OSHA PSM Update. Stakeholder Comments: Natural Hazards and Root Cause Analysis

We have published many posts (and a book) to do with the proposed changes to OSHA’s process safety management standard.

During the public Stakeholder Meeting in October 2022 participants provided comments. As time permits. we will discuss some of those comments.

Sutton Comment

I will start with my own comment. It is to do with two of the proposed change areas: Natural Disasters and Extreme Temperatures and Root Cause Analysis. These topics are included in paragraph (e) (Process Hazards Analysis) and paragraph (m) (Incident Investigation) respectively.

The transcript is shown at the end of this post.

Environmental Protection Agency

The EPA has proposed adding Climate Change to an updated Risk Management Program. The agency is also proposing to update its Root Cause Analysis requirements.

With regard to climate change, the EPA states,

Adding amplifying regulatory text to emphasize that natural hazards (including those that result from climate change) and loss of power are among the hazards that must be addressed in Program 2 hazard reviews and Program 3 process hazard analyses.

19th Global Congress on Process Safety

I will be providing further thoughts to do with process safety and climate change at the upcoming Global Congress on Process Safety (Tuesday, March 14 2023 at 2:30 p.m.). The title of my paper is ‘Process Safety in Net Zero Programs’. If you plan on attending the Congress, we welcome your participation in this session.

Transcript

My remarks complement my written submission, dated October the 6th, and I'd like to focus on two items that are part of the stakeholder meeting document.

First is number 8, clarifying paragraph (e) to require consideration of natural disasters, and paragraph 12, amending paragraph (m), to require root cause analysis.

The year 2022 represented something of a psychological tipping point with respect to natural disasters. There was a seemingly endless string of reports to do with
record floods, droughts and high temperatures occurring all over the world. We can
debate the speed with which the climate crisis is evolving. But it is clear that events
such as these will have an ever-increasing impact on process safety in coming years.

OSHA is not the only government agency that is concerned about the impact of
natural events on business and industry. For example, in the United States, leadership has been provided by the Securities and Exchange Commission. They have issued a 490-page proposed rule that calls on publicly traded companies to provide the following information to the investment community:

1) existing emissions of greenhouse gases;
2) plans to reduce those emissions and;
3) analysis of the risks, of the risk that they face as a result of a changing climate.

The limitation of these financially oriented rules is that they do not analyze climate change in terms of its physical reality, nor do they always recognize the complexity of climate issues and the potential for reaching sub-optimal solutions.

The process safety community can speak to these limitations. A core way of
thinking is on the lines. What are the hazards? What could go wrong? What are the high consequences of, high consequence events that might result? What other factors and parameters need to be considered in what are often very complex systems? The same reasoning can be applied to climate change. What are the climate related hazards? What are the consequences of those hazards?

The climate is certainly a very complex issue affected by many other factors. It cannot be analyzed, analyzed in isolation.

The last item - understanding complexity - provides a justification for including root cause analysis in an updated process safety standard.

Given this background, I suggest that paragraph (e) of the standard, process hazard analysis, be expanded to include a statement on the following lines: “hazard analyses should include an assessment of the risks associated with climate change.” Then paragraph (m), could be expanded as follows: “root cause analysis can be used to understand how climate change can lead to catastrophic releases of highly hazardous chemicals, including the potential for fires and explosions.”

---