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Construction sites can contain a surprising assortment of dangerous chemicals, from fuels and solvents to the explosives used in largescale demolition. OSHA created a standard specifically to help construction companies and other employers prevent accidents in processes involving these volatile substances, and the agency holds those employers responsible for following its recommendations.

OSHA keeps a close watch on chemicals safety in the energy and petrochemical industry, but its standard, Process Safety Management of Highly Hazardous Chemicals, applies to a much wider swath of industries. Any firm handling 10,000 pounds or more of a flammable liquid or gas, or using threshold amounts of any of the more than 130 reactive and toxic chemicals listed in an appendix to the rule, must comply with its detailed provisions. There are some exceptions, including retail stores and unoccupied, remote facilities, which are not required to follow process safety management.

Unfortunately, too many businesses neglect to follow established guidance in processes involving dangerous substances. Employers that fail to adopt rigorous compliance programs in this area are at heightened risk not only of incurring citations and fines, but of accidents that can result in injuries and death, typically coupled with long-term damage to their brands and businesses.

Minimize the risk of these needless and costly outcomes by establishing and enforcing a process safety management program. OSHA spells out 14 essential elements for compliance, from safety standards to training and best practices. Third-party service providers can assist employers that lack the internal resources to institute and consistently follow a PSM initiative.

This article looks at the 14 components that every PSM program must address for compliance with the federal standard and discusses some practical points to make implementation easier over the long term.

OSHA's 14 PSM Essentials

1. Employee Participation. All on-site workers, employees and contractors must understand the PSM program, work requirements and environment related to dangerous chemicals used there. Keep them informed through PSM meetings.

2. Process Safety Information. Create a library of information about the risks and safety precautions for working with hazardous materials and make sure all workers understand and can access it.

3. Process Hazard Analysis. Identify processes posing the greatest risks to employees. Use “what if” scenarios, checklists methods, hazard and operability studies, and failure modes. Repeat this analysis every five years. 

4. Operating Procedures. Document every procedure, along with how to maintain safety during startup, normal operations, temporary operations, emergency shutdowns and when starting back up.

5.  PSM Training. Establish or outsource a program to train employees in how to work with hazardous materials and how the organization will document that training.

6. Contractor Training. Every worker including contractors must know the risks and protocols for hazardous materials, so include them in training and documentation.

7. Pre-Startup Safety Review. Any facility changes affecting a PSM-regulated process require a safety procedure review.

8. Mechanical Integrity. Periodically inspect pressure vessels, storage tanks, piping systems, ventilation systems and any other major equipment.

9. Hot Work Permits. Issue hot work permits for anyone who welds, grinds metal or performs other high-temperature work. Train them to post and file their permits.

10. Management of Change Process. With any change to procedures related to chemicals, technology and/or equipment, address the technical basis for the change, health and safety considerations, necessary operational changes, duration of the change and any authorization required.

11. Incident Investigation/Accident Investigation. Investigate any incident resulting in a catastrophic release of hazardous materials to determine root causes and provide recommendations for resolution.

12. Emergency Planning and Emergency Response. Establish procedures for mitigating chemical releases.

13. Safety Compliance Audits. Require workers handling hazardous materials to recertify their credentials every three years. Retain the two most recent compliance audit reports.

14. Trade Secret Protection. Every worker has a right to know the hazardous processes occurring in the workplace, even those involving trade secrets.

PSM Outsourcing

An effective PSM program that is compliant with OSHA requirements is necessary to protect employees, contractors and any visitors to a construction company's building sites, storage yards and other facilities. Yet the wide scope of working parts described in the federal PSM rule can be daunting, even for large firms with administrative staff able to take on the challenge of setting up and running a program. In practice, some construction firms focus on process safety just long enough to complete employee training and documentation each year and then slacken compliance until they repeat the process the next year, letting safety suffer in the interim and exposing their organizations to increased liability for accidents.

Technology and services can ease the employer's burden in every aspect of an OSHA-compliant PSM program. Software platforms simplify and automate much of the administrative tasks, while outsourced training providers enable even small firms to access industry-leading instructors and teaching systems. Some providers can integrate an employer's own site-specific training or orientation material into a larger curriculum. Established providers can also meet an employer's need for training certification, tracking and badging, so workers can prove their qualifications at the jobsite.

Service providers can take the onerous administrative and training aspects of PSM off of a contractor's plate, leaving the employer to focus on operations. But whether outsourced or handled entirely in-house, process safety management is well worth the effort required to maintain compliance.

Construction companies that follow OSHA's guidance in the handling of volatile chemicals enable employees to perform their jobs free of fear or uncertainty about the safety of processes they use. Those employers enjoy the peace of mind that comes with a defensible PSM program, one that minimizes the organization's exposure to fines and penalties while establishing a safer workplace for employees and contractors.


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