Understand PSM and covered processes
Learning objective: Identify the employer’s documented process boundary and coverage decision before relying on an exemption.
Process safety management, or PSM, aims to prevent major releases of highly hazardous chemicals. A release may cause a toxic exposure, fire or explosion that harms many people. Good injury statistics do not prove that a process is safe. PSM looks at the equipment, chemistry, work methods and systems that prevent a major event.
Coverage depends on the process, chemical and quantity. Appendix A lists chemicals and their threshold quantities. Another coverage path addresses Category 1 flammable gases and liquids with flashpoints below 100 degrees F at 10,000 pounds or more in one location, subject to the stated exceptions. This is not a universal 10,000-pound threshold for all chemicals.
The process definition includes use, storage, handling, manufacture and on-site movement. Interconnected vessels and separate vessels positioned so they could be involved in a release may form one process. Do not divide connected equipment into separate small inventories to assume it is exempt. The employer must evaluate the actual facts, thresholds and exclusions, including the specific fuel, atmospheric-storage, retail, well-operation and remote-facility provisions.
Construction rule 1926.64 directs employers to 1910.119. This course explains the program and training duties. It does not qualify a person to operate a specific process, lead a hazard study or respond to a chemical emergency. Even where PSM does not apply, other safety requirements may still apply.
Source context: 29 CFR 1910.119(a)-(b), Appendix A; 1926.64