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Unexpected releases of toxic, reactive, or flammable liquids and gases in processes involving highly hazardous chemicals have been reported for many years. Incidents continue to occur in various industries that use highly hazardous chemicals which may be toxic, reactive, flammable, or explosive, or may exhibit a combination of these properties.

Regardless of the industry that uses these highly hazardous chemicals, there is a potential for an accidental release any time they are not properly controlled. This, in turn, creates the possibility of disaster.

Record Disasters

Several major disasters involving highly hazardous chemicals drew international attention to the potential for major catastrophes; the public record in the U.S. is replete with information concerning many other less notable releases of highly hazardous chemicals.

Hazardous chemical releases continue to pose a significant threat to employees and provide impetus, internationally and nationally, for authorities to develop or consider developing legislation and regulations to eliminate or minimize the potential for such events.

 

On July 17, 1990, the U.S. Dept. of Labor, OSHA issued the “Process Safety Management of Highly Hazardous Chemicals” (PSM) (29 CFR 1910.119), containing requirements for the management of hazards associated with processes using highly hazardous chemicals to help assure safe and healthful workplaces.

OSHA’s PSM standard emphasizes the management of hazards associated with highly hazardous chemicals and establishes a comprehensive management program that integrates technologies, procedures, and management practices.

The Clean Air Act Amendments and the PSM Standard

Shortly after the publication of OSHA’s proposed PSM standard, Congress enacted the Clean Air Act Amendments (CAAA) which contained revisions to the Clean Air Act of 1990.

Section 304 of the CAAA requires that the Secretary of Labor, in coordination with the Administrator of the Environmental Protection Agency (EPA), promulgate a PSM standard to prevent accidental releases of chemicals that could pose a threat to employees.

The CAAA also requires that the PSM standard include a list of highly hazardous chemicals which includes toxic, flammable, highly reactive, and explosive substances.

CAAA Requirements for the PSM Standard

The CAAA requires that the standard include a list of highly hazardous chemicals which includes toxic, flammable, highly reactive, and explosive substances. These requirements have become widely known as the “14 PSM Program Elements.”

OSHA’s Final PSM Standard

The final PSM standard was promulgated in 1992 and requires the employer to incorporate each of the 14 key elements in a formal PSM program. The key provision of final PSM standard is process hazard analysis (PHA)—a careful review of what could go wrong and what safeguards must be implemented to prevent releases of hazardous chemicals. Employers must identify those processes that pose the greatest risks and begin evaluating those first.

PSM clarifies the responsibilities of employers and contractors involved in work that affects or takes place near hazardous processes to ensure that the safety of both plant and contractor employees is considered.

The standard also mandates written operating procedures; employee training; pre-startup safety reviews; evaluation of mechanical integrity of critical equipment; and written procedures for managing change. PSM specifies a permit system for hot work; investigation of incidents involving releases or near misses of covered chemicals; emergency, action plans; compliance audits at least every three years; and trade secret protection.

The final PSM standard mainly applies to manufacturing industries – particularly, those pertaining to chemicals, transportation equipment, and fabricated metal products. Other affected sectors include natural gas liquids; farm product warehousing; electric, gas, and sanitary services; and wholesale trade. It also applies to pyrotechnics and explosives manufacturers covered under other OSHA rules and has special provisions for contractors working in covered facilities.

The various lines of defense incorporated into the design and operation of the PSM process should be evaluated and strengthened to make sure they are effective at each level. Process safety management is the proactive identification, evaluation and mitigation or prevention of chemical releases that could occur as a result of failures in processes, procedures, or equipment.

Check Out: Ignoring Workplace Safety

What is a “process?”

To understand PSM and its requirements, employers and employees need to understand how OSHA uses the term “process” in PSM.

1. Any group of vessels which are interconnected, and
2. Separate vessels which are located such that a highly hazardous chemical could be involved in a potential release

For purposes of this definition, any group of vessels that are interconnected, and separate vessels located in a way that could involve a highly hazardous chemical in a potential release, are considered a single process.

