The challenge to implement and maintain an effective PSM program

Many facilities have now implemented and maintained process safety management (PSM) programs for 20 years or more, but these facilities continue to have sometimes serious incidents and injuries suggesting a continuing need to improve their PSM performance. Of course, new requirements are often added to upgrade PSM programs, due to near‐miss learnings, audit findings, and new recommended and generally accepted good engineering practices, for example, but often overall performance improvements have not occurred or have not achieved the desired level of performance. How can significant performance improvements be obtained? Although performance issues at different facilities will certainly vary, this article provides several key approaches for improving overall PSM performance and for helping prevent injuries and incidents. © 2012 American Institute of Chemical Engineers Process Saf Prog, 2012

This article presents a brief analysis of the Occupational Safety and Health Administration (OSHA) Petroleum Refinery Process Safety Management National Emphasis Program (NEP) citation results as of early 2009. It includes trends distilled from the OSHA inspections performed to date. Recommendations for preparing for PSM NEP level inspections are provided.A proven approach to designing and implementing an upgrade project for OSHA process safety management systems and EPA risk management program is described. The model presented can be targeted to a facility's NEP specific citations or used for a general PSM system effectiveness upgrade.This article includes recommendations for improving PSM as a result of an NEP inspection. The recommendations are for the PSM elements that routinely have major OSHA citations; that is: Operating Procedures, Mechanical Integrity, Process Hazards Analysis, Process Safety Information, Management of Change, and Incident Investigations. © 2009 American Institute of Chemical Engineers Process Saf Prog 2009

A Little Occupational Audiology for the Clinical Audiologist

The OSHA process safety management (PSM) and EPA risk management program (RMP) standards require that process hazards analyses (PHAs) be performed on processes that contain listed toxic or flammable chemicals. A number of PHA techniques are listed in both standards that can be used to satisfy this requirement. Typical PHA studies use analysis techniques, such as hazard and operability (HAZOP), what‐if, and checklists, to review potential hazards, such as deviations from normal process conditions of flow, temperature, pressure, etc. The influences of control and instrument system failures on process system safety are usually considered indirectly. This paper reviews some of the considerations needed to conduct a PHA that includes control and instrument system failures. Information on (1) how to organize the review analysis team, (2) what type of documentation is needed, and (3) the special considerations needed in a control and instrument system review are included in this paper. The wide use of advanced programmable and electronic systems in the chemical process industry introduces a number of special considerations that must also be included in a review. These considerations are also discussed in this paper.

The Occupational Safety and Health Administration (OSHA) was developed to ensure that every American has a safe and healthy work environment. An important component of OSHA's mission is to develop and promulgate minimum standards for workplace safety, and we recently published, JAVMA fan 15, 1994 through Mar 1, 1994, a series of articles giving practical suggestions for complying with current OSHA standards. However, an equally important part of OSHA's mission is inspection of American workplaces to determine whether those workplaces are complying with safety standards. Few veterinarians know what to expect during an OSHA inspection, nor understand what their rights and responsibilities are. In this article, Ms. Richard, an attorney who specializes in management labor and employment law, outlines what to expect and what to do if your practice is inspected by the OSHA. Please remember that the information in this article is based on the author's best interpretation of current law. However, the law can change, and the accuracy of any interpretation of the law can be challenged by the OSHA. Therefore, information in this article is intended to be only a guideline and is not intended to be, nor should it be construed as, legal advice. Veterinarians are advised to consult with their own attorneys for advice on specific matters. Finally, this information is based on current federal OSHA guidelines. Veterinary practices located in one of the 25 states and territories with OSHA-approved state plans may have to comply with slightly different guidelines.—Kurt J. Matushek, Assistant Editor.

The Integrated Management Information System (IMIS) is the largest multi-industry source of exposure measurements available in North America. However, many have suspected that the criteria through which worksites are selected for inspection are related to exposure levels. We investigated associations between exposure levels and ancillary variables in IMIS in order to understand the predictors of high exposure within an enforcement context. We analyzed the association between nine variables (reason for inspection, establishment size, total amount of penalty, Occupational Safety and Health Administration (OSHA) plan, OSHA region, union status, inspection scope, year, and industry) and exposure levels in IMIS using multimodel inference for 77 agents. For each agent, we used two different types of models: (i) logistic models were used for the odds ratio (OR) of exposure being above the threshold limit value (TLV) and (ii) linear models were used for exposure concentrations restricted to detected results to estimate percent increase in exposure level, i.e. relative index of exposure (RIE). Meta-analytic methods were used to combine results for each variable across agents. A total of 511,047 exposure measurements were modeled for logistic models and 299,791 for linear models. Higher exposures were measured during follow-up inspections than planned inspections [meta-OR = 1.61, 95% confidence interval (CI): 1.44-1.81; meta-RIE = 1.06, 95% CI: 1.03-1.09]. Lower exposures were observed for measurements collected under state OSHA plans compared to measurements collected under federal OSHA (meta-OR = 0.82, 95% CI: 0.73-0.92; meta-RIE = 0.86, 95% CI: 0.81-0.91). A 'high' total historical amount of penalty relative to none was associated with higher exposures (meta-OR = 1.54, 95% CI: 1.40-1.71; meta-RIE = 1.18, 95% CI: 1.13-1.23). The relationships observed between exposure levels and ancillary variables across a vast majority of agents suggest that certain elements of OSHA's process of selecting worksites for inspection influence the exposure levels that OSHA inspectors encounter. Nonetheless, given the paucity of other sources of exposure data and the lack of a more demonstrably representative data source, our study considers the use of IMIS data for the estimation of exposures in the broader universe of worksites in the USA.

