A chemical manufacturer has been cited by OSHA for 15 serious violations of the process safety management standard. The August 2013 inspection was initiated under OSHA’s Process Safety Management Covered Chemical Facilities National Emphasis Program. The company faces $73,500 in proposed penalties for exposing workers to hazardous chemical risks. The majority of violations relate to potential hazards at this company’s facility stemming from the use of liquefied petroleum gases, fluorocarbons and dimethyl ether. The serious violations include the company’s failure to:
PLEASE NOTE: these citations are NOT the final settlement and some are BEFORE the employer’s informal conference. They are shared as a learning tool to show what types of issues OSHA and EPA are finding in their PSM/RMP inspections. I have scrubbed all company information from these postings as this is NOT about any one company, but rather a trend of issues that continue to be found by OSHA and EPA.
- Develop and implement written procedures for mechanical integrity and operating procedures to conduct activities in each covered process safely.
- Complete a thorough process hazard analysis and emergency action plan.
- Document that equipment met good engineering practice.
- Follow good engineering practices when performing inspections and testing equipment.
- Complete an adequate compliance audit.
- Conduct inspections and tests on equipment.
- Annually certify that operating procedures were current and accurate.
- Establish and implement a system to address previous hazard analysis findings promptly.
- Address the impact of changes to processes, equipment, and/or personnel that are related to working conditions covered by the process safety management standard.
- Complete accurate piping and instrument diagrams.
- Include relief system design and design basis in information pertaining to the equipment.