As with any safety effort, there are varying degrees of what all of us would consider being compliant vs. world-class safety. When we enter the PSM/RMP realm, this line gets even blurrier since these are “performance-oriented” standards. But a PSM/RMP audit SHOULD be much more than looking at just 1910.119 and Part 68! There are dozens of other OSHA standards with a DIRECT link to 1910.119 or an association with PSM/RMP that should be included in all PSM/RMP 3-year audits. Here they are and how they are connected/associated with process safety…
1910.24 – Fixed industrial stairs – yes, OSHA cites this standard in some refrigeration processes. Basically, anytime a worker has to travel to an upper or lower area at least once per shift, the standard requires that “stairs” be provided. In the refrigeration industry we have seen an effort to move evaporator piping and valves to the roof so as to limit the risk they will be struck by forklifts; however, when this is done PROPER access to the roof needs to be provided. And ladders are NOT acceptable for daily access. See my previous article about this concern and egress requirements from a rooftop.
1910.36 – Design and construction requirements for exit routes AND 1910.37 – Maintenance, safeguards, and operational features for exit routes – these two standards are, in my opinion, an ABSOLUTE CRITICAL path the process safety. We often find PSM areas that have no EXIT signs, evac plans posted, no functioning emergency lighting, etc. An outdoor process with many levels and catwalks NEEDS to meet these egress requirements! Just because it is outside does not exempt the process area from complying with these basic requirements. Let’s not forget our contractors, who may not know the process area, as well as our operators, and they will NEED GUIDANCE to exit the process area safely. CLICK HERE to see my detailed breakdown of these requirements.
1910.38 – Emergency action plans – this should be self-explanatory as 1910.119(n) directly ties .38 to ALL PSM facilities. In fact, it is a good idea for everyone to have an EAP; however, did you know that OSHA has only seven (7) standards that actually REQUIRE an EAP? They are 1. Process Safety Management of Highly Hazardous Chemicals – 1910.119, 2. Fixed Extinguishing Systems, General – 1910.160, 3. Fire Detection Systems, 1910.164, 4. Grain Handling – 1910.272, 5. Ethylene Oxide – 1910.1047, 6. Methylenedianiline – 1910.1050, 7. 1,3-Butadiene – 1910.1051. Don’t believe me, CLICK HERE to see it directly from OSHA (Section VIII). As I said I think every workplace should have an EAP, but strictly speaking, only, those that fall under any of the seven listed standards must have one. The EAP MUST contain six (6) bits of information in order to comply:
- Escape procedures and emergency escape route assignments (e.g., how do workers get to their assembly areas – we can NOT have them traveling through covered processes!!)
- Procedures to be followed by employees who remain to operate critical plant operations before they evacuate (e.g., those operators who stay behind and shelter in place to execute emergency shutdown procedures)
- Procedures to account for all employees after emergency evacuation has been completed (includes visitors, contractors, truck drivers, etc.)
- Rescue and medical duties for those employees who are to perform them (e.g., 1st Aid Teams)
- Means of reporting fires and other emergencies (e.g., how do workers/contractors report emergencies, phone, pull stations, radios, etc.)
- Names or job titles of persons who can be contacted for further information or explanation of duties under the plan.
1910.106 – Flammable liquids – Now, this one could be a stretch. Still, when we come to a facility that has a flammable process, and they have not chosen a “code or standard” for their flammable process, we use applicable sections 1910.106 as our baseline. The same concept goes with 1910.110 – Storage and handling of liquefied petroleum gasses and 1910.111 – Storage and handling of anhydrous ammonia.
1910.120 – Hazardous waste operations and emergency response – NO PSM/RMP audit would be complete without establishing compliance with 1910.120(q) for those facilities that have an organized response team for releases/spills of their HHC/EHS. This part of the audit will easily take 3/4 to a full day of auditing as there is just a lot of items to review and verify.
