Envirosure regularly assists in the development of OSHA Process Safety Management (PSM) and EPA Risk Management Programs (RMP)
OSHA’s PSM program is designed to protect the worker in facilities that use hazardous chemicals. EPA’s RMP program is designed to protect the environment and the surrounding community from hazardous chemicals.
OSHA and EPA have defined and listed hazardous and extremely hazardous chemicals that, in the event of accidental release, could cause death, injury or serious health effects. These lists contain threshold values for each chemical with specific requirements dependant upon amount of chemical on site. For anhydrous ammonia (R-717), the most commonly used industrial refrigerant, the threshold value is 10,000 pounds, and a PSM program as defined by OSHA Standard 29CFR 1910.119 is required. (Some local officials have adopted parts of 1910.119 for anyfacility using anhydrous ammonia regardless of system charge.)
PSM Program Required Elements Include:
Process Safety Information
Material Safety Data Sheets (MSDSs) may be used to comply with this requirement to the extent they contain the required information, and information on equipment, piping and instrument diagrams (P&IDs), materials of construction, electrical classification, relief system design and design basis, ventilation system design, codes and standards employed, material and energy balances, and safety systems.
A written plan of action about how employees will participate.
Process Hazard Analysis (PHA)
An organized and systematic effort to identify any potential hazards associated with an operation. PHA’s must be updated and revalidated at least every 5 years.
To include: initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, startup after an emergency shutdown.
Records showing the identity of the person trained, the training date, and determining that the person understood the training. PSM also calls for refresher training at least every three years and requires written documentation of training.
OSHA requires a review of a contractor’s training procedures and review of safety records.
Pre-Startup Safety Review
Ensure, before any startup, that appropriate safety, operating, maintenance, and emergency procedures are in place.
Requirement to have written procedures to ensure the integrity of the process systems, new and old.
A permit system in place for all hot work operations.
Management of Change
A written program in place to ensure that any modification made to a process system is performed in a safe manner.
Incident investigation is the process of identifying the underlying causes of accidents or near misses and setting in place procedures to prevent similar accidents. Need to ensure that the incident investigation procedures tie into EPA’s five year accident history.
Must certify that compliance with OSHA’s PSM and the U.S. EPA’s RMP program is evaluated at least every three years.
Emergency Preparedness – Emergency Planning and Response
Develop and implement an emergency action plan.
It should be noted that regardless of the amount or type of chemicals in any facility, EPA Clean Air Act Section 112(r) contains a General Duty Clause (GDC) which in part states “…the owners and operators of stationary sources producing, processing, handling, or storing such substances have a general duty… to identify hazards which may result from such releases using appropriate hazard assessment techniques to design and maintain a safe facility… ”
PSM – Envirosure has developed PSM programs for major cold storage, food processing, and food distribution facilities employing ammonia as a refrigerant.
Our activities, tailored to the needs of each facility include:
- Process Safety Information
- Process Hazard Analysis
- SOP Development
- Mechanical Integrity
- Compliance Audits
- Emergency Action Plans
For information on a complete PSM program, or for assistance with any of the required PSM elements, give us a call at 480-784-4621. We welcome the opportunity to discuss your requirements.