The new OSHA chemical use directive deprecates thirty-year-old standing instructions and covers process safety management at warehouses and factories.
New OSHA Chemical Directive
A federal worker safety enforcement directive for chemical plants, refineries, and other facilities that house or handle large amounts of chemicals has received an update for the first time in 30 years.
This new, 103 page enforcement document updates process safety management guidance to include OSHA (Occupational Safety and Health Administration) advice plus direction that’s been issued since the last update in 1994.
Process safety management (PSM), covers how a wide range of facilities – from chemical refineries to food manufacturing plants and warehouses – are required to handle large quantities of potentially dangerous chemicals.
This new enforcement document is written mainly with OSHA Compliance Safety and Health Officers (CSHO’s) in mind, but also informs employers what is expected of them in relation to the new policies and procedures.
OSHA Interpretation Letters
The directive mainly uses a question and response format based on OSHA’s interpretation letters of the standard dating back to 1992, which are also available to search and view individually online.
Questions include whether the amount of a hazardous chemical stored at a facility requires compliance. In many responses, 10,000 pounds is the limit level before compliance is required.
Other questions look into how chemicals are monitored and how they must be stored, for example, the types and specificity or acceptable barriers between liquid storage tanks.
There is also guidance on whether discrete operations within refineries and chemical plants are connected in such a way as to require compliance.
OSHA has not, to our knowledge, previously stated a guidance change was imminent.
It appears likely that OSHA is attempting to transform its prior non-enforceable letters of interpretations into distinct and enforceable policies.
The new guidance removes instructions from the 1994 directive that guided inspectors on how to conduct inspections. Rather, it instructs inspectors to follow a separate directive, the 2017 national emphasis program for process safety that was released in the Obama administration.
OSHA Training Implications
There is no immediate guidance from OSHA on any impact to the various optional and mandated training program content.
It is fairly safe to assume that popular courses such as OSHA 10 Hour Construction will not be impacted.
The HAZWOPER series of courses, which deal more specifically with chemical management and associated hazards are less clear. In the absence of any advice from OSHA and until such time as this is provided we will be adding the directive as an addendum to our HAZWOPER certification courses.