Instructions
The Occupational Safety and Health Administration’s (OSHA) Process Safety Management of Highly Hazardous Chemicals (PSM) standard (29 C.F.R. § 1910.119) contains requirements for the safe management of chemicals for facilities that exceed OSHA’s threshold quantities for highly hazardous substances. This standard requires the establishment of a PSM program that contains 14 elements for the safe management of hazards associated with the use, storage, manufacturing, handling, or moving of highly hazardous chemicals.
You have recently been promoted to the position of health, environmental, and safety (HES) manager at Marz Pulp and Paper, Inc. (MPP), a pulp and paper manufacturer that is located in the Pacific Northwest region of the United States. The company employs 120+ management, supervisory, operations, and ancillary personnel, including contractor employees from 15 different companies. MPP uses the kraft pulping process to convert wood chips to a pulp for use in their paper production process. The pulp mill is considered a covered facility pursuant to the PSM standard (29 C.F.R. §1910.119). The 14 elements of OSHA’s PSM standard are discussed in the document “Process Safety Management Guidelines for Compliance.” (https://www.osha.gov/Publications/osha3133.html)
You have been accompanying an OSHA inspector this past week on a PSM inspection of your pulp mill process facilities, including the review of all PSM-related operating procedures, process information, hazardous material, mechanical integrity inspection, and incident and training records. The OSHA inspector has completed their inspection of your facility and presented the following preliminary observations during the PSM inspection in the briefing for your facility management and operations supervisors:
Some of the hazardous materials of concern utilized at MPP’s facility are as shown below. (SEE THE ATTACHMENT)
Note: The hazardous material usage (in pounds) shown in the table is only for purposes of this assignment exercise and does not reflect the actual chemical usage at a commercial pulp mill.
Key facility PSM inspection observations were as shown below.
The frequency of the inspection and testing of process equipment was not performed in accordance with the manufacturer’s recommendations, good engineering practices, or prior operating experience.
Process equipment records for 65 of 422 records reviewed were missing either the name of the person who performed the inspection, the date of the inspection, or the serial number of the equipment.
The process hazard analysis performed by MPP did not address all of the process hazards.
MPP did not review or evaluate their contractor’s safety performance and safety programs during the contractor selection process.
No written plan of action for the implementation of employee participation in PSM/safety activities was available for review.
An incident investigation of a potentially catastrophic release of chlorine dioxide was not initiated as required by PSM within 48 hours following the incident.
MPP’s Emergency Action Plan does not include procedures for handling small releases of hazardous materials.
Your MPP management team is not familiar with the requirements of OSHA’s PSM standard. Although it will be several weeks before OSHA provides the formal PSM inspection report and findings, you plan to proactively schedule an internal follow-up meeting with your management team and operations supervisors to prepare them for what to expect, including possible citations and fines for violations of the PSM standard. At a minimum, the questions below need to be addressed at this meeting.
Discuss the purpose of OSHA’s PSM standard, including why it was initially implemented and its scope. Explain why MPP’s pulp mill manufacturing process is considered a covered facility under OSHA’s PSM standard. Identify which hazardous material(s) used at the pulp mill facility exceed the threshold quantities (TQ) shown in 29 C.F.R. § 1910.119 Appendix A.
Describe an oxidizer. Identify at least three oxidizers used at this MPP facility, and discuss their potential hazards to human health and the environment. Based on the OSHA 8-hour permissible exposure limit (PEL)/time-weighted average (TWA) for your three identified oxidizers, which one would pose the greatest threat to human health? Explain why, and elaborate on how you should respond if this oxidizer is accidentally released.
Review the OSHA inspector’s preliminary observations, and provide recommendations regarding how MPP can improve their compliance with at least three elements of OSHA’s PSM standard. Each recommendation you provide must discuss the noncompliance issue(s) observed, the specific PSM standard requirement, and what program changes need to be implemented to improve your company’s PSM compliance.
Your paper must be at least three pages in length, not including your title page and references page. You are required to cite the course textbook, the OSHA PSM standard, and at least two other sources in your response. All sources used, including the textbook, must be referenced. Paraphrased or quoted materials must have accompanying in-text citations and references in APA format. Please adhere to APA Style when creating citations and references for this assignment.
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