Health & Safety Insights

How Flammable Gases Apply to PSM and RMP

Mitch Lagerstrom - Director of Consulting - EHS Practice

Date: 11/21/2022

OSHA’s Process Safety Management (PSM) of Highly Hazardous Chemicals Standard (29 CFR 1910.119) contains requirements for the management of hazards associated with processes using chemicals deemed to be “highly hazardous.” Processes that involve a category 1 flammable gas are subject to PSM if the quantity exceeds 10,000 pounds in one location in accordance with 29 CFR §1910.119(a)(1)(ii). Category 1 flammable gases are a highly hazardous chemical (HHC) under the PSM standard.

Any facility storing in excess of 10,000 pounds of these flammable gases becomes subject to PSM. This includes the state of California, which has similar language in the state code. Listing category 1 flammable gases as a category subjects any facility to the PSM standard if the total of all category 1 flammable gases exceeds 10,000 pounds. The only exception for category 1 flammable gases is if it is a fuel used for workplace consumption under 29 CFR §1910.119(a)(1)(ii)(A).

Storage of category 1 flammable gases below 10,000 pounds and any used as fuel at the workplace are required to be in compliance with OSHA’s General Duty Clause (GDC).

The Risk Management Plan (RMP) does not contain a provision including category 1 flammable gases, but it does include several category 1 flammable gases on the list of regulated flammable substances contained in Table 3 of 40 CFR §68 with a threshold of 10,000 pounds each. Each chemical individually is subject to RMP as an extremely hazardous substance (EHS) if the total quantity exceeds 10,000 pounds for each chemical separately. Storage of any of these chemicals below 10,000 pounds are required to be in compliance with EPA’s RMP GDC.

While these thresholds and requirements can be complex, compliance is critical for the safety of your employees and compliance of your company.