What industries does PSM focus on?

The process safety management standard targets highly hazardous chemicals that have the potential to cause a catastrophic incident.

OSHA’s standard applies mainly to manufacturing industries–particularly those pertaining to chemicals, transportation equipment, and fabricated metal products.

Other affected sectors include those involved with:

• natural gas liquids
• farm product warehousing
• food processing
• electric, gas, and sanitary services
• wholesale trade
• pyrotechnics and explosives manufacturers

It has special provisions for contractors working in covered facilities.

Who is Not Covered by the PSM Standard?

The PSM standard does not apply to the following:

• retail facilities;
• oil or gas well drilling or servicing operations;
• normally unoccupied remote facilities;
• hydrocarbon fuels used solely for workplace consumption as a fuel (e.g. propane used for comfort heating, gasoline for vehicle refueling), if such fuels are not a part of a process containing another highly hazardous chemical covered by this standard; and
• flammable liquid stored in atmospheric tanks or transferred which are kept below their normal boiling point without benefit of chilling or refrigerating and are not connected to a process

To control these types of hazards, employers need to develop the necessary expertise, experience, judgment, and initiative within their work force to properly implement and maintain an effective process safety management program as envisioned in the OSHA PSM standard

 

Incident reporting is a vital component of creating a safer workplace. For the purpose of this article, an incident is any event which results in plant and equipment damage, injury or a “near hit.” The organization can only learn and change when there is a culture of full reporting. Prevention can only take place when there is sufficient knowledge to introduce change to the circumstances which created the incident. The importance of “near miss” cannot be emphasized enough. It is this behavior or the circumstances that are the precursor of an event causing loss.

Getting employees to report all incidents can be quite challenging. Plenty of companies have rules and policies that require the reporting of every single incident. The employee are clearly informed that they have been told and told frequently that accidents and incidents must be reported.

They are told that if they fail to report an accident or an incident, they will lose their job or be punished in some way. The threat of punishment is designed to make them comply with the rule. This creates a problem with the consequences of reporting an incident. The employees believe that reporting an incident will end up in a witch hunt so that blame can be apportioned. T

This is why it is so hard to get people to report incidents consistently and frequently.

The consequences if they don’t report are severe and the consequences if they do report may potentially be even worse. Given these choices is clear that by not reporting they have a better chance of avoiding consequences. When there is a system of reporting, maintaining it is just as difficult. Getting people to report depends on two major factors.

Firstly, it must be easy for them to report.

Secondly, work must be carried out to minimize anxiety.

Making it easy for people to report means that reporting forms are easy to find and accessible at all times. The design of the report must be simple and easy to complete either in a hard copy form or online. The questions must be set up in a logical fashion and pass the common sense test. This is a true system whether using paper forms or an online reporting system.

Check out this simple accident reporting form

When the system of reporting is installed there will be considerable anxiety until people are reassured by the consequences over a period of time. Initial anxiety can include, what will happen to the report? Who will see it? Am I damaging my career or career of others by submitting the report? Will I be subject to legal action if I report an incident?

To counter that anxiety, it is important that there is a written policy clearly explaining to everybody in the organization everything they should know about reporting. The policy should include what the consequences of reporting could be, what obligations people have to report, what rights and privileges they have and what protection they may expect. Without a written policy, uncertainty will prevail, and with uncertainty, reporting will be minimized.

Remove the Risk and Create the Right Environment For Incident Reporting

When the company safety culture encourages reporting using positive reinforcement, the rate of reporting increases. The people who are reporting the incidents are certain that they will not be blamed or punished because of their errors of judgment or mistakes. When this environment prevails, the staff within the organization understand that they can benefit much more by learning from the mistakes that have been made rather than being subjected to blame.

