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Written by Bryan Haywood

Parent Category: Safety Info Posts

Category: Chemical Process Safety (PSM/RMP)

Published: 31 July 2013

There is one small little sentence in 1910.119 (as well as Part 68) that is causing all kinds of heartburn. I like to call this requirement the "General Duty Clause" of process safety. To fully understand what this requirement entails we first have to understand what is meant by a standard being a "performance oriented" standard, which PSM (and RMP) is. A performance oriented standard is "open ended"; by this I mean that OSHA does not prescribe the exact way to comply. Take 1910.23 for example, OSHA says that a guardrail must have a top rail at 42", mid rail at 21" and a toe board that is 4" high and less than 1/4" from the surface. The standard also has strength specifications, materials of construction specifications, etc. That is pretty "prescriptive" and does not leave much to the imagination as to how a guardrail MUST be constructed and installed! The PSM standard is MUCH MORE open as the standard is meant to be a management framework that can be used in all types of processes handling highly hazardous chemicals (HHC) and extremely hazardous substances (EHS). Now there are certain parts of the PSM standard that are prescriptive, such as Process Safety Information (PSI); but for the most part, the 14 elements are set up as a management system framework and the employer is expected to "adopt" (i.e. implement) consensus standards/codes for the design, installation, operations, and maintenance of their process(s) equipment. And this is where 1910.119(d)(3)(ii) comes into play...

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