CSU Chemistry Purpose of OSHAs PSM Standard Paper


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 “

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Process Safety Management Guidelines for Compliance


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.

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.
    Chemistry of Some Oxidizers
    Course Learning Outcomes for Unit V
    Upon completion of this unit, students should be able to:
    2. Analyze chemical interactions as they relate to control of potential hazards.
    2.1 Determine the chemical interactions and associated hazards of some common oxidizers.
    4. Determine strategies for dealing with chemical properties of specific types of hazardous substances.
    4.1 Discuss recommended response actions or strategies in dealing with chemical properties,
    including potential releases of some common oxidizers.
    5. Research important standards related to hazardous substances.
    5.1 Research applicable standards to some common oxidizers.
    Learning Outcomes
    Learning Activity
    Unit Lesson
    Chapter 11, pp. 445–491
    Unit V Research Paper
    Unit Lesson
    Chapter 11, pp. 445–491
    Unit V Research Paper
    Unit Lesson
    Chapter 11, pp. 445–491
    Unit V Research Paper
    Required Unit Resources
    Chapter 11: Chemistry of Some Oxidizers, pp. 445–491
    Unit Lesson
    Unit V will focus on the chemistry of oxidizers, as discussed in Chapter 11 of your textbook. Although not
    directly covered in your textbook, in this unit, we will also learn the elements of process safety management
    (PSM). PSM is a regulation promulgated by the Occupational Safety and Health Administration (OSHA) to
    prevent the unwanted releases of highly hazardous materials into locations that could expose employees and
    the public to serious hazards (OSHA, n.d.-a; OSHA, n.d.-b). PSM will be discussed further at the end of this
    unit lesson.
    Oxidizers and Redox Reactions
    Most or all of you must have likely heard of oxidizers or oxidation-reduction reactions (redox in short). These
    reactions, when controlled, are beneficial to life. Some examples of redox reactions are the combustion of
    fuels, disinfection of water, household cleaning, and the spoiling of food. However, if such reactions are
    uncontrolled, the resulting fire or explosion or damage could result in the loss of life or property.
    OSH 3308, Interactions of Hazardous Materials
    Before we get into these redox reactions, we will first review what an oxidizer is.
    OSHA defines an oxidizer as any gas, liquid, or solid that gives up oxygen or other
    oxidizing gases readily or reacts to promote or initiate combustion of combustible
    materials. Under some circumstances, oxidizers can undergo vigorous selfsustained decomposition when subjected to heat or from contamination. The
    National Fire Protection Association (NFPA) and the U.S. Department of
    Transportation (DOT) have the same definition as OSHA for oxidizers (Meyer,
    2020). Note that an oxidizer does not necessarily have oxygen to give up. A
    substance that removes electrons from other substances is also an oxidizer (also
    known as an oxidizing agent). Therefore, an oxidizer may be elements such as
    oxygen, chlorine, fluorine, bromine and iodine, and acids or salts classified into
    families with associated hazards (Burke, 2003). If you recall from the periodic table
    in Unit I, these elements belong to the same family. An example of a common
    oxidizer is hydrogen peroxide.
    To learn redox reactions, we have to know what an oxidation number or oxidation
    state is. Meyer (2020) defines oxidation number as the ability of an ion or atom to
    combine with another ion or atom. It provides a way to keep track of electrons in
    redox reactions. Section 11.3 of your textbook describes the rules for assigning
    oxidation numbers.
    Bottle of hydrogen
    (Msmartchief, n.d.)
    In an oxidation process, there is an increase in oxidation number and a loss of
    electrons. Reduction is the opposite of oxidation, and there is a decrease in oxidation number and gain of
    electrons. In summary, there are three ways to recognize a redox reaction (Finch, 2015).
    Loss of electrons
    Gain of electrons
    Addition of oxygen
    Loss of oxygen
    Loss of hydrogen
    Addition of hydrogen
    See the examples below.
    Oxidation (iron is oxidized)
    4 Fe(s) + 3 O2(g) —-→ 2 Fe2O2 (s)
    Reduction (CO is reduced by the
    CO(g) + 2 H2(g) —–→ CH3OH (l) addition of hydrogen)
    Common Oxidizers
    Oxidizers react rapidly, even at explosive rates with other materials such as grease, lubricants, oils, cotton,
    animal and vegetable fats, paper, coal, coke, straw, sawdust, and wood shavings (Meyer, 2020). It should be
    noted that different oxidizers have different strengths; therefore, the resulting reaction is dependent on their
    strength as well as other factors.
    The textbook discusses several oxidizers in sufficient detail; therefore, it is not necessary to discuss them
    further in this unit lesson. Pay attention to their interaction (or decomposition) with various materials, which
    could be beneficial or harmful to human health. These oxidizers include are listed below:

    hydrogen peroxide;
    chlorine dioxide;
    metallic hypochlorites, such as sodium hypochlorite;
    oxidizers in fireworks and pyrotechnics;
    oxidizing chromium compounds (more commonly called hexavalent chromium with +6 oxidation
    sodium and potassium permanganate;
    metallic nitrite or nitrates;
    metallic peroxides and superoxides;
    OSH 3308, Interactions of Hazardous Materials

    potassium and sodium persulfate; and
    Some of these oxidizers are usually found in homes in lower concentrations. Many household products used
    to sanitize indoor/outdoor surfaces and swimming pools contain oxidizers such as calcium or sodium
    hypochlorite (bleach). Hydrogen peroxide is used to help heal insect bites, burns, etc., and it is also used in
    hair coloring products. Some have even used hydrogen peroxide to clean teeth.
    Fireworks are entertaining but inherently
    dangerous. Fireworks contain a mixture of
    pyrotechnic substances, of which there is an
    oxidizing agent and a reducing agent. The
    oxidizing agent could be sodium
    chlorite/chlorate, and the reducing agent
    could be charcoal, sulfur, pulverized
    magnesium, or aluminum flakes (Meyer,
    Multicolored fireworks display on a dark blue night sky
    There are only a few thermally stable
    (Smileus, n.d.)
    ammonium compounds, so their use is
    limited. A common compound that is used
    commercially is ammonium nitrate, which is
    used as a fertilizer. Another example of an ammonium compound that is also used is ammonium perchlorate.
    According to Meyer (2020), this accounts for approximately 70% of the solid propellants used by the
    aerospace industry.
    Notable incidents involving ammonium compounds are listed below.

    The SS Grandcamp ship was carrying nearly 2,280 tons of fertilizer grade ammonium nitrate in 1947
    when it caught fire. The heat generated by the fire resulted in the decomposition of the ammonium
    nitrate (Meyer, 2020). The decomposition products, oxygen, and nitrogen dioxide supported
    combustion in the storage hold of the ship, a confined space, resulting in an explosion.
    The 1947 High Flyer ship, which was anchored adjacent to the SS Grandcamp, exploded 15 hours
    after the SS Grandcamp explosion. The ship was carrying 1,000 tons of ammonium nitrate and 2,000
    tons of elemental sulfur (Meyer, 2020).
    In the 1995 Oklahoma City bombing of the Alfred P. Murrah Federal Building, fertilizer-grade
    ammonium nitrate and fuel oil were mixed and detonated (Meyer, 2020).
    Oxidation-reduction reactions, also called redox reactions, greatly benefit our modern lifestyle. When
    oxidation-reduction reactions are conducted in a controlled fashion, the energy they release can be
    harnessed to our advantage. However, when redox reactions occur in an uncontrolled fashion, the generated
    energy is released into the immediate environment where it can initiate or intensify fire and explosion,
    resulting in the loss of life and property. This necessitates the study of redox reactions by health, safety, and
    fire science professionals responding to hazardous materials incidents.
    Process Safety Management (PSM)
    Because oxidizers are commonly used in various industries at high concentrations, this would be a good unit
    to discuss PSM. PSM, as indicated above, is an OSHA standard to protect employees from unwanted or
    unexpected releases of highly hazardous materials. This standard, which contains 14 elements, is for the safe
    management of hazards associated with the use, storage, manufacturing, handling, or moving of highly
    hazardous chemicals. These elements are discussed on the webpage “Process Safety Management
    Guidelines for Compliance” and are listed below:

    process safety information,
    process hazard analysis,
    operating procedures,
    employee participation,
    OSH 3308, Interactions of Hazardous Materials

    pre-startup safety review,
    mechanical integrity,
    hot work permit,
    management of change,
    incident investigation,
    emergency planning and response,
    compliance, and
    trade secrets.
    A list of hazardous chemicals along with their specific PSM threshold quantities (TQ) is included in the
    webpage “Appendix A: List of Highly Hazardous Chemicals, Toxics and Reactives (Mandatory)” on the OSHA
    website. The process is subject to PSM if it uses one of the listed hazardous chemicals in excess of its TQ or
    is a PSM defined as a flammable chemical substance in excess of 10,000 pounds by weight.
    Burke, R. (2003). Hazardous chemistry for emergency responders (2nd ed.). Lewis.
    Finch, M. (2015). Chem 2 (2nd ed.). Cengage Learning.
    Meyer, E. (2020). Chemistry of hazardous materials (L. Mauerman, Ed.; 7th ed.). Pearson.
    Msmartchief. (n.d.). Brown plastic bottle of hydrogen peroxide. Isolated. Vertical [Illustration]. Dreamstime.
    Occupational Safety and Health Administration. (n.d.-a). Process safety management guidelines for
    compliance. https://www.osha.gov/Publications/osha3133.html
    Occupational Safety and Health Administration. (n.d.-b). PSM of highly hazardous chemicals.
    Smileus. (n.d.). Fireworks display panorama [Illustration]. Dreamstime. https://www.dreamstime.com/stockphoto-fireworks-display-panorama-gorgeous-multi-colored-dark-blue-night-sky-copyspaceimage47700394
    Learning Activities (Nongraded)
    Nongraded Learning Activities are provided to aid students in their course of study. You do not have to submit
    them. If you have questions, contact your instructor for further guidance and information.
    In order to access the following resources, click the links below.
    Review some of the key concepts from this unit by completing the Chapter 11 Practice Quiz (PDF version of
    the practice quiz). You can attempt as many times as you wish.
    OSH 3308, Interactions of Hazardous Materials

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