALITY CRITERIA REFERENCES
A. 1910.119(d): Process Safety Information
B. 1910.119(e)(1): Process Hazard Analysis
C. 1910.1200: Hazard Communication
III. VERIFICATION OF PROGRAM ELEMENTS
A. Records Review
1. Has written process safety information been compiled before conducting
any process hazard analysis (PHA)? [Criteria Reference .119(d)]
2. Is information included pertaining to the hazards of the highly
hazardous chemicals used or produced by the process, and does the information
include at least: [Criteria Reference .119(d)(1): .1200(g)]
* toxicity information
* PEL's
* physical data
* reactivity data
* corrosivity data
* thermal and chemical stability data
* hazardous effects of inadvertent mixing of different materials that could foreseeably occur?
NOTE: MSDS's meeting the requirements of 29 CFR 1910.1200(g) may be used to
the extent they contain the information required.
3. Is information included concerning the technology of the process, and
does it include at least: [Criteria Reference .119(d)(2)]
* a block flow diagram or simplified process flow diagram?
* process chemistry?
* maximum intended inventory?
* safe upper and lower limits?
* an evaluation of the consequences of deviations?
(Where the original technical information no longer exists, it may be
developed in conjunction with the PHA.)
4. Is information included pertaining to equipment in the process, and
does it include at least: [Criteria Reference .119(d)(3)(i)]
* materials of construction?
* piping and instrument diagrams (P&iD's)?
* electrical classification?
* relief system design and design basis?
* ventilation system design?
* design codes and standards employed?
* material and energy balances for processes built after May 26, 1992?
* safety systems (e.g. interlocks, detection or suppressions systems)?
5. Has the employer documented that equipment complies with recognized,
generally accepted good engineering practices? [Criteria Reference
.119(d)(3)(ii)]
(Review the documentation for evidence that compliance with the appropriate
consensus standards has been researched.)
6. Has the employer determined and documented that existing equipment
designed and constructed in accordance with codes, standards, or practices no
longer in general use are designed, maintained, inspected, tested, and
operating in a safe manner? [Criteria Reference .119(d)(3)(iii)]
(Documentation may be through methods such as: documenting successful prior
operation procedures; documenting that the equipment is consistent with the
appropriate editions of codes and standards; or performing an engineering
analysis to determine that the equipment is appropriate for its intended
use.)
B. On-site Conditions
1. Do observations of a representative sample of process chemicals and
equipment indicate that the process information is complete? [Criteria
Reference .119(d)]
(Information that does not correspond to the actual conditions demonstrates
incomplete information. Check critical equipment and components to see if
they have been properly identified.
2. Do observations of a representative sample of process components
indicate that the process complies with recognized and generally accepted
good engineering practice? [Criteria Reference .119(d)(3)(ii)]
(Review a representative number of safety devices such as pressure relief
devices for proper sizing according to the maximum anticipated pressure.)
3. Do observations of a representative sample of the existing equipment
designed and constructed according to codes, standards, or practices no
longer in general use indicate that this equipment is inspected and is
operated in a safe manner (as documented by the employer)? [Criteria
Reference .119(d)(3)(iii)]
C. Interviews
Process Hazard Analysis (PHA) Team: 1. Based on interviews with a representative number of PHA team members, was the process safety information
complete before the process hazard analysis was conducted? [Criteria
Reference .119(d)]
Operators: 2. Based on interviews with a representative number of
operators, is MSDS information readily available to the operators who work
with hazardous materials? [Criteria Reference .1200]
Engineers (if any; or other qualified persons capable of providing the
information requested; see Note, p. A-2): 3. Based on interviews with a
representative number of engineers, has the employer documented that the
process equipment complies with recognized and generally accepted good
engineering practice? [Criteria Reference .119(d)(3)(ii)]
(Ask about the technical bases for design and selection of equipment, the
materials of construction, electrical classifications, relief devices sizing
versus maximum anticipated pressures, installation procedures to assure
equipment meets design specifications, etc.)
For more information on Process Safety Information, see Appendix D,
references 8. and 9.
1910.119(e): PROCESS HAZARD ANALYSIS
I. PROGRAM SUMMARY
The intent of this paragraph is to require the employer to develop a
thorough, orderly, systematic approach for identifying, evaluating and
controlling processes involving highly hazardous chemicals. Minimum
requirements include: (1) Setting a priority order and conducting analyses
according to the required schedule; (2) Using an appropriate methodology to
determine and evaluate the process hazards; (3) Addressing process hazards,
previous incidents with catastrophic potential, engineering and
administrative controls applicable to the hazards, consequences of failure of
controls, facility siting, human factors, and a qualitative evaluation of
possible safety and health effects of failure of controls on employees; (4)
Performing PHA by a team with expertise in engineering and process
operations, the process being evaluated, and the PHA methodology used; (5)
Establishing a system to promptly address findings and recommendations,
assure recommendations are resolved and documented, document action taken,
develop a written schedule for completing actions, and communicate actions to
operating, maintenance and other employees who work in the process or might
be affected by actions; (6) Updating and revalidating PHA's at least every 5
years; and (7) Retaining PHA's and updates for the life of the process.
II. QUALITY CRITERIA REFERENCES
A. 1910.119(e): Process Hazard Analysis
III. VERIFICATION OF PROGRAM ELEMENTS
A. Records Review
1. Has the employer determined and documented a priority order for
conducting initial PHA's based on a rationale that includes at least these
factors: [Criteria Reference .119(e)(1)]
* the extent of process hazards
* number of potentially affected employees
* age of process
* operating history?
2. Are the initial PHA's for processes covered by the PSM standard being
performed as soon as possible? [Criteria Reference .119(e)(1)]
3. Does the priority schedule for PHA's assure that all initial PHA's will
be performed by 5/26/97 and that: [Criteria Reference .119(e)(1)]
* No less than 25% of the PHA's shall be completed by 5/26/94?
* No less than 50% of the PHA's shall be completed by 5/26/95?
* No less than 75% of the PHA's shall be completed by 5/26/96?
(PHA's completed after May 26, 1987 which meet the requirements of this
paragraph are acceptable as initial PHA's; they must be updated and
revalidated at least every 5 years.)
4. Does the hazard evaluation use one or more of the following PHA
methodologies: [Criteria Reference .119(e)(2)]
* What-if?
* Checklist?
* What-if/Checklist?
* Hazard & Operability Study (HAZOP)?
* Failure Mode and Effects Analysis (FMEA)?
* Fault Tree Analysis (FTA)?
* Other appropriate methodology?
(See Appendix B for a discussion of appropriate methodologies).
5. Does the PHA address the following: [Criteria Reference .119(e)(3)]
* The hazards of the process?
* Previous incidents with likely potential for catastrophic consequences?
* Consequences of failure of engineering and administrative controls?
(For example, potential injury, maximum release of hazardous materials,
property damage, etc.)
5. (Continued) Does the PHA address the following: [Criteria Reference .119(e)(3)]
* Engineering and administrative controls applicable to the hazards and their interrelationships?
(Such controls may include appropriate application of detection
methodologies to provide early warning of releases; inventory reduction;
substitution of less hazardous materials; protective systems such as deluges,
monitors, foams; increased separation distances; modification of the process
temperature or pressure; redundancy in instrumentation; etc.)
* Facility siting?
(Review calculations, charts, and other documents that verify facility
siting has been considered. For example, safe distances for locating control
rooms may be based on studies of the individual characteristics of equipment
involved such as: types of construction of the room, types and quantities of
materials, types of reactions and processes, operating pressures and
temperatures, presence of ignition sources, fire protection facilities,
capabilities to respond to explosions, drainage facilities, location of fresh
air intakes, etc.)
* Human factors?
(Such factors may include a review of operator/process and
operator/equipment interface, the number of tasks operators must perform and
the frequency, the evaluation of extended or unusual work schedules, the
clarity and simplicity of control displays, automatic instrumentation versus
manual procedures, operator feedback, clarity of signs and codes, etc.)
* A qualitative evaluation of a range of possible safety and
health effects of failure of controls on employees in the
workplace?
6. Are the process hazard analyses performed by teams with expertise in
engineering and process operations, including at least one employee with
experience and knowledge specific to the process being evaluated and one
member knowledgeable in the specific PHA methodology used? [Criteria
Reference .119(e)(4)]
7. Has a system been established to promptly address the team's findings
and recommendations? [Criteria Reference .119(e)(5)]
Review a representative sample of the documentation. Has the system been
able to:
* Assure that the recommendations are resolved and documented in a timely manner?
* Document actions to be taken?
* Complete actions as soon as possible?
* Develop a written schedule of when actions are to be completed?
* Communicate the actions to operating, maintenance and other
employees whose work assignments are in the process and who may be affected
by the recommendations or actions?
8. Are the PHA's updated and revalidated at least every five years by a
qualified team meeting the requirements in paragraph (e)(4), to assure that
the process hazard analysis is consistent with the current process?
[Criteria Reference .119(e)(6)]
9. Are all initial PHA's, updates or revalidations, and documented
resolutions of recommendations kept for the life of the process? [Criteria
Reference .119(e)(7)]
B. On-site Conditions
1. Do observations of a representative sample of process-related equipment
indicate that obvious hazards have been identified, evaluated, and
controlled? [Criteria Reference .119(e)(1)]
(For example, hydrocarbon or toxic gas monitors and alarms are present;
electrical classifications are consistent with flammability hazards; destruct
systems such as flares are in place and operating; control room siting is
adequate or provisions have been made for blast resistant construction,
pressurization, alarms, etc.; pressure relief valves and rupture disks are
properly designed and discharge to a safe area; pipework is protected from
impact; etc.)
2. Do observations of a representative sample of process-related equipment
indicate that PHA recommendations have been promptly resolved? [Criteria
Reference .119(e)(5)]
C. Interviews
PHA Team Member: 1. Based on interviews with a representative
number of the PHA team members, are the PHA methodologies used appropriate
for the complexity of the process? [Criteria Reference .119(e)(1)]
2. Based on interviews with a representative number of the PHA team
members, is the priority order for conducting PHA's based on the extent of
the process, the number of potentially affected employees, the age of the
process, and the operating history of the process? [Criteria Reference
.119(e)(1)]
3. Based on interviews with a representive number of the PHA team members,
have the following been addressed: [Criteria Reference .119(e)(3)]
* The hazards of the process?
* Previous incidents with likely potential for catastrophic consequences?
* Engineering and administrative controls applicable to the hazards?
* Consequences of control failures?
* Facility siting?
* Human factors? (Ask about shift rotations, extended schedules, and other possible sources of error.)
* A qualitative evaluation of a range of possible safety and health effects of failure of controls on employees in the workplace?
4. Based on interviews with a representative number of the PHA team
members, do the members have the appropriate expertise in engineering,
process operations, and the process methodology used? Does one member of the
team have experience and knowledge in the specific process? [Criteria
Reference .119(e)(4)]
5. Based on interviews with a representative number of the PHA team
members, does the system established by the employer address the team's
findings and recommendations promptly? [Criteria Reference .119(e)(5)]
Operators and maintenance: 6. Based on interviews with a
representative number of operator and maintenance employees, have the PHA's
addressed the recognized hazards of the process and previous incidents which
had a likely potential for catastrophic consequences? [Criteria Reference
.119(e)(3)]
7. Based on interviews with operator, maintenance, and other employees who
may be affected by PHA recommendations, have actions taken to resolve PHA (5)
findings been communicated to these employees? [Criteria Reference
.119(e)(5)]
For more information on PHA, see Appendix D, references: 8.; 9.; 10.; 11.;
12.; 13.; 14.; 15.; 16.; 17.; 25.; 26.; 27, Part I, Section UG-125; 31.; 32.;
and 33.
1910.119(f): OPERATING PROCEDURES
I. PROGRAM SUMMARY
The intent of this paragraph is to provide clear instruction for conducting
activities involved in covered processes that are consistent with the process
safety information. The operating procedures must address steps for each
operating phase, operating limits, safety and health considerations, and
safety systems and their functions.
II. QUALITY CRITERIA REFERENCES
A. 1910.119(f)
B. 1910.120
C. 1910.147
D. 1910.1000
E. 1910.1200
III. VERIFICATION OF PROGRAM ELEMENTS
A. Records Review
1. Do written operating procedures exist for each covered process? Do the
procedures provide clear instructions for conducting activities safely?
[Criteria Reference .119(f)(1)]
2. Do the operating instructions address, as a minimum, step for each
operating phase, including: [Criteria Reference .119(f)(1)(i)]
* Initial start-up?
* Normal operations?
* Temporary operations?
* Emergency shutdowns?
* Conditions requiring emergency shutdown?
* Assignment of shutdown responsibility to qualified operators?
* Emergency operations?
* Normal shutdown?
* Start-ups following a turnaround or emergency shutdown?
3. Do the operating procedures include operating limits that outline
consequences of process deviation and steps required to correct or avoid
deviations? [Criteria Reference .119(f)(1)(ii)]
4. Have safety and health considerations been included in the operating
procedures? Do they include at a minimum: [Criteria Reference
.119(f)(1)(iii)]
* Properties of, and hazards presented by, chemicals used in the process?
* Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment?
* Control measures to be taken if physical contact or airborne exposure occurs?
* Quality control for raw materials and control of hazardous chemical inventory levels?
* Any special or unique hazards?
5. Are safety systems and their functions included in the operating
procedures? [Criteria Reference .119(f)(1)(iv)]
6. Are the operating instructions consistent with the process safety
information? [Criteria Reference .119(f)(1)]
7. Are operating procedures readily accessible to employees who work in or
maintain a process? [Criteria Reference .119(f)(2)]
8. Are operating procedures reviewed as often as necessary to assure that
they reflect current operating practice? Are they certified annually by the
employer that they are current and accurate? Do they reflect current
operating practices that have resulted from changes in: [Criteria Reference
.119(f)(3)]
* Process chemicals?
* Technology?
* Equipment?
* Facilities?
9. Have safe work practices been developed and implemented for employees
and contractors to control hazards during operations such as: [Criteria
Reference .119(f)(4)]
* Lockout/tagout?
* Confined space entry?
* Opening process equipment or piping?
* Control over entrance into a facility by maintenance, contractor, laboratory or other support personnel?
B. On-site Conditions
1. Does observation of a representative sample of processes indicate that
the written operating procedures are being implemented? [Criteria Reference
.119(f)(1)]
2. Does observation of a representative sample of processes indicate that
the written operating procedures are readily accessible to employees who work
or maintain a process? [Criteria Reference .119(f)(2)]
3. Does observation of a representative sample of processes indicate that
operating procedures reflect current practice, including changes that result
from process chemicals, technology, equipment, and facilities? [Criteria
Reference .119(f)(3)]
(Observe to see if actual procedures match the written operating procedures.)
4. Does observation of representative operations indicate that safe work
practices have been implemented for company and contractor employees? Do
such work practices include, where appropriate: [Criteria Reference
.119(f)(4)]
* Lockout/tagout?
