Is Your Process Safety a 'Paper Tiger'?

Make sure your company's process safety management program is not just on paper, but is being used, OSHA official tells NSC Congress attendees.

When the Occupational Safety and Health Administration (OSHA) came out with its process safety management (PSM) standard in 1992, the agency basically told companies to "tell us what you're going to do, and OSHA will hold you to it."

The PSM standard (29 CFR 1910.119) is a performance-based, comprehensive management rule that varies from specification standards, which tell employers exactly what to do, George Yokas, area director of the Milwaukee OSHA office, said Oct. 20 at the 87th annual National Safety Council Congress & Expo in New Orleans. Yokas is process safety management coordinator for OSHA Region 5.

With this standard, OSHA told employers to "be safe, don't blow up your plant, and don't have a toxic release or a chemical reaction," he said. "But don't promise me a Cadillac (program) if you're going to deliver a subcompact car."

Because employers better do what they say they are going to do in their process safety management plan, Yokas said, they need to make sure a good program is not poorly implemented. "If you're not going to use it, it's not worth the paper it's written on," he said.

The purpose of 29 CFR 1910.119 is to prevent or minimize consequences of catastrophic releases of toxic or explosive chemicals. The standard not only applies to the chemical industry, but other industries that handle chemicals covered in the regulation.

From the standard's inception, in May 1992, through September 1999, OSHA has had 1,247 inspections, 6,637 proposed citations and $20 million in proposed penalties. The most violations (1,186) involved operating procedures.

Part 119(f) of the standard, which deals with operating procedures, requires that these procedures must be developed and implemented, with clear instructions at the task level. Otherwise, Yokas said, it's on paper, but has not been put into practice. Operating phases covered by the standard include initial startup; normal, temporary and emergency operations; emergency shutdowns; and startups and shutdowns.

Another factor to keep in mind when implementing process safety management is the Environmental Protection Agency's (EPA) risk management plan (RMP), which became effective in June 1999. "They look an awful lot alike," Yokas said of PSM and RMP. "Unfortunately, there are covered chemicals that don't match each list" when comparing the two rules.

OSHA is working with EPA on making the lists more comparable, Yokas said.

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