356 

§§ 1910.112–1910.113 29 CFR Ch. XVII (7–1–15 Edition) 

marked in accordance with DOT regulations. 

(6) Farm vehicles. (i) Farm vehicles 

shall conform with State regulations. 

(ii) All trailers shall be securely attached to the vehicle drawing them by 

means of drawbars supplemented by 

suitable safety chains. 

(iii) A trailer shall be constructed so 

that it will follow substantially in the 

path of the towing vehicle and will not 

whip or swerve dangerously from side 

to side. 

(iv) All vehicles shall carry a can 

containing 5 gallons or more of water. 

(h) Systems mounted on farm vehicles 

for the application of ammonia. (1) This 

paragraph applies to systems utilizing 

containers of 250 gallons capacity or 

less which are mounted on farm vehicles (implement of husbandry) and used 

for the application of ammonia to the 

soil. Paragraph (b) of this section applies to this paragraph unless otherwise noted. Where larger containers are 

used, they shall comply with paragraph 

(g) of this section. 

(2) Design pressure and classification of 

containers. (i) The minimum design 

pressure for containers shall be 250 

p.s.i.g. 

(ii) The shell or head thickness of 

any container shall not be less than 

three-sixteenths inch. 

(3) Mounting of containers. All containers and flow-control devices shall 

be securely mounted. 

(4) Container valves and accessories. (i) 

Each container shall have a fixed liquid-level gage. 

(ii) The filling connection shall be 

fitted with a combination back-pressure check valve and an excess-flow 

valve; one double or two single backpressure check valves: or a positive 

shutoff valve in conjunction with an 

internal back-pressure check valve or 

an internal excess-flow valve. 

(iii) The applicator tank may be 

filled by venting to open air provided 

the bleeder valve orifice does not exceed seven-sixteenths inch in diameter. 

(iv) Regulation equipment may be 

connected directly to the tank coupling or flange, in which case a flexible 

connection shall be used between such 

regulating equipment and the remainder of the liquid withdrawal system. 

Regulating equipment not so installed 

shall be flexibly connected to the container shutoff valve. 

(v) No excess flow valve is required in 

the liquid withdrawal line provided the 

controlling orifice between the contents of the container and the outlet of 

the shutoff valve does not exceed 

seven-sixteenths inch in diameter. 

[39 FR 23502, June 27, 1974, as amended at 43 

FR 49748, Oct. 24, 1978; 49 FR 5322, Feb. 10, 

1984; 53 FR 12122, Apr. 12, 1988; 61 FR 9238, 

Mar. 7, 1996; 63 FR 1269, Jan. 8, 1998; 63 FR 

33466, June 18, 1998; 72 FR 71069, Dec. 14, 2007] 

§§ 1910.112–1910.113 [Reserved] 

§ 1910.119 Process safety management 

of highly hazardous chemicals. 

Purpose. This section contains requirements for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, 

flammable, or explosive chemicals. 

These releases may result in toxic, fire 

or explosion hazards. 

(a) Application. (1) This section applies to the following: 

(i) A process which involves a chemical at or above the specified threshold 

quantities listed in appendix A to this 

section; 

(ii) A process which involves a Category 1 flammable gas (as defined in 

1910.1200(c)) or a flammable liquid with 

a flashpoint below 100 °F (37.8 °C) on 

site in one location, in a quantity of 

10,000 pounds (4535.9 kg) or more except 

for: 

(A) Hydrocarbon fuels used solely for 

workplace consumption as a fuel (e.g., 

propane used for comfort heating, gasoline for vehicle refueling), if such fuels 

are not a part of a process containing 

another highly hazardous chemical 

covered by this standard; 

(B) Flammable liquids with a 

flashpoint below 100 °F (37.8 °C) stored 

in atmospheric tanks or transferred 

which are kept below their normal 

boiling point without benefit of 

chilling or refrigeration. 

(2) This section does not apply to: 

(i) Retail facilities; 

(ii) Oil or gas well drilling or servicing operations; or, 

(iii) Normally unoccupied remote facilities. 

(b) Definitions. Atmospheric tank 

means a storage tank which has been 

designed to operate at pressures from 


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atmospheric through 0.5 p.s.i.g. (pounds 

per square inch gauge, 3.45 Kpa). 

