New Regulations to Pave Way for Greater IH Role
On April 17, 2013, an explosion at an ammonium nitrate storage and distribution facility in West, Texas, left 15 people dead, including 12 emergency responders, and more than 260 injured. The U.S. Chemical Safety and Hazard Investigation Board (CSB) would find that the responders were unaware of the hazards at the facility and that the community was unprepared to evacuate in the event of an emergency. Other factors that contributed to the severity of the incident, according to CSB, included poor planning and lack of local coordination.

The West fire and explosion was in the news again this past May, when the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) concluded its investigation and announced, to the surprise of many, that the fire was intentionally set. While media attention largely turned to the search for suspects, the fact remains that proper implementation of process safety could have reduced or eliminated casualties. Four months after the fire, President Obama issued an executive order establishing the Chemical Facility Safety and Security Working Group. The order tasked a number of government agencies to modernize chemical safety regulations, improve local emergency planning and coordination, and enhance the collection and sharing of information. Under the executive order, OSHA and EPA are working to promulgate new Process Safety Management (PSM) and Risk Management Program (RMP) regulations. While current versions of these regulations already require processes and procedures for ensuring safe chemical handling, production, and storage, both agencies’ new rules will provide ample opportunity for industrial hygienists to participate in process safety. CURRENT REGULATIONS Process safety regulatory action in the U.S. was first authorized by the Clean Air Act Amendments of 1990. OSHA subsequently established its PSM regulation in 1992. EPA published its RMP regulation in two stages, issuing a list of regulated substances and their threshold quantities in 1994 and a final RMP regulation containing risk management requirements in 1996. OSHA’s PSM focuses on protecting workers, while EPA’s RMP focuses on protecting public health and the environment. Together, PSM and RMP form a framework for the prevention of and protection from catastrophic chemical accidents. Industrial hygiene is essential to process safety, which incorporates many aspects of the profession, including the recognition, evaluation, control, and prevention of catastrophic releases of hazardous chemicals or energy from toxic, reactive, and flammable chemicals. At present, a number of industrial hygienists have indirect or moderate involvement in process safety. Their role may be limited to hazard training, accident investigation, and emergency planning and response, but several aspects of the current regulations provide opportunities for industrial hygienists to apply their relevant expertise to process safety. PSM requires the gathering of process safety information (PSI), including toxicity, exposure limits, physical data, and ventilation system design. In many facilities, industrial hygienists already gather and evaluate this information. Other work practices and conditions with which IHs are intimately familiar—process ventilation, exposure, ergonomics, effects of personal protective equipment and clothing, emergency response and planning, hazard communication, and training—can affect process safety conditions. Safety systems such as chemical detection and alarms, and even conditions that may affect employees’ decision-making abilities such as thermal stress, lighting, and noise, are considerations of process safety. All of these systems, conditions, controls, and human factors should be reviewed during a process hazard analysis (PHA). Both OSHA and EPA require a PHA to help identify and analyze potential hazards associated with the processing or handling of hazardous chemicals.
The current PSM regulation also requires that operating procedures address health and safety considerations. Employees must be aware of chemical hazards, engineering controls, administrative controls, personal protective equipment, and signs and symptoms of exposure. Training on these hazards and controls is required initially and then at least every three years.