Chemical safety and process safety continue to garner significant media attention around the United States as chemical and process safety events continue to occur. OSHA's Process Safety Management (PSM) standard and EPA's Risk Management Program (RMP) standard provide a framework for preventing unwanted release of highly hazardous chemicals. It is also important to note that these are performance standards, meaning that regulated processes are told what the goal (unwanted release) is, not how to meet it. OSHA began a PSM National Emphasis Program (NEP) for Petroleum Refineries in June of 2007 and later implemented an additional PSM National Emphasis Program for Chemical Facilities in November of 2011. Enforcement data shows key trends and areas where both EPA and OSHA focus their efforts. This paper will review the key enforcement trends for PSM and RMP regulated processes, provide some best practices for ensuring process safety is a way of life, and review actual and potential regulatory activity resulting from Executive Order 13650 Improving Chemical Facility Safety and Security.
February 26, 2014 – XXXXXXXX
(Includes specific PSM standards cited ≥: 100 times by both Federal and State-Plan)
Table 1 – Citations Sorted by Frequency
Table 2 – Citations Sorted by PSM Element
(February 26, 2014 - XXXXXXXXXX)1
Total Number of PSM Inspections2…………………………………………….…3,721
Total Number of Violations………………………………………………………..20,100
Total Initial Penalty……………………………………………………………$93 Million
Total Number of CHEM NEP Inspection (Opened Nov. 2011 to 2/26/14)….………890
Total Number of Refinery NEP Inspections (opened as of 4/4/2013)……..…………74
Top Three (3) Best Practices
Permit to Work System for Contractors
Car Seal Program
MOC for Personnel Changes
Contractors tend to have a safety disadvantage due to their ever changing working environment. One week they are working in ABC Chemical Plant and the next they are working in XYZ Chemical Plant. Both of these plants have different safety and emergency response procedures with different phone numbers, different evacuation areas, different alarms, and much more. Even within the same facility, different units will have different alarms, different chemical hazards, different PPE requirements, and numerous other safe work practices. This is a lot to keep straight from plant to plant and unit to unit on a DAILY basis. Keeping in mind that almost all businesses train their contractors on an annual basis. A Contractor Work Permit provides a DAILY REFRESHER training for these workers as well as provides a HAZARD ASSESSMENT based on the current working conditions and the work the contractor will be conducting. Like other permit processes the daily Contractor Work Permit must be kept at the site of the work being performed. This permit reviews required safety equipment, emergency procedures, other required permits, and safe work practices such as lockout. The work permit process also fulfills the safe work practices of controlling the entrance, presence and exit of contract employers and contract employees in covered process areas. (1910.119(h)(2)(iv)