* Confined space entry?
* Opening process equipment or piping?
* Control over entrance into a facility by maintenance, contractor, laboratory, and other support personnel?
C. Interviews
1. Based on interviews with a representative number of operators, are the
written operating procedures implemented for each covered process? [Criteria
Reference .119(f)(1)]
2. Based on interviews with a representative number of operators, do
operating procedures provide clear instructions for safely conducting
activities? [Criteria Reference .119(f)(1)]
(Specifically ask for conditions requiring emergency shutdown, the operating
limits of a particular process or item of equipment, what might occur if a
deviation from those limits should take place, steps to avoid the deviation,
and precautions necessary to prevent exposure to hazardous chemicals.)
3. Based on interviews with a representative number of employees who work
in or maintain a process, are the operating procedures readily accessible?
[Criteria Reference .119(f)(2)]
4. Based on interviews with a representative number of operators and
maintenance employees, do the operating procedures reflect current operating
practice? [Criteria Reference .119(f)(3)]
1910.119(g): TRAINING
I. PROGRAM SUMMARY
The intent of this paragraph helps employees and contractor employees
understand the nature and causes of problems arising from process operations,
and increases employee awareness with respect to the hazards particular to a
process. An effective training program significantly reduces the number and
severity of incidents arising from process operations, and can be
instrumental in preventing small problems from leading to a catastrophic
release. Minimum requirements for an effective training program include:
Initial Training, Refresher Training, and Documentation.
II. QUALITY CRITERIA REFERENCES
A. 1910.119(g): Training
B. 1910.119(f)(1): Operating procedures
III. VERIFICATION OF PROGRAM ELEMENTS
A. Records Review
1. For employees and contractor employees involved in operating a process
do initial and refresher training records exist? Do the records contain the
identity of the employee, the date of the training, and the means used to
verify that the employee understood the training? [Criteria Reference
.119(g)(1)(i)]
2. Has each employee and contractor employee been trained before being
involved in a newly assigned process (except employees involved in operating
a process prior to 5/26/92)? [Criteria Reference .119(g)(1)(i)]
3. If initial training has not been given to employees and contractor
employees involved in operating a process prior to 5/26/92, is there written
certification that they have the required knowledge, skills and abilities to
safely carry out the duties and responsibilities specified in the operating
procedures? [Criteria Reference .119(g)(1)(ii)]
(Review the documents to make sure the certification has not been
invalidated by a change in duties.)
4. Has each employee and contractor employee involved in operating a
process been trained in an overview of the process and the operating
procedures including: [Criteria Reference .119(g)(1)(i)] * Steps for each
operating phase? Initial startup, normal operations, temporary operations,
emergency shutdown, emergency operations, normal shutdown, and startup
following a turnaround or emergency shutdown * Operating limits?
Consequences of deviations and steps required to avoid deviations * Safety
and health considerations? Properties and hazards of chemicals used and
precautions for preventing exposure * Safety systems and their functions?
5. Has the employer consulted with employees and contractor employees
involved in operating the process to determine the appropriate frequency for
refresher training? Is the frequency at least once every 3 years? [Criteria
Reference .119(g)(2)]
B. On-site Conditions
Verification is not required. [Criteria Reference .119(g)(1) or (2)]
C. Interviews
1. Based on interviews with a representative number of employees, has
their training emphasized specific safety and health hazards, emergency
operations including shutdown, and safe work practices applicable to their
tasks? [Criteria Reference .119(g)(1)(i)]
2. Based on interviews with employees named as having provided
consultation, has the employer consulted with employees involved in operating
the process to determine the appropriate frequency of refresher training?
[Criteria Reference .119(g)(2)]
1910.119 (h) CONTRACTORS
I. PROGRAMS SUMMARY
The intent of this paragraph is to require employers who use contractors to
perform work in and around processes that involve highly hazardous chemicals
to establish a screening process so that they hire and use contractors who
accomplish the desired job tasks without compromising the safety and health
of employees at a facility. The contractor must assure that contract
employees are trained on performing the job safely, of the hazards related to
the job, and applicable provisions of the emergency action plan.
NOTE: The term contractor includes subcontractor.
II. QUALITY CRITERIA REFERENCES
A. 1910.119(h)
B. 1910.119(f)(4)
C. 1910.119(n)
D. 29 CFR 1926 Subpart C (for contractors engaged in construction work)
E. 1910.119 Appendix C, 57 Fed. Reg. 6413/3
F. 1910.119 Appendix D, Sources 7, 9, and 10
NOTE: Other provisions of 1910.119, such as (g) and (j), may also
apply in appropriate circumstances.
III. VERIFICATION OF PROGRAM ELEMENTS
A. Records Review - Employer's Program [Criteria Reference .119(h)(1)]
1. Does the program include all contractor activities that have the
potential for affecting process safety, including -- but not limited
to -- contractors performing maintenance or repair, turnaround, major
renovation or specialty work on or adjacent to covered processes?
(Contractors performing incidental services which do not influence process
safety such as janitorial work, food and drink services, laundry, delivery,
and other supply services need not be included However, contractors
performing construction, demolition, equipment installation, and other work
that may affect the safety of a covered process should be included.)
2. Is the information regarding the contractor's safety performance and
programs obtained and evaluated for selection of contractors? [Criteria
Reference .119(h)(2)(i), .119 Appndxs C & D]
3. Are the contract employers informed, prior to the initiation of the
contractors' work at the site, of the known potential fire, explosion, or
toxic release hazards related to the contractors' work and the processes?
[Criteria Reference .119(h)(2)(ii)]
4. Are contract employers informed, prior to the initiation of the
contractors' work at the site, of the applicable provisions of the emergency
action plan required by .119(n)? [Criteria Reference .119(h)(2)(iii)]
5. Have safe work practices to control the entrance, presence and exit of
contract employers and contract employees in covered process areas been
developed and implemented? [Criteria Reference .119(h)(2)(iv); .119(f)(4)]
6. Are contract employers periodically evaluated for their performance in
fulfilling their obligations to: [Criteria Reference .119(h)(2)(v)]
* Assure their employees are trained in safe work practices needed to perform the job?
* Assure their employees are instructed in the known potential fire, explosion, or toxic release hazards related to the job and the applicable provisions of the emergency action plan?
* Document the required training and the means to verify their employees have understood the training?
* Assure their employees follow the facility safety rules and work practices?
* Advise the employer of unique hazards presented by the contractor's work?
7. Has the host employer ensured, through periodic evaluations, that the
training provided to contractor employees by the contractor employer is
equivalent to the training required for direct hire employees? [Criteria
Reference .119(h)(2)(v)]
8. If the employer has identified deficiencies in the performance of
contract employers, what action has the employer taken to correct the
deficiencies? [Criteria Reference .119(h)(2)(v)]
9. Does the employer maintain a contract employee injury and illness log
related to the contractor's work in process areas? [Criteria Reference
.119(h)(2)(vi)]
Records Review - Contractor's Programs
10. Are all contractor employees trained in the work practices necessary to
perform their jobs safely? [Criteria Reference .119(h)(3)(i)]
11. Is each contract employee instructed in the known potential fire,
explosion, or toxic release hazards related to his/her job and the processes
and applicable provisions of the emergency action plan? [Criteria Reference
.119(h)(3)(ii)]
12. Is there documentation that each contract employee has received and
understands the required training? [Criteria Reference .119(h)(3)(iii)]
13. Do the contract employee training records contain the following:
[Criteria Reference .119(h)(3)(iii)]
* The identity of the employee?
* The date of the training?
* The means used to verify that the training was understood?
14. Are there means to assure that contract employees follow the safety
rules of the facility, including safe work practices required in .119(f)(4)?
[Criteria Reference .119(h)(3)(iv); .119(f)(4)]
(Review evidence of enforcement by the contractor.)
15. Is the employer advised of any unique hazards presented by the contract
employer's work or any hazards found by the contract employer's work?
[Criteria Reference .119(h)(3)(v)]
B. On-site Conditions
1. Based on a representative sample of observations of contractor
employees, has the employer's program to control their entrance, presence,
and exit been implemented? [Criteria Reference .119(h)(2)(iv)]
2. Based on a representative sample of observations of contractor
employees, do they follow the safety rules of the facility? [Criteria
Reference .119(h)(3)(iv)]
(These rules include the employer's safe work practices such as
lockout/tagout, confined space entry, and opening process equipment or
piping; they may also include other rules such as excavation procedures or
use of PPE.)
C. Interviews
1. Based on interviews with contractor employers, did the host employer
obtain and evaluate information regarding the contractor's safety performance
and programs for selection of contractors? [Criteria Reference
.119(h)(2)(i); .119 Appndxs C & D]
2. Based on interviews with contractor employers, have they been informed
of the known fire, explosion, or toxic release hazards related to their work
and the processes in which they are involved prior to the initiation of their
work at the site? [Criteria Reference .119(h)(2)(ii)]
3. Based on interviews with contractor employers, have they been informed
of the applicable provisions of the employer's emergency action plan prior to
the initiation of their work at the site? [Criteria Reference
.119(h)(2)(iii)]
4. Based on interviews with contractor employers and employees, have work
practices to control their entrance, presence, and exit of covered process
areas been implemented? [Criteria Reference .119(h)(2)(iv)]
5. Based on interviews with the contractor employer, has the employer
periodically evaluated the contractor's performance in fulfilling the
obligations required in .119(h)(3) to: [Criteria Reference .119(h)(2)(v)]
* Assure their employees are trained in safe work practices needed to perform the job?
* Assure their employees are instructed in the known potential fire, explosion, or toxic release hazards related to the job and the applicable provisions of the emergency action plan?
* Document the required training and the means to verify their employees have understood the training?
* Assure their employees follow the facility safety rules and work practices?
* Advise the employer of unique hazards presented by the contractor's work?
6. Based on interviews with the contractors employer, has the host
employer ensured, through periodic evaluations, that the training provided to
contractor employees by the contractor employer is equivalent to the training
required for direct hire employees? [Criteria Reference .119(h)(2)(v)]
7. Based on interviews with the contractor employer, if the employer has
identified deficiencies in the performance of contract employers, what action
has the employer taken to correct the deficiencies? [Criteria .119(h)(2)(v)]
8. Based on interviews with a representative number of contractor
employees, has the contractor employer trained them in the work practices
necessary to perform their jobs? [Criteria Reference .119(h)(3)(i)]
9. Based on interviews with a representative number of contractor
employees, are they being instructed in the known potential fire, explosion,
or toxic release hazards related to their work and the processes in which
they are involved? [Criteria Reference .119(h)(3)(ii)]
10. Based on the interview with a representive number of contractor
employees, have they been instructed in the applicable provisions of the
emergency action plan? [Criteria Reference .119(h)(3)(ii)]
(Ask them to explain the plan and evacuation procedures.)
11. Based on interviews with a representative number of contractors
employees, has the contract employer assured that they follow the safety
rules of the facility? [Criteria Reference .119(h)(3)(iv)]
(Ask how safe work practices, entry restrictions for the facility, and use
of required PPE are enforced.)
For additional information on Contractors, see Appendix D, reference 16.
1910.119(i): PRE-STARTUP SAFETY REVIEW
I. PROGRAM SUMMARY
The intent of this paragraph is to make sure that, for new facilities an for
modified facilities when the modification necessitates a change to process
safety information, certain important considerations are addressed before any
highly hazardous chemicals are introduced into the process. Minimum
requirements include that the pre-startup safety review confirm the
following: construction and equipment is in accordance with design
specifications; safety, operating, maintenance, and emergency procedures are
in place and adequate; for new facilities, a PHA has been performed and
recommendations resolved or implemented; modified facilities meet the
requirements of paragraph (1), management of change; and training of each
employee involved in the process has been completed.
II. QUALITY CRITERIA REFERENCES
A. 1910.119(i): Pre-startup Safety Review
B. 1910.119(l): Management of Change
III. VERIFICATION OF PROGRAM ELEMENTS
A. Records Review
1. Has a pre-startup safety review been performed for all new facilities
and for modified facilities when the modification is significant enough to
require a change in process safety information? [Criteria Reference
.119(i)(1)]
2. Do pre-startup safety reviews confirm that prior to the introduction of
highly hazardous chemicals to a process: [Criteria Reference .119(i)(2)]
* Construction and equipment is in accordance with design Specifications?
* Safety, operating, maintenance, and emergency procedures are in place and adequate?
2. (Continued) Do pre-startup safety reviews confirm that prior to the
introduction of highly hazardous chemicals to a process: [Criteria Reference
.119(i)(2)]
* For new facilities, a PHA has been performed and recommendations resolved or implemented before startup?
* Modified facilities meet requirements of paragraph (1)?
* Training of each employee involved in operating the process has been completed?
On-site Conditions
1. Do observations of new or modified facilities indicate that prior to
the introduction of highly hazardous chemicals:
* Construction and equipment is in accordance with design specifications?
* Safety, operating, maintenance, and emergency procedures are in place and adequate?
C. Interviews (See NOTE, p. A-2.]
1. Based on interviews with a representative sample of operators,
maintenance employees, and engineers, can it be confirmed that the
construction and equipment are in accordance with design specifications prior
to introducing highly hazardous chemicals to a process? [Criteria Reference
.119(i)2(i)]
2. Based on interviews with a representative sample of operators,
maintenance employees, and engineers, are safety, operating, maintenance, and
emergency procedures in place prior to introduction of highly hazardous
chemicals into a process? Are these procedures adequate? [Criteria Reference
.119(i)2(ii)]
3. Based on interviews with a representative sample of operators,
maintenance employees, and engineers, is a PHA performed and are
recommendations resolved prior to a startup that introduces highly hazardous
chemicals into a new process? [Criteria Reference .119(i)2(iii)]
4. Based on interviews with a representative sample of operators,
maintenance employees, and engineers, do modified facilities meet
requirements of paragraph (1), Management of Change prior to introducing a
highly hazardous chemical? [Criteria Reference .119(i)2(iii)]
5. Based on interviews with a representative sample of operators, is
training completed for each employee involved in operating the process prior
to the introduction of a highly hazardous chemical? [Criteria Reference
.119(i)2(iv)]
1910.119(j): MECHANICAL INTEGRITY
I. PROGRAM SUMMARY
The intent of this paragraph is to assure that equipment used to process
store, or handle highly hazardous chemicals is designed, constructed;
installed, and maintained to minimize the risk of releases of such chemicals.
This requires that a mechanical integrity program be in place to assure the
continued integrity of process equipment. The elements of a mechanical
integrity program include the identification and categorization of equipment
and instrumentation, development of written maintenance procedures, training
for process maintenance activities, inspection and testing, correction of
deficiencies in equipment that are outside acceptable limits defined by the
process safety information, and development of a quality assurance program.