Boiling point means the boiling point 

of a liquid at a pressure of 14.7 pounds 

per square inch absolute (p.s.i.a.) (760 

mm.). For the purposes of this section, 

where an accurate boiling point is unavailable for the material in question, 

or for mixtures which do not have a 

constant boiling point, the 10 percent 

point of a distillation performed in accordance with the Standard Method of 

Test for Distillation of Petroleum 

Products, ASTM D–86–62, which is incorporated by reference as specified in 

§1910.6, may be used as the boiling 

point of the liquid. 

Catastrophic release means a major 

uncontrolled emission, fire, or explosion, involving one or more highly hazardous chemicals, that presents serious 

danger to employees in the workplace. 

Facility means the buildings, containers or equipment which contain a 

process. 

Highly hazardous chemical means a 

substance possessing toxic, reactive, 

flammable, or explosive properties and 

specified by paragraph (a)(1) of this 

section. 

Hot work means work involving electric or gas welding, cutting, brazing, or 

similar flame or spark-producing operations. 

Normally unoccupied remote facility 

means a facility which is operated, 

maintained or serviced by employees 

who visit the facility only periodically 

to check its operation and to perform 

necessary operating or maintenance 

tasks. No employees are permanently 

stationed at the facility. 

Facilities meeting this definition are 

not contiguous with, and must be geographically remote from all other 

buildings, processes or persons. 

Process means any activity involving 

a highly hazardous chemical including 

any use, storage, manufacturing, handling, or the on-site movement of such 

chemicals, or combination of these activities. For purposes of this definition, 

any group of vessels which are interconnected and separate vessels which 

are located such that a highly hazardous chemical could be involved in a 

potential release shall be considered a 

single process. 

Replacement in kind means a replacement which satisfies the design specification. 

Trade secret means any confidential 

formula, pattern, process, device, information or compilation of information 

that is used in an employer’s business, 

and that gives the employer an opportunity to obtain an advantage over 

competitors who do not know or use it. 

See Appendix E to §1910.1200—Definition of a Trade Secret (which sets out 

the criteria to be used in evaluating 

trade secrets). 

(c) Employee participation. (1) Employers shall develop a written plan of action regarding the implementation of 

the employee participation required by 

this paragraph. 

(2) Employers shall consult with employees and their representatives on 

the conduct and development of process hazards analyses and on the development of the other elements of process safety management in this standard. 

(3) Employers shall provide to employees and their representatives access to process hazard analyses and to 

all other information required to be developed under this standard. 

(d) Process safety information. In accordance with the schedule set forth in 

paragraph (e)(1) of this section, the employer shall complete a compilation of 

written process safety information before conducting any process hazard 

analysis required by the standard. The 

compilation of written process safety 

information is to enable the employer 

and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous 

chemicals. This process safety information shall include information pertaining to the hazards of the highly 

hazardous chemicals used or produced 

by the process, information pertaining 

to the technology of the process, and 

information pertaining to the equipment in the process. 

(1) Information pertaining to the hazards of the highly hazardous chemicals in 

the process. This information shall consist of at least the following: 

(i) Toxicity information; 

(ii) Permissible exposure limits; 

(iii) Physical data; 


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§ 1910.119 29 CFR Ch. XVII (7–1–15 Edition) 

(iv) Reactivity data: 

(v) Corrosivity data; 

(vi) Thermal and chemical stability 

data; and 

(vii) Hazardous effects of inadvertent 

mixing of different materials that 

could foreseeably occur. 

NOTE: Safety data sheets meeting the requirements of 29 CFR 1910.1200(g) may be 

used to comply with this requirement to the 

extent they contain the information required 

by this subparagraph. 

(2) Information pertaining to the technology of the process. (i) Information 

concerning the technology of the process shall include at least the following: 

(A) A block flow diagram or simplified process flow diagram (see appendix B to this section); 

(B) Process chemistry; 

(C) Maximum intended inventory; 

(D) Safe upper and lower limits for 

such items as temperatures, pressures, 

flows or compositions; and, 

(E) An evaluation of the consequences of deviations, including 

those affecting the safety and health of 

employees. 

