Process safety management

OSHA announced this week a shift in how it will evaluate inspections, recognizing that inspections are not all equal and that more-complex inspections deserve more weight. The complexity of an inspection affects the amount of time, manpower and other resources required by OSHA and this new tiered inspection system will reflect this complexity. Under the

OSHA issues new guidance to Regional Administrators and State Plan Designees on the enforcement of the Process Safety Management (PSM) standard’s recognized and generally accepted good engineering practices (RAGAGEP) requirements. The new guidance clarifies OSHA’s positions with respect to enforcing the PSM standards that reference or imply the use of RAGAGEP. The memorandum provides the most detailed information on how OSHA will handle PSM inspections with respect to the RAGAGEP requirements and it includes 16 detailed enforcement considerations that inspectors will evaluate when reviewing an employer’s compliance. The memorandum also provides specific guidance on when citations may be issued.

Employers covered under 29 C.F.R. § 1910.119 should carefully review their compliance with the following standards in light of this new guidance and OSHA’s renewed focus on the proper application of RAGAGEP to covered processes and equipment:

  • 119(d)(3)(ii) – The employer shall document that equipment complies with RAGAGEP.
  • 119(d)(3)(III) – For existing equipment designed and constructed in accordance with codes, standards, or practices that are no longer in general use, the employer shall determine and document that the equipment is designed, maintained, inspected, tested, and operating in a safe manner.
  • 119(j)(4)(ii) – Inspection and testing procedures shall follow RAGAGEP.
  • 119(j)(4)(iii) – The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers’ recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.

Issuance of this memorandum signals that inspectors will be looking more closely at these requirements during PSM-related inspections and that they will specifically be looking for information on whether employers have identified and documented the appropriate RAGAGEP that applies to each piece of equipment and are following the inspection and testing requirements including frequency of those inspections and tests.

Continue Reading Eight Tips for Addressing OSHA’s New Enforcement Guidance on RAGAGEP under the Process Safety Management Standard

In a speech recently before the Small Business Administration’s safety and health forum in Washington, DC, Richard E. Fairfax, OSHA’s Director of Enforcement and Construction Programs, provided an update on the agency’s key enforcement initiatives. Of particular note, Mr. Fairfax stated:

OSHA has announced a new National Emphasis Program (NEP) to focus enforcement resources on process safety management (PSM) hazards in chemical facilities across the country. Chemical facilities with PSM-covered processes should review their programs now to ensure full compliance with OSHA standards.

The NEP, effective July 27, 2009, is billed as a “new approach for inspecting

Signaling its renewed focus on enforcement, OSHA has announced it is developing six new National Emphasis Programs (NEPs). NEPs focus OSHA’s resources on industries, hazards, and occupational injuries and illnesses that need additional targeted enforcement, in the Agency’s view.

OSHA’s Director of Enforcement Programs revealed the following industry-specific NEPs are in development:

 

  • Chemical plants –