Health & Safety Insights

Process Safety Management (PSM) is a performance-based, regulatory-required management system designed to protect workers from highly hazardous chemicals (HHC).

PSM applies to all companies that deal with any of more than 130 toxic and reactive chemicals in quantities listed in Appendix A of OSHA’s Process Safety Management of Highly Hazardous Chemicals Standard (29 CFR 1910.119).

J. J. Keller offers quick access to OSHA's 1910 General Industry and 1926 Constructure regulations along with other regulatory requirements within RegSense.

1910.119(d)(3)(ii) requires the employer document that PSM covered equipment complies with recognized and generally accepted good engineering practices. Additionally, 1910.119(e)(1) requires documentation of a PHA. Though OSHA doesn't outright say all 14 elements must be documented, remember "that which was not documented, was not done" meaning it's hard to demonstrate to OSHA something that isn't documented.

Yes. Refer to the TQs listed in 1910.119, Appendix A and consider how each will affect a potential incident or event in combination with the other.

The PSM standard at 1910.119(a)(1)(ii)(a) applies when the threshold quantity (TQ) hits 10,000# of a flammable liquid. Typically, they have flashpoints below 100 degrees F. PSM does have some exemptions, like hydrocarbons. Users should always refer to a product or chemical’s safety data sheet (SDS) and compare with the classifications outlined in 1910.119.

"Flammability" criteria for the PSM standard is Category 1 flammable gases (as defined by 1910.1200©) or flammable liquid with a flashpoint below 100 °F (37.8 °C) on site in one location, in a quantity of 10,000 pounds (4535.9 kg) or more. The only exceptions are Hydrocarbon fuels used solely for workplace consumption as a fuel or flammable liquids with a flashpoint below 100 °F (37.8 °C) stored in atmospheric tanks or transferred which are kept below their normal boiling point without benefit of chilling or refrigeration.

When it comes to water mixtures, there are so many variables that employers will want to review Appendix A to see what information is available for their specific mixtures.

There is the retail exemption, so you will want to look at it from the end user’s perspective. OSHA says apply the 50% rule. If half of your income is from direct sales are from retail of chemical quantities, you will apply. Warehouses and storage facilities do fall under PSM. 

LOI Feb 15, 1994 - "When processes are in close proximity to each other such that an incident in one process could involve the potential release of a highly hazardous chemical (HHC) in another process, these processes are considered to be a single process. Processes which are not in close proximity are considered to be at a remote distance." It's really up to the employer to determine and is based on type of chemical, quantity, equipment, and other factors.

The general response is “yes”. It is flammable and the TQ is 10,000#. OSHA published a letter of interpretation on March 14, 2000, that gives a great deep dive on PSM and propane.