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.
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.
Not a lightweight program, the fines for non-compliance are not insignificant either. Fines for individual workers may be as high as $250,000; for companies, $500,000 dollars. Although it may seem like actual release and outright injuries account for most or all the fines, not meeting necessary paperwork can also result in heavy regulatory penalties. Civil lawsuits and/or criminal liability may also come into play with violators.
Making PSM Work
Faced with a potentially catastrophic anhydrous ammonia incident, what’s the best way for a regulated company in the food industry to get the edge? The solution is three-part and comes under the heading of Risk Mitigation.
One, a specialist is worth his/her weight in gold. At most companies, people with specific skillsets are hired for positions fitting that expertise. Some positions, however, are considered fair game for a “Jack of all trades, master of none.” If a company has an individual filling its PSM coordinator position, it is usually the generalist. Unfortunately, experience has shown that PSM’s wide-ranging complexity and scope cannot be met with minimum resources or personnel wearing multiple hats.
The solution, even if it stretches the company budget, is hiring a PSM coordinator who is preferably an engineer with a minimum five years’ experience in the company’s industry and, ideally, with regulatory management experience. Bringing that type of experienced individual onboard will pay dividends in the savings recognized from avoiding potential penalties and fines. If hiring in this job area is not familiar to HR, work with the department and/or recruiters to develop a staffing plan for a coordinator and, optimally, a team.
Two, companies in the food industry should develop a budget that does not cut so close that it barely covers what must be done. Before anyone envisions a gloomy projection, however, OSHA does not see excessive spending as necessary. In a company’s initial five years of regulatory compliance, OSHA’s estimate is that worst case—not typical, but worst—budgeting would be 1.1 percent for large companies and 3.2 percent for small companies. When preparing the budget, imagine that this money will have a real, everyday impact on workplace safety.
Three, above all, arrive at a solution that addresses all the company’s requirements in a cost-effective way that works with the budget to accomplish compliance initiatives. Within this solution or plan is an emphasis on project management rather than dollars and cents to avoid penalties and ensure a safe workplace.
PSM is a real challenge but, when done right, it keeps a company at peace with regulators and reduces or eliminates workplace incidents, such as with anhydrous ammonia.
Steffens is process safety manager at Houston-based ACS Engineering. Reach him at firstname.lastname@example.org.