On December 14, 2023, OSHA published its revised Compliance Directive for Process Safety Management standard 1910.119, effective January 26, 2024. This new version is in Q7A format and was done nicely, although there are a number of things in the answers that I am sure will be challenged. I have highlighted some of the interesting (albeit I believe the correct answer).
For example, QA-31 deals with the use of Hydrogen in Forklift fueling systems (a popular climate change move for clean energy). The question is:
Does hydrogen used as a fuel for powered industrial trucks qualify for the hydrocarbon fuels exemption?
The answer may surprise some folks… Hydrogen is NOT a hydrocarbon and therefore is NOT eligible for the “fuel exemption”.
BTW, H2 weighs 0.6 pounds per gallon, so a process holding 16,666 gallons of Cryogenic H2 would be a PSM-covered process.
And the BIGGEST SHOCK AWARD goes to QA-37 regarding flammable liquids in atmospheric storage tanks! The question is:
Are flammable liquids which are kept below their normal boiling point without benefit of chilling or refrigeration that are stored in or transferred to atmospheric tanks counted toward the 10,000 pounds TQ for a flammable liquid?
No. Flammable liquids which are stored in or transferred to atmospheric tanks are not used to determine if a process contains a TQ of a flammable liquid. However, if a process other than storage or transfer is occurring, the flammable liquids would not be exempt from counting towards the TQ.
Runner-Up for “Knock my Socks off” question goes to QA-39, regarding N2 blanketing over 0.5 psig:
Does storing a flammable liquid under a dry nitrogen pressure of 8-10 psig negate the atmospheric storage exemption?
Yes. Tanks containing flammable liquids that operate at pressures exceeding 0.5 psig are not atmospheric tanks by the definition of atmospheric tank in the PSM. Therefore, the storage of the TQ of flammable liquids above 0.5 psig is a PSM-covered process.
Also, in this newest revision, OSHA cancels the OSHA Instruction CPL 02-02-045A (REVISED) and provides enforcement policy concerning applying occupational safety and health standards in facilities with PSM-covered processes. Significant modifications in this instruction include:
- Removal of the Appendix A PQV Audit Checklist in the OSHA Instruction CPL 02-02-045A (REVISED)
- Incorporation of existing OSHA PSM enforcement policies into a question-and-answer format
PSM Questions and Responses
OSHA promulgated the PSM standard in 1992 in response to the numerous catastrophic chemical manufacturing incidents that occurred worldwide. These incidents stimulated broad recognition that handling highly hazardous chemicals (HHC), flammables, and explosives could lead to incidents that may occur infrequently but, due to their catastrophic nature, often result in multiple injuries and fatalities. Since the promulgation of the standard, numerous questions have been submitted and compliance guidance provided to industry on the application of the standard.
Below is a compilation of questions, references to applicable Letters of Interpretation (LoIs) or standard interpretations addressing the question, and current OSHA compliance guidance. The below is formatted as a question and response, with some questions having a scenario preceding it to provide context for the question and response.