Exposure to chemicals and other materials commonly used in the workplace can lead to a variety of health issues including poisoning, skin rashes, and disorders of the lungs, kidney and liver.

Keep your employees safe from injuries or illness related to hazardous materials.

Highlights from the Occupational Safety and Health Administration’s Part #1910

Written Action Plan
OSHA mandates that employers have a written plan of action and consult with their employees and representatives regarding hazard analyses and related process safety management.

Compile information that enables everyone to understand the hazards posed by toxic, reactive, flammable or explosive chemicals. This includes:

• Pertinent details on toxicity levels, permissible exposure limits, process technology and chemistry.
• Maximum intended inventory.
• Physical, reactivity and corrosivity data.
• Thermal and chemical stability data
• Potentially hazardous effects of inadvertently mixing different materials
• Upper and lower limits for temperature, flow and compositions
• Information relevant to equipment including construction materials, piping and instrument design, electrical classification and the design of relief and ventilation systems.

Process Hazard Analysis
As an employer, you must perform an initial hazard evaluation on processes being used in your workplace. This must be regularly updated and revalidated. OSHA requires that you use one of the following methodologies:

• What-If
• Checklist
• What-If/Checklist
• Hazardous and Operability Study
• Failure Mode and Effects Analysis

Or, you may utilize an appropriate equivalent methodology. Regardless, your analysis must address:

• All potential process hazards.
• Any previous incidents with the potential for catastrophic consequences.
• Engineering and administrative controls, such as the application of detection methodologies to provide early warning of releases.
• Facility siting.
• Human factors.

Analyses must be performed by a team with expertise in both engineering and process operations. At least one team member must have expertise specific to the process being evaluated and another must be knowledgeable in the particular methodology being used.

Finally, OSHA requires that you establish a system to promptly address team findings and assure timely resolution of any identified issues.

• Resolutions must be accurately documented and a written schedule of corrective actions developed.
• All actions and follow-up activity and progress must be communicated to affected workers.

Employee Training
Employees and contractors must be trained in the processes and procedures involved in managing and properly handling hazardous materials. This includes an emphasis on those specific to their positions and related tasks, such as emergency operations, shutdowns and other practices.

• Refresher training must be provided at least every three years.
• Contactors must be informed of any known fire, explosion or toxic release hazards related to their work. As an employer, you are responsible for periodically evaluating contractor performance in this regard.
• Contract employer must ensure that each of their employees is instructed in potential job hazards. This includes pre-start safety reviews.

Incident Investigation
An incident investigation team needs to be established, with at least one member knowledgeable in the specific process involved. The team is responsible for preparing a comprehensive report including:

• Date and description of the incident.
• Contributing factors.
• Resulting recommendations.

Compliance Audits
Process audits to ensure ongoing OSHA compliance must be completed at least once every three years to verify that procedures are adequate and are being consistently followed.

Visit www.osha.gov for further details or to review Part #1910 in its entirety. To learn more about best practices in developing your safety program, read our related posts or contact the HR workforce experts at Premium Staffing today.

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