Ian Pitt
OSH 370
Executive Summary
: Currently, McNeely’s Processed Meats does not have an active process safety management (PSM) program. The amount of ammonia our company has on our site makes our company subject to compliance OSHA’s 1910.119 standard of PSM standard. The characteristic of our company that places us in the PSM standard is the 12,000 pounds of ammonia stored within the refrigeration system, as the amount OSHA identifies as the PSM threshold quantity is 10,000 pounds. To enter compliance with OSHA, as well as protect our workforce, we need to implement a PSM program and take the corrective actions necessary to reduce the risk of storing this hazardous chemical. Compliance with the PSM standard is a non-negotiable need, and it is imperative that we take on the time and cost to achieve compliance. Section 1
To comply with OSHA’s PSM standard, there are a few basic needs for our company policy. A written program must be documented, and a PHA must be completed and documented as well. Within the program, operating procedures must be created and will be kept on file and available for employees. To ensure employee knowledge, training will be conducted for the hazards and risk associated with ammonia and the operations the workforce will be completing. The implementation of a hot work permit program for our process will be included in the program. In the case our company has an incident, an emergency action plan will be clearly detailed for our employees. For changes that need to be made for compliance, a plan for evaluating contractors will be included in the PSM program. Also outlined in the program will be
a pre-start review will be needed for our ammonia process. A review will be implemented for mechanical integrity evaluations through engineering. Some management elements included in compliance will be incident investigation procedures, management of change plans, and compliance audits. Section
2
While there are many tasks to be completed in order to achieve compliance with OSHA’s PSM standard, there is a clear path to complete what needs to be done. First, using current knowledge and utilization of OSHA’s PSM standard, a PSM policy will need to be developed and implemented in the workplace. Once a program is drafted, conducting a process hazard analysis (PHA) will be done by safety, along with engineering to identify mechanical aspects that
generate risk. Once hazards are identified and a plan is in place, training and implementation of the PSM program and safe operating procedures will be expected. Once implemented, auditing and evaluation of the program will be conducted.
Section 3
Safety personnel will be responsible for forming the PSM policy and documents. The program as a whole, safe operating procedures, emergency action plans, management of change policy, audit checklists, and training for employees are to be developed, implemented, and 1