1910.132 – General requirements and all the associated PPE-specific standards (.133, .135, .136, etc.) – We get a lot of pushback in our auditing that there is no connection between PSM/RMP and 1910.132, and it surprises us. 1910.132(d) is the basis for ALL PPE used in the workplace. It requires the employer
to assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the employer shall…
One of the PSM Operating procedure requirements is:
1910.119(f)(1)(iii)(B) Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment;
If PPE is listed in a SOP or Maintenance procedure, we need to have the supporting documentation as to how that level of PPE was determined and who certified it. We tie this back to the PPE Hazard Assessment (or Safe Work Permitting if PPE is prescribed in the permitting process).
1910.134 – Respiratory Protection – although this standard is lumped in with the other PPE standards, it is a MAJOR standard to audit, and it touches many aspects of PSM/RMP work. Operators and Maintenance personnel are often times required to wear respirators during their normal duties. If the facility has a Fire Brigade, HAZMAT team, or PRCS Rescue team, this standard has a direct link to the facility’s PSM/RMP and emergency response programs. We must be sampling annual medical evals, annual fit testing records, annual training records, facial hair issues, etc.
1910.146 – Permit-required confined spaces – DIRECT link to 1910.119(f)(4), as OSHA specifically calls out LOTO, PRCS, Process Opening, and Control over the entrance to a covered process. If we can audit an actual entry taking place this is a MAJOR PLUS for the audit; if not, we settle for reviewing closed permits from the past year and interviews. We also look at the PRCS rescue element VERY CLOSELY in our audits as this area continues to cause major issues and places a lot of workers at HIGH RISK.
1910.147 – The control of hazardous energy (lockout/tag out) – DIRECT link to 1910.119(f)(4), as OSHA specifically calls out LOTO, PRCS, Process Opening, and Control over the entrance to a covered process. We will audit the overall written program, machine-specific procedures associated with PSM/RMP covered process equipment, training from authorized and affected employees who may gain access to the PSM/RMP battery limits, annual “periodic inspections”, and contractor’s role within the LOTO program/procedures. It matters NOT to us that the facility has had a safety audit before our PSM/RMP audit, as we feel that LOTO in a PSM/RMP process can be QUITE DIFFERENT than in other parts of the facility. Oftentimes, the PSM area is the only area that utilizes group lockout due to the nature of the isolations and the fact that multiple contractors may be associated.
1910.151 – Medical services and first aid – this is applicable to those facilities that have 1st aid teams (which also pulls in 1910.1030) as well as the requirement for Eyewash/Safety Showers in process areas. This can be directly tied back to the process SOPs that include:
1910.119(f)(1)(iii)(C) Control measures to be taken if physical contact or airborne exposure occurs
Almost every MSDS and SOP we see calls for the use of an EW/SS.
1910.156 – Fire brigades – ONLY when the facility has the fire brigade.
1910.157 – Portable fire extinguishers – If the facility has trained employees to use and permits employees to use fire extinguishers on incipient stage fires then this standard is applicable. We look to make sure the CORRECT TYPE of extinguisher is provided and that the travel DISTANCE is proper. Even for those facilities that PROHIBIT their use and instead evac all workers from their areas, 1910.157 will STILL HAVE A ROLE in HOTWORK/Firewatchers, so be careful claiming 1910.157 will never have a role in a PSM/RMP facility. I would also like to point out that if your process is a flammable process and fire extinguishers are listed as a safeguard in the PHA(s), AND the facility utilizes a “contractor” for the inspection and maintenance of said fire extinguishers (portable and wheeled) then that “contractor” has become a “PSM contractor” and needs to meet all of the contractor safety elements of PSM/RMP.
1910.158 – Standpipe and hose systems and 1910.159 – Automatic sprinkler systems – as applicable. If the facility lists these devices as safeguards in their PHA(s) they have linked them to their PSM/RMP programs, and these standards would apply to those applicable systems.
