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Comment Submitted to OSHA
The United States Occupational Safety and Health Administration (OSHA) published its Process Safety Management (PSM) standard (29 CFR 1910.119) in the year 1992. That’s thirty years ago, and thirty years is a long time.
In August of this year the agency published notice of a Stakeholder Meeting. In that notice they identified around 24 topics in their standard that they would like to modify or enhance. Crucially, the standard is also open for comments on any other issues that are relevant to process safety regulations.
I have submitted my first comment at the Regulations.gov site today.
In principle, all comments are open for all to read. Yet, as far as I could make out, there are no published comments to do with this new initiative. (I suppose it is possible that I was the first to submit a comment, but that seems unlikely.)
We have been publishing a series of reviews and discussions on the categories that the agency has identified. We have also written a few posts to do with the basics of process safety management. All this material is indexed at Update to OSHA’s Process Safety Management Regulation: An Index. We will add submitted comments to that index.
In the meantime, here is the text of the first submitted comment.
This comment is associated with docket number OSHA-2013-0020.
In the notice to do with the Stakeholder Meeting (August 30, 2022), OSHA included the following paragraph,
8. Clarifying paragraph (e) to require consideration of natural disasters and extreme temperatures in their PSM programs, in response to E.O. 13990;
Issues such as rising water levels and increasing temperatures will also affect the safety of process facilities, and will increase the likelihood of a release of highly hazardous chemicals.
The United States Securities and Exchange Commission (SEC) published a proposed rule in March 2022. Its title is ‘The Enhancement and Standardization of Climate-Related Disclosures for Investors’ (https://www.sec.gov/rules/proposed/2022/33-11042.pdf). Their proposed rule calls on public companies to:
Report their greenhouse gas emissions;
Describe their programs to reduce the greenhouse gas emissions; and
Evaluate the risk that climate change poses to their financial situation.
All three of these topics are relevant to the process industries and to the process safety regulation.
The process safety “way of thinking” is helpful when considering climate issues. For example, when it comes to hazards analysis the process safety community ,
(1) Identifies the hazards;
(2) Assesses the likelihood and consequences of those hazards;
(3) Risk ranks each of the identified hazards; and
(4) Evaluates the feasibility of proposed responses to control that hazard.
This approach to identifying and controlling high-risk situations can be applied to climate change problems because they possess many of the same features.
A further area of commonality is to do with systems analysis. Process incidents are rarely simple. They occur within complex systems, and are often difficult to identify or analyze. This justifies the paragraph to do with root cause analysis.
12. Amending paragraph (m) to require root cause analysis;
Similarly, climate change challenges are part of complex systems involving many factors such as resource depletion and economics. Root cause analysis techniques can be helpful in understanding how to effectively address climate issues.
To conclude: it is suggested that paragraph (e) be expanded to show how process safety techniques can help address climate concerns.
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