OSHA Process Safety Management (PSM) of Highly Hazardous Chemicals

The US Department of Labor's Bureau of Labor Statistics reported 5,702 workplace related fatalities (around 4 deaths per 100,000 workers) and approximately 4.2 million incidents of workplace related non-fatal injuries and illnesses. This demonstrates the continuing need for OSHA programs and initiatives to ensure safety and health in the workplace.

Available data from the US Bureau of Labor Statistics (BLS) highlights the fact that non-fatal workplace injuries and illnesses have been progressively reduced from 5.3 to 4.6 cases/ 100 equivalent full time workers, during the period 2002 to 2005. Stringent regulations for workplace safety and the dedication of agencies enforcing the same have made this remarkable feat a reality.

The Occupational Safety and Health Administration (OSHA), an agency under the Department of Labor, has the primary responsibility of developing and enforcing worker and workplace related health and safety regulations. OSHA promotes workplace safety through a variety of ways, including the 29 CFR 1910.119 PSM standard and the 29 CFR 1910.120 HAZWOPER standard. The essentials of the OSHA Workplace Injury and Illness Prevention Program emanate from the provisions of these standards.

All employers are required to implement and maintain (a) a workplace Injury and Illness Prevention Program (IIPP), (b) an OSHA mandated Hazard Communication Program (as per 29 CFR 1910.1200), (c) an Emergency Action Plan (EAP) in accordance with provisions of 29 CFR 1910.38 and (d) a Fire Protection Plan.

The EAP, orientated towards disaster management, and the IIPP, designed for minimizing incidents, are not mutually exclusive. The two programs complement each other and have certain common requirements. An example of this is the recommended use of Material Safety Data Sheets (MSDS) to identify potential hazards that may arise from the different types of chemicals in use at the workplace. The 1910.119 PSM standard mandates the use of MSDS, meeting the requirements of 29 CFR 1910.1200, section (g).

An IIPP is a mechanism for reviewing and eliminating/reducing potential hazards in the workplace. An effective IIPP can not only protect workers but also benefit employers by reducing lost man-days and workers' compensation costs.

The workplace Injury and Illness Prevention Program (IIPP) can be conveniently discussed in terms of the California-OSHA adopted IIPP. Applicable categories of employers in California are required by law, Title 8 (T8), of the California Code of Regulations (CCR) to have an effective, documented Injury and Illness Prevention Program.

The Cal-OSHA mandated IIPP essentially has seven basic components. These are: (1) identification of program implementing personnel, (2) a written outline of the company's system of evaluating and combating safety and health hazards, (3) a schedule of periodic inspections, (4) investigation procedures for workplace injuries and illnesses, (5) a description of employee training program(s) on safe work practices and specific job-related safety information, (6) a system for communicating with employees on occupational health and safety matters and for enforcing safe working practices, and (7) a retention policy for record documentation compliance.

Records and reports (29 CFR 1904) are integral and important parts of any effective OSHA workplace Injury and Illness Prevention Program. Records help to identify causes of incidents and develop future strategies for improving workplace safety. Records typically include work-related accidents, fatalities, injuries and illnesses, incidents of exposure to toxic or hazardous materials, Material Safety Data Sheets, health and safety related training imparted to employees, inspections, audits and other statutory records required for worker's compensation, insurance etc.

The OSHA workplace Injury and Illness Prevention program, admittedly, imposes meticulous requirements on employers. However the benefits that an effective IIPP can provide far outweigh its inconveniences.