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.