CONSAD Research Corporation
Occupational Safety and Health
ANALYTICAL SUPPORT AND DATA GATHERING FOR AN ECONOMIC ANALYSIS OF THE ADDITION OF SELECTED REACTIVE CHEMICALS WITHIN THE SCOPE OF THE OSHA PROCESS SAFETY MANAGEMENT STANDARD
U.S. Department of Labor, Occupational Safety and Health Administration
The Occupational Safety and Health Administration (OSHA) is preparing to reopen the rulemaking record concerning the need to amend the Process Safety Management of Highly Hazardous Chemicals (PSM) standard (29 CFR 1910.119). The purpose of this action is to obtain comments, recommendations, data, and information from interested parties concerning the need for regulatory changes to ensure an acceptable level of safety for those workers using reactive chemicals. Information will also be sought concerning the costs and benefits associated with such changes and ways to minimize the impacts on small entities affected by any changes that may be made. Further, information will be sought concerning alternative regulatory and non-regulatory approaches for ensuring the safe handling of reactive chemicals.
The issue concerning the appropriate treatment of reactive chemicals within the context of process safety management has received closer attention in the Agency in the wake of a serious accident that took place at a U.S. chemical plant. On April 21, 1995, a catastrophic explosion and fire occurred at a facility owned by Napp Technologies, Inc., a specialty chemical plant in Lodi, N.J. The explosion and fire resulted in the deaths of five workers, injuries to eight workers, evacuation of 400 residents of the community, and destruction of the plant.
At this time, OSHA has decided to exercise its rulemaking authority under section 6(b) of the Act by proceeding with an advance notice of proposed rulemaking (ANPRM) addressing reactive chemicals. Specifically, OSHA is considering adding all chemicals with an NFPA reactivity rating of 2 to the list of chemicals covered by the PSM standard. Moreover, other chemicals with a reactivity rating of 3 or 4 that are not now in the PSM chemical list would also be added. OSHA is also including all chemicals with a reactivity rating of 1, although the Agency states that it does not believe that these chemicals should be covered by the PSM standard, since the standard is intended to cover only highly hazardous chemicals. In total, almost 100 chemicals have been identified in the ANPRM.
The purpose of this study was to provide technical and analytical support for the forthcoming OSHA PSM rulemaking and to assist in data gathering for a preliminary chemical and industry profile and accident analysis for the identified reactive chemicals to be possibly added to the scope of the process safety management standard. More specifically, the tasks that were performed include: