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OSHA: Hazardous Chemical Management Standard under Review

As a result of the April, 2013 fertilizer plant explosion in West, Texas, President Obama signed Executive Order 13650, “Improving Chemical Facility Safety and Security”, directing OSHA and other government agencies to improve operational coordination with state and local partners; improve federal agency coordination and information sharing; modernize policies, regulations, and standards; and identify best practices. Changes to the current OSHA standard regarding management of highly hazardous chemicals in the workplace (29 CFR Part 1910) are being fast tracked and will likely be significant.

The purpose of the standard, whether in current or revised form, is to prevent employee exposure to catastrophic chemical release accidents. Employers must comply if certain chemicals are present on site at or above a threshold quantity (TQ). The specific chemicals and associated TQs are listed in the standard at www.osha.gov, including chlorine, ozone, anhydrous ammonia, and flammable liquids.

Some of the changes to the standard currently under consideration are: removing the exemption for flammable liquids in tanks at atmospheric pressure; requiring that compliance self-audits be accomplished using third parties; expanding coverage to include reactive combinations of chemicals; expanding coverage to include ammonium nitrate; increased OSHA enforcement; and increased data reporting from employers.

Because the standard is under review and changes are inevitable, the chances of an OSHA visit are likely increased. AMRRP advises all Members to review their written plan and ensure any required updates are implemented and documented. This could include training, process hazard analysis, SOP certifications and compliance self-auditing.

For questions or help reviewing your municipality’s hazardous chemical standard operating procedure (SOP), feel free to contact AMRRP’s Nancy Graves-Green at (602) 368-6626 or [email protected]

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