In most organizations, people do not feel that they can safely report incidents because reporting them can carry with it an element of risk. The risk lies in the possible consequences initiated by the supervisor, the manager, as well as the organization. People will be reluctant to report when they are unaware of their rights and obligations. There is also a sense of nervousness regarding the information being used outside the organization. When people feel this way, they will actively avoid reporting. These fears and doubts have to be eliminated to create the correct environment for incident reporting. Not only does it have to be said but also practiced because people will believe and trust the behavior before they believe the words.

Check Out: Incident Report Writing Guide

The reasons why reporting is so difficult to initiate are deeply embedded in the culture of the organization. This is why the organization must develop a consistent approach to the consequences of reporting. People avoid reporting not because they’re dishonest but because they simply don’t know the consequences of reporting, so they are uneasy about these unknown consequences. The organization and its management must be consistent in setting down what the consequences are for reporting and then stick to them.

The other barrier to comprehensive reporting is that the people know the consequences and believe that there is no point in reporting because the organization will not respond.

For the organization that is intent on creating a safer workplace, there is some serious work to be done in creating an environment which encourages people to report incidents. They have to make clear what the procedures and rules for reporting entail, the reporter’s rights and obligations and how the reporter will be protected when they report.

Check Out: Tips to Improve Accident Reporting

Punishment is an Ineffective Leadership Strategy

The measure of a leader is their ability to create an environment where followers produce their discretionary effort. Discretionary effort is probably best described as, “The behavior that a person chooses to do, but they wouldn’t be punished if they didn’t.” Without a doubt, it has been clearly established that discretionary effort is the outcome of positive reinforcement and never punishment. This means that the organization that uses punishment will never achieve significant levels of discretionary effort from their staff. From a leadership point of view, punishment is counterproductive, yet it can be seen every day in the workplace.

One of the byproducts of punishment is that the workplace behavior becomes less stable and predictable. On the other hand, positive reinforcement will create stable and predictable patterns of behavior. Look at your organization. During the goal setting process is negative reinforcement factor? If it is, any improvement or development will be limited to the goal. Just enough to avoid any negative reinforcement. The logic is inescapable. Positive reinforcement must be the preferred consequence in business for the simple reason that it is the only consequence that produces discretionary effort. Negative reinforcement has some unpleasant and unwelcome side effects. When it is used to as the predominant consequence, things start to go wrong. Absenteeism increases, staff turnover increases, disputes increase, blame becomes endemic and morale sinks.

When you look at the two methods of reinforcement, either positive or negative, it’s clear that the way to achieve anything is the use of positive reinforcement rather than punishment. Regrettably, negative reinforcement is by far the most common method of delivering consequences in today’s workplace. The majority of managers and leaders don’t know they are doing it. Groups that are managed by negative reinforcement, don’t say anything in case there is some form of retribution. Often, they won’t even give their opinion anonymously for the same reason.

Frequently, leaders may think that because they have very few face-to-face interactions with their teams, that they can’t possibly be negatively reinforcing them. Unfortunately, when there is no active, frequent and consistent positive reinforcement the effect is the same as constant and consistent negative reinforcement. This is how the group members perceive the way that they are being treated. The neglect of positive reinforcement creates negative reinforcement. This is clearly shown by the person in a leadership position who says, “You get on with the job and you will only hear from me if it goes wrong.” Obviously, this will not generate any discretionary effort and the person doing the job will take no risks, use no creative methods and to the barest minimum. This is obviously not very good formula for high performance

Putting on a workplace safety training workshop is a great way to prepare your employees for an emergency situation. This training workshop will need to include both general safety training for your industry, as well as specific safety training for hazards that directly impact your company, job sector, location. These training workshops need to be given to all of your employees, however, you can offer several sessions to make the group size more manageable.

5 Steps to a Successful Safety Training Workshop

Step #1 – Determine What General Safety Issues to Deal With

The first step is to determine what general safety procedures you want to teach your employees about. Common safety issues include medical emergencies, building security and fire emergencies. A good way to handle these training needs is to bring in a professional for each type of general safety issue. For example, you can bring in an instructor to teach employees CPR and general first aid, you can have the fire department put on a demonstration about fire safety and you can have your security company come in to teach your employees how to use the security system and how to stay safe.

