You are the safety professional at a food processing plant. Your primary safety concerns, perhaps, are hand safety, preventing slips and falls, machine guarding and ergonomics.
How much of your time do you spend thinking about the ammonia refrigerant system used at your facility? If you're like many safety professionals, that system does not fall high on your list of priorities, because it is not part of your primary business: processing food. But it does fall under OSHA's process safety standard, and even if you don't think about it much, any OSHA inspector who shows up at your door will have something to say about it.
That was the message sent to attendees at the American Society of Safety Engineers (ASSE) professional development conference, held this week in Nashville, by David Einolf, CHMM, ARM, director of industrial compliance, URS Corp., Portland, Or.
"Process safety management (PSM) is a known commodity to every chemical industry employee," said Einolf. "But how many employees at Wal-Mart distribution centers, and there are 19 of them, know about process safety?"
Employers outside of the chemical industry that must implement PSM face unique challenges, said Einolf. Unlike at chemical companies, hazards are not always visible; management buy-in for PSM is sometimes a difficult sell; process safety is often part of a peripheral process; and employee education and training is lacking.
He cautioned safety professionals who have a PSM program at their facilities to involve employees in developing a process hazard analysis (PHA) and to offer them education about the hazards that are part of the processes at their facilities.
"The listed hazard is either nearly invisible to employees or minimized at the point of use," said Einolf of non-chemical facilities. He said he couldn't tell audience members the number of times he visited facilities that should be practicing PSM and was unable to find an employee who's done anything with PHA. "The chance of you surviving an OSHA citation without employee participation in PHA is next to nothing," he said.
Involve employees in determining the risks at your facility, and communicate information about hazards and emergency response to them. "Often, members of [an emergency response] team have not been provided with proper training," said Einolf. "In some cases, they don't even know they're on the team."
Should an incident occur, even one that does not lead to a release, make sure an incident investigation is started within 48 hours, counseled Einolf, and determine if the incident "could possibly have led to a catastrophic release," as is required by the process safety management standard.
"As somebody who has spent hours with OSHA inspectors who picked apart maintenance logs for a piece of machinery and said, 'On this day, on this machine, you had a leak but didn't do an incident investigation,' you don't want to go through that," said Einolf.