(ii) Where the original technical information no longer exists, such information may be developed in conjunction with the process hazard analysis 

in sufficient detail to support the analysis. 

(3) Information pertaining to the equipment in the process. (i) Information pertaining to the equipment in the process 

shall include: 

(A) Materials of construction; 

(B) Piping and instrument diagrams 

(P&ID’s); 

(C) Electrical classification; 

(D) Relief system design and design 

basis; 

(E) Ventilation system design; 

(F) Design codes and standards employed; 

(G) Material and energy balances for 

processes built after May 26, 1992; and, 

(H) Safety systems (e.g. interlocks, 

detection or suppression systems). 

(ii) The employer shall document 

that equipment complies with recognized and generally accepted good engineering practices. 

(iii) For existing equipment designed 

and constructed in accordance with 

codes, standards, or practices that are 

no longer in general use, the employer 

shall determine and document that the 

equipment is designed, maintained, inspected, tested, and operating in a safe 

manner. 

(e) Process hazard analysis. (1) The 

employer shall perform an initial process hazard analysis (hazard evaluation) 

on processes covered by this standard. 

The process hazard analysis shall be 

appropriate to the complexity of the 

process and shall identify, evaluate, 

and control the hazards involved in the 

process. Employers shall determine and 

document the priority order for conducting process hazard analyses based 

on a rationale which includes such considerations as extent of the process 

hazards, number of potentially affected 

employees, age of the process, and operating history of the process. The 

process hazard analysis shall be conducted as soon as possible, but not 

later than the following schedule: 

(i) No less than 25 percent of the initial process hazards analyses shall be 

completed by May 26, 1994; 

(ii) No less than 50 percent of the initial process hazards analyses shall be 

completed by May 26, 1995; 

(iii) No less than 75 percent of the 

initial process hazards analyses shall 

be completed by May 26, 1996; 

(iv) All initial process hazards analyses shall be completed by May 26, 1997. 

(v) Process hazards analyses completed after May 26, 1987 which meet 

the requirements of this paragraph are 

acceptable as initial process hazards 

analyses. These process hazard analyses shall be updated and revalidated, 

based on their completion date, in accordance with paragraph (e)(6) of this 

section. 

(2) The employer shall use one or 

more of the following methodologies 

that are appropriate to determine and 

evaluate the hazards of the process 

being analyzed. 

(i) What-If; 

(ii) Checklist; 

(iii) What-If/Checklist; 

(iv) Hazard and Operability Study 

(HAZOP): 

(v) Failure Mode and Effects Analysis 

(FMEA); 

(vi) Fault Tree Analysis; or 

(vii) An appropriate equivalent methodology. 


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Occupational Safety and Health Admin., Labor § 1910.119 

(3) The process hazard analysis shall 

address: 

(i) The hazards of the process; 

(ii) The identification of any previous 

incident which had a likely potential 

for catastrophic consequences in the 

workplace; 

(iii) Engineering and administrative 

controls applicable to the hazards and 

their interrelationships such as appropriate application of detection methodologies to provide early warning of 

releases. (Acceptable detection methods might include process monitoring 

and control instrumentation with 

alarms, and detection hardware such as 

hydrocarbon sensors.); 

(iv) Consequences of failure of engineering and administrative controls; 

(v) Facility siting; 

(vi) Human factors; and 

(vii) A qualitative evaluation of a 

range of the possible safety and health 

effects of failure of controls on employees in the workplace. 

(4) The process hazard analysis shall 

be performed by a team with expertise 

in engineering and process operations, 

and the team shall include at least one 

employee who has experience and 

knowledge specific to the process being 

evaluated. Also, one member of the 

team must be knowledgeable in the 

specific process hazard analysis methodology being used. 

(5) The employer shall establish a 

system to promptly address the team’s 

findings and recommendations; assure 

that the recommendations are resolved 

in a timely manner and that the resolution is documented; document what 

actions are to be taken; complete actions as soon as possible; develop a 

written schedule of when these actions 

are to be completed; communicate the 

actions to operating, maintenance and 

other employees whose work assignments are in the process and who may 

be affected by the recommendations or 

actions. 

