OSHA & Hazardous MaterialsAdvanced 30 min read

OSHA & Hazardous Materials: Advanced Safety Program Management I — Process Safety Management & the EPA Risk Management Program

Top-tier, program-owner-level coverage of OSHA's full Process Safety Management standard and EPA's Risk Management Program under the Clean Air Act — the two overlapping federal frameworks that govern facilities storing significant quantities of chlorine gas.

Two federal agencies, working from two different laws, both single out the same chemical your treatment plant likely stores in bulk: chlorine. OSHA regulates it as a catastrophic workplace hazard under the OSH Act; EPA regulates it as a catastrophic community hazard under the Clean Air Act. If you're at the top license class, you may be the person who has to make both programs work together — or the person deciding whether your utility should get out of gas chlorine entirely to avoid triggering either one. This guide covers both frameworks in full depth.

The Full PSM Program — 29 CFR 1910.119

As covered at the System Optimization tier, PSM applies once a process holds an Appendix A-listed chemical at or above its threshold quantity — for chlorine, 1,500 pounds. Once covered, the standard requires a comprehensive, interlocking set of program elements. Understood at the program-

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