Book: The OSHA Process Safety Standard: The 30-Year Update

Book Outline

In August 2022 the United States Occupational Safety and Health Administration stated that they intended to update their Process Safety Management standard (29 CFR 1910.119). At a Stakeholder Meeting held in October of that year they listed some of the areas that they would like to update.

The OSHA Process Safety Standard: The 30-Year Update provides detailed information, analysis and discussion to do with these proposed updates.

Ordering Information

The book is priced at $25 (U.S.). It can be ordered here.

Table of Contents

The book has 27 chapters:

Preface
Chapter 1 The Process Safety Management Standard
Chapter 2 Proposed Updates
Chapter 3 Atmospheric Storage Tanks
Chapter 4 Oil and Gas-Well Drilling
Chapter 5 Oil and Gas Production Facilities
Chapter 6 Reactive Chemical Hazards
Chapter 7 Highly Hazardous Chemicals
Chapter 8 Explosives and Blasting Agents
Chapter 9 Clarifying the Scope of the Retail Facilities Exemption
Chapter 10 Defining the Limits of a PSM-Covered Process
Chapter 11 RAGAGEP: Definition and Updates
Chapter 12 Definition of Critical Equipment
Chapter 13 Employee Participation and Stop Work Authority
Chapter 14 Updates to RAGAGEP
Chapter 15 Updating Collected Information
Chapter 16 Formal Resolution of PHA Recommendations
Chapter 17 Safer Technology and Alternatives Analysis
Chapter 18 Natural Disasters and Extreme Temperatures
Chapter 19 Mechanical Integrity of Critical Equipment
Chapter 20 Equipment Deficiencies
Chapter 21 Organizational Changes
Chapter 22 Root Cause Analysis
Chapter 23 Local Emergency Response
Chapter 24 Third-Party Compliance Audits
Chapter 25 Review of PSM Management Systems
Chapter 26 Written PSM Procedures
Chapter 27 Themes
Glossary
Works Cited

Still Performance Based

The OSHA document includes the following statement.

OSHA published the PSM standard, 29 CFR 1910.119, in 1992 in response to several catastrophic chemical-release incidents that occurred worldwide. The PSM standard requires employers to implement safety programs that identify, evaluate, and control highly hazardous chemicals. Unlike some of OSHA’s standards, which prescribe precisely what employers must do to comply, the PSM standard is ‘‘performance-based,’’ and outlines 14 management system elements for controlling highly hazardous chemicals. Under the standard, employers have the flexibility to tailor their PSM programs to the unique conditions at their facilities.

It is encouraging to see that the performance-based philosophy remains. It is less encouraging that they seem to be retaining the rather dated 14-element list.

The Chemical Safety Board

The OSHA Process Safety standard, the EPA Risk Management Program (RMP) and the Chemical Safety Board (CSB) were all authorized under the same legislation.

The CSB investigates actual accidents and has published many detailed reports ― some of which are discussed at this site. The reports provide invaluable lessons learned. However, the CSB cannot issue regulations ― it is confined to asking OSHA and other agencies to do so. (The recent update to process safety standards in the State of Washington is an example, as discussed in our post The Root Cause Conundrum.)

One of the reasons for OSHA’s update to the PSM standard is to respond to the findings and recommendations of the CSB.