Step #2 – Determine Hazard Specific Issues to Teach

The next step is to determine company specific hazards to deal with in your training workshop. For example, if your company works with hazardous materials like chemicals, then you will need to include an OSHA standards training segment that deals with the proper handling and safety protocols for chemicals. On the other hand, if you utilize heavy machinery, then you will want to include a segment on proper use of machinery, safety precautions for machine use and what to do if a body part or a foreign object gets caught in the machine.

Read: 10 Reasons Why Safety Training is Often Ineffective

Step #3 – Scheduling Concerns

After you have the format and topics of your workplace safety training workshops in place, your next step is to figure out how to set up the schedule. If you only have a few safety issues to cover then you can schedule one long workshop, however, if there are a lot of safety issues to cover then you will want to divide the issues into several workshops. Another scheduling concern you need to figure out is how to get all of your employees to attend the workshops without leaving your business unsupervised. You have a couple of options. Your first option is to schedule several repeat workshops that allow employees to be scheduled to attend the workshop in groups. Your second option is to hold one workshop for all employees on a day when the business is closed.

Step #4 – Put Together Your Training Materials

You need to put together training material for the workshop. This material will include instructions for responding to and managing specific safety issues, general information about each safety issue and a quiz. The material needs to be organized in a binder or folder, and one set of training materials needs to be published for each employee.

Check Out:  FREE pre-made trainings

Step #5 – Testing Your Employees

To ensure your employees have mastered the safety strategies in each segment of your training workshop you need to test them. A simple multiple choice quiz at the end of each segment is sufficient. After passing all of the quizzes you can award each employee with a certificate of completion.

Safety is good business and good for business. For the small business owner, initiatives taken to ensure employee and workplace safety are not only the right way to conduct business, but can result in lower costs, increased productivity, healthier profit margins,  and overall stronger employee morale.

What does OSHA require for small business owners?

OSHA maintains a set of six guidelines that are common to most general industry employers. These procedures protect yourself, your assets, the public you are in contact with in the course of your business and any employees you may be carrying.

1. Hazard Communication Standard

If your business uses or comes into contact with any material that is determined to be hazardous, as an employer it is your responsibility to make this known, mark the area clearly and have a plan in place to deal with any emergencies.

You must inform and maintain regular training of your employees regarding the proper use or disposal of any hazardous chemicals , as well as keep any storage areas well-maintained and inspected on a regular basis.

Learn more about the hazard communication standard

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2. Emergency Action Plan Standard

Depending on the physical size of your business location and the number of employees you may have, OSHA mandates that an emergency plan be available and ready to implement. The plan describes the expectations of both yourself, as the employer, and what your employees need to do to ensure their safety.

Included in this would be a visible evacuation plan, a means to report fires or other emergencies, a guide to any critical business operations that must be done during an emergency and a method to account for all employee whereabouts during the emergency.

Learn more about Emergency Action Plans

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3. Fire Safety

Employers must have a fire prevention plan that addresses the potential areas that a fire could initiate in, such as fuel sources or flammable chemicals. The plan also must address the requirement to install fixed extinguishing systems, such as overhead sprinklers, alarm systems and multiple portable extinguishers that are marked and inspected regularly.

Learn more about workplace fire safety

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4. Exit Routes

All exit routes must be marked and available for emergency use. Exit access must be free from obstructions and unlocked. Normally, a workplace must have two exits at a minimum, but depending on the location of your business or the number of employees you have, additional exits may be required.

Learn all about OSHA standards for emergency exits

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5. Walking / Working Surfaces

All businesses have areas that must be kept clean, free from debris and well maintained. This includes floors, aisles, stairways, ladders and platforms. Most accidents result from falls on ground surfaces or falls from elevated surfaces.