II. QUALITY CRITERIA REFERENCES
A. .119(j): Mechanical integrity
III. VERIFICATION OF PROGRAM ELEMENTS
A. Records Review
1. Does the written mechanical integrity program include? [Criteria
Reference .119(j)(1)]
* Pressure vessels and storage tanks
* Piping systems and components such as valves
* Relief and vent systems and devices
* Emergency shutdown systems
* Controls (including monitoring devices and sensors, alarms and interlocks)
* Pumps
2. Are there written procedures to maintain the on-going integrity of
process equipment? Does the documentation indicate the procedures have been
implemented? [Criteria Reference .119(j)(2)]
3. Has training been provided to each employee contractor employee
involved in maintaining the on-going integrity of process equipment in the
following: [Criteria Reference .119(j)(3)]
* An overview of the process and its hazards?
* Procedures applicable to the employee's job tasks to assure that the employee can perform the job tasks in a safe manner?
(Review certification documents for employees doing non-destructive tests,
welding on pressure vessels, etc., where these certifications are required.)
4. Are inspections and tests performed on each item of process equipment
included in the program? [Criteria Reference .119(j)(4)(i)]
5. Do inspection and testing procedures follow good engineering practices?
[Criteria Reference .119(j)(4)(ii)]
6. Are inspection and test frequencies consistent with the manufacturer's
recommendation and good engineering practice? Are inspections and tests
performed more frequently if determined necessary by operating experience?
[Criteria Reference .119 (j)(4)(iii)]
7. Is there documentation of each inspection and test that has been
performed including all of the following: [Criteria Reference
.119(j)(4)(iv)]
* Date of the inspection or test?
* Name of person performing the procedure?
* Serial number or other identifier of equipment on which procedure was performed?
* Description of inspection or test performed?
* Results of inspection or test?
8. Are deficiencies in equipment that are outside limits (as defined in
process safety information) corrected before further use or in a safe and
timely manner when necessary means are taken to assure safe operation?
[Criteria Reference .119(j)(5)]
9. In the construction of new plants and equipment, does the employer
assure that equipment as it is fabricated is suitable for the process for
which it will be used? [Criteria Reference .119(j)(6)(i)]
10. Have appropriate checks and inspections been made to assure equipment
is installed properly and consistent with design specifications and
manufacturer's instructions? [Criteria Reference .119(j)(6)(ii)]
(Include contractor supplied equipment.)
11. Does the employer assure that maintenance materials, spare parts, and
equipment are suitable for the process application for which they are used?
[Criteria Reference .119(j)(6)(iii)]
(Include contractor supplied equipment.)
B. On-site Conditions
1. Do observations of a representative sample of process equipment
indicate deficiencies outside acceptable limits? [Criteria Reference
.119(j)(5)]
(Compare process safety information criteria with the conditions of the
equipment found in the process.)
2. If new plants or equipment are being constructed, do observations
indicate that the equipment as it is fabricated is suitable for the process
application? [Criteria Reference .119(j)(6)(i)]
3. Do observations of a representative sample of maintenance materials,
spare parts, and equipment indicate that they are suitable for the process
application for which they will be used? [Criteria Reference .119(j)(6)(iii)]
C. Interviews
Engineers (if any; or other qualified persons capable of providing the
information requested; see NOTE, p. A-2): 1. Based on interviews with a
representative number of engineers, have procedures to maintain the on-going
integrity of the process equipment been implemented for: [Criteria Reference
.119(j)(2)]
* Pressure vessels and storage tanks?
* Piping systems and components such as valves?
* Relief and vent systems and devices?
* Emergency shutdown systems?
* Controls (including monitoring devices and sensors, alarms and interlocks)?
* Pumps?
(Ask about the possibility of safety critical equipment being inadvertently
rendered inoperative. For example, a relief device might be isolated by
closing an upstream valve.)
2. Based on interviews with a representative number of engineers, do the
inspection and testing procedures follow recognized and generally accepted
good engineering practice? Has prior operating experience indicated a need
for a more frequent test and inspection schedule than has been implemented?
[Criteria Reference .119(j)(4)]
3. Based on interviews with a representative number of engineers, are
equipment deficiencies corrected before use when they are outside the
acceptable limits? If not, are the deficiencies corrected in a timely manner
and are necessary means taken to assure safe operation? [Criteria Reference
.119(j)(5)]
4. Based on interviews with a representative number of engineers, has the
employer assured that, for new plants and equipment, the equipment as it is
fabricated is suitable for the process application? Are appropriate checks
and inspections made to assure equipment is installed properly and consistent
with design specifications and manufacturer's instructions? Are maintenance
materials, spare parts, and equipment suitable for the process application
for which they will be used? [Criteria Reference .119(j)(6)]
(Ask about contractor supplied items.)
Maintenance: 5. Based on interviews with a representative number of
maintenance employees (and, where applicable, contractor maintenance
employees), have the written procedures for maintaining the on-going
integrity of process equipment been implemented? [Criteria Reference
.119(j)(2)]
6. Based on interviews with a representative number of employees and
contractor employees involved in maintaining the on-going integrity of the
process, have they been trained to assure they can perform their tasks in a
safe manner? Did the training include an overview of the process, its
hazards, and procedures applicable to the job? [Criteria Reference
.119(j)(3)]
(Determine if certification, specialized training, or unique qualifications
are required.)
7. Based on interviews with a representative number of maintenance
employees, do test and inspection procedures follow recognized and generally
accepted good engineering practices? Is the frequency of inspections and
tests consistent with applicable manufacturer's recommendations and good
engineering practices? Are more frequent inspections and tests necessary due
as indicated by prior operating experience? [Criteria Reference .119(j)(4)]
8. Based on interviews with a representative number of maintenance
employees, are equipment deficiencies that are outside acceptable limits
corrected before further use? If not, are corrections made in a timely manner
and are necessary means taken to assure operation? [Criteria Reference
.119(j)(5)]
9. Based on interviews with a representative number of maintenance
employees, are maintenance materials, spare parts and equipment suitable for
the process application for which they are intended? [Criteria Reference
.119(j)(6)]
(Ask about availability and use of substitutes.)
For additional information on Mechanical Integrity, see Appendix D,
reference: 9.; 18.; 19.; 20.; 21.; 22.; 23.; 27.; 28.; 29.; and 34.
1910.119(k): HOT WORK PERMIT
I. PROGRAM SUMMARY
The intent of this paragraph is to require employers to control, in a
consistent manner, nonroutine work conducted in process areas. Specifically,
this subparagraph is concerned with the permitting of hot work operations
associated with welding and cutting in process areas.
Minimum requirements include: that the employer issue a hot work permit for
hot work operations conducted on or near a covered process and that hot work
permits shall document compliance with the fire prevention and protection
requirements of 29 CFR 1910.252(a).
II. QUALITY CRITERIA REFERENCES
A. 1910.119(k): Hot Work Permit
B. 1910.252(a): Fire Prevention and Protection
III. VERIFICATION OF PROGRAM ELEMENTS
A. Records Review
1. Have hot work permits been issued for all hot work operations conducted
on or near a process covered by this standard? [Criteria Reference
.119(k)(1)]
2. Do the hot work permits indicate the date(s) authorized for hot work
performed? [Criteria Reference .119(k)(2)]
3. Do the hot work permits describe the object on which the hot work is to
be performed? [Criteria Reference .119(k)(2)]
4. Have the hot work permits been kept on file until the hot work
operations were complete? [Criteria Reference .119(k)(2)]
5. Have the hot work permits identified openings, cracks and holes where
sparks may drop to combustible materials below? [Criteria Reference
.252(a)(2)(i)]
6. Have the hot work permits described the fire extinguisher required to
handle any emergencies? [Criteria Reference .252(a)(2)(ii)]
7. Have the hot work permits assigned fire watchers whenever welding is
performed in locations where other than a minor fire might develop?
[Criteria Reference .252(a)(2)(iii)]
8. Are the hot work permits being authorized, preferably in writing, by
the "individual" responsible for all welding and cutting operations? Is
authorization preceded by site & inspection and designation of appropriate
precautions? [Criteria Reference .252(a)(2)(iv) & .252(a)(2)(xiii)(A)]
9. Have the hot work permits described precautions associated with
combustible materials on floors or floors, walls, partitions, ceilings or
roofs of combustible construction? [Criteria Reference .252(a)(2)(v) &
.252(a)(2)(ix]
10. Has hot work permitting been successful in prohibiting welding in
unauthorized areas, in sprinklered buildings while such protection is
impaired, in the presence of explosive atmospheres, and in storage areas for
large quantities of readily ignitable materials? [Criteria Reference
.252(a)(2)(vi)]
11. Have the hot work permits required relocation of combustibles where
practicable and covering with flameproofed covers where not practicable?
[Criteria Reference .252(a)(2)(vii)]
12. Have hot work permits identified for shutdown any ducts or conveyors
systems that may convey sparks to distant combustibles? [Criteria Reference
.252(a)(2)(viii)]
13. Have hot work permits required precautions whenever welding on
components (e.g., steel members, pipes, etc,) that could transmit heat by
radiation or conduction to unobserved combustibles? [Criteria Reference
.252(a)(2)(x) & .252(a)(2)(xii)]
14. Have hot work permits identified hazards associated with welding on
walls, partitions, ceilings or roofs with combustible coverings or welding on
walls or panels of sandwich-type construction? [Criteria Reference
.252(a)(2)(xi)]
15. Has management established areas and procedures for safe welding and
cutting based on fire potential? [Criteria Reference .252(a)(2)(xiii)]
16. Has management designated the "individual" responsible for authorizing
cutting and welding operations in process areas? [Criteria Reference
.252(a)(2)(xiii)(B)]
17. Has management ensured that welders, cutters and supervisors are
trained in the safe operation of their equipment? [Criteria Reference
.252(a)(2)(xiii)(C)]
18. Has management advised outside contractors working on their site about
all hot work permitting programs? [Criteria Reference .252(a)(2)(xiii)(D)]
19. Has the Supervisor determined if combustibles are being protected from
ignition prior to welding by moving them, shielding them, or scheduling
welding around their production? [Criteria Reference .252(a)(2)(xiv)(A)(B) &
(C)]
20. Has the Supervisor, prior to welding, secured authorization from the
responsible "individual" designated by management? [Criteria Reference
.252(a)(2)(xiv)(D]
B. On-Site Conditions
1. Conduct checks of current welding and cutting operations to
ensure compliance with the requirements of 1910.119(k) and 1910.252(a). The
twenty items listed above in "Records Review" may serve as an audit
checklist. A management representative, the "individual"
responsible for welding operations and the supervisor should all
be invited to participate in this on-site check. [Criteria Reference .119(k)
& .252(a)]
C. Interviews - Employees and Contractors
1. Based on interviews with a representative number of maintenance and
contractor employees, has the Supervisor visited welding work operations to
verify that: [Criteria Reference .252(a)(2)(xiv)(E),(F) & (G)]
* Welders have approval for safe go ahead prior to welding?
* Fire protection and extinguishing equipment is properly located at the work site?
* Fire watches are functional, where required?
2. Based on interviews with a representative number of maintenance and
contractor employees, have hot work permits been issued for all hot work
operations conducted on or near a process covered by this standard?
[Criteria Reference .119(k)(1)]
3. Based on interviews with a representative number of maintenance and
contractor employees, have the hot work permits been kept on file until the
hot work operations were complete? [Criteria Reference .119(k)(2)]
4. Based on interviews with a representative number of maintenance and
contractor employees, have the hot work permits identified openings, cracks
and holes where sparks may drop to combustible materials below? [Criteria
Reference .252(a)(2)(i)]
5. Based on interviews with a representative number of maintenance and
contractor employees, have the hot work permits assigned fire watchers
whenever welding is performed in locations where other than a minor fire
might develop? [Criteria Reference .252(a)(2)(iii)]
6. Based on interviews with a representative number of maintenance and
contractor employees, are the hot work permits being authorized, preferably
in writing, by the "individual" responsible for all welding and cutting
operations? Is authorization preceded by site inspection and designation of
appropriate precautions? [Criteria Reference .252(a)(2)(iv) &
.252(a)(2)(xiii)(A)]
7. Based on interviews with a representative number of maintenance and
contractor employees, have the hot work permits described precautions
associated with combustible materials on floors or floors, walls, partitions,
ceilings or roofs of combustible construction? [Criteria Reference
.252(a)(2)(v) & .252(a)(2)(ix)]
8. Based on interviews with a representative number of maintenance and
contractor employees, has hot work permitting been successful in prohibiting
welding in: [Criteria Reference .252(a)(2)(vi)]
* Unauthorized areas?
* Sprinklered buildings while such protection is impaired?
* The presence of explosive atmospheres?
* Storage areas for large quantities of readily ignitable materials?
9. Based on interviews with a representative number of maintenance and
contractor employees, have the hot work permits required relocation of
combustibles where practicable and covering with flameproofed covers where
not practicable? [Criteria Reference .252(a)(2)(vii)]
10. Based on interviews with a representative number of maintenance and
contractor employees, have hot work permits identified for shutdown any ducts
or conveyors systems that may convey sparks to distant combustibles?
[Criteria Reference .252(a)(2)(viii)]
11. Based on interviews with a representative number of maintenance and
contractor employees, have hot work permits required precautions whenever
welding on components (e.g., steel members, pipes, etc.) that could transmit
heat by radiation or conduction to unobserved combustibles? [Criteria
Reference .252(a)(2)(x) & .252(a)(2)(xii)]
12. Based on interviews with a representative number of maintenance and
contractor employees, have hot work permits identified hazards associated
with welding on walls, partitions, ceilings or roofs with combustible
coverings or welding on walls or panels of sandwich-type construction?
[Criteria Reference .252(a)(2)(xi)]
13. Based on interviews with a representative number of maintenance and
contractor employees, has management established areas and procedures for
safe welding and cutting based on fire potential? [Criteria Reference
.252(a)(2)(xiii)]
14. Based on interviews with a representative number of maintenance and
contractor employees, has management designated the "individual" responsible
for authorizing cutting and welding operations in process areas? [Criteria
Reference .252(a)(2)(xiii)(B)]
15. Based on interviews with a representative number of maintenance and
contractor employees, has management ensured that welders, cutters and
supervisors are trained in the safe operation of their equipment? [Criteria
Reference .252(a)(2)(xiii)(C)]
16. Based on interviews with contractors and contractor employees, has
management advised outside contractors working on the site about all hot work
permitting programs? [Criteria Reference .252(a)(2)(xiii)(D)]
17. Based on interviews with a representative number of maintenance and
contractor employees, has the supervisor determined if combustibles are being
protected from ignition prior to welding by moving them, shielding them, or
scheduling welding around their production? [Criteria Reference
.252(a)(2)(xiv)(A)(B) & (C)]
1910.119(l): MANAGEMENT OF CHANGE
I. PROGRAM SUMMARY
The intent of this paragraph is to require management of all modifications
to equipment, procedures, raw materials and processing conditions other than
"replacement in kind" by identifying and reviewing them prior to
implementation of the change. Minimum requirements for management of change
include: establishing written procedures to manage change; addressing the
technical basis, impact on safety and health, modification to operating
procedures, necessary time period, and authorizations required; informing and
training employees affected; and updating process safety information and
operating procedures or practices.
