UPDATED 4/19/2017 – OSHA has published the approved edition https://www.osha.gov/Publications/OSHA3908.pdf
OSHA has published a DRAFT revision of their OSHA 3132, Process Safety Management. This new version is NOT meant to be a replacement for OSHA 3132, but instead meant to be a companion to the original OSHA 3132 specifically for small businesses that may be impacted by the PSM standard. The booklet calls attention to five (5) of the fourteen PSM elements that may have the most impact on small businesses and their process risks…
- Process Safety Information (PSI)
- Process Hazards Analysis (PHA)
- Training
- Mechanical Integrity (MI)
- Audits
I have read this document and I love that OSHA has offered some guidance on how to STAY OUT OF PSM! Yes, you heard that correct, I favor companies that have NO experience in managing hazardous process to use inventory control methods to stay BELOW the PSM thresholds. This is in NO WAY saying companies should cheat, but rather REDUCE their inventories so that they ELIMINATE the catastrophic risk(s) by limiting the amount of the HHC available. OSHA has also FINALLY explained how a business can SEGREGATE their storage of their HHC(s) such that a SINGLE EVENT will NOT impact more than the PSM Threshold. This means we can actually allow a facility to have MORE THAN the PSM Threshold, but by using its storage/management practices they are not covered by the PSM as they do NOT have more than the PSM threshold within a single “process”. On the other hand, OSHA also points out, and rightfully so, that merely staying below the PSM threshold does NOT absolve the employer of any safety obligations in handling their highly hazardous chemicals SAFELY. See more of this discussion on page 3-4.
Here is the DRAFT for your review. OSHA is accepting comments on this document