Hazard Communication Standard

The Hazard Communication Standard (HCS) (29 CFR 1910.1200(g)), revised in 2012, requires that the chemical manufacturer, distributor, or importer provide Safety Data Sheets (SDSs) (formerly MSDSs or Material Safety Data Sheets) for each hazardous chemical to downstream users to communicate information on these hazards. The information contained in the SDS is largely the same as the MSDS, except now the SDSs are required to be presented in a consistent user-friendly, 16-section format. This brief provides guidance to help workers who handle hazardous chemicals to become familiar with the format and understand the contents of the SDSs.

Hazard Communication @ OSHA

Confined Space Permits now required by OSHAhttps://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9797

1910.146(a)

Scope and application. This section contains requirements for practices and procedures to protect employees in general industry from the hazards of entry into permit-required confined spaces. This section does not apply to agriculture, to construction, or to shipyard employment (Parts 1928, 1926, and 1915 of this chapter, respectively).

The Rest @  1910 OSHA 

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Process Safety Management notes (Initial)

Process safety Management

Process Safety Management - Guidelines for Compliance" (OSHA 3133)

-these are notes from the manuals, and are incomplete, partial statements. please use the references listed above from OSHA to do this process.

-Editor

The process safety management standard targets highly hazardous chemicals that have the potential to cause a catastrophic incident. The purpose of the standard as a whole is to aid employers in their efforts to prevent or mitigate episodic chemical releases that could lead to a catastrophe in the workplace and possibly in the surrounding community.

o control these types of hazards, employers need to develop the necessary expertise, experience, judgement, and initiative within their work force to properly implement and maintain an effective process safety management program as envisioned in the Occupational Safety and Health Administration (OSHA) standard.

The standard mainly applies to manufacturing industries-particularly, those pertaining to chemicals, transportation equipment, and fabricated metal products. Other affected sectors include natural gas liquids; farm product warehousing; electric, gas, and sanitary services; and wholesale trade. It also applies to pyrotechnics and explosives manufacturers covered under other OSHA rules and has special provisions for contractors working in covered facilities.

o control these types of hazards, employers need to develop the necessary expertise, experience, judgement, and initiative within their work force to properly implement and maintain an effective process safety management program as envisioned in the Occupational Safety and Health Administration (OSHA) standard.

in each industry, PSM applies to those companies that deal with any of more than 130 specific toxic and reactive chemicals in listed quantities; it also includes flammable liquids and gases in quantities of 10,000 pounds (4,535.9 Kg) or more.

The PSM standard does not apply to the following:

• Retail facilities
• Oil or gas well drilling or servicing operations
• Normally unoccupied remote facilities
• Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g. propane used for comfort heating, gasoline for vehicle refueling), if such fuels are not a part of a process containing another highly hazardous chemical covered by this standard; or
• Flammable liquid stored in atmospheric tanks or transferred, which are kept below their normal boiling point without benefit of chilling or refrigerating and are not connected to a process.

Subject to the rules and procedures set forth in OSHA's Hazard Communication Standard (29 Code of Federal Regulations (CFR) 1910.1200(i)(1) through 1910.1200(i)(12)), employees and their designated representatives must be given access to trade secret information contained within the process hazard analysis and other documents required to be developed by the PSM standard.

Information required

Complete and accurate written information concerning process chemicals, process technology, and process equipment is essential to an effective process safety management program and to a process hazard analysis. The compiled information will be a necessary resource to a variety of users including the team performing the process hazard analysis as required by PSM; those developing the training programs and the operating procedures; contractors whose employees will be working with the process; those conducting the pre-startup reviews; as well as local emergency preparedness planners, and insurance and enforcement officials.

*******

Employers must complete a compilation of written process safety diagram (piping and instrument diagrams (P&ID) information before conducting any process hazard analysis.

*************

A PHA analyzes potential causes and consequences of fires, explosions, releases of toxic or flammable chemicals, and major spills of hazardous chemicals. The PHA focuses on equipment, instrumentation, utilities, human actions (routine and nonroutine), and external factors that might affect the process.

The selection of a PHA methodology or technique will be influenced by many factors including how much is known about the process. Is it a process that has been operated for a long period of time with little or no innovation and extensive experience has been generated with its use? Or, is it a new process or one that has been changed frequently by the inclusion of innovation features? Also, the size and complexity of the process will influence the decision as to the appropriate PHA methodology to use.