(6) At least every five (5) years after 

the completion of the initial process 

hazard analysis, the process hazard 

analysis shall be updated and revalidated by a team meeting the requirements in paragraph (e)(4) of this section, to assure that the process hazard 

analysis is consistent with the current 

process. 

(7) Employers shall retain process 

hazards analyses and updates or revalidations for each process covered by 

this section, as well as the documented 

resolution of recommendations described in paragraph (e)(5) of this section for the life of the process. 

(f) Operating procedures (1) The employer shall develop and implement 

written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements. 

(i) Steps for each operating phase: 

(A) Initial startup; 

(B) Normal operations; 

(C) Temporary operations; 

(D) Emergency shutdown including 

the conditions under which emergency 

shutdown is required, and the assignment of shutdown responsibility to 

qualified operators to ensure that 

emergency shutdown is executed in a 

safe and timely manner. 

(E) Emergency Operations; 

(F) Normal shutdown; and, 

(G) Startup following a turnaround, 

or after an emergency shutdown. 

(ii) Operating limits: 

(A) Consequences of deviation; and 

(B) Steps required to correct or avoid 

deviation. 

(iii) Safety and health considerations: 

(A) Properties of, and hazards presented by, the chemicals used in the 

process; 

(B) Precautions necessary to prevent 

exposure, including engineering controls, administrative controls, and personal protective equipment; 

(C) Control measures to be taken if 

physical contact or airborne exposure 

occurs; 

(D) Quality control for raw materials 

and control of hazardous chemical inventory levels; and, 

(E) Any special or unique hazards. 

(iv) Safety systems and their functions. 

(2) Operating procedures shall be 

readily accessible to employees who 

work in or maintain a process. 

(3) The operating procedures shall be 

reviewed as often as necessary to assure that they reflect current operating practice, including changes that 

result from changes in process chemicals, technology, and equipment, and 


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§ 1910.119 29 CFR Ch. XVII (7–1–15 Edition) 

changes to facilities. The employer 

shall certify annually that these operating procedures are current and accurate. 

(4) The employer shall develop and 

implement safe work practices to provide for the control of hazards during 

operations such as lockout/tagout; confined space entry; opening process 

equipment or piping; and control over 

entrance into a facility by maintenance, contractor, laboratory, or other 

support personnel. These safe work 

practices shall apply to employees and 

contractor employees. 

(g) Training—(1) Initial training. (i) 

Each employee presently involved in 

operating a process, and each employee 

before being involved in operating a 

newly assigned process, shall be 

trained in an overview of the process 

and in the operating procedures as 

specified in paragraph (f) of this section. The training shall include emphasis on the specific safety and health 

hazards, emergency operations including shutdown, and safe work practices 

applicable to the employee’s job tasks. 

(ii) In lieu of initial training for 

those employees already involved in 

operating a process on May 26, 1992, an 

employer may certify in writing that 

the employee has the required knowledge, skills, and abilities to safely 

carry out the duties and responsibilities as specified in the operating procedures. 

(2) Refresher training. Refresher training shall be provided at least every 

three years, and more often if necessary, to each employee involved in 

operating a process to assure that the 

employee understands and adheres to 

the current operating procedures of the 

process. The employer, in consultation 

with the employees involved in operating the process, shall determine the 

appropriate frequency of refresher 

training. 

(3) Training documentation. The employer shall ascertain that each employee involved in operating a process 

has received and understood the training required by this paragraph. The 

employer shall prepare a record which 

contains the identity of the employee, 

the date of training, and the means 

used to verify that the employee understood the training. 

(h) Contractors—(1) Application. This 

paragraph applies to contractors performing maintenance or repair, turnaround, major renovation, or specialty 

work on or adjacent to a covered process. It does not apply to contractors 

providing incidental services which do 

not influence process safety, such as 

janitorial work, food and drink services, laundry, delivery or other supply 

services. 

(2) Employer responsibilities. (i) The 

employer, when selecting a contractor, 

shall obtain and evaluate information 

regarding the contract employer’s safety performance and programs. 

(ii) The employer shall inform contract employers of the known potential 

fire, explosion, or toxic release hazards 

related to the contractor’s work and 

the process. 

