Since its inception, the U.S. government’s Occupational Safety & Health Administration (OSHA) has been concerned with regulating food industry safety from many different directions. However, it was only in the 1990s that the federal agency brought its regulatory powers down hard in a new area: Process Safety Management (PSM). In turn, PSM’s impact continues to resonate throughout wide-ranging industry sectors, with food and beverage being no exception.
Shifting Gears in Safety Focus
OSHA’s creation and implementation of PSM was a bold move in a new direction. Not targeting the processing, distribution, or retail sales of food and the risks involved with these different stages, PSM charted its own course. It is all about the use, storage, manufacturing, or handling of highly hazardous chemicals (HHCs). And OSHA drew an important distinction in not addressing low-chemical exposure.
What triggered this sudden attention to HHCs? As is often the case, disasters make more of a statement than numerous proposals, speeches, and lobbying combined. In a relatively short time period, there were several chemical explosions that resulted in death and injury. Union Carbide’s 1984 methylisocyanate gas leak, which killed approximately 2,000 people in Bhopal, India, was the most notable. Because of this and other U.S. incidents, OSHA has vowed to never let these kinds of chemical accidents happen again, at least in its national jurisdiction.
Getting Down to Business with PSM
PSM’s goal is to prevent the release of toxic, reactive, flammable, or explosive chemicals. HHCs represent the potential for a catastrophic event at or above the threshold quantity (TQ). In the food and beverage industry, the chemical of overriding importance is anhydrous ammonia, with a 10,000-pound TQ as being a “covered facility” under PSM regulations. However, walking a somewhat fine line, OSHA’s enforcement policy is to not cite companies for violations if stored flammable liquids in atmospheric tanks are connected to a process. That is, unless the process outside of the storage amount contains more than 10,000 pounds of the substance.
PSM actions begin with compiling broad-based safety information; this process must precede the launch of the critical process hazard analysis (PHA). The purpose of PSM is to advise in advance, in a threefold approach, both employer and employees who operate the process about potential HHCs involved. One is specific hazards with mandatory information required ranging from toxicity to physical data to chemical stability data.
Two is the process technology, with required information including flow diagram, maximum intended inventory, and consequences of deviations. Three is about the process equipment, which requires more information than the first two above. Detailed descriptions must be provided on construction materials, electrical classification, ventilation system design, design codes as well as safety systems. Further, virtually every equipment characteristic must be documented, assuring it was designed and constructed to code and documenting that it is regularly maintained, tested, and operated safely.
With the properly compiled safety information in hand, the important PHA is next. It mandates a careful review of what could possibly go wrong and, after identifying those, companies must develop safeguards that can be implemented to effectively prevent the release of HHCs. As could be expected, there is not a unique PSM procedure to follow for anhydrous ammonia in the food industry while specifying other separate procedures for each industry and type of business. With PSMs, “one size fits all” actually applies in terms of what must be done for regulatory compliance.
In the overall PSM procedural marathon not only must hazard identification be made and safeguards instituted but companies must also prepare written procedures, train employees, conduct safety reviews, evaluate critical equipment, and develop procedures for management of change. At the outset, however, the PHA must address process hazards, identify previous incidents with catastrophic potential and acceptable detection methods, and determine the possible outcome when engineering and administrative controls fail, where facility is located, human factors, and qualitative evaluation of possible workplace effects if controls do fail.