Of the 14 elements which make up OSHA standard 1910.119, there are four which most refineries, chemical facilities, and petrochemical facilities can get citations from OSHA.
In today’s article, we’re going to explore what those elements are, why companies have findings for them, and how ETA can help ensure that you don’t have violations in the future.
Let’s dive in.
1) Operating Procedures
OSHA Number: OSHA Standard 1910.119(f)
How OSHA Defines It: “The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements.”
Why Violations Occur with This Element: Here are some real-life examples of why companies received citations for this element in the past few years.
- An employer’s written operating procedures did not address emergency shutdowns.
- One company did not certify annually that their operating procedures were accurate and current.
- Another facility did not provide their employees with written operating procedures which provided clear instructions that addressed elements like temporary operations, operating limits, emergency operations, and consequences of deviations.
2) Process Hazard Analysis (PHA)
OSHA Number: OSHA Standard 1910.119(e)
How OSHA Defines It: “The employer shall perform an initial process hazard analysis (hazard evaluation) on processes covered by this standard. The process hazard analysis shall be appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process.”
Why Violations Occur with This Element: Here are some real-life examples of why companies received citations for this element in the past few years.
- One facility’s use of the What-if methodology did not completely evaluate the hazards of the process being analyzed.
- Another employer did not complete a finding to address the toxic gas hazard from an uncontrolled release and dispersion identified in a previous study.
- One company received a serious violation for not performing an initial process hazard analysis for their chlorine process.
3) Mechanical Integrity
OSHA Number: OSHA Standard 1910.119(j)
How OSHA Defines It: This relates to all aspects of process equipment in a facility, from written procedures to training for process maintenance activities, inspection and testing, quality assurance, and corrections to equipment deficiencies.
Why Violations Occur with This Element: Here are some real-life examples of why companies received citations for this element in the past few years.
- One facility did not perform inspection and tests on process equipment in their propane container filling and evaluation areas.
- Another employer did not develop and implement a written integrity procedure for evaluating valves in the chlorine process.
- One facility didn’t develop and implement a written mechanical integrity procedure that addressed inspective pressure vessels and piping for minimum wall thickness.
4) Management of Change
OSHA Number: OSHA Standard 1910.119(l)
How OSHA Defines It: “The employer shall establish and implement written procedures to manage changes (except for ‘replacements in kind’) to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.”
Why Violations Occur with This Element: Here are some real-life examples of why companies received citations for this element in the past few years.
- An employer did not ensure that written procedures were established and implemented for the installation of a larger container filling station.
- Another facility did not establish procedures to address all process changes, and as a result, modifications affecting the covered process could not be completed without proper analysis and assessment.
How ETA Can Help
Through our PSM consulting services, we work with all of your staff to ensure that they are trained in the basics of PSM and the specifics of their role in implementing a PSM program.
Our goal is that every employee will fully understand the hazards involved in their industries and their specific role in eliminating and/or minimizing those hazards.
Most findings are uncovered during PSM audits. During this time, we turn these finds over to our clients so they can identify ways to prevent these findings from turning into citations.
We can work with your staff to develop programs to address potential issues and establish procedures for best practices within your facility.
But there’s more. In addition to PSM audits, we also can work with you for your PHAs and help you identify all potential hazards by using the HAZOP method to ensure that this element is fully addressed per OSHA standards.
Contact ETA today to prevent future violations and ensure that you do not have citations for these four – or any – PSM elements.