Questions and Answers from PSM Webinar Sept. 29, 2015. Answers provided by Jeff Wanko, PE, CSP, and Safety Engineer in OSHA’s Directorate of Enforcement, Office of Chemical Process Safety in Washington, D.C.
Q. Do you have to test the safety equipment annually?
A. Under paragraph (j), mechanical integrity, OSHA requires that employers inspect and test process equipment in accordance with manufacturer’s recommendations or good engineering practices. OSHA does not require specific testing frequencies.
Q. A company that has multiple NH3 facilities/sites would be required to submit a PSM per site?
A. OSHA does not have a submittal requirement. Facilities do not submit PSM programs or documentation to OSHA.
Q. Do you have to be specially qualified to do PHAs? ie: do you need to be trained in PHA?
A. The process hazard analysis paragraph, (e), requires that one member of the PHA team be knowledgeable in the PHA methodology used.
Q. As you talked about pressure vessels, can a rail car be used as perm. storage tanks?
A. It depends. Most importantly, an employer would need the process safety information for the railcar including codes and standards to which the railcar was designed, relief calculations, materials of construction, etc. and ensure that it is appropriate for the service.
Q. Could you comment on RAGAGEP, P&ID, and equipment tagging?
A. The process safety information paragraph requires that employers develop piping and instrumentation diagrams and process flow diagrams. While OSHA does not have a requirement for a specific style of P&ID or flow diagram, it expects drawings to be accurate and reflect the current equipment and piping arrangement in the field.
There is no equipment tagging requirement in PSM. However, if an employer chooses the ANSI marking standard, OSHA expects the employer to follow it. In addition, equipment likely requires some marking to clearly and unambiguously match the instructions in the operating procedures.
RAGAGEP, recognized and generally accepted good engineering practice,
Q. Under mechanical integrity element of PSM – what are OSHA’s expectations for the retailer to show storage tanks and piping for these systems are safe? Are there any specific tests?
A. First, the process safety information for the equipment in the process should show that equipment is designed and installed in accordance with recognized and generally accepted good engineering practice (RAGAGEP) and the employer shall document that the equipment in the process meets the chosen RAGAGEP.
Second, the employer shall ensure the integrity of the equipment in the process. That means that the employer performs the inspections, tests, and other maintenance necessary to ensure the equipment performs its function(s). The inspections and tests shall be based on RAGAGEP or manufacturer’s recommendations. The frequency of said inspections and the test must also follow RAGAGEP or manufacturer’s recommendations.
OSHA does not prescribe any specific tests or inspections or respective frequencies. OSHA would look to RAGAGEP or manufacturer information.
Q. Would building a process according to state requirements instead of CGA requirements be acceptable?
A. Possibly. In its process safety information, the employer must document the design codes and standards employed for the process equipment and the employer must document that the process equipment complies with those design codes and standards. If a state publishes design codes or standards for an ammonia distribution facility, OSHA could look to it as RAGAGEP.
However, in our experience, states do not independently develop design codes and standards, but rather adopt standards and codes developed by code development organizations such as the National Fire Protection Association, American Society of Mechanical Engineers, International Code Council, Compressed Gas Association, etc.
Q. Can we get a fill in a blank program?
A. A fill-in-the-blank PSM program does not exist. PSM, as described in the webinar, is a living safety management system. However, Asmark is developing an easy to follow web-based program, that appears to give employers model programs customizable for a specific facility.
Q. What is the CFR reference for PSM?
A. 29 CFR 1910.119
Q. These changes will need to be completed January 1, 2016, correct?
A. Six months from issuance of the memorandum – January 22, 2016.
Q. Was there ever a meeting between ARA and OSHA as requested in a letter to Jordan Barab sent 9/8/15?
A. OSHA met with ARA, TFI, National Grain, and Feed Association, and many other agricultural industry groups on July 31, 2015.
Q. Based on the PSM changes we will need to update RMP to Level 3, correct?
A. Yes. OSHA and EPA speak regularly to discuss the specifics of EPA’s plan of action. Expect the EPA to make an announcement in the near future.
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