Process Safety Management

Process Safety Management is a regulation, promulgated by the U.S. Occupational Safety and Health Administration OSHA, intended to prevent an incident like the 1984 Bhopal Disaster. A process is any activity or combination of activities including any use, storage, manufacturing, handling or the on-site movement of Highly Hazardous Chemicals (HHC's). A process includes any group of vessels which are interconnected or separate and contain HHC's which could be involved in a potential release. A process safety incident is the "Unexpected release of toxic, reactive, or flammable liquids and gases in processes involving highly hazardous chemicals. Incidents continue to occur in various industries that use highly hazardous chemicals which exhibit toxic, reactive, flammable, or even explosive properties, or may exhibit a combination of these properties. Regardless of the industry that uses these highly hazardous chemicals, there is a potential for an accidental release any time they are not properly controlled. This, in turn, creates the possibility of disaster. To help assure safe and healthy workplaces, OSHA has issued the Process Safety Management of Highly Hazardous Chemicals regulation (Title 29 of CFR Section 1910.119) which contains requirements for the management of hazards associated with processes using highly hazardous chemicals."

A great many industrial facilities must comply with OSHA's Process Safety Management (PSM) regulations as well as the quite similar EPA Risk Management Program (RMP) regulations (Title 40 CFR Part 68). The EPA has published a model RMP plan for an ammonia refrigeration facility which provides excellent guidance on how to comply with either OSHA's PSM regulations or the EPA's RMP regulations.

The Center for Chemical Process Safety (CCPS) of the American Institute of Chemical Engineers (AIChE) has published a widely used book that explains various methods for identifying hazards in industrial facilities and quantifying their potential severity. Appendix D of the OSHA's PSM regulations endorses the use of the methods explained in that book.

CLARIFICATIONS AND INTERPRETATIONS OF THE PSM STANDARD CPL 2-2.45A APPENDIX B

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.