Investigations of fatalities by the Occupational Safety and Health Administration (OSHA) provide the most detailed available information about traumatic workplace deaths that are potentially related to violations of existing safety standards. Comparison of the number of such deaths investigated by OSHA from 1977 to 1986 with the comparable category of deaths reported to the Bureau of Labor Statistics Survey of Occupational Injuries and Illnesses indicates that the overall magnitudes have been roughly similar. The OSHA data contain more information than other sources and are especially valuable for analyses of fatalities at smaller workplaces. The OSHA data show that death rates decline sharply with establishment size; the inverted "U" pattern for lost workday injury rates is absent. Because accident investigations are conducted as part of an administrative system, the OSHA data can be influenced by changes in administrative policies. Changes over time in the percent of fatalities in which violations of OSHA standards were cited have clearly been influenced by changes in OSHA citation policy and thus do not provide a valid measure of the rate of violation-caused deaths. Realization of the epidemiological value of this data source depends upon a commitment from OSHA to maintain consistency in investigating accidents and to improve its data collection methods.

Guidance to improve the effectiveness of process safety management systems in operating facilities

This paper will consider medical surveillance in the context of the Occupational Safety and Health Act of 1970. The Occupational Safety and Health Administration (OSHA) has issued (after rule making) health standards covering approximately 24 toxic substances, and all these standards have included medical surveillance programs. OSHA is not only empowered but compelled by law to require medical surveillance programs for exposed employees. At the same time, a number of major legal/policy issues relating to medical surveillance have been raised at the standards rule-making stage and litigated in court. Among the more significant of these are access to medical records, selection of physician, and medical removals. Many of these issues were involved in OSHA's Lead Standard, issued in 1978 and affirmed in relevant part by the Court of Appeals for the District of Columbia in 1980, and in the "medical access" rule, issued in 1980 and upheld by the Court of Appeals for the Fifth Circuit. These two proceedings will be used as a focus for the discussions of medical surveillance programs under the OSHA act.

Chapter 1 - Definitions, Statistics, and the Occupational Safety and Health Administration

Regulatory law enforcement bias in the inspection, charging, and sanctioning process has been linked to the characteristics of offenses, the attributes of the regulatory agencies and the corporation, and the political and economic environment. However, the bargaining process of regulatory agencies has been less thoroughly investigated. To fill this gap in the literature, this study investigates whether certain extralegal variables affect the post-inspection bargaining process at the Occupational Safety and Health Administration (OSHA). In particular, since previous studies have focused exclusively on fine reductions, this study examines the full range of bargaining options, including count, charge, and fine reductions. Further, this is one of the first studies to directly examine whether company financial resources impact bargaining at OSHA. Because the data are multilevel data, I use multilevel logistic and linear regressions to examine whether extralegal variables affect the reductions given to facilities in the steel, oil, pulp, and paper industries. Specifically, I test whether facility level variables (unionization and experience with the system), company level variables (financial performance and size) and state level variables (political and economic environment) affect the reductions received by facilities during the post-inspection process at OSHA. Although there was some evidence to support the idea that state political views and system familiarity affect bargaining, the results overall tend to cast doubt on the notion that extralegal variables impact the decision-making process at OSHA. Due to sample limitations, the multilevel models employed here are exploratory, but they suggest that previous studies may have overestimated the effects of extralegal variables.

This book chapter reviews the issues of occupational safety and health administration in the composites industry in three countries, the United States, the United Kingdom, and Malaysia. In the United States, Occupational Safety and Health Administration (OSHA) was established in 1971 under the Occupational Safety and Health Act of 1970. It was the Department of United States of Labour agency that enforced the law and standards and responsible for ensuring safe and healthy working conditions and environments for the workers of both genders. In 1802, Sir Robert Peel introduced the first piece of Occupational Safety and Health legislation in the United Kingdom, The Health and Morals of Apprentices Act. The historical aims of OSH have been mostly safety matters, measurement problems, enhancing difficulty between well-being and health, and associated financial costs. In Malaysia, The Occupational Safety and Health Act 1994 (OSHA) was developed due to increased concern in enormous movement and transformation from year to year and was well-established in Feb 1994 in Malaysia. For further understanding, this paper discusses Occupational Safety and Health management in those countries. Based on the literature, different countries have different management systems in terms of administration. Besides, this paper also confers about the safety and health legislation that has been practiced in these three countries. The United States was concerned with protecting the workers from hazardous materials and chemicals, improving workplace performance, reducing workplace injuries and death, providing adequate information, and training to all employees especially those who engage in hazardous and dangerous works. In Malaysia, the purpose of the bureau is to encourage employers and workers to practise effective safety and health measures at the geographic point. This paper also proposes the safety and health management of composite industries in the United States, the United Kingdom, and Malaysia. Effective safety will solely be achieved once there is proper management of interaction between technological systems and other people.KeywordsOSH managementLegislationSafetyHealthComposite industry

Compilation of this list is the initial step in OSHA's screening process for suspected carcinogens. To compile this list, substances for which there was some evidence of carcinogenicity and potential occupational hazard were drawn from such lists the NIOSH Registry of Toxic Effects of Chemical Substances (RTECS); U.S. Public Health Service, Publication No. 149; EPA's Inventory of Chemical Substances; the

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Biological monitoring and standard setting in the USA: a critical appraisal