II. QUALITY CRITERIA REFERENCES
A. 1910.119(l): Management of Change
III. VERIFICATION OF PROGRAM ELEMENTS
A. Records Review
1. Are there written procedures for managing changes (except for
"replacements in kind") to process chemicals, technology, equipment, and
procedures and changes to facilities that affect a covered process?
[Criteria Reference .119(l)(1)]
(Review procedures that address responsibilities, steps for assessing risks
and approving changes, requirements for reviewing designs for temporary and
permanent changes, steps needed to verify that modifications have been made
as designed, variance procedures, time limit authorizations for temporary
changes, and steps required to return the process to status quo after
temporary changes.)
2. Do the procedures assure that the technical basis for the proposed
change is addressed prior to any change? [Criteria Reference .119(l)(2)(i)]
3. Do the procedures assure that the impact of the change on safety and
health is addressed prior to any change? [Criteria Reference .119(l)(2)(ii)]
4. Do the procedures assure that modifications to operating procedures is
addressed prior to any change? [Criteria Reference .119(l)(2)(iii)]
5. Do the procedures assure that the necessary time period for the change
is addressed prior to any change? [Criteria Reference .119(l)(2)(iv)]
6. Do the procedures assure that the authorization requirements for the
proposed change are addressed prior to any change? [Criteria Reference
.119(l)(2)(v)]
7. Are employees involved in operating a process, and maintenance and
contract employees whose job tasks will be affected by change informed of,
and trained in, the change prior to start-up of process or affected part of
process? [Criteria Reference .119(l)(3)]
8. Is the process safety information required by paragraph (d) updated if
changed? [Criteria Reference .119(l)(4)]
9. Are the operating procedures or practices required by paragraph (f)
updated if changed? [Criteria Reference .119(l)(5)]
B. On-site Conditions
1. Do observations of new or recently modified process chemicals,
technology, equipment, or procedures (except "replacement in kind") indicate
that the Management of Change procedures have been implemented? [Criteria
Reference .119(l)(1)]
(Determine if records are available to support the procedures for new or
revised processes found in the facility.)
C. Interviews
Operator, Maintenance, and Contractor Employees:
1. Based on interviews with operators, maintenance employees and
contractor employees, are procedures implemented to manage changes to
existing process chemicals, technology, equipment, facilities, and
procedures? [Criteria Reference .119(l)(1)]
2. Based on interviews with operators, maintenance employees and
contractor employees, is training in process changes provided to employees
whose job tasks will be affected by the changes prior to start-up? [Criteria
Reference .119(l)(3)]
For additional information on Management of Change, see Appendix D,
reference 9., Chapter 7.
1910.119(m): INCIDENT INVESTIGATIONS
I. PROGRAM SUMMARY
The employer is required to investigate each incident which resulted in, or
could reasonably have resulted in a catastrophic release of highly hazardous
chemical in the workplace. An investigation shall be initiated no later than
48 hours following the incident. An investigation team shall be established
and a report prepared which includes: 1) Date of incident 2) Date
investigation began 3) Description of incident 4) Factors that contributed to
the incident 5) Recommendations from the investigation. The employer is
required to establish a system to promptly address the incident report
findings and recommendations, documenting all resolutions and corrective
actions. Incident reports shall be reviewed with all affected personnel
whose job tasks are relevant to the investigation and retained for five
years.
II. QUALITY CRITERIA REFERENCES
A. 1910.119(m): Incident Investigations
III. VERIFICATION OF PROGRAM ELEMENTS
A. Records Review
1. Has each incident been investigated which resulted in, or could
reasonably have resulted in a catastrophic release of highly hazardous
chemicals in the workplace? [Criteria Reference .119(m)(1)]
2. Have incident investigations been initiated as promptly as possible,
but not later than 48 hours following the incident? [Criteria Reference
.119(m)(2)]
3. Have incident investigation teams been established? Do the teams
contain at least one person knowledgeable in the process involved in the
incident, and other members with appropriate knowledge and experience to
thoroughly investigate and analyze the incident? Has a contractor employee
been included in the team if the incident involved work of the contractor?
[Criteria Reference .119(m)(3)]
4. Have incident investigation reports been prepared at the conclusion of
the investigation which include at minimum: [Criteria Reference .119(m)(4)]
* Date of the incident?
* Date the inspection began?
* A description of the incident?
* The factors that contributed to the incident?
* Any recommendations resulting from the investigation?
5. Has a system been established to promptly address and resolve the
incident investigation report findings and recommendations? [Criteria
Reference .119(m)(5)]
6. Have resolutions and corrective actions from the incident investigation
reports been documented? [Criteria Reference .119(m)(5)]
7. Have incident investigation reports been reviewed with all affected
personnel whose job tasks are relevant to the incident findings including
contract employees, where applicable? [Criteria Reference .119(m)(6)]
8. Are incident investigation reports retained for five years? [Criteria
Reference .119(m)(7)]
B. On-site Conditions
1. Do observations of a representative sample of process components
involved in incident investigations indicate that recommendations have been
resolved? [Criteria Reference .119(m)(5)]
(Compare the corrective actions outlined in the investigation documentation
with the actual equipment, procedures, material use, etc.)
C. Interviews
1. Based on interviews with a representative number of operators,
maintenance employees and contractor employees, have all incidents that
resulted in or could reasonably have resulted in a catastrophic release of
highly hazardous chemicals in the workplace, been investigated? [Criteria
Reference .119(m)(1)]
2. Based on interviews with a representative number of the members of past
investigation teams, do the teams contain at least one person knowledgeable
in the process involved in the incident, and other persons with appropriate
knowledge and experience to thoroughly investigate and analyze the incident?
Was a contractor employee included in the team if the incident involved work
of the contractor? [Criteria Reference .119(m)(3)]
3. Based on interviews with a representative number of employees whose job
tasks are relevant to the past incident investigation findings, have the
investigation reports been reviewed with the affected personnel? [Criteria
Reference .119(m)(6)]
For additional information on Incident Investigations, see Appendix D,
references 9. and 24.
1910.119 (n): EMERGENCY PLANNING AND RESPONSE
I. PROGRAM SUMMARY
The intent of this paragraph is to require the employer to address what
actions employees are to take when there is an unwanted release of highly
hazardous chemicals. The employer must establish and implement an emergency
action plan in accordance with the provisions of 29 CFR 1910.38(a) and
include procedure. for handling small releases. Certain provisions of the
hazardous waste and emergency response standard, 29 CFR 1910.120(a), (p), and
(q), may also apply.
[NOTE: 1910.120(a) addresses scope, application, and definitions for the
entire standard. 1910.120(p) addresses treatment, storage, and disposal
(TSD) facilities under the Resource Conservation and Recovery Act (RCRA).
1910.120(q) addresses requirements for facilities that are not RCRA TSD's,
where there is the potential for an emergency incident involving hazardous
substances. Cleanup operations -- including corrective actions and
post-emergency response cleanup -- are covered by 1910.120(b) through (o). For
further guidance, refer to the forthcoming directive on 29 CFR 1910.120.]
II. QUALITY CRITERIA REFERENCES
A. 1910.119(n)
B. 1910.38(a)
C. 1910.120(a),(p),(q)
D. 1910.165
E. 1910.1200
F. 1910.36
III. VERIFICATION OF PROGRAM ELEMENTS
A. Records Review
1. Has an emergency action plan been established and implemented for the
entire plant in accordance with the requirements of 1910.38? Does the plan
address the following: [Criteria Reference .119(n) or .38(a)(2)]
* Escape procedures and routes?
* Procedures for post-evacuation employee accounting?
* Preferred means to report emergencies?
* Duties and procedures of employees who:
* Remain to operate critical equipment?
* Perform rescue and medical duties?
* The names for persons or locations to contact for more action plan information?
* Employee alarm systems?
2. Is the plan written if the facility has more than ten employees?
[Criteria Reference .38(a)(1)]
3. Is there sufficient number of persons designated and trained to assist
in the safe and orderly emergency evacuation of employees? [Criteria
Reference .38(a)(5)(i)]
4. Is the plan reviewed with each employee covered by the plan: initially
when the plan is developed; and whenever the employees' responsibilities or
designated action under the plan change; and whenever the plan is changed?
[Criteria Reference .38(a)(5)(ii)]
5. Does the emergency action plan cover procedures for handling small
releases? [Criteria Reference .119(n)]
6. Is an alarm system established and implemented which complies with
1910.165? Are the alarms: [Criteria Reference .165(b-e)]
* Distinctive for each purpose of the alarm?
* Capable of being perceived above ambient noise and light levels by all employees in the affected portions of the workplace?
* Distinctive and recognizable as a signal to evacuate the work area or perform actions designated under the plan?
* Maintained in operating condition?
* Tested appropriately and restored to normal operating condition as soon as possible after test?
* Non-supervised systems tested not less than every two months?
* Supervised systems tested at least annually?
* Serviced, maintained, and tested by appropriately trained persons?
* Unobstructed, conspicuous and readily accessible, if they are manual alarm systems?
7. Does the written emergency response plan meet the requirements of
1910.120(a), (p), and (q), if appropriate? [Criteria Reference .120(a);
120(p); 120(q)]
(See the NOTE at I., Program Summary. Clean-up operations required by a
governmental body are addressed in .120(a); treatment, storage, and disposal
(TSD) facilities under the Resource Conservation and Recovery Act are
addressed in .120(p); and .120(q) addresses requirements for emergency
response no matter where they occur, except that it does not cover employees
engaged in operations at TSD facilities or hazardous waste sites.)
8. If employees are engaged in emergency response (except clean-up
operations), does the plan address the following: [Criteria Reference
.120(q)]
* Coordination with outside parties?
* Personnel roles, lines of authority, training, and communication?
* Emergency recognition and prevention?
* Safe distances and places of refuge?
* Site security and control?
* Evacuation routes and procedures?
* Decontamination?
* Emergency medical treatment and first aid?
* Emergency alerting and response procedures?
* Critique of response and followup?
* PPE and emergency equipment?
B. On-site Conditions
1. Do observations of a representative sample of alarm systems indicate
that they comply with the requirements in .165(b-e)? Are the alarms:
[Criteria Reference .165(b-e)]
* Distinctive for each purpose of the alarm?
* Capable of being perceived above ambient noise and light levels by all employees in the affected portions of the workplace?
* Distinctive and recognizable as a signal to evacuate the work area or perform actions designated under the plan?
* Maintained in operating condition?
* Tested appropriately and restored to normal operating condition as soon as possible after test? (Be present for an alarm test if possible or review video if available.)
* Tested no greater than every two months?
* Serviced, maintained, and tested by appropriately trained persons?
* Unobstructed, conspicuous and readily accessible, if they are manual alarm systems?
2. Do observations of the evacuation routes indicate that they are not
blocked, locked, or barricaded? [Criteria Reference .36(b)(4)]
3. Do observations of the evacuation routes indicate that there are
readily visible signs for evacuation routes leading to safe locations?
[Criteria Reference .36(b)(5)]
4. Do observations of a representative sample of the evacuation route
signs during dark conditions indicate that they are adequately illuminated?
[Criteria Reference .120(b)(6)]
C. Interviews
1. Based on interviews with employees who have been identified as likely
to discover releases or assigned other emergency response duties, are they
provided training? Is the training based on the duties they are expected to
perform? [Criteria Reference .120(q)(6)]
2. Based on interviews with employees who are likely to discover hazardous
substance releases, can they demonstrate competency in the provisions listed
in the first responder awareness level: [Criteria Reference .120(q)(6)(i)]
* Understanding what hazardous substances are, and the risks associated with them in an incident?
* Understanding potential outcomes associated with an emergency when hazardous substances are present?
* Ability to recognize the presence of hazardous substances in an emergency?
* Ability to identify the hazardous substances, if possible?
* Understanding the role of the first responder awareness individual in the employer's emergency response plan, including site security and control and the U.S. Dept. of Transportation's Emergency Response Guidebook?
* Ability to realize the need for additional resources, and make appropriate notifications to the communication center?
3. Based on interviews with employees who will take defensive action in
containing and controlling a release as part of the response, can demonstrate
the competencies for a first responder operations level: [Criteria Reference
.120(q)(6)(ii)]
* Knowledge of the basic hazard and risk assessment techniques?
* Knowledge of how to select and use proper PPE provided to them?
* Understanding of basic hazardous materials terms?
* Knowledge of how to perform basic containment, confinement, and control operations within the capability of their unit?
* Knowledge of how to implement basic decontamination procedures?
* Knowledge of relevant standard operating procedures and termination procedures for a response?
4. Based on interviews with employees who will take offensive action in
containing and controlling a release as part of the response, can they
demonstrate the competencies for a hazardous materials (HAZMAT) technician:
[Criteria Reference .120(q)(6)(iii)]
* Knowledge of how to implement the employer's emergency response plan?
* Knowledge of the classification, identification, and verification of known and unknown materials using field survey instruments and equipment?
* Ability to function within an assigned role in the Incident Command System?
* Knowledge of how to select and use proper Specialized chemical PPE provided to them?
* Understanding of hazard and risk assessment techniques?
* Ability to perform advanced control, containment, and/or confinement operations within the capability of their unit?
* Understanding of how to implement decontamination procedures?
* Understanding of termination procedures?
* Understanding of basic chemical and toxicological terminology and behavior?
5. Based on interviews with a representative number of operator and
maintenance employees, do they know the emergency action plan to protect
themselves in an emergency? [Criteria Reference .38(a)]
1910.119(o): COMPLIANCE AUDITS
I. PROGRAM SUMMARY
The intent of this paragraph is to require employers to self-evaluate the
effectiveness of their PSM program by identifying deficiencies and assuring
corrective actions. Minimum requirements include: audits at least every
three years; maintenance of audit reports for at least the last two audits;
audits conducted by at least one person knowledgeable in the process;
documentation of an appropriate response to each finding; documentation that
the deficiencies found have been corrected.
II. QUALITY CRITERIA REFERENCES
A. 1910.119(o): compliance Audits
B. 1910.119(c): Employee Participation
III. VERIFICATION OF PROGRAM ELEMENTS
A. Records Review
1. Has the employer certified in writing that there has been an audit of
compliance with PSM at least every three years? [Criteria Reference
.119(o)(1)]
2. Do the audit reports include an evaluation of all the required
paragraphs of the PSM standard? [Criteria Reference .119(o)(1)]
3. Was the compliance audit conducted by at least one person who was
knowledgeable in the process? [Criteria Reference .119(o)(2)]
4. Has a report of the findings been developed for each audit? [Criteria
Reference .119(o)(3)]
5. Has the employer promptly determined and documented and appropriate
response to each of the findings? [Criteria Reference .119(o)(4)]
6. Does the employer document that deficiencies have been corrected?
[Criteria Reference .119(o)(4)]
7. Has the employer retained the two most recent compliance audit reports?
[Criteria Reference .119(o)(5)]
B. On-site Conditions
No observations are required; on-site Conditions will be cited under other
paragraphs. [Criteria Reference .119(o)(4)]
C. Interviews
1. Based on interviews with auditors, are they knowledgeable in processes?
[Criteria Reference .119(o)(2)]
2. Based on interviews with a representative number of employees and their
designated representatives, do they have access to compliance audit
information? [Criteria Reference .119(o)(3)]
1910.119(p): TRADE SECRETS
I. PROGRAM SUMMARY
The intent of this paragraph is to require employers to provide all
information necessary to comply with the standard to personnel developing
paragraphs (d), (e), (f), (n) and (o) without regard to possible trade
secrets. In addition, employees and their designated representatives shall
have access to trade secret information contained within documents required
to be developed by the standard.
II. QUALITY CRITERIA REFERENCES
A. 1910.119(p): Trade Secrets
B. 1910.1200: Hazard Communication
III. VERIFICATION OF PROGRAM ELEMENTS
A. Records Review
1. Has all information necessary been provided to those persons
responsible for compiling the process safety information (paragraph d), those
assisting in development of the PHA (paragraph e), those responsible for
developing the operating procedures (paragraph f), and those involved in
incident investigations (paragraph m) and emergency planning and response
(paragraph n), and compliance audits (paragraph o) been without regard to
possible trade secret status of such information? [Criteria Reference
.119(p)(1)]
2. Do employees and their designated representatives have access to trade
secret information contained in the PHA and to other documents required to be
developed by the standard, subject to the provisions set forth in
1910.1200(i)(1) through (i)(12)? [Criteria Reference .119(p)(3)]
B. On-site Conditions
Not applicable.
C. Interviews
Employees involved in specific duties: 1. Based on interviews with
a representative number of employees involved in compiling the process safety
information, developing PHA's, developing operating procedures, investigating
incidents, planning and responding to emergencies, and auditing compliance,
has all information necessary been provided to them without regard to
possible trade secret status of such information? [Criteria Reference
.119(p)(1)]
Employees and Representives: 2. Based on interviews with a
representative number of employees and their designated representatives, do
they have access to trade secret information contained within the PHA and
other documents required to be developed by the standard? [Criteria
Reference .119(p)(3)]
(Note that this access is subject to the provisions set forth in
1910.1200(i)(1).)
Appendix B
Clarifications and Interpretations of the PSM Standard
The guidance contained in this appendix is provided for compliance
assistance. It shall be followed in interpreting the PSM standard for
compliance purposes. Unless otherwise noted, all paragraph citations refer
to 29 CFR 1910.119.
This appendix contains clarifications agreed to in a settlement agreement
dated April 5, 1993, between OSHA, the United Steelworkers of America, the
Oil, Chemical and Atomic Workers International Union, and the Building and
Construction Trades Department of the AFL-CIO. The settlement agreement
clarifications reflect modifications jointly and cooperatively agreed to by
the above parties and by the Chemical Manufacturers Association, the American
Petroleum Institute, the Dow Chemical Company, and the National Petroleum
Refiners Association.
Where possible, clarifications and interpretations have been presented in a
question-and-answer format.
NOTE: OSHA plans to include additional clarifications and
interpretations in this appendix through future page changes to this
instruction.
(a) Application
(a) Registration
Do covered establishments have to register with OSHA?
No. There is no requirement that establishments
covered by the standard register with or otherwise notify OSHA.
(a) Explosives -- fireworks manufacture
How does the PSM standard apply to pyrotechnics (fireworks) and
explosives?
The PSM standard amended the scope of 29 CFR 1910.109, Explosives
and blasting agents, by revising paragraph (k), which requires that the
manufacturer of explosives and pyrotechnics comply with 29 CFR 1910.119. As
defined at 1910.109(a)(10), pyrotechnics are commonly referred to as
fireworks. Employers who manufacture explosives and fireworks must comply
with both 29 CFR 1910.109 and 1910.119.
The applicability of 29 CFR 1910.109 to employers who manufacture
fireworks is delineated in OSHA Instruction CPL 2.73, Fireworks
Manufacturers: Compliance Policy. In accordance with that directive, a
fireworks plant employer can be cited for violation of 29 CFR 1910.109 with
reference to certain National Fire Protection Association (NFPA) standards in
NFPA 1124, Code for the Manufacture, Transportation and Storage of
Fireworks.
What is the role of the Bureau of Alcohol, Tobacco and Firearms (BATF)
vis-a-vis the PSM standard and fireworks manufacture?
By 27 CFR 55 Subpart K, BATF regulates the storage, including
minimum distances, of explosive materials including fireworks in the
workplace. As such, BATF limits the amount of special fireworks, pyrotechnic
composition, and explosive materials used to assemble fireworks in processing
building to no more than 500 pounds. Also, the maximum quantity of flash
powder permitted by BATF in any fireworks process building is 10 pounds.
These BATF limitations should not be confused with the applicability of the
PSM standard to any amount of fireworks being manufactured.
(a) Laboratories
Does the PSM standard apply to laboratory and research operations?
A laboratory or research operation involving at least the threshold
quantity of one or more highly hazardous chemicals is subject to the PSM
standard.
(a) Flammable liquids
Are processes involving flammable liquids (e.g., ethyl alcohol) covered
by the standard?
Processes involving flammable liquids (e.g., in a distillation
process) in quantities at or above 10,000 lbs. are covered. Quantities of
flammable liquids in storage are considered a part of the process if the
storage tanks are interconnected with the process, or if they are
sufficiently near the process that an explosion, fire, or release could
reasonably involve the storage area combined with the process in quantities
sufficient to meet the threshold amount of 10,000 lbs.
Flammable liquids that are stored on a tank farm (e.g., a wholesale
gasoline regional tank farm) where only transferring and storage are done are
not covered by the PSM standard. They are, however, covered under
1910.106.
(a)(1)(i) Hydrogen chloride (HCL)
Does the PSM standard apply to muriatic (32% HCL) acid?
The chemical names: hydrogen chloride (HCL) and anhydrous
hydrochloric acid are included in the highly hazardous chemicals listing in
Appendix A of the PSM standard. Anhydrous (without water) hydrochloric acid
is hydrogen chloride. Both hydrogen chloride and anhydrous hydrochloric acid
are identified by the same Chemical Abstract Service (CAS) Number 7647-01-0,
as denoted in Appendix A. Hydrochloric acid (muriatic acid) -- i.e., a solution
of hydrogen chloride gas in water -- is not listed in Appendix A and therefore
is not considered to be a highly hazardous chemical subject to the PSM
standard.
(a)(1)(i) Highly hazardous chemicals (HHCs)
What is meant by "Formaldehyde (Formalin)" listed in Appendix A of the
PSM standard?
This highly hazardous chemical should be listed to read:
Formaldehyde (37% by weight or greater). The PSM standard will be
revised to reflect this change in the near future. Any amount of mixture of
Formaldehyde, less than 37%-by weight, in solution would not be covered by
the PSM standard.
Does the PSM standard apply to solutions of Dimethylamine?
Anhydrous Dimethylamine, identified by Chemical Abstract Service
(CAS) Number 124-40-3, is listed in Appendix A of the PSM Standard as a
highly hazardous chemical. Dimethylamine in aqueous solutions, which is not
listed in Appendix A, is not considered to be a highly hazardous chemical
covered by the PSM standard except when the solution qualifies as a flammable
liquid.
(a)(1)(i) HHCs -- mixtures
Does the threshold quantity listed under Appendix A of the PSM standard
apply to the quantity of the whole mixture or just the quantity of the
component chemical, or to neither (i.e., does the threshold quantity apply
only to quantities of pure chemical unless otherwise specified in the
appendix)?
The threshold quantities listed in Appendix A of the standard apply
only to pure (or "commercial grade") chemicals unless otherwise specified,
for example, Hydrogen Peroxide, 52% by weight or greater.
Does the PSM standard apply to an employer who uses cellulose nitrate in
a concentration greater than 12.6% nitrogen to which water is added,
producing a mixture containing greater than 23% water, which will not
burn?
Appendix A of the standard lists cellulose nitrate in concentrations
of greater than 12.6% nitrogen as a chemical which presents a potential for a
catastrophic event at or above the threshold quantity of 2500 pounds (1,133.9
kg). The standard does not distinguish between "wet" or "dry" cellulose
nitrate.
Therefore, if an employer's process involves cellulose nitrate in a
concentration greater than 12.6% nitrogen, with the total quantity of the
mixture or solution at or above the threshold quantity -- no matter what
percentage of water may be used in treatment -- the process is covered under
the requirements of the PSM standard.
(a)(1)(i) and (b) Covered process -- Hazardous waste operations
Does the PSM standard apply to the EPA-regulated and permitted RCRA
hazardous waste treatment, storage and disposal (TSD) facilities, when such
facilities keep on-site in one location a hazardous waste chemical in a
concentration and quantity which exceeds the applicable threshold quantity of
Appendix A. If so, why? If not, why not?
Employers of worksites with TSD facilities which contain covered
processes must comply with the PSM standard. The requirements of the PSM
standard are intended to eliminate or mitigate workplace catastrophic
releases of highly hazardous chemicals and resulting employee exposure to
explosion, fire and toxic hazards.
(a)(1)(i) and (b) Covered process -- dispersal of inventory
Can an employer who keeps threshold quantities of highly hazardous
chemicals listed in Appendix A to 29 CFR 1910.119, such as ammonia, separated
into smaller lots and used and stored in separate systems or locations, be
exempt from the requirements of the PSM standard?
From a storage standpoint, the 1910.119 standard would not apply to
an employer who segregates his inventory by dispersing storage of highly
hazardous chemicals, such as ammonia, in amounts which do not exceed the
threshold quantity so that a release from one storage area would not
contribute to or cause a release from others around the workplace.
Additionally, an employer could reduce his on-site inventory of highly
hazardous chemicals by ordering more frequent, smaller shipments so that they
do not exceed the threshold quantities set forth in the PSM
Standard.
The PSM standard's non-mandatory Appendix C suggests that, if reduced
inventory of highly hazardous chemicals is not feasible, an employer might
consider dispersing inventory to several locations on-site. When are such
materials to be considered part of a single process?
Under the definition of "process" provided at 29 CFR 1910.119(b),
any group of vessels which are interconnected and separate vessels which are
located such that a highly hazardous chemical could be involved in a
potential release shall be considered a single process. Inventories of
highly hazardous chemicals would not be considered to be adequately dispersed
if the storage vessels are connected with or in proximity to a covered
process such that they could be involved in a potential release.
What evaluation techniques are appropriate to determine adequate
separation distances?
OSHA has not developed, nor is it aware of, any standard evaluation
technique to determine adequate distances to separate chemical inventories.
If an employer chooses to disperse highly hazardous chemicals on-site, the
separation distances would have to be determined on a case-by-case basis,
considering such factors as the nature of the chemicals and covered
processes, total inventories, threshold quantities of pertinent chemicals,
and facility layout.
(a)(1)(ii) Application -- 55-gallon drums
Would more than 10,000 pounds (4535.9 kg) of a flammable liquid stored
together in 55-gallon (209-liter) drums be covered under the PSM
standard?
For the purposes of the PSM standard, this would be considered
exempt as storage in atmospheric tanks (notwithstanding the definitions of
"containers" and "tanks" in 29 CFR 1910.106), unless the drums are near a
covered process, as described in the Q & A on "flammable liquids" at page B-2
of this appendix. For the purposes of 1910.106, 55-gallon (209-liter) drums
are covered in the definition of "container."
(a)(1)(ii) Covered Process -- Flammable gases
For processes involving flammable gas mixtures, are the non flammable
components in a flammable gas mixture included when determining the threshold
quantity?
The non-flammable components contribute to the determination of
threshold quantity, i.e., 10,000 pounds (4535.9 kg) or greater amounts of a
flammable gas, as defined in 29 CFR 1910.1200(c) and noted below:
Gas, flammable means:
(a) A gas that at ambient temperatures and pressure forms a
flammable mixture with air at a concentration of thirteen (13) percent by
volume or less; or
(b) A gas that, at ambient temperature and pressure, forms a range
of flammable mixtures with air wider than twelve (12) percent by volume,
regardless of the lower limit.
(a)(1)(ii) Covered process -- Flammable liquids
Does the PSM standard apply to processes in a paint manufacturing
facility, which include the mixing and blending of flammable liquids with
other raw materials, and which typically involve few or no chemical
reactions? Typically, the flammable products are processed below their
normal boiling points and that several large batch vessels are located near
each other, with an aggregate weight above the threshold quantity of 10,000
pounds (4535.9 kilograms).
The requirements of the PSM standard would apply to such operations.
The exemption provided in the standard at 1910.119(a)(1)(ii)(B) for
situations involving flammable liquids applies only when such liquids are
being stored in atmospheric tanks (where the tank pressure does not exceed
0.5 pounds per square inch gauge [p.s.i.g.]) or transferred and the liquids
are kept below their normal boiling point without benefit of chilling or
refrigeration. This exemption does not apply to a mixing and blending
operation related to paint manufacturing.
(a)(1)(ii)(A) Application -- Exceptions -- Hydrocarbon fuels
Does the PSM standard apply to ceramic manufacturing facilities utilizing
propane in amounts exceeding 10,000 pounds as the fuel for firing ceramic
ware in a process which does not involve any other highly hazardous
chemicals?
No. The PSM standard would not apply to such a situation.
Does gasoline used as a fuel to test run inboard and outboard engines
fall within the scope of the PSM standard?
Gasoline used in such a manner does not fall within the scope of
1910.119, because it is used as a fuel in this situation and thus meets the
exception at 1910.119(a)(l)(ii)(A). However, other OSHA standards, such as
1910.106, Flammable and combustible liquids, would apply.
Does the PSM standard apply to a plant that has more than 10,000 pounds
of hydrocarbon fuel on site where the fuel is used solely as a fuel for a
furnace used to melt glass?
The requirements of 1910.119 do not apply to this situation because
1910.119(a)(1)(ii)(A) of the standard specifically excludes from coverage
hydrocarbon fuels used solely for workplace consumption as a fuel if the fuel
is not part of a process containing another highly hazardous chemical covered
by the standard.
(a)(1)(ii)(A) Tote tanks
350-gallon tote tanks containing flammable liquids are used at a facility
to refuel vehicles. Are they covered by the standard?
No. 1910.119(a)(1)(ii)(a) exempts hydrocarbon fuels used solely for
workplace consumption as a fuel (e.g., gasoline for vehicle refueling) if
such fuels are not part of a process containing another highly hazardous
chemical covered by the standard. They are, however, covered under
1910.106.
(a)(1)(ii)(A) Fuels for heating
Are flammable liquids and gases used as fuels for such items as heaters
or exchanges contained in (covered) processes also included within the
coverage of the standard?
