In OSHA’s opinion, the analysis or evaluation i.e., PHA, is best accomplished by a team rather than an individual. The team should be knowledgeable not only in engineering but also in specific process operations, and one team member should have direct knowledge of each process being evaluated. Through a system, the findings and recommendations should be addressed in a timely manner, and corrective actions should be completed as soon as possible and communicated to possibly affected employees. To stay current, the PHA should be re-evaluated every five years.
In the final phase of this PSM overview, the major target must be addressed: operating procedures of each covered facility (primarily anhydrous ammonia in the food industry). Eschewing bureaucratic language, OSHA states that “clear instructions” must be provided to workers that allow them to safely operate each covered process. These operating procedures safety mandates are in two categories: operating phase steps and operating limits. With injuries and possible fatalities at stake, much more than “Here’s the on/off switch” qualifies as need-to-know information. Instructions in each operating phase, for example, include initial startup, normal operations, emergency shutdown/operations, normal shutdown, and start-up after a turnaround or emergency shutdown.
On the operating limits side of process safety information are a number of critical factors, which were developed to essentially cover all safety angles. These include describing what could happen with operational deviations and how to correct or avoid any and all safety and health issues; relevant chemical properties and hazards; necessary precautions and control measures; controlling HHC inventory levels and addressing any special or unique hazards; and discussing the safety systems and the function of each.
Beware of Incidents and Audits
Without drilling down into every single detail about PSM and its implementation, this overview (not intended as legal advice) shows the scope of what must be done (along with the “where, how, and why”). Leaving virtually nothing to chance, success depends on employee participation, training, contractor cooperation, pre-startup safety review, mechanical integrity of critical process equipment, management of change, incident investigation, emergency planning and response, and compliance audits.
In the daily workplace, what is the anhydrous ammonia risk? Consider OSHA’s tally of anhydrous ammonia accidents dating back to 1999 and the initial reported exposure to an ammonia release. That was followed by 19 incidents in subsequent years ranging from exposures and various injuries to fatalities. Included are incidents of inhalation, spray in eyes, a 16-employee exposure to an ammonia release, two refrigeration technicians sustaining corneal burns, and a total of four workers killed in separate incidents. Those statistics make two points: regulation is necessary and even with regulation, incidents can still occur, making adherence to procedures that much more critical.
In helping ensure that PSM compliance works as effectively as possible, it is important to recognize that regulatory programs such as PSM revolve around resources, time, and money. By reducing an emphasis on any of these three, not surprisingly, the risk of causing a catastrophic release or being on the receiving end of a regulatory penalty is dramatically compounded. Additionally, to drive home how critically OSHA considers PSM, the agency does not provide partial credit for companies achieving incremental success. In other words, 100 percent compliance from day one is required.
Keep in mind that making compliance simple was not on OSHA’s agenda. To underscore its stance, take note that a PSM safety auditor can ask a company more than 500 questions and can potentially issue that many citations for compliance performance. Increasing the difficulty, sometimes a question may comprise “nested” questions requiring multiple questions to be answered in order to satisfy one regulation. Companies may be audited at any time and OSHA selects the questions. Although it could theoretically ask all 500 plus questions, that typically is not the case but full compliance is still necessary.