(iii) The employer shall explain to 

contract employers the applicable provisions of the emergency action plan 

required by paragraph (n) of this section. 

(iv) The employer shall develop and 

implement safe work practices consistent with paragraph (f)(4) of this section, to control the entrance, presence 

and exit of contract employers and 

contract employees in covered process 

areas. 

(v) The employer shall periodically 

evaluate the performance of contract 

employers in fulfilling their obligations as specified in paragraph (h)(3) of 

this section. 

(vi) The employer shall maintain a 

contract employee injury and illness 

log related to the contractor’s work in 

process areas. 

(3) Contract employer responsibilities. 

(i) The contract employer shall assure 

that each contract employee is trained 

in the work practices necessary to safely perform his/her job. 

(ii) The contract employer shall assure that each contract employee is instructed in the known potential fire, 

explosion, or toxic release hazards related to his/her job and the process, 

and the applicable provisions of the 

emergency action plan. 

(iii) The contract employer shall document that each contract employee 

has received and understood the training required by this paragraph. The 

contract employer shall prepare a 


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Occupational Safety and Health Admin., Labor § 1910.119 

record which contains the identity of 

the contract employee, the date of 

training, and the means used to verify 

that the employee understood the 

training. 

(iv) The contract employer shall assure that each contract employee follows the safety rules of the facility including the safe work practices required by paragraph (f)(4) of this section. 

(v) The contract employer shall advise the employer of any unique hazards presented by the contract employer’s work, or of any hazards found by 

the contract employer’s work. 

(i) Pre-startup safety review. (1) The 

employer shall perform a pre-startup 

safety review for new facilities and for 

modified facilities when the modification is significant enough to require a 

change in the process safety information. 

(2) The pre-startup safety review 

shall confirm that prior to the introduction of highly hazardous chemicals 

to a process: 

(i) Construction and equipment is in 

accordance with design specifications; 

(ii) Safety, operating, maintenance, 

and emergency procedures are in place 

and are adequate; 

(iii) For new facilities, a process hazard analysis has been performed and 

recommendations have been resolved 

or implemented before startup; and 

modified facilities meet the requirements contained in management of 

change, paragraph (l). 

(iv) Training of each employee involved in operating a process has been 

completed. 

(j) Mechanical integrity—(1) Application. Paragraphs (j)(2) through (j)(6) of 

this section apply to the following 

process equipment: 

(i) Pressure vessels and storage 

tanks; 

(ii) Piping systems (including piping 

components such as valves); 

(iii) Relief and vent systems and devices; 

(iv) Emergency shutdown systems; 

(v) Controls (including monitoring 

devices and sensors, alarms, and interlocks) and, 

(vi) Pumps. 

(2) Written procedures. The employer 

shall establish and implement written 

procedures to maintain the on-going 

integrity of process equipment. 

(3) Training for process maintenance 

activities. The employer shall train each 

employee involved in maintaining the 

on-going integrity of process equipment in an overview of that process 

and its hazards and in the procedures 

applicable to the employee’s job tasks 

to assure that the employee can perform the job tasks in a safe manner. 

(4) Inspection and testing. (i) Inspections and tests shall be performed on 

process equipment. 

(ii) Inspection and testing procedures 

shall follow recognized and generally 

accepted good engineering practices. 

(iii) The frequency of inspections and 

tests of process equipment shall be consistent with applicable manufacturers’ 

recommendations and good engineering 

practices, and more frequently if determined to be necessary by prior operating experience. 

(iv) The employer shall document 

each inspection and test that has been 

performed on process equipment. The 

documentation shall identify the date 

of the inspection or test, the name of 

the person who performed the inspection or test, the serial number or other 

identifier of the equipment on which 

the inspection or test was performed, a 

description of the inspection or test 

performed, and the results of the inspection or test. 

(5) Equipment deficiencies. The employer shall correct deficiencies in 

equipment that are outside acceptable 

limits (defined by the process safety information in paragraph (d) of this section) before further use or in a safe and 

timely manner when necessary means 

are taken to assure safe operation. 

(6) Quality assurance. (i) In the construction of new plants and equipment, 

the employer shall assure that equipment as it is fabricated is suitable for 

the process application for which they