Over the years we have seen a very large movement to skinny down PSM/RMP operating procedures. At first glance this movement makes a lot of sense; but with any great idea comes pitfalls and it is the pitfalls that I would like to discuss in this posting. Recently we came across the end results of this movement gone awry… an SOP that had been annually certified but yet contained not one piece of the required data – EVERYTHING was either referenced or linked to other documents. I mean even the tasks listing in how to carry out the procedure referenced the JSA that had been done for the job. An SOP that would have been 10 or so pages was a single sided 8.5X11″ piece of paper. And they did this to the vast majority of their procedures. So of course the facility defends their position saying that it is a “common practice” in industry to do this referencing and therefore was a “generally accepted practice” – yes they even created a new term for it! So rather than argue the fundamentals I began to test the references and links and as I expected there were serious problems. From broken links – to out of date data, they ended up with well over 100 deficiencies with their SOPs and that was just me spending 3 hours reviewing their SOPs; imagine what I could have found had I had six months to do the inspection. Here are a few things to consider when referencing or linking other documents to the SOPs in order to meet the content requirements of 1910.119(d) and (f)…
1) without a doubt the most popular data to “reference” in an SOP is the MSDS. However, I caution everyone that OSHA is not so dumb when it comes to the quality of many MSDS’s. Hence why their statement in 1910.119 is worded as such…
Note: Material Safety Data Sheets meeting the requirements of 29 CFR 1910.1200(g) may be used to comply with this requirement to the extent they contain the information required by this subparagraph.
Notice the wording “meeting the requirements of 29 CFR 1910.1200(g)“. Any safety professional will tell you one of the most basic safety documents found in every workplace in the USA are typically not worth the paper they are written on. I am holding out a lot of hope that in 2015 the new Safety Data Sheets that everyone is converting over to will be worth something! With that said, merely referencing an MSDS that does NOT meet 1910.1200(g) requirements will merely open the doors for the CSHO to begin to dig into your MSDSs and their accuracy.
- a.One of my favorites to take issue with is1910.119(d)(1)(ii) Permissible Exposure Limits (PEL). All PELs are based on an 8-hour Time Weighted Average (TWA) and these are clearly stated on most MSDS; however, their is one small problem for many facilities… they work 12-hour shifts, not 8-hour shifts. So I merely ask the operators and mechanics what the chemical(s) PEL for their exposure is and without hesitation they recite what the MSDS states. Do you think there is an issue here? You better bet your !@#$ this a problem! So if your workers are on 12-hr shifts and unless your MSDS does the 8 to 12 hour conversion for you and list the 12-hr TWA on the MSDS then the data on the MSDS is NOT accurate data! Some may call this picky, but folks this is a FACT and any safety professional or IH professional who knows why the sky looks blue can vouch for this – they may not like it or agree with my position, but they can not dispute this fact.
- b.1910.119(d)(1)(v) CorrosivityIn most cases this is like taking candy from a baby! For those of you outside the USA, that is just a saying we use – I do not take candy from babies! What this means is that we can randomly select 100 MSDSs from a facility’s inventory and how many do you think will contain this data? Maybe, on a good day, we find one (1) MSDS that states what type of materials of construction should be used or what materials should be avoided. There are some that would like to argue that “Corrosivity data” is nothing more than stating the pH of the material. They would be wrong; the pH of the material is a “physical property” of the material and is found in the “physical properties” section of the MSDS. Go check it out if you don’t believe me.
- c.1910.119(d)(1)(vii) Hazardous effects of inadvertent mixing of different materials that could foreseeablyHas anyone ever seen this on an MSDS? Keep in mind this is DIFFERENT than the requirement of1910.119(d)(1)(vi) Thermal and chemical stability data. The “Hazardous effects of inadvertent mixing” is routinely on MSDSs for acids and bases and sometimes can be found on MSDS for flammable liquids; however, from a pure process safety position this requirement goes much further than any MSDS I know of can provide. For example, at my last plant I managed we had some really exotic reactions. Some were so weird that the reaction was based on mass and temperature. You can take the two chemicals and mix them at room temperature inside a 55-gallon drum and nothing would happen. Mix several hundred gallons at room temperature and you have a bomb or mix them at an elevated temperature and you get the same results. We even had issues if you put in Chemical A before Chemical B, and Chemical C had to “rest” for 10 minutes before Chemical D could be added. I will not attempt to argue the phrase “could foreseeably occur”, but anyone taking this as a defensible position will struggle to win if the materials are handled in the same process area by the same operators! And the PHA for those processes are LONG and DETAILED, but well worth the effort.