1910.160 – Fixed extinguishing systems, general, 1910.161 – Fixed extinguishing systems, dry chemical, 1910.162 – Fixed extinguishing systems, gaseous agent, and 1910.163 – Fixed extinguishing systems, water spray, and foam, 1910.164 – Fire detection systems – as applicable to the covered process(s). Officially, OSHA cannot use these, as many of these are applicable ONLY when other OSHA standards require them. But when a facility claims them in a PHA, and they have not adopted a proper RAGAGEP for their installation and maintenance, we will use these OSHA standards as a baseline for compliance.
1910.165 – Employee alarm systems – this has a direct link to 1910.38, which has a direct link to 1910.119(n). ALL process areas with a PSM/RMP covered process MUST have some type of alarm system in place. Now granted I have seen OSHA accept the most basic and crazy “alarm system”, but the facility has to prove to OSHA/EPA that it is “effective”. .165 also gets into using phone numbers to report emergencies, then these numbers have to be posted throughout the facility. It also specifies the testing frequencies for the type of alarm systems used.
1910.169 – Air receivers – Admittedly, this is a HUGE stretch. Still, when we come across an air receiver that is sitting right next to a covered vessel or in the middle of the process, we will certainly make sure it is being managed per 1910.169, as this vessel (when not installed, operated, and maintained properly) could be a ticking time bomb in the middle of your covered process. We do not seek out air receivers that are OUTSIDE the covered process… UNLESS compressed air is being utilized as a “critical utility” and thus pulling in the compressed air system into the PSM/RMP Programs. CLICK HERE to read my thoughts on “Critical utilities and plant air.”
1910.178 – Powered industrial trucks – typically, we will not dive into this standard UNLESS we see something that raises a concern, such as incident reports where PITs are striking PSM/RMP covered equipment, we observe an UNSAFE use of a PIT while executing a PSM/RMP related task, or we see a NON-APPROVED PIT in a HAZLOC within the covered process. This last one, using the wrong PIT in a HAZLOC, is usually what causes us to pull .178 into the audit; however, we have seen PSM/RMP tasks being carried out using a PIT that was modified and using a homemade boom extension that caused us to pull .178 into the audit.
1910.179 – Overhead and gantry cranes, 1910.180 – Crawler locomotive and truck cranes, and 1910.184 – Slings – We will audit against these standards when we see their applicability to the covered process(s). For example, if cranes are used to handle 1-ton Chlorine cylinders or they are set up for construction/maintenance tasks in such a way that their collapse could impact the covered process, then we would expect to see compliance with these baseline standards. We also find a lot of nylon slings and chain link slings used by maintenance personnel in their daily duties, and still today, there continue to be issues with 1910.184 compliance!
1910.252 – General requirements – Section (a) of this standard has a direct link back to 1910.119(k)(2). If observed within the covered process or workers using these techniques on covered process components, we will also audit using 1910.253 – Oxygen-fuel gas welding and cutting, 1910.254 – Arc welding and cutting, and 1910.255 – Resistance welding.
1910 Subpart S – Electrical, but more specifically 1910.307 – Hazardous (classified) locations – This has a direct link back to
1910.119(d)(3)(i)(C) Electrical classification
If the facility claims to have HAZLOCs, then we use 1910.307 to show they are maintaining their equipment as CLASS I, II, or III compliant. Also, since 2007, a new process with HAZLOCs MUST DOCUMENT these locations. CLICK HERE to read my update on this change. PLEASE do not confuse this will applying API 500 or NFPA 497/70 to the covered process(s). These codes are tools meant to aid the employer in determining they have a HAZLOC and how it should be classified. 1910.307 is the OSHA minimum for the equipment that will be used in these HAZLOCs. We typically will NOT audit 1910.332, .333, .335 during a PSM/RMP audit even though we may see IMPROPER electrical practices. We will DISCUSS our concerns and point out ALL unsafe acts/conditions we see, but these requirements are just TOO LARGE to pile on during a PSM/RMP audit and deserve a solid review all in itself.
