Seyfarth Synopsis: New OSHA guidance documents may provide employers in these industries with another tool for carefully measuring compliance with the PSM standards.
OSHA recently released guidance documents on Process Safety Management for Explosives and Pyrotechnics Manufacturing (PSM Explosive Pyrotechnics Guidance) (OSHA 3912-03 2017), and the Process Safety Management for Storage Facilities (PSM Storage Guidance) (OSHA 3909-03 2017).
The PSM Explosive Pyrotechnics Guidance focuses on aspects of the standard particularly relevant to explosives and pyrotechnic manufacturers, found in OSHA’s standard on Explosives and Blasting Agents, 29 CFR 1910.109. The PSM Storage Guidance focuses on aspects of the PSM standard particularly relevant to storage facilities generally.
OSHA notes that while all elements of the PSM standard apply to all PSM-covered pyrotechnics manufacturing or storage facilities, the following elements are most relevant to hazards associated with these facilities:
- Employee Participation
- Process Safety Information (PSI)
- Process Hazard Analysis (PHA)
- Operating Procedures
- Mechanical Integrity (MI)
- Emergency Planning and Response
OSHA emphasizes that as to explosives, these PSM elements complement the “cardinal principle for explosive safety: expose the minimum number of people to the smallest quantity of explosives for the shortest period consistent with the operation being conducted.”
These Guidance documents provide employers with an outline to compliance with the applicable PSM standards that provide another review tool to achieve compliance. Employers in these industries are encouraged to review these Guidance documents carefully to measure compliance with the standard, as you may be sure that OSHA’s inspector’s, if or when they visit, will do so.