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(e)(1) The employer shall perform an initial process hazard analysis (hazard evaluation) on processes covered by this standard. The process hazard analysis shall be appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process. Employers shall determine and document the priority order for conducting process hazard analyses based on a rationale which includes such considerations as extent of the process hazards, number of potentially affected employees, age of the process, and operating history of the process. The process hazard analysis shall be conducted as soon as possible, but not later than the following schedule: (e)(1)(i) No less than 25 percent of the initial process hazards analyses shall be completed by May 26, 1994; (e)(1)(ii) No less than 50 percent of the initial process hazards analyses shall be completed by May 26, 1995; (e)(1)(iii) No less than 75 percent of the initial process hazards analyses shall be completed by May 26, 1996; (e)(1)(iv) All initial process hazards analyses shall be completed by May 26, 1997. (e)(1)(v) Process hazards analyses completed after May 26, 1987 which meet the requirements of this paragraph are acceptable as initial process hazards analyses. These process hazard analyses shall be updated and revalidated, based on their completion date, in accordance with paragraph (e)(6) of this standard. e)(2) The employer shall use one or more of the following methodologies that are appropriate to determine and evaluate the hazards of the process being analyzed. (e)(2)(i) What-If; (e)(2)(ii) Checklist; (e)(2)(iii) What-If/Checklist; (e)(2)(iv) Hazard and Operability Study (HAZOP); (e)(2)(v) Failure Mode and Effects Analysis (FMEA); (e)(2)(vi) Fault Tree Analysis; or (e)(2)(vii) An appropriate equivalent methodology. (e)(3) The process hazard analysis shall address: (e)(3)(i) The hazards of the process; (e)(3)(ii) The identification of any previous incident which had a likely potential for catastrophic consequences in the workplace; (e)(3)(iii) Engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases. (Acceptable detection methods might include process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors.) (e)(3)(iv) Consequences of failure of engineering and administrative controls; (e)(3)(v) Facility siting; (e)(3)(vi) Human factors; and (e)(3)(vii) A qualitative evaluation of a range of the possible safety and health effects of failure of controls on employees in the workplace. (e)(4) The process hazard analysis shall be performed by a team with expertise in engineering and process operations, and the team shall include at least one employee who has experience and knowledge specific to the process being evaluated. Also, one member of the team must be knowledgeable in the specific process hazard analysis methodology being used. e)(5) The employer shall establish a system to promptly address the team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions. (e)(6) At least every five (5) years after the completion of the initial process hazard analysis, the process hazard analysis shall be updated and revalidated by a team meeting the requirements in paragraph (e)(4) of this section, to assure that the process hazard analysis is consistent with the current process.

Process Safety Management notes (Initial)

Process safety Management

Process Safety Management - Guidelines for Compliance" (OSHA 3133)

-these are notes from the manuals, and are incomplete, partial statements. please use the references listed above from OSHA to do this process.
-Editor


The process safety management standard targets highly hazardous chemicals that have the potential to cause a catastrophic incident. The purpose of the standard as a whole is to aid employers in their efforts to prevent or mitigate episodic chemical releases that could lead to a catastrophe in the workplace and possibly in the surrounding community.

o control these types of hazards, employers need to develop the necessary expertise, experience, judgement, and initiative within their work force to properly implement and maintain an effective process safety management program as envisioned in the Occupational Safety and Health Administration (OSHA) standard.

The standard mainly applies to manufacturing industries-particularly, those pertaining to chemicals, transportation equipment, and fabricated metal products. Other affected sectors include natural gas liquids; farm product warehousing; electric, gas, and sanitary services; and wholesale trade. It also applies to pyrotechnics and explosives manufacturers covered under other OSHA rules and has special provisions for contractors working in covered facilities.

o control these types of hazards, employers need to develop the necessary expertise, experience, judgement, and initiative within their work force to properly implement and maintain an effective process safety management program as envisioned in the Occupational Safety and Health Administration (OSHA) standard.

in each industry, PSM applies to those companies that deal with any of more than 130 specific toxic and reactive chemicals in listed quantities; it also includes flammable liquids and gases in quantities of 10,000 pounds (4,535.9 Kg) or more.

The PSM standard does not apply to the following:

• Retail facilities
• Oil or gas well drilling or servicing operations
• Normally unoccupied remote facilities
• Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g. propane used for comfort heating, gasoline for vehicle refueling), if such fuels are not a part of a process containing another highly hazardous chemical covered by this standard; or
• Flammable liquid stored in atmospheric tanks or transferred, which are kept below their normal boiling point without benefit of chilling or refrigerating and are not connected to a process.

Subject to the rules and procedures set forth in OSHA's Hazard Communication Standard (29 Code of Federal Regulations (CFR) 1910.1200(i)(1) through 1910.1200(i)(12)), employees and their designated representatives must be given access to trade secret information contained within the process hazard analysis and other documents required to be developed by the PSM standard.

Information required

Complete and accurate written information concerning process chemicals, process technology, and process equipment is essential to an effective process safety management program and to a process hazard analysis. The compiled information will be a necessary resource to a variety of users including the team performing the process hazard analysis as required by PSM; those developing the training programs and the operating procedures; contractors whose employees will be working with the process; those conducting the pre-startup reviews; as well as local emergency preparedness planners, and insurance and enforcement officials.

*******

Employers must complete a compilation of written process safety diagram (piping and instrument diagrams (P&ID) information before conducting any process hazard analysis.