Furnaces, boilers, heaters, etc., fueled by flammable liquids or
gases -- regardless of the quantity of the fuel -- used in processes that are
otherwise covered by the PSM standard (i.e., the existence of a threshold
quantity of another highly hazardous chemical) are considered part of the
process and are covered by the PSM standard. Flammable liquid-or-gas-fueled
furnaces, boilers, etc., used in processes not otherwise covered by the PSM
standard are exempt from the standard.
(a)(1)(ii)(B) Tank farms
Are flammable liquids stored in a tank farm covered under the
standard?
Atmospheric tanks containing flammable liquids at bulk transfer
terminals are not covered. However, atmospheric tanks containing flammable
liquids that have feeder connections to processes are covered by the
standard.
EXAMPLE. Atmospheric tanks in an outside storage area contain a
flammable liquid that is pumped to a mixing vessel. If the total quantity of
flammable liquids in this equipment is at or above 10,000 pounds (4535.9 kg),
then this is a covered process which includes, at a minimum, the storage
tanks, the piping, and the mixing vessel.
(a)(1)(ii)(B) Flammable liquids
Does 1910.119(a)(l)(ii)(B) exempt all flammable liquids stored or
transferred which are kept below their normal boiling point without the
benefit of chilling or refrigeration, including, but not limited to,
flammable liquids in atmospheric tanks?
No. The exemption is limited to flammable liquids stored in
atmospheric tanks or transferred which are kept below their normal boiling
point without benefit of chilling or refrigeration. This exemption is
applicable to flammable liquids in tanks, containers and pipes used only for
storage and transfer (to storage), and not connected to a process or a
process vessel. Similarly, stored flammable liquids in containers, including
cans, barrels and drums, would be exempt from coverage by the PSM standard.
We recommend you carefully consider the definition of "process" to determine
further applicability of the PSM standard in situations where flammable
liquids are stored in tanks or containers at a worksite.
(a)(2)(i) Retail facilities
What is the definition of "retail facilities" that are exempted from
coverage by the PSM standard?
With respect to enforcement of the PSM standard, a retail
facility means an establishment that would otherwise be subject to the
PSM standard at which more than half of the income is obtained from direct
sales to end users.
If an employer that would otherwise be covered by the PSM standard
operates at several locations and the majority of its income comes from sales
to end users, is the employer exempt as a "retail facility"?
The PSM standard defines a retail facility as "an establishment
which would otherwise be subject to the PSM standard, at which more than half
of the income is obtained from direct sales to end users." If such an
employer operates at multiple locations, the questions becomes whether this
constitutes a single "establishment" for the purposes of the
standard.
The intent of the PSM Standard is to prevent catastrophic releases
of highly hazardous chemicals, thereby, providing for safe and healthful
workplaces for employees. Consistent with this intent, the term
"establishment," when used to define retail facility, means a company name at
a specific site (normally with a street address). Thus, if an employer
operates at several locations, some might be covered by the standard, and
others not affected.
Are facilities that fill propane tanks for "will call" type customers
exempt from the PSM standard? Most of these facilities are under the
aggregate quantity of 10,000 pounds (4535.9 kilograms), The majority of the
business is transferring propane from the supply tank to small containers for
barbecues and "RV" units.
Such facilities appear to be exempt from coverage by the PSM
standard because they are retail facilities or because they do not involve
processes with threshold (or greater) quantities of propane. A retail
facility is defined as a site-specific establishment which otherwise would be
subject to the PSM standard, at which more than half of the income is
obtained from direct sales to end users.
(a)(2)(ii) Oil or gas well operations
Are single well processing facilities with equipment including
separators, heat-treaters and storage tanks used in gas production (from
non-H2S containing petroleum fluids) operations exempt from coverage under
1910.119(a)(2)(ii), which excludes oil and gas well drilling and servicing
operations?
The 1910.119(a)(ii) exemption of oil or gas well drilling or
servicing operations is intended to cover all drilling operations and any
well servicing operation including acidizing. Additionally, water separation
facilities adjacent to or near the well (including tanks used primarily for
water separation in conjunction with oil or gas well production) are not
normally covered by the PSM standard.
The following processes, when they involve at least threshold
quantities of oil or gas, are covered by the PSM standard. Oil or gas well
production fluids from several wells are processed by heating the fluids and
physically separating the water from the gas or oil. The water is returned
to the ground via a "down hole well" for disposal return to the strata from
which it came. But if these oil or gas well drilling operations take place
at "normally unoccupied remote facilities", then according to
1910.119(a)(2)(iii), they are exempt from PSM standard coverage.
(a)(2)(iii) Meaning of "facility"
Can a facility contain more than one process?
A facility can include multiple processes. If multiple processes
are interconnected, they may be considered a single process for purposes of
the standard.
(b) Definitions
(b) "Process"
What are "aggregate threshold quantities"?
In accordance with the second sentence of the definition of
"process," quantities of a particular hazardous chemical contained in vessels
that are interconnected -- and in unconnected vessels that may be adversely
affected due to an incident at a nearby process -- must be combined to
determine whether the threshold level of a hazardous chemical has been
reached. If the threshold level is exceeded by the combination of the amount
in separate tanks and interconnected vessels, then all of these may be
considered one process.
Is waste burning of covered solvents considered a process?
Yes.
(b) "Hot work"
"Spark-producing operations" include operations which use
flame-or spark-producing equipment -- such as grinders, welding, burning, or
brazing -- that are capable of igniting flammable vapors or gases.
(b) "Normally unoccupied remote facility"
"Normally unoccupied remote facility" means that employees
are not permanently stationed at the remote location. This includes those
sites for which periodic visits by employees may be made on a scheduled
basis. Examples could include pump stations located miles from the main
establishment. Employees may be assigned to check on the station as
needed.
The intent behind "remote" is that, due to the isolation of the
process from employees by distance, such employees would not be affected by
the consequences of a catastrophic release. Therefore, the remote location
must be geographically separated from other facilities and employees such
that employees would not be affected by an explosion, vapor cloud of toxic
gas, or other consequence of an uncontrolled release at the remote
site.
(c) Employee participation
(c) Employee participation
In implementing employee participation as required by 1910.119 (c) of the
PSM standard, can an employer mandate that employees e.g., top operators of
process units -- provide the company with information such as step-by-step
procedures for routine tasks performed on their operating units? Can the
employer threaten disciplinary action for employees who do not cooperate?
The employee participation called for at 1910.119(c) is intended to
provide for a cooperative participatory environment and necessary flow of
information from management to employees and from employees to management on
process safety to eliminate or mitigate the consequences of catastrophic
releases of highly hazardous chemicals in the workplace. Paragraph
1910.119(c)(2) contains language taken from the Clean Air Act Amendments
(CAAA) of 1990. As prescribed by the CAAA, the standard at 1910.119(c)(3)
requires that PSM information developed by the employer be made available to
employees and their representatives. Also, OSHA requires that an employer
carefully consider and structure the plant's approach to employee involvement
in the PSM program.
The plan-of-action standard at 1910.119(c)(1) is intended to address
this issue to ensure that the employer actively considers the appropriate
method of employee participation in the implementation of the PSM program in
the workplace.
(c)(2) Consultation
What does consult mean? Can the employer simply inform the employees?
Consultation refers to a two-way dialogue between the employer and
the employees and their representatives (where they exist), in which the
employer elicits, and responds to, employees' concerns and suggestions
bearing upon the elements of process safety management required under this
standard. Consultation is therefore more than a way to inform employees
about aspects of process safety; it is a process of seeking advice,
criticisms, and suggestions from employees and their
representatives.
1. The employer should establish a method for informing all
employees and their representatives that their process safety concerns and
suggestions are welcome. The employer must also establish a mechanism by
which it will respond, orally or in writing, to such concerns and
suggestions.
2. In addition, the employer should affirmatively solicit the
suggestions and concerns of employees and their representatives, who, by
virtue of their job responsibilities, actual knowledge, or representative
positions, can reasonably be expected to make substantive contributions to
the development and evaluation of specific elements of process safety
management.
The standard requires employers to consult with "employees and their
representatives." Is the term broad enough to include a representative of
the international union? A consultant designated by the union local or
international?
The standard requires consultation with "employees and their
representatives". The term "employee representative" is intended
to mean union representative where a union exists, or an employee
designated representative in the absence of a union. The term is to be
construed broadly, and may include the local union, the international union,
or an individual designated by these parties, such as the safety and health
committee representative at the site or a non-employee consultant. In the
absence of a union, employees have a right under the standard to designate a
representative to participate in the consultation process.
With respect to the PHA team, in all cases it must consist of one or
more persons knowledgeable about the process. The intent of the
consultation requirement at 1910.119(c)(2) is not to compel the inclusion of
any person(s) who are not knowledgeable; ideally, the employer and
employees/employee representatives should reach a consensus on including the
most capable parties.
(c)(2) Consultation -- contractors
Must the employer consult with employees of contractors?
A host employer must consult with employees of covered contractors
and their representatives, to the same extent that it must consult with
similarly situated direct hire employees. Therefore, the host employer must
establish a method for informing all contractor employees and their
representatives that their process safety concerns and suggestions are
welcome, and will be responded to. In addition, the following non-exclusive
examples illustrate circumstances under which the host employer may be
required to solicit the advice and suggestions of specific contractor
employees about specific aspects of process safety:
1. Contract employees who function as process operators on covered
processes, or perform routine maintenance on covered processes, should be
consulted to the same extent as equivalent direct hire operating and
maintenance employees, respectively.
2. Contract employees who routinely interface with a host
employer's Management of Change program should be consulted on the
effectiveness of the program as it relates to their jobs and based upon their
interaction with it.
3. Contract employees who routinely participate in activities
pursuant to mechanical integrity should be consulted on the effectiveness of
the program as it relates to their jobs and based upon their interaction with
it; e.g., contract employees should be encouraged to identify any
deficiencies they observe in the host employer' s program.
4. Contract employees who have unique experience or knowledge
concerning the operation, maintenance, or safe performance of any portion of
a covered process should be consulted, as appropriate, on that portion of the
process during the PHA.
5. Contract employees who routinely interface with the host
employer's safe work practices (such as, for example, the employer's
lockout/tagout rules, hot work permit procedures, and confined space entry
procedures) should be consulted as to the effectiveness of those
practices.
Host employers can consult with contractor employees and their
representatives directly, or through the contractor employer. Contractor
employers share responsibility for ensuring that there is consultation with
their employees.
(c)(3) Access
What does "access" mean? Does this mean simply make it available at a
central location? Does the employer have to make copies for employees if
requested?
The intent of access under this standard is for the
information to be made available for employees and their representatives in a
reasonable manner. Reasonable access may require providing copies or loaning
documents. The trade secret provision of the standard permits the employer
to require confidentiality agreements before providing the
information.
(c)(3) Equal access to information
Under (c)(3), the employer is required to provide access to process
hazard analyses and all other information to be developed under this standard
to employees of covered contractors, to the same extent that it must provide
access to direct hire employees, if similarly situated. Contract employers
share responsibility for assuring that their employees are provided with the
requested information.
(d) Process safety information
(d) Retention of information
How long must the employer maintain process safety information?
In order to demonstrate compliance with this paragraph, and to meet
the purpose of the standard, the process safety information is to be kept for
the lifetime of the process, and updated whenever changes other than
"replacement in kind" are made.
(d)(2)(ii) Original process safety information not present
If process safety information on the original technology does not exist,
what must the employer do?
The employer must obtain or generate the missing information. If
the information on the original technology does not exist, then the employer
may delay the development of this information until the process hazard
analysis (PHA) is initiated, but in no case later than the applicable dates
specified at 1910.119(e)(1). However, the other information required by this
section must be compiled before conducting any PHA. The information on the
technology must be gathered as the PHA's are conducted in accordance with the
priority schedule developed by the employer.
(d)(3)(iii) Older codes -- PSM standard deadlines
For equipment based on old design codes, the employer must determine and
document that the equipment is designed and operated safely. By what date
must the employer do this? Specifically:
* When must the employer determine adequacy of design based on old codes, and
* How much time does the employer have to make corrections?
Generally speaking, the time frames which apply to implementation of
the PHA's also apply to this paragraph.
Such documentation must be completed either before or in conjunction
with the development of the PHA, except where a pre-startup safety review is
required, in which case the documentation must be completed before startup.
For older equipment, this may require verification that the design and
construction are safe for the intended application. Where corrective action
is required as a result of the PHA, it must be completed as soon as possible
pursuant to paragraph (e)(5).
EXCEPTION: For actions required by a pre-startup safety
review (see (i)(2)), such corrective action must be implemented prior to the
startup if the correction is safety-critical.
(e) Process hazard analysis
(e)(1) PHA priority
What rationale must employers use to determine the priority for
conducting the process hazard analyses? May the rationale include age,
history, extent of employee exposure, etc.?
The appropriate priority for conducting PHA's is to be determined by
using all of the criteria identified in this paragraph, e.g., extent of the
process hazards (catastrophic potential), age of the process, number of
potentially exposed employees, and operating history. Other appropriate
factors may also be considered in establishing the priority. The
documentation required by this paragraph shall demonstrate the underlying
rationale for the prioritization.
(e)(1) PHA priority -- "as soon as possible"
Paragraph (e) contains a five year phased-in compliance schedule for
completing process hazard analyses. The provision mandates that employers
first "determine and document the priority order for conducting process
hazard analyses" and then complete 25 percent or more of the analyses each
year after the second year. (See 57 Fed. Reg. 6378/3.) However, because
OSHA believes that "plants with a limited number of processes, with simple
processes, or which have already completed a number of process hazard
analyses" will need less time to complete their analyses (57 Fed. Reg.
6375/3), it included a specific provision requiring that analyses "be
completed as soon as possible." 29 C.F.R. 1910.119(e)(1)
(e)(1) PHA completion dates
What is the time frame for completion of the initial PHAs and for
updating and revalidating them?
In accordance with 1910.119(e)(l), all initial PHAs must be
completed as soon as possible, with at least 25 percent of them completed by
May 26, 1994; 50 percent by May 26, 1995; 75 percent by May 26, 1996; and all
completed by May 26, 1997. Initial PHAs must be updated and revalidated at
least every 5 years thereafter (see 1910.119(e)(6). When employers update
and revalidate a PHA before the 5-year deadline, the subsequent update and
revalidation must be completed within the next 5-year period.
(e)(1) PHAs -- Required site-by-site?
If a natural gas company has five sites with facilities performing the
same process, does a separate PHA need to be performed for each site, for
each facility at these sites, or for each process at each facility?
The PSM Standard is applicable, on a site-by-site basis, to each
worksite which has one or more facilities containing one or more processes
involving one or more of the covered highly hazardous chemicals. A worksite
may be simply one facility containing a single process. (See the definition
of "facility" in Subsection (b) of 1910.119). On the other hand, a worksite
may be a complex of facilities, each containing one or more
processes.
