When you think about chemical safety and compliance, the first standard that comes to mind might be the hazard communication standard. However, there are a lot of standards that apply to hazardous chemical safety. Yesterday, we looked at two employers that failed to comply with Hazardous Waste Operations and Emergency Response, personal protective equipment, and chemical-specific standards.
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Today we’ll look at a third employer and yet another chemical safety standard: the process safety management (PSM) standard.
Plastics Engineering Company: Failing at Chemical Process Safety
The Occupational Safety and Health Administration (OSHA) inspected Plastics Engineering Company in Sheboygan, Wisconsin, as part of its national emphasis program for PSM. As a result of the inspection, Plastics Engineering Company was cited for one willful, five serious, and one other-than-serious safety violation, carrying $82,000 in proposed penalties.
The federal agency cited the company for:
- Not certifying that PSM procedures had been evaluated every 3 years. Operating procedures for multiple job tasks and situations were more than 3 years out of date; its most recent management audit was dated 2010.
- Failing to consider the impact of equipment and operation changes on safety and health. The employer had prepared management of change procedures for multiple process changes, but those procedures were not reviewed by the safety and health department; did not address potential safety and health impacts of the change; and did not include the expected duration or date of completion for the change operation.
- Not ensuring process safety information was current and accurate. The employer’s piping and instrument diagrams (P&ID) were not up to date. OSHA identified 21 instances where PSM-covered systems were not documented on the company’s P&ID; 10 instances in which equipment that was documented on the P&ID was not actually installed; and 10 instances where equipment found on the P&ID was installed in a different location than shown, or was improperly identified on the P&ID.
- Failing to address incident report findings. Two different formalin leaks at the facility had generated incident reports, but neither incident investigation included recommendations for corrective action. In addition, the incident reports were not reviewed with all affected personnel.
- Having an inadequate emergency action plan. The emergency action plan failed to distinguish between small and large spills and did not include procedures for small releases.
- Failing to document in its process safety information the design codes and standards it employed. This enables OSHA to evaluate compliance based on the specific design code or standard used, but the employer neglected to include this information.
The takeaway for employers? PSM is a detailed rule, with many requirements that apply to each individual piece of equipment or process. Don’t shortcut your PSM compliance, or you’ll have to pay for your noncompliance!
Need more advice on PSM compliance? Safety.BLR.com® will give you all the details you need.