*************

A PHA analyzes potential causes and consequences of fires, explosions, releases of toxic or flammable chemicals, and major spills of hazardous chemicals. The PHA focuses on equipment, instrumentation, utilities, human actions (routine and nonroutine), and external factors that might affect the process.

The selection of a PHA methodology or technique will be influenced by many factors including how much is known about the process. Is it a process that has been operated for a long period of time with little or no innovation and extensive experience has been generated with its use? Or, is it a new process or one that has been changed frequently by the inclusion of innovation features? Also, the size and complexity of the process will influence the decision as to the appropriate PHA methodology to use.

**************

(e)(1) The employer shall perform an initial process hazard analysis (hazard evaluation) on processes covered by this standard. The process hazard analysis shall be appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process. Employers shall determine and document the priority order for conducting process hazard analyses based on a rationale which includes such considerations as extent of the process hazards, number of potentially affected employees, age of the process, and operating history of the process. The process hazard analysis shall be conducted as soon as possible, but not later than the following schedule: (e)(1)(i) No less than 25 percent of the initial process hazards analyses shall be completed by May 26, 1994; (e)(1)(ii) No less than 50 percent of the initial process hazards analyses shall be completed by May 26, 1995; (e)(1)(iii) No less than 75 percent of the initial process hazards analyses shall be completed by May 26, 1996; (e)(1)(iv) All initial process hazards analyses shall be completed by May 26, 1997. (e)(1)(v) Process hazards analyses completed after May 26, 1987 which meet the requirements of this paragraph are acceptable as initial process hazards analyses. These process hazard analyses shall be updated and revalidated, based on their completion date, in accordance with paragraph (e)(6) of this standard. e)(2) The employer shall use one or more of the following methodologies that are appropriate to determine and evaluate the hazards of the process being analyzed. (e)(2)(i) What-If; (e)(2)(ii) Checklist; (e)(2)(iii) What-If/Checklist; (e)(2)(iv) Hazard and Operability Study (HAZOP); (e)(2)(v) Failure Mode and Effects Analysis (FMEA); (e)(2)(vi) Fault Tree Analysis; or (e)(2)(vii) An appropriate equivalent methodology. (e)(3) The process hazard analysis shall address: (e)(3)(i) The hazards of the process; (e)(3)(ii) The identification of any previous incident which had a likely potential for catastrophic consequences in the workplace; (e)(3)(iii) Engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases. (Acceptable detection methods might include process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors.) (e)(3)(iv) Consequences of failure of engineering and administrative controls; (e)(3)(v) Facility siting; (e)(3)(vi) Human factors; and (e)(3)(vii) A qualitative evaluation of a range of the possible safety and health effects of failure of controls on employees in the workplace. (e)(4) The process hazard analysis shall be performed by a team with expertise in engineering and process operations, and the team shall include at least one employee who has experience and knowledge specific to the process being evaluated. Also, one member of the team must be knowledgeable in the specific process hazard analysis methodology being used. e)(5) The employer shall establish a system to promptly address the team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions. (e)(6) At least every five (5) years after the completion of the initial process hazard analysis, the process hazard analysis shall be updated and revalidated by a team meeting the requirements in paragraph (e)(4) of this section, to assure that the process hazard analysis is consistent with the current process.

Example EHS Manager Job Description

Position Objective:Responsible for the local implementation, management and adherence to the company's corporate safety and loss control programs, policies, and procedures. This position will be responsible for standards and functions to reduce and prevent employee injuries, accidents, occupational illnesses and exposure to long-term health hazards, as well as reducing the environmental aspects and impacts associated with the company's operations.

Job Requirements:

• Develops standard procedures, along with safe and environmentally friendly work practices to protect the safety of the company's employees
• Enhance the safety performance of the company, prevent pollution, comply with applicable EH&S laws and strengthen the company's EHS Program
• Lead the local EH&S compliance assurance program
• Serve as the primary local contact with regulatory agencies on all local EH&S matters
• Manage timely reporting of worker compensation claims, accommodations for return to work, and interface with Risk Management to ensure appropriate employee care and case management
• Participate in safety committees and sustainability council
• Coordinate safety and health exposure assessments, hazard evaluations, and environmental aspects analysis of operations
• Provide assistance and support to local management in identifying and resolving EH&S matters
• Organize EHS program orientation and new employee EH&S orientation
• Facilitate EHS training for managers, supervisors, and other field staff
• Complete routine job analysis, observations, inspections, and audits on all EH&S related matters
• Maintain records of incidents best practices
• Oversee investigation and root cause analysis process for incidents

Knowledge and Skill Requirements:

• Must be Bilingual: English and Spanish
• Ability to work alternating day, evening, and weekends hours
• Must be a self-starter who can effectively evaluate situations and take independent action to expedite the resolution of open issues
• Excellent written and oral communication skills
• Industry experience required
• (5-7) years of experience required in EH Program Management, Regulatory Compliance, Loss Control, Risk Management
• This position requires up to 35% of travel per year

Environment Health and Safety References

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Environment Health and Safety References

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