OSHA Compliance

OSHA Compliance

Over two decades ago, OSHA implemented regulations for safe and healthy workplaces under the Safety Management of Highly Hazardous Chemicals. This law regulates the safety performance and procedures of companies or facilities that may handle highly hazardous chemicals.  ACC has a team of highly experienced experts that can assist clients develop and implement management plans that are most successful and within OSHA regulation.

EMPLOYEE PARTICIPATIONACC can help determine if:

• The employee participation clause that requires employees—including production and maintenance staff—be involved in every aspect of the PSM programs at their respective worksites.
• Employees are represented at the meetings where PSM-related issues are discussed.  Assist employers in creating formal PSM plans.

PROCESS SAFETY INFORMATION

ACC can help employer to:

• Determine adequacy of PSI and/or assist in the compilation of required PSI.
• Complete a compilation of written process safety information before conducting any process safety hazard analysis required by the standard.
• Ensure that all workers are able to access and understand the technical data regarding the HHC-related risks they face on the job.

PROCESS HAZARD ANALYSIS

ACC can assist the employer to perform and document the Process Hazard Analysis which requires that engineers and maintenance leaders analyze the consequences of safety failures. These analyses must be conducted in teams, and each team must include one person who is “knowledgeable in the specific process hazard methodology being used.

OPERATING PROCEDURES

ACC can help employers develop required startup procedures after turnarounds and emergency shutdowns.

TRAINING

ACC can train and document workers who carry out processes involving highly hazardous chemicals

CONTRACTORS

ACC can assist the employer in developing programs to inform contract employers of the known potential fire, explosion or toxic release hazards related to the contractor’s work and the process.”

PRE-STARTUP SAFETY REVIEW

ACC can assist employers to develop and perform pre-startup safety reviews for both new and modified facilities. This rule also applies if the procedural changes only affect a single component or process

MECHANICAL INTEGRITY

ACC can help develop periodic, documented inspections are required for systems, including:

• Pressure vessels
• Storage tanks
• Piping systems
• Ventilation systems

HOT WORK PERMIT

ACC can develop and implement the employer Hot Work Program to issue permits to employees and contractors who weld or perform other high-temperature work near covered processes. Employers also need to train their personnel to post and file these permits when necessary.

MANAGEMENT OF CHANGE

ACC can assist companies in developing standard procedures for managing changes to process chemicals, technology, equipment and procedures. Each change also requires the following considerations:

• The technical basis for the change.
• The impact of the change on worker safety and health.
• Necessary modifications to operating procedures.
• The necessary time period for the change.
• Authorization requirements for the proposed change.

INCIDENT INVESTIGATION

OSHA’s state standard calls for investigations for all incidents that result in—or could have resulted in—a catastrophic highly hazardous chemical release. Because of that ambiguous wording, cautious companies must keep every potential HHC-related scenario in mind.

EMERGENCY PLANNING AND RESPONSE

ACC can assist employers with emergency planning and responses for even minor chemical releases that can lead to major incidents. This element mandates employers to create emergency plans for handling smaller HHC releases.

COMPLIANCE AUDITS

ACC can audit and determine if an employer has adequately certified that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed.

TRADE SECRETS

ACC can assist employers in determining if their Trade Secrets policy gives employees the right to know processes that may affect their health and safety.