OSHA’s Process Safety Management regulation, also known as PSM, sets specific requirements for employers who use highly hazardous chemicals at the workplace.
And because these highly hazardous chemicals can lead to catastrophic events, OSHA takes the PSM regulation very seriously. Part of that seriousness includes rigorous PSM inspections at work areas covered by the PSM regulation.
Not so long ago, we sat in on a conference presentation about PSM inspections from Brandi Davis of Oregon OSHA. Ms. Davis is a Senior Health Compliance Officer (and Industrial Hygienist) with Oregon OSHA who performs PSM inspections and she’s been kind enough to talk with us about what to expect during an OSHA PSM inspection. So if you’re curious about this, go right ahead and read the rest of the article.
Also, please know we’ve included a free PSM compliance checklist for you at the bottom of this article in addition to the tips from the OSHA PSM inspector.
With a quick additional thank you to Brandi Davis and Oregon OSHA, let’s get right to the questions about PSM and PSM inspections by an OSHA inspector.
Brandi Davis: Let me give a technical answer first. PSM is Process Safety Management. It is a management system based on 13 elements that are designed to identify, evaluate, eliminate or manage the inherent risks of processes containing highly hazardous chemicals. Process Safety Management is a regulation found in Oregon OSHA’s rules under 1910.119. Employers are required to comply with Process Safety Management if they have quantities of highly hazardous chemicals in excess of the threshold quantities listed in the 1910.119 regulation.
Now let me give a non-technical answer. Process Safety Management is a management system designed to understand the limits and weaknesses of a process. These processes have sufficient quantities of highly hazardous chemicals on site that a release could seriously impact the employees and the surrounding community. The purpose of the PSM management system is to ensure that the chemical tiger does not get out of the cage.
Brandi Davis: The history to PSM is a long one that is paved with numerous chemical catastrophes throughout the world. In general, most would agree that the birth of the process safety movement came after the 1984 Bhopal India Union Carbide event that released methylisocyanate and killed over 3000 people. A. few years later Union Carbide had another leak at a different facility that resulted in the deaths of over 100 people.. These fatal events triggered a heightened level of awareness to the hazards these processes pose to employees. In July of 1990, Federal OSHA proposed the PSM regulation and then after extensive public hearings and debate the PSM standard became effective in 1992.
Brandi Davis: I can only provide insight from Oregon OSHA operations. There is no specific answer to this question. In general Oregon OSHA sets annual goals for the number of PSM inspections to complete. Typically, this goal has been about 10 Process Safety Management inspections a year. There are four ways Oregon OSHA will enter into a facility in order to perform a Process Safety Management inspection. The first, is a PSM program planned (pro-active) inspection. This is where the employer number was selected from a randomized list of facilities with known quantities of a covered chemical on site. Second, is a complaint filed against an employer regarding some aspects of their PSM program. Third, is an accident at a facility with a covered process. The fourth is a referral from another agency or internally from a different compliance officer (without the expertise in PSM) that has identified some concern or hazard related to the PSM covered process.
It is possible for a facility to undergo more than one PSM inspection in a short period of time. This is unusual, but possible. For example, Oregon OSHA received a complaint regarding a covered process and conducts an inspection to evaluate those complaint items. Then 6 months later a release at the facility results in the hospitalization of an employee, and Oregon OSHA conducts another PSM related inspection to evaluate the conditions that lead to the release.
Brandi Davis: This is difficult to answer. I will provide you with some general observations, but this is not to be taken as any absolute. Each PSM inspection is unique and the information can take the inspection in several different directions. But here are some things to consider:
Brandi Davis: This is from my point of view as a compliance officer – looking from the outside in.
Brandi Davis: The simple answer is that a citation is issued to the facility. Let me explain this response. It is rare that a problem at a PSM facility is a simple isolated event that does not impact or is not connected to another one of the 13 elements of the PSM program. Oregon OSHA’s perspective on “problems” at a PSM facility is that they generally are considered serious in nature, when you realize that the highly hazardous chemical can be impacted because of the “problem.”
Brandi Davis: Oregon OSHA offers every employer in the State of Oregon access to our consultative services. A facility can request an evaluation of their PSM program by a trained consultant without fear of receiving citations for their deficiencies.
Here are some other helpful resources:
Brandi Davis: Utilize a variety of the resources listed above to develop, implement and maintain your PSM program. Trying to piece together a PSM program without the needed information or expertise is often a fruitless process.
Brandi Davis: Most of these facilities are well educated about the PSM regulation and have implemented a PSM program at their facilities. My thoughts for them or recommendations for this industry – fight complacency. In addition, I would recommend these facilities adopt a combustible dust program into their PSM programs.
We hope that answered all or at least many of your questions about OSHA PSM inspections. Let us know if you’ve still got any questions.
You might also find these other PSM-related articles interesting:
To help you prepare for those inspections, and to provide PSM training at your workplace, you may be interested in our online Process Safety Management (PSM) training video. We’ve included a short sample immediately below.
And hey, don’t forget to download the free PSM compliance checklist below!
Here is a checklist to help your process safety management compliance.