Under 1910.119(e)(l), employers are required to perform initial PHAs
on processes involving highly hazardous chemicals covered by the PSM
standard. An employer may use a generic hazard analysis approach for the
same (or nearly the same) covered process at an individual worksite. The
employer must account for variations (e.g., differences in siting, incident
histories, technology, equipment, or operations) for each process covered by
this generic approach. Generic process hazard analysis is addressed in
section 4. of nonmandatory Appendix C of 1910.119, Compliance Guidelines and
Recommendation for Process Safety Management.
(e)(2) Process hazard analysis -- "appropriate methodology"
What type of methodology must employers use in the PHA in order to be
sure it is "appropriate"?
Employers are expected to use sound judgment, on a case-by-case
basis, to determine an appropriate methodology for the process hazard
analysis for each covered process. It is not the intent of the standard to
require a PHA methodology that is excessively burdensome, but rather one that
is appropriate and which will have the capability to elicit all hazards,
defects, failure possibilities, etc., for the process being analyzed, and
also have the capability to address all the factors at
1910.119(e)(3).
(e)(3) Meaning of "control"
The regulation requires that the PHA address the "control" of the
hazards. What is meant by: "identification, evaluation, and control of
process hazards" -- ?
The PHA is intended to identify and evaluate acceptable controls for
process hazards. The evaluation of the hazards must include all the steps
set out in section (e)(3)(i) -vii), using a methodology consistent with
section (e)(2). Through the timely resolution of the PHA findings and
recommendations, the PHA is intended to control process hazards.
(e)(3)(iv) Quantitative determination?
Must the employer make a quantitative determination to determine the
consequences of failure of the controls?
The intent of this paragraph is to require the employer to at least
identify each type of control as well as identify the possible effects of the
failure of the listed control. OSHA believes employers can determine the
consequences of a failure of these controls, and establish a reasonable
estimate of the safety and health effects on employees without conducting a
specialized quantitative evaluation.
(e)(3)(v) Facility siting
What does "facility siting" mean?
With respect to existing plants, "siting" does not refer to the site
of the plant in relation to the surrounding community. It refers, rather, to
the location of various components within the establishment.
(e)(5) Abatement = shutdown?
Hazards may be identified for which a recommended solution/action might
be the shutdown of the process. For example, several processes might be
located very close, and if fire were to occur a domino effect might result in
a catastrophic release. The resolution may be to separate the processes, but
there is no additional property on which to expand. What is required of the
employer?
In such situations, the employer could implement protective measures
to minimize the probability of a major uncontrolled release. An appropriate
response in this specific case, for example, might be to install additional
detection systems which may be interlocked to deluge systems for tanks and
process equipment, to provide additional protective measures for onsite
personnel, and to implement administrative controls, such as reducing
inventories and numbers of exposed personnel.
(e)(5) Timeliness
Employers must "promptly" address the problems identified in the PHA in a
"timely manner," and complete actions "as soon as possible." What time frame
did OSHA intend here?
The standard's intent is for the employer to take corrective action
as soon as possible. As soon as possible means that the employer shall
proceed with all due speed, considering the complexity of the recommendation
and the difficulty of implementation. OSHA expects employers to develop a
schedule for completion of corrective actions, to document what actions are
to be taken, and to document the completion of those actions as they
occur.
(e)(5) Addressing PHA team's findings and recommendations
Paragraph (e) of the standard requires that a team with expertise in
engineering and process operations conduct a process hazard analysis,
containing specific findings and recommendations for each covered process.
The employer is then required to promptly "address" and "resolve[]" the
team's findings, document the actions taken, and communicate these actions to
the affected employees. 29 C.F.R. 1910.119(e)(5).
OSHA considers an employer to have "resolved" the team's findings
and recommendations when the employer either has adopted the recommendations,
or has justifiably declined to do so. Where a recommendation is rejected,
the employer must communicate this to the team, and expeditiously resolve any
subsequent recommendations of the team.
An employer can justifiably decline to adopt a recommendation where
the employer can document, in writing and based upon adequate evidence, that
one or more of the following conditions is true:
1. The analysis upon which the recommendation is based contains
material factual errors;
2. The recommendation is not necessary to protect the health and
safety of the employer's own employees, or the employees of
contractors;
3. An alternative measure would provide a sufficient level of
protection; or
4. The recommendation is infeasible.
(e)(7) Retention
How long must the process hazard analyses, updates, and revalidations be
retained?
For the life of the process.
(f) Operating procedures
(f)(1) Written operating procedures
Many employers have computerized process control systems and safety
interlock systems software. Can simplified loop diagrams or narrative
descriptions be used to describe the logic of software and the relationship
between the equipment and computerized process control systems, to meet the
requirements for written operating procedures at 1910.119(f)(1)? Can system
logic flow charts or narrative descriptions of the computerized safety
interlock systems be used to meet these same requirements?
It is anticipated that employers would include loop diagrams, flow
charts, and narrative descriptions of control and interlock systems in their
compilations of written process safety information required by 1910.119(d)
before conducting any PHAs required by 1910.119(e). Written operating
procedures must be developed to provide clear instructions for safely
conducting activities involved in each covered process, consistent with the
process safety information and with the associated PHA. Simplified diagrams,
flow charts, and narratives could be used in conjunction with instructions to
meet the requirements for written operating procedures at
1910.119(f)(1).
(f)(1)(iii)(c) "Control measures to be taken if physical contact or
airborne exposure occurs"
Does this mean first aid, or industrial hygiene services?
It primarily means first aid procedures or emergency medical
attention, which should be consistent with the information on the material
safety data sheet.
(g) Training
(g)(1)(i) Initial training
Training in an overview of the process, and in safety and health
hazards, emergency operations, and safe work practices, must have been
completed by May 26, 1992. In situations where operating procedures were
already in place, training in those existing procedures was required by May
26, 1992. Initial training shall have been provided by that date, based on
existing procedures and available process information. As new information
and procedures are developed, refresher training must be provided in
accordance with paragraph (g)(2).
(g)(1)(ii) Initial training -- "grandfathering"
What is required in the employer's written certification regarding
employees whose initial training is "grandfathered"?
Where employees involved in operating the process have not received
the initial training required under (g)(1)(i), but have been involved in
operating the process safely for a period of time prior to May 26, 1992, the
employer may waive the initial training requirement by certifying in
writing that the employee has the required knowledge, skills, and
abilities to safely carry out the duties and responsibilities as specified in
the operating procedures, written or otherwise. Such certification may be
based on on-the-job evaluation or other equivalent determination methods.
When new operating procedures -- which must be written -- are subsequently
developed, the employer must give training to operating employees prior to
their implementation.
(g)(2) Refresher training
Employees have to be given refresher training at least every 3
years -- measured from when?
The time period for refresher training of an employee involved in
operating a process is to be measured from the date of the employee's last
training [or "grandfathering," as allowed at (g)(1)(ii)] in the overview and
current operating procedures of the process.
Under what circumstances must refresher training be provided more often
than every 3 years?
Employers, in consultation with employees, shall determine the
appropriate frequency, which may be based on consideration of such factors as
deviations from standard operating procedures, recent incidents, or apparent
deficiencies in training.
Is training under "management of change" considered to be refresher
training?
No. It is an independent training requirement, in addition to other
training requirements of the standard.
(g)(3) Training documentation
This paragraph requires the employer to make sure that operators
"understand" the training provided to them under this section. Is some
method of testing required?
There must be some positive means taken by the employer to determine
if employees have understood their training and are capable of adhering to
the current operating procedures of the process. This could include the
administration of a written test, although the standard does not require that
a formal written test be used. Other means of ascertaining comprehension of
the training, such as on-the-job demonstrations, etc., are acceptable, as
long as they are adequately documented.
(h) Contractors
(h) Scope of activities
The list of covered and exempted activities in paragraph (h) is
meant to be illustrative of potential contractor activities. The standard
covers all contractor activities that have the potential for affecting
process safety. Therefore, paragraph (h) applies to all contractor activities
on or adjacent to a covered process, except those incidental activities that
do not influence process safety, such as janitorial work, food and drink
services, laundry, delivery or other supply services. Consequently,
contractors performing construction, demolition, equipment installation and
other work that bay affect the safety of a covered process must comply with
the requirements of this paragraph. Furthermore, paragraph (h) is not the
only part of the process safety management standard that applies to
contractors. In appropriate circumstances, other provisions of the standard
apply.
(h) Scope of activities -- construction work
Do contractors performing construction work at a site covered by the PSM
standard also have to comply with 29 CFR 1926 standards?
Contractors performing construction work at a site covered by the
PSM standard must comply with all applicable standards under 29 CFR 1926,
including Part 1926, Subpart C requirements. See the regulation at 29 CFR
1910.12(b), which defines the term "construction work," and the regulation at
29 CFR 1926.13, which discusses the terms "construction," "alteration," and
"repair."
(h)(1) and (2) Contractors and subcontractors
Paragraph (h) applies to all subcontractors whose work falls within
the scope of covered work as established in (h)(1). The host employer and the
general contractors are both responsible for ensuring that the duties
contained in (h)(2) are performed; this applies to inquiring into the safety
records of their subcontractors, informing the subcontractor as to the known
potential hazards, the emergency action plan, and safe work practices, and
ensuring the subcontractor's compliance with the standard. Furthermore,
under (h)(2)(v), the host employer has the obligation to assure that the
contract employer and the subcontractor are properly performing their
obligations under (h)(2) with respect to their subcontractors' compliance
with the standard
The intention is that host employers and contractors exercise
responsible oversight of their respective contractors' and subcontractors'
performance of safety and health requirements under the standard.
(h)(2) Contractors -- Employer responsibilities -- Training
How much of the burden of training contractor employees is placed on the
employer?
The burden of training contractor employees is on the contractor
employer. However, under 1910.119(h)(2)(v), the host employer shall
periodically evaluate the contract employer's performance with respect to the
(contract) employee instruction and training requirements at
1910.119(h)(3).
NOTE: The employer must inform a contract employer of the hazards
related to the contractor's work and the process [as noted at
1910.119(h)(2)(ii) and (iii)].
Although the standard places the primary responsibility for
providing training to its employees on the contract employer itself, the host
employer bears the responsibility to "periodically evaluate the performance
of contract employers in fulfilling their obligations as specified in
paragraph (h)(3)." 29 C.F.R. 1910.119(h)(2)(v). Such "obligations" clearly
include training obligations. The standard also requires the host employer
to select a contract employer only after evaluating its safety performance
and programs [(h)(2)(i)], and to inform the contract employer about the
specific hazards associated with the process [(h)(2)(ii)] and the provisions
of the emergency action plan [(h)(2)(iii)].
If contract employees are involved in operating a process or
maintaining the on-going integrity of process equipment, then they must
receive training in accordance with the specific training requirements set
forth in paragraphs (g) and (j), respectively. In order to satisfy its
obligations under (h)(2)(v), the host employer must ensure, through periodic
evaluations, that the training provided to these contract employees by the
contract employer is in fact equivalent to the training that the standard
requires for direct hire employees. Such training need not be identical in
format or content or context to training given to the host's employees. The
critical element is that information required by the standard must be
conveyed to and learned by contract employees as well as direct hire
employees. The obligation may be satisfied by joint training or by separate
training.
Moreover, (h) requires that every employee of a covered contractor
be trained in the work practices necessary to perform safely his or her job.
The contract employee must be able to perform his or her own job tasks safely
and should receive:
(a) training prior to beginning work on or near a covered process,
which should encompass (i) instruction regarding known process hazards
related to his or her job, including training in the applicable provisions of
the emergency action plan; and (ii) training in the safe work practices
adopted by the host employer and the contract employer; and
(b) additional training as necessary (i) to prepare the employee
for changes in the operations or work practices at the facility and (ii) to
ensure that the employees's understanding of the applicable safe work
practices and other rules remains current.
(h)(2)(i) Contractors -- Employer responsibilities -- Selecting a
contractor
When selecting a contractor, an employer has to evaluate the potential
contractor's safety performance and programs. Must the employer document
this? If so, to what extent?
The standard does not require the employer to document the
evaluation of the information obtained regarding contractor safety
performance and programs. However, OSHA compliance officers are directed to
review records about these aspects of the selection process and to determine
if the employer has met the intent of this provision. (See Appendix A of
this instruction, page A-25.)
(h)(2)(vi) Contractors -- Employer responsibilities -- Contractor injury and
illness log
What type of injury and illness log does an employer have to maintain
regarding contract employees?
If the contract employer is willing to share the OSHA 200 log and
OSHA 101 first reports of injury (or equivalent) with the employer, and if
those logs and reports specifically indicate which injuries and illnesses are
related to process areas, then such records would be acceptable to OSHA.
Acceptable alternatives would be for the employer to develop a contract
employee injury and illness log separately for each contractor, or a combined
log for all contractors if the combined log distinguishes among
contractors.
(i) Pre-startup safety review
(i)(2)(i) Pre-startup safety review -- equipment in accordance with design
specifications
The employer is responsible for ensuring that process equipment
meets design specifications prior to startup. For equipment that has been
modified to the extent that a change to the process safety information is
required, the employer must ensure that the process safety information has
been modified prior to startup. (Note also the requirements of
1910.119(j)(4)(ii) -- Mechanical integrity -- Inspection and testing.
(j) Mechanical integrity
(j)(1)(i) Application
"Pressure vessels and storage tanks" includes "pressurized"
storage tanks; i.e., tanks designed to be used above atmospheric pressure, as
well as non-pressurized (atmospheric) storage tanks.
(j)(2) Written Procedures
The purpose of this provision is to require written procedures in
adequate detail to ensure that the specific process equipment receives
careful, appropriate, regularly scheduled maintenance to ensure its continued
safe operation. A "breakdown" maintenance program (i.e., a program wherein
action is taken only when something breaks down) does not meet the
requirements of this paragraph.
(j)(2) Written Procedures
Do these written procedures need to be specific to each vessel, each type
of vessel, or each group of equipment types listed?
The procedures need to be specific to the type of vessel or
equipment. Identical or very similar vessels and items of equipment in
similar service need not have individualized maintenance procedures. Each
procedure must clearly identify the equipment to which it applies.
(j)(3) Training for process maintenance activities
As OSHA indicated in the preamble, paragraph (j)(3) requires that
employers provide maintenance employees with "on-going" or "continual"
training adequate "to assure that they can perform their jobs in a safe
manner." (See 57 Fed. Reg. 6390/1.) In this regard, the paragraph clearly
contemplates that new maintenance employees be trained before beginning work
at the site, and all maintenance employees receive additional training
appropriate to their constantly changing job tasks.
Moreover, although "maintenance employees need not be trained in
process operating procedures to the same extent as those employees who are
actually involved in operating the process" (57 Fed. Reg. 6390/1), they must
be trained in all "procedures applicable to the employee's job tasks to
assure that the employee can perform the job tasks in a safe manner." 29
C.F.R. 1910.119(j)(3). Thus, a maintenance worker sent to work on a process
breakdown must be trained in operating procedures that are relevant to the
repair or installation on which he or she is working.
