OSHA 1910.119, the Process Safety Management regulations mandate that plant operators manage the hazards associated with processes using highly hazardous chemicals.

Covered processes involve either specified quantities of hazardous chemicals or significant quantities of flammable substances, with exemptions for retail, oil, gas, and remote facilities.

The Process Safety Management (PSM) standard applies broadly to interconnected and closely located components that could contribute to or exacerbate a hazardous chemical release.

The regulation requires a great deal of information be maintained and kept current such as

• process safety information
• hazards analyses
• operating procedures

A key element of OSHA Process Safety Management (PSM) is the requirement for, and adherence to, a Management of Change (MOC) procedure.

Before change Implementation: 

• document the technical basis for change
• assess the impact of the change
• acquire proper approvals

After change Implementation:

• mechanical integrity inspections
• pre-startup safety review
• conduct training
• update process safety information

“Replacement in Kind” (RIK) in the context of OSHA’s Process Safety Management (PSM) regulation, allows certain replacements that meet original design specifications to bypass the formal Management of Change (MOC) process.

There are three primary assumptions that guide Replacement in Kind (RIK) decisions.

• “Grandfathering” allows identical part replacements
• “Generic” permits parts from alternative manufacturers with the same operational criteria
• “Recognized and Generally Accepted Good Engineering Practices” (RAGAGEP)

• A Management of Change (MOC) procedure must accommodate a wide range of potential changes from low to high complexity, cost or risk
• Management of Change (MOC) requires rigorous document management controls for each Management of Change (MOC) project
• A Management of Change (MOC) project typically involves different participants, skills, authority, etc. to accomplish

API RP 1173 Pipeline Safety Management System (PSMS) and OSHA 1910.119 Process Safety Management (PSM) standard both focus on managing safety risks in industrial operations, but they have distinct scopes and emphases.

OSHA 1910.119, the Process Safety Management (PSM) standard, specifically targets facilities that handle hazardous chemicals above certain threshold quantities, such as refineries and chemical plants. In contrast, API RP 1173 is tailored to pipeline operators, addressing the unique risks associated with transporting hazardous liquids and gases over long distances.

Both standards emphasize risk-based safety management, but API RP 1173 is structured around a broader safety culture for continuous improvement and risk management tailored to the pipeline industry. OSHA PSM is more prescriptive, with specific requirements for elements like hazard analysis, mechanical integrity, and process design.

The Center for Chemical Process Safety (CCPS) guidelines complement both the OSHA PSM standard (29 CFR 1910.119) and API RP 1173 Pipeline Safety Management System (PSMS) by providing comprehensive best practices and tools that enhance safety management within hazardous industries.

CCPS guidelines were instrumental in shaping the OSHA PSM standard, and they continue to provide more detailed, in-depth guidance on implementing each PSM element. For example, CCPS covers advanced methodologies for hazard analysis, mechanical integrity, and emergency preparedness that support facilities in meeting OSHA’s regulatory requirements.

CCPS guidelines offer broader safety management principles that align well with RP 1173’s goals. CCPS emphasizes creating a safety culture, continuous improvement, and robust incident investigation—key areas also highlighted in RP 1173. CCPS guidelines provide a toolkit for API RP 1173’s framework, enabling pipeline operators to adapt best practices from the chemical process industry to their own safety systems.

Both API RP 1173 and OSHA PSM promote risk management and a proactive safety culture, and CCPS guidelines delve into these areas with additional strategies for leadership commitment, workforce engagement, and risk-based decision-making. CCPS’s focus on human factors and operational discipline can strengthen compliance with both standards and enhance an organization’s overall safety performance.

In summary, CCPS guidelines serve as a rich resource for both OSHA PSM and API RP 1173 by offering practical, advanced insights that support and enhance compliance while promoting an integrated approach to safety management across hazardous industries.

The EPA Clean Air Act Risk Management Plan (RMP) Rule, found in Section 112(r) of the Clean Air Act, is a regulation designed to prevent chemical accidents that could harm public health or the environment. The RMP rule requires facilities that use, store, or handle significant quantities of certain hazardous substances to develop and implement a Risk Management Plan. Key aspects of the RMP rule include:

• Hazard Assessment: Facilities must conduct hazard assessments that include a worst-case release scenario and alternative release scenarios, analyzing the potential impacts of chemical releases on surrounding communities and the environment.
• Prevention Program: Like OSHA’s Process Safety Management (PSM) requirements, the RMP rule mandates a prevention program that includes process hazard analyses, operating procedures, maintenance, training, and incident investigation to reduce the likelihood of accidents.
• Emergency Response: Facilities must have an emergency response program, coordinating with local emergency planning and response authorities to ensure readiness in the event of a chemical release. This includes notifying the public and first responders of potential risks.
• Public Disclosure and Community Right-to-Know: The RMP rule requires facilities to submit their RMPs to the EPA, and these plans are made available to the public (with some security-sensitive details restricted). This transparency helps inform communities about nearby chemical hazards and emergency procedures.

The RMP rule applies to industries such as chemical manufacturing, oil and gas processing, and large-scale agricultural operations that use chemicals like ammonia or chlorine. The RMP rule ultimately seeks to protect public health, community safety, and the environment by preventing catastrophic chemical accidents and ensuring coordinated emergency response plans.

Federal EPA standards and regulations complement the OSHA Process Safety Management (PSM) standard, 29 CFR 1910.119, particularly through the Risk Management Plan (RMP) rule under the Clean Air Act, which focuses on preventing and mitigating chemical accidents. Here’s how they are integrated and aligned:

• Shared Goals for Chemical Safety: Both OSHA PSM and EPA RMP are designed to prevent chemical accidents, but they apply to slightly different aspects of chemical safety and have different scopes. OSHA PSM focuses on worker safety within a facility, while EPA RMP emphasizes the protection of public health and the environment outside the facility.
• Overlapping Requirements: Many PSM elements (e.g., process hazard analysis, mechanical integrity, and emergency response) overlap with requirements in the EPA RMP rule. These shared requirements allow facilities to develop integrated programs that comply with both standards, reducing redundancy in compliance efforts. For instance, both standards require facilities to conduct hazard analyses and establish robust operating procedures, though RMP also requires an assessment of potential offsite impacts.
• Incident Investigation and Prevention: Both OSHA and the EPA require incident investigations and continuous improvement efforts to prevent chemical releases, though RMP includes additional components like the development of a worst-case scenario analysis and public disclosure of certain risk information.
• Coordination and Enforcement: OSHA and the EPA coordinate on enforcement actions and share information to streamline compliance for facilities subject to both PSM and RMP requirements. This collaboration helps avoid conflicting directives and enhances safety management by promoting unified standards.
• Emergency Response and Community Involvement: EPA’s RMP rule goes further than OSHA PSM in requiring facilities to involve local communities and emergency responders in emergency planning. This requirement reflects the EPA’s broader focus on environmental safety and public health in addition to worker safety.

In essence, EPA standards supplement OSHA PSM by focusing on environmental and public safety impacts, while the two standards collectively ensure comprehensive risk management for facilities handling hazardous chemicals.