OSHA in the Process of Inspecting Process Safety Management

Failure to comply with process safety management requirements can lead to catastrophic incidents in which employees are injured or killed, the public is threatened, facilities are damaged, and OSHA is on your case.

Since last summer, facilities where accidental release of highly hazardous chemicals could result in toxic discharges, fires, or explosions have been the focus of a 1-year pilot National Emphasis Program (NEP). Known as the Chemical NEP, this program involves policies and procedures for inspecting workplaces covered by OSHA’s Process Safety Management (PSM) Standard (29 CFR 1910.119).

The inspection process required by the NEP includes asking detailed questions designed to gather facts related to PSM requirements and verifying that employers’ written and implemented PSM programs are consistent.

Under Chemical NEP, quick inspections have been conducted at a large number of facilities. Facilities have been randomly selected from a list of worksites likely to have highly hazardous chemicals in amounts at or greater than the threshold quantities listed in the PSM standard.

The Chemical NEP has been piloted in several regions using programmed inspections (i.e. those that don’t result from an accident, complaint, or referral). In regions not covered by the NEP, inspectors have been sent into workplaces in response to PSM-related complaints, referrals, accidents, or catastrophes.

OSHA says that the NEP was initiated because of a number of catastrophic incidents in recent years resulting in loss of workers’ lives that were caused by failure to comply with the requirements of the PSM standard. The NEP was designed to allow OSHA inspectors to verify that employers are complying with the requirements of the PSM standard.

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Case in Point

Here’s an example of the kind of accident the Chemical NEP inspection program is trying to prevent.

The incident occurred in Glendale, Arizona, at DPC Enterprises, where over 1,900 pounds of chlorine where accidentally released from the facility. Chlorine is one of the highly hazardous chemicals listed in Appendix A of the PSM Standard.

On the day of the accident, excess chlorine vented to a scrubber where it completely depleted the active scrubbing material (caustic soda), overchlorinating the scrubber. The resulting decomposition reaction vented chlorine vapors to the atmosphere. Hazardous emissions continued for about     6 hours and led to the medical evaluation of 5 residents and 11 police officers, and the evacuation of 1.5 square miles of Glendale and Phoenix.

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One of the root causes of the incident was that DPC’s single administrative safeguard, an operating procedure, did not adequately address the risk of overchlorinating the scrubber.

The Chemical Safety Board’s lead investigator said: "It is necessary to integrate appropriate layers of protection into all processes handling hazardous chemicals. In this case, we recommended that DPC adopt safety features such as additional interlocks, automatic shutdowns, and mitigation measures to prevent the release of chlorine to the atmosphere due to overchlorination."

CSB had investigated an incident a few years before at a DPC facility in Festus, Missouri, that led to the release of 48,000 pounds of chlorine, causing 3 workers and 63 residents to seek medical treatment.

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