Update to OSHA’s Process Safety Management Regulation. Part 19: Natural Disasters and Extreme Temperatures

Most of the proposed updates to the standard fall into the general category of housekeeping. OSHA aims to fine tune existing standards and/or to take care of legalistic difficulties. However, some of the proposed changes could be a door that opens on to new ways of interpreting and applying the regulation. This element — Natural Disasters and Extreme Temperatures — is that type of change.

The Regulation

This proposed update to the standard is to do with paragraph (e) of the regulation, Process Hazards Analysis.

(a) Application
(b) Definitions
(c) Employee Participation
(d) Process Safety Information
(e) Process Hazards Analysis
f) Operating Procedures
(g) Training
(h) Contractors
(i) Prestartup Safety Review
(j) Mechanical Integrity
(k) Hot Work
(l) Management of Change
(m) Incident Investigation
(n) Emergency Planning and Response
(o) Compliance Audits
(p) Trade Secrets

Paragraph (e) does not contain explicit provisions to do with natural disasters. However, most PHA teams do discuss predictable natural events, such as local flooding or extended periods of freezing temperatures. The key word here is ‘predictable’ — the team will not usually discuss the impact of unprecedented issues such as climate change or loss of biosphere diversity. PHA teams generally confine their discussions to events that are considered plausible within the current norms.

Proposed Update

This proposed update reads,

Clarifying paragraph (e) to require consideration of natural disasters and extreme temperatures in their PSM programs.

Discussion