Finally, OSHA intends that employers incorporate all safety-related
topics applicable to maintenance tasks into the ongoing training program
required by paragraph (j) to assure that maintenance employees can perform
their job tasks in a safe manner. Thus, in order to train maintenance
workers in "procedures applicable" to their job tasks under paragraph an
employer must, in appropriate circumstances, train these workers in the safe
work practices required under paragraph (f)(4), in the written procedures to
manage change under paragraph (l), and in the appropriate provisions of the
emergency action plan under paragraph (n) of the standard. These provisions,
in turn, may implicate other OSHA general industry requirements, such as, for
instance, the training requirements of the lockout/tagout standard. (See 29
C.F.R. 1910.147(c)(7).
(j)(5) Equipment deficiencies
If equipment is found to be operating outside acceptable limits, must the
process be shut down and the equipment deficiencies corrected before further
use?
To ensure the ongoing mechanical integrity of the covered process,
equipment deficiencies must be corrected promptly if the equipment is outside
the acceptable limits specified in the process safety information. There may
be situations where it may not be necessary that the deficiencies be
corrected "before further use" as long as the deficiencies are corrected in a
safe and timely manner when necessary means (e.g., protective measures and
continuous monitoring) are taken to ensure safe operation.
NOTE: Operating equipment outside acceptable limits is considered
to be a deficiency.
(j)(6)(ii) Quality assurance
If an installation is being done by contractors, does this require the
employer to implement a quality assurance program to monitor the activities
of these contractors?
The employer is responsible for ensuring that equipment is installed
consistent with design specifications and manufacturer's instructions. This
may require the employer to be involved in the review, inspection,
certification, and quality assurance of work performed by
contractors.
(l) Management of change
(l) Management of change
What does "change" encompass?
Any change whatsoever that may affect a covered process triggers the
management of change provisions. The only exception to this is when there is
a replacement in kind.
Do the management of change procedures apply to items such as gaskets?
Replacements in kind are not covered. If a new gasket is to be
installed that is of different material, composition, shape, size, or design,
then a management of change would be required.
(m) Incident investigation
(m)(5) Addressing team's findings
Paragraph (m) requires that a team of knowledgeable individuals
investigate every catastrophic incident and "near-miss," and likewise
requires that the employer promptly "address and resolve" the team's
recommendations and document corrective action. [See
1910.119(m)(5).]
As with the similar provision in paragraph (e), this provision was
designed to require the employer to respond to the team's findings and
recommendations, while at the same time allowing the employer the flexibility
not only to reject proposals that are erroneous or infeasible, but also to
modify a recommendation that may not be as protective as possible or may be
no more protective than a less complex or expensive measure. (See 57 Fed.
Reg. 6395/3.)
OSHA considers an employer to have "resolved" the team's findings
and recommendations when the employer either has adopted the recommendations,
or has justifiably declined to do so. Where a recommendation is rejected,
the employer must communicate this to the team, and expeditiously resolve any
subsequent recommendations of the team.
An employer can justifiably decline to adopt a recommendation where
the employer can document, in writing and based upon adequate evidence, that
one or more of the following conditions is true:
1. The analysis upon which the recommendation is based contains
material factual errors;
2. The recommendation is not necessary to protect the health and
safety of the employer's own employees, or the employees of
contractors;
3. An alternative measure would provide a sufficient level of
protection; or
4. The recommendation is infeasible.
(o) Compliance audits
(o)(1) Compliance audits -- required frequency?
Employers must certify at least every 3 years that they have
evaluated compliance with 1910.119. Under 1910.119(o)(1), employers must
conduct compliance audits in a timely manner to meet this certification
requirement. The first certification is required no later than May 26, 1995.
When employers conduct compliance audits and certify compliance with
1910.119 before May 26, 1995, the subsequent certification must be within 3
years from the certification date.
NOTE: It may be necessary for employers to conduct compliance
audits and certify that they have evaluated compliance more frequently than
every 3 years, because of significant or numerous deficiencies disclosed by
the previous audit, or for other reasons.
(o)(4) Documenting actions based on compliance audit findings
The purpose of this paragraph is to ensure that employers determine
an appropriate response to each of the report findings and, if employers
identify a deficiency that needs to be corrected, that they document the
correction of the deficiency. The appropriate response to each of the report
findings must be promptly documented. The correction of any
identified deficiency must be documented as soon as possible after the
corrective action is taken.
Appendix D
References for Compliance with the PSM Standard
1. OSHA Instruction CPL 2.45B, June 15, 1989, the Revised Field Operations
Manual (FOM).
2. OSHA Instruction STP 2.22A, CH-2, January 29, 1990, State Plan Policies
and Procedures Manual.
3. OSHA Instruction ADM 1-1.12B, December 29, 1989, Integrated Management
Information System (IMIS) Forms Manual, Chapter
4. OSHA Instruction CPL 2.94, July 22, 1991, OSHA Response to Significant
Events of Potentially Catastrophic Consequences.
5. "Safety and Health Program Management Guidelines," 1989; U.S.
Department of Labor, Occupational Safety and Health Administration
6. "Safety and Health Guide for the Chemical Industry," 1986, (OSHA 3091);
US.DOL, OSHA.
7. "Review of Emergency Systems," June 1988; U.S.E.P.A., Office of Solid
Waste and Emergency Response, Washington, DC 20480.
8. "Guidelines for Hazard Evaluation Procedures," Center for Chemical
Process Safety of the American Institute of Chemical Engineers; 345 East 47th
Street, New York, NY 10017.
9. "Plant Guidelines for Technical Management of Chemical Process Safety,"
Center for Chemical Process Safety (CCPS) of The American Institute of
Chemical Engineers (AICHE).
10. "Guidelines for Safe Storage and Handling of High Toxic Hazard
Materials," AICHE, CCPS.
11. "Guidelines for Vapor Release Mitigation," AICHE, CCPS.
12. "Process Safety Management (Control of Acute Hazards)," Chemical
Manufacturers Association (CMA).
13. "Evaluating Process Safety in the Chemical Industry," Chemical
Manufacturers Association; 2501 M Street NW, Washington, DC 20037.
14. "Safe Warehousing of Chemicals," Chemical Manufacturers Association.
15. "A Managers Guide to Reducing Human Errors Improving Human Performance
in the Chemical Industry," Chemical Manufacturers Association.
16. "Improving Owner and Contractor Safety Performance," API Recommended
Practice 2220.
17. "Management of Process Hazards," American Petroleum Institute (API)
Recommended Practice 750, First Edition, January 1990; 1220 L Street NW,
Washington, DC 20005.
18. "Sizing, Selection, and Installation of Pressure Relieving Devices,"
Part 1, July 1990, API RP 520.
19. "Guide for Pressure relieving and Depressuring Systems," Nov. 1990, API
RP 521.
20 "Avoiding Environmental Cracking in Amine Units," Aug. 1990, API RP 945.
21. "Pressure Vessel Inspection Code: Inspection, Rating, Repair, and
Alteration," June 1989, API STD 510.
22. "Inspection of Piping, Tubing, Valves, and Fittings," API RP 574.
23. "Prevention of Brittle Fracture of Pressure Vessels," API RP 920.
24. "Accident Investigation * * * A New Approach," 1983, National Safety
Council; 444 North Michigan Avenue, Chicago, IL 60611-3991.
25. "Fire & Explosion Index Hazard Classification Guide," 6th Edition, May
1987, Dow Chemical Company; Midland, Michigan 48674.
26. "Chemical Exposure Index," May 1988, Dow Chemical Co.
27. "Pressure Vessels, Section VIII," The American Society of Mechanical
Engineers (ASME).
28. "Chemical Plant and Petroleum Refinery Piping," ASME B31.3.
29. "Personnel Qualification and Certification in Nondestructive Testing,"
American Society of Nondestructive Testing, Recommended Practice No.
SNT-TC-1A.
30. "Prevention of Furnace Explosions/Implosions in Multiple Burner Boiler
Furnaces," National Fire Protection Association, NFPA 85C.
31. "Purged and Pressurized Enclosures for Electrical Equipment," NFPA 496.
32. "Spacing of Facilities in Outdoor Chemical Plants," Factory Mutual Loss
Prevention Data Sheet, 7-44.
33. "Chemical Process Control and Control Rooms," Factory Mutual Loss
Prevention Data Sheet, 7-45.
34. "National Board Inspection Code, A Manual for Boiler and Pressure
Vessel Inspectors," The National Board of Boiler and Pressure Vessel
Inspectors, 1992.
35. Gideon, James A., and Thomas W. Carmody, "Process Safety Management:
Resources from the American Institute of Chemical Engineers for Use by
Industrial Hygienists," American Industrial Hygiene Association Journal (53),
June 1992.
Additional References on Explosives Manufacture:
36. Institute of Makers of Explosives Safety Library Publications, 1120
19th Street, N.W., Suite 310, Washington, D.C. 20036:
No. 1 Construction Guide for Storage Magazines
No. 2 The American Table of Distances
No. 3 Suggested Code of Regulations for the Manufacture, Transportation, Storage, Sale, Possession, and Use of Explosive Materials
No. 4 "Do's and Don'ts" Instructions and Warnings
No. 12 Glossary of Industry Terms
No. 17 Safety in the Transportation, Storage, Handling and Use of Explosives
No. 20 Safety Guide for the Prevention of Radio Frequency Radiation Hazards in the Use of Electrical Blasting Caps
No. 22 IME Standard for the Safe Transportation of Class C Detonators (Blasting Caps) in a Vehicle with Certain Other Explosives
37. Department of Defense (DOD) Standards:
DOD 5154.45 DOD Ammunition & Explosives Safety Standards
DOD 4145.26M DOD Contractor's Safety Manual for
Ammunition, Explosives and Related Dangerous
Material
38. National Fire Protection Association (NFPA) Codes:
NFPA 495 Code for the Manufacture, Transportation, Storage
and Use of Explosive Materials
NFPA 77 Static Electricity
NFPA 78 Lightning Protection Code
Training Program References:
39. Synthetic Organic Chemical Manufacturers Association (SOCMA) Level I
Chemical Process Operator Certification Training Trainee Manual, May 1990;
NUS Corporation, Fossil and Industrial Training Services Department, 910
Clopper Road, Gaithersburg, MD 20877-0962.
Appendix E
(RESERVED)
[PAGE INTENTIONALLY LEFT BLANK]
Appendix G
Recommended Guidelines for PQV Inspection Preparation (Nonmandatory)
The following guidelines are suggested as background and preparation for a
PQV inspection. These are suggested actions only, and shall in no case take
precedence over the guidance presented elsewhere in this instruction.
AREA OFFICE COORDINATION
Coordination within the Area Office is absolutely essential in the orderly
conduct of a PQV inspection. The Area Director and all those involved in a
PQV inspection must commit the resources with the understanding that the
project is long-term, possibly several weeks or months. It is imperative
that team members complete all outstanding assignments prior to the PQV
inspection. Equally important, team participants should not be directed or
"asked" to do assignments while they are engaged in the PQV inspection. An
obvious exception would be court hearings, over which the Area Office has
little control.
The Area Director should designate a contact person in the Area Office to
coordinate and oversee all aspects of the inspection. The contact person
should be a supervisor, safety or industrial hygiene (IH), who is familiar
with the PQV concept. In addition to providing Area Office coordination, the
contact person would review the entire case file/report. The team leader
would communicate at least weekly with the contact supervisor, who would then
brief the Area Director as appropriate.
INSPECTION TEAM COMPOSITION
By design, a PQV inspection is a large and complex undertaking, to be
accomplished by a select, well-trained team. All members of the team must be
experienced journey or senior level compliance officers who are familiar with
the chemical industry and have taken the appropriate OSHA training. Newer
compliance officers can be utilized in the inspections, but not as a
substitute for regular team members.
The team should consist of two safety compliance officers/engineers, two
industrial hygiene compliance officers, an administrative support person and
a construction specialist. The team leader could be from either discipline in
the team, but preferably a safety specialist, due to the fact that most of
the critical PSM and construction related hazards reside in the area of
safety.
The team leader should be a GS-12 Senior Compliance Officer with experience
in large team inspections. He or she should have excellent organizational
and communication skills, both oral and written. It would also be of benefit
that the team leader be knowledgeable in word processing and data base
management computer operations. Since the team leader will be the focal
point during the conduct of the inspection, that person should also have
demonstrated leadership abilities. The entire team, the company,
employees/unions and other OSHA personnel will look to the team leader for
direction and answers to the many questions that will arise during the course
of the inspection.
The team leader is responsible for the overall conduct of the inspection
including planning, onsite activities and report preparation. The leader
would assign the various inspection areas to team members in accordance with
their expertise and abilities, and determine what, if any, special expertise
is needed. Additional responsibilities include:
1. Keeping the Area Office contact apprised of activities;
2. Providing and tracking requests for documents;
3. Resolving problems with the company;
4. Ensuring that the report addresses all questions in the directive.
An administrative support person would greatly increase the overall
efficiency of the inspection. This position would be ideal for an
accommodated compliance officer with some computer skills and organizational
abilities. The support person would answer directly to the team leader and
would be responsible for organizing, labeling and filing the many documents
that will become part of the case file. An accommodated CSHO could also
review the documents and document requests to assure the request was properly
fulfilled. In addition, an accommodated CSHO could assist the inspecting
team members with the many interviews that will be conducted. The support
person would also be responsible for the inspection supplies and equipment.
Safety and IH team members are responsible for carrying out the PQV
inspection activities under the direction of the team leader. They must keep
the team leader apprised of their activities and potential problems when they
arise. The construction specialist would work for the most part
independently of the rest of the team, under the general direction of the
team leader. Some crossover of inspection areas is to be expected, as many
of the contractors and company responsibilities overlap.
PRE-INSPECTION PREPARATION
Effective planning and preparation is essential to the efficient
implementation and successful completion of any large inspection, especially
a PQV. Exhibit 1 provides an outline that can be used as a guide to plan and
prepare for a PQV inspection. Establishment histories can be obtained and
reviewed well in advance of the target date for the inspection. The
inspection strategy and scheduling should be done after the team has been
selected. A pre-inspection meeting with all members and the Area Office
contact person should be held prior to entry.
The case file begins in the planning and preparation stage. Any documents
received, such as micro to host reports, citations and PSM-related findings
(including PetroSEP) in other regions must be logged and identified to allow
for easy retrieval. An activity log/diary should be started to record all
pertinent actions taken. A computer data base management program is
recommended to keep track of the document requests and to provide a ready
index of the documents that have been obtained. With this type of system it
would be easy to search for pertinent documents by using the OSHA
identification number, topic of document, company identification number, date
of request, etc., and to ensure that various members of the team do not
duplicate requests for documents.
The team should develop a weekly schedule of activities, taking into account
travel days, holidays, start time, stop time, company briefings and internal
briefings. Time should be allotted during the inspection week to complete
necessary paperwork and documentation and tie up loose ends.
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