1910.1030 – Bloodborne pathogens – as stated above, ONLY when the facility has a designated 1st aid team that has responsibilities of treating injured personnel.
1910.1200 – Hazard Communication – direct link back to
1910.119(d)(1) Information pertaining to the hazards of the highly hazardous chemicals in the process
1910.119(d)(2)(i)(E) An evaluation of the consequences of deviations, including those affecting the safety and health of employees
1910.119(f)(1)(iii)(B) Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment
1910.119(f)(1)(iii)(C) Control measures to be taken if physical contact or airborne exposure occurs
We also use .1200 for process vessel and piping labeling when the facility has not adopted a RAGAGEP of their own for this labeling.
1910.1201 – Retention of DOT markings, placards, and labels – How many of you have ever even read this standard or seen OSHA where OSHA issued a citation against it? It is rare, but it does have applicability to PSM/RMP covered processes that receive/ship their HHC/EHS. The standard is short and sweet so I will paste it below for all to see how it has a place in a PSM/RMP audit…
1910.1201(a) Any employer who receives a package of hazardous material which is required to be marked, labeled or placarded in accordance with the U. S. Department of Transportation’s Hazardous Materials Regulations (49 CFR Parts 171 through 180) shall retain those markings, labels and placards on the package until the packaging is sufficiently cleaned of residue and purged of vapors to remove any potential hazards.
1910.1201(b) Any employer who receives a freight container, rail freight car, motor vehicle, or transport vehicle that is required to be marked or placarded in accordance with the Hazardous Materials Regulations shall retain those markings and placards on the freight container, rail freight car, motor vehicle or transport vehicle until the hazardous materials which require the marking or placarding are sufficiently removed to prevent any potential hazards.
1910.1201(c) Markings, placards and labels shall be maintained in a manner that ensures that they are readily visible.
1910.1201(d) For non-bulk packages which will not be reshipped, the provisions of this section are met if a label or other acceptable marking is affixed in accordance with the Hazard Communication Standard (29 CFR 1910.1200).
1910.1201(e) For the purposes of this section, the term “hazardous material” and any other terms not defined in this section have the same definition as in the Hazardous Materials Regulations (49 CFR Parts 171 through 180).
I have a problem coming across at least a dozen occasions where facilities were running using an RCar or TTruck as their storage tank, and when they would swap cars/trucks, they were NOT meeting these requirements. Something to consider, especially from an emergency response perspective! A so-called “empty” railcar full of flammable vapors is in some ways MORE DANGEROUS than a full car of flammable liquid!
So there is SAFTENG.net’s PSM/RMP framework, outside of OSHA’s PSM CPL and EPA’s Program Audit Checklist, for our official 3-year PSM/RMP audits. Yes, it is a lot, and yes, the size of the process does NOT necessarily reduce our time constraints in auditing; the larger the process, the larger our sample sizes. We feel for a management group to get an accurate assessment of how well they are managing their risk, they must get this full picture, and the only way to do this honestly is for the PSM/RMP auditors to cover these areas of compliance. We do not believe that an S&H audit team NOT familiar with PSM/RMP requirements should have the sole responsibility of auditing some of these programs as they have a different meaning in a PSM/RMP covered process. Although OSHA would most likely accept a “piecing” of different audits by different auditors at different times and with different skill sets, we think management gets a much clearer picture when done by the same auditors, at the same time, with the proper skill sets. Of course, there is ABSOLUTELY nothing wrong with OVERLAPPING these areas during PSM/RMP and S&H Audit protocols. We are usually given only one week or less to cover all of these areas, and we may likely miss one or two items (no one is perfect!), so having a different set of eyes review this material during another audit is NOTHING BUT GOOD! We feel it is our RESPONSIBILITY as safety professionals to ensure they are covered during our PSM/RMP audits regardless of what other auditing has taken place or is scheduled to take place.