2) 1910.119(f)(1)(iii) Safety and health considerations
FIRST off I want point out that there is NO “Note” in this section that permits the use of an MSDS that complies with 1910.1200(g). That “Note” ONLY applies to 1910.119(d)(1). With that said, this section, .119(f)(1)(iii), is the second most popular section to be referenced or linked.
- 1.1910.119(f)(1)(iii)(A) Properties of, and hazards presented by, the chemicals used in theThis is not so much an issue with referencing and linking, but more so of just LACK OF DATA and really goes back to the “heart and soul” of the requirement for “Hazardous effects of inadvertent mixing of different materials that could foreseeably occur”. Many of us have seen the effects of a mechanic using some type of lube or putty in an effort to fix something and because the materials were not compatible the workers made matters MUCH WORSE. The phrase “the chemicals used in the process” is all the chemicals used in the process, including maintenance materials, utilities (such as steam, nitrogen, etc.). This requirement mistakenly gets applied only to the HHC/EHS that makes the process covered under PSM/RMP and this would be a mistake.
- 2.1910.119(f)(1)(iii)(B) Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protectiveYes some MSDSs contain this information, but how many companies are actually wearing all the prescribed PPE listed on the MSDS? Now granted this should have all been resolved when the facility conducted their PPE Hazard Assessments required by 1910.132(d), yet we still come across many businesses that have yet to conduct formal “ppe hazard assessments”. This is an easy one to find deficiencies in, as when the MSDS calls for a respirator and the facility claims they have no respirator program and no exposures that require respirators, just point to the MSDS. See the MSDS provider is doing what I like to call “CYA”… covering your ass”ets” and they put on their MSDS that a respirator is needed and all we have done is link to or reference said MSDS we have dug our own grave. This is not based on any exposure assessment, it is just a CYA statement by the manufacturer; however, when the MSDS is blanket referenced to cover all the bases and the MSDS states a respirator is required AND the employees are NOT wearing respirators when handling this chemical then the facility is NOT following its referenced document.
- 3.1910.119(f)(1)(iii)(C) Control measures to be taken if physical contact or airborne exposureI will give credit where credit is due and from my experiences with MSDS, most do a good job at providing this instruction; however, I will state this word of caution: If you have some exotic chemicals that require specialized treatment in a timely manner, it is the employers responsibility, NOT the local fire or EMS groups, to ensure the employee receives the medical care he/she needs within 3-5 minutes. Chemicals like Hydroflouric Acid have some very specific care instructions and unless you work in an area where HF is a widely used chemical your FD and EMS groups will be poorly prepared for treating an exposure to this chemical. So although the MSDS has the instructions, we still may need to have on hand the supplies referenced, as the FD/EMS, and quite possibly the hospital, may have no idea on what is needed.
So those are some potential conflicts with the content requirements; now lets refresh our memories from an article I wrote several years back for the newsletter talking about going “electronic” with all our documents. FIRST and foremost ALWAYS have a hard copy back-up on site and ACCESSIBLE to operators. In the early days we were all worried about loosing power so everyone got uninteruptable power supplies (UPS) for their computers; but then one day we lost our fiber opitics (still had power) and thus no access to SOP or PSI. OSHA has stated that if everything is electronic, they will expect personnel to know how to log in, search and find the data in a TIMELY MANNER. I have been burned countless times because the empoyee(s) have not logged in for three months and hence their password(s) expired and thus they could not access the system. I have been burned with IT updates that moved the content from the local server to a corporate server across the country! Sure IT told us this was going to happen but they said it would be seamless and once the move was done everything would return to normal; of course IT did not know that the EHS and Operations groups had over 10,000 active links to data else where on the server! And of course this occurs the week before the 5-year VPP refresher assessment. This may sound crazy, but I quickly learned that my IT group needed to be involved with my MOC program and trained in the procedure. They were not happy about it, but it was the only way to ensure changes were not made to the document management system that broke links to critical data.
So I hope this has sparked some thoughts as you read through this and maybe some of these scenarios hit right at home, either way I hope you feel the time you spent reading my thoughts has been worth it. I do not expect everyone to agree or like what I have to say, but I do hope others can learn from my mistakes before they find themselves in a major bind.