Make sure all surfaces are free from anything that could cause a fall and that all stairways have the correct amount of railings. Any scaffolding or powered manlifts must be properly working.

If you are conducting your business out of your home, these same standards apply. Make sure entrances are free from debris and uneven steps or holes, and that required handicapped access ramps are also easily accessible.

I have a whole series on Slip, trip, and fall, check out the free policy I have for free here

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6. Medical and First Aid

Medical and first-aid supplies must be kept on-hand and must be available to employees. As an employer, you need to expect that accidents will happen and be ready to address concerns, either minor or major ones.

Learn about OSHA requirements for first aid supplies and medical response

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The above six standards apply to any workplace environment, including small business owners. For more information on OSHA requirements, as well as protecting yourself from liability claims, review the OSHA Handbook for Small Businesses.

Effectively managing a fleet of vehicles within a company involves more than mere logistical coordination; it encompasses mitigating risks, ensuring the safety of both drivers and assets, and optimizing operational efficiency. Unfortunately, for many businesses, especially those with a limited number of vehicles or larger enterprises that may overlook the integral role of their fleet, the necessity for a robust Fleet Safety Program can be underestimated.

A company’s fleet, if not managed with diligence, can become a hidden source of shrink, contribute to accidents, and escalate insurance costs. While logistics and trucking companies often recognize the criticality of focusing on fleet safety due to the nature of their operations, smaller businesses with a handful of vehicles may not fully grasp the importance of implementing a comprehensive safety program.

To proactively protect both employees and the fleet itself, employers can take several measures:

1. Establish Comprehensive Policies: Designate a key member of the management team with the responsibility and authority to develop and enforce a comprehensive driver safety policy. This policy should encompass all aspects of safe driving practices, from vehicle maintenance to adherence to traffic regulations.
2. Mandatory Seat Belt Use: Prioritize safety by enforcing mandatory seat belt use among all drivers. This seemingly simple measure can significantly reduce the risk of injuries in the event of an accident and instill a culture of safety within the organization.
3. Thoughtful Management of Driving Hours: Avoid requiring workers to drive irregular hours or extend far beyond their normal working hours. Driver fatigue is a common factor in accidents, and establishing reasonable driving hour expectations helps mitigate this risk.
4. Prohibit Cell Phone Usage While Driving: Implement policies that prohibit workers from conducting business on a cell phone while driving. Distracted driving is a leading cause of accidents, and such policies contribute to a safer driving environment.
5. Develop Well-Considered Work Schedules: Create work schedules that allow employees to adhere to speed limits and comply with hours-of-service regulations. Thoughtful scheduling promotes safer driving practices and ensures compliance with industry regulations.

By implementing these comprehensive measures, businesses can transform their approach to fleet management, fostering a culture of safety, responsibility, and accountability. A well-structured Fleet Safety Program not only protects employees but also safeguards the company’s assets and minimizes potential liabilities. In the complex world of fleet management, prioritizing safety is an investment that pays dividends in the form of reduced accidents, lower insurance costs, and enhanced overall operational efficiency.

 

Check out this Sample Fleet Safety Policy from Secura Insurance

Fleet Management

• Adopt a structured vehicle maintenance program.
• Provide company vehicles that offer the highest possible levels of occupant protection.

Safety Programs

• Teach workers strategies for recognizing and managing driver fatigue and in-vehicle distractions.
• Provide training to workers operating specialized motor vehicles or equipment.
• Emphasize to workers the need to follow safe driving practices on and off the job.

Check out: How to Improve Your Safety Culture

Driver Performance

• Ensure that workers assigned to drive on the job have a valid driver’s license and one that is appropriate for the type of vehicle to be driven.
• Check driving records of prospective employees, and perform periodic rechecks after hiring.
• Maintain complete and accurate records of workers’ driving performance.

Source: NIOSH 2004-136:Work-related Roadway Crashes Prevention Strategies for Employers

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An unmanaged fleet can cost your company profits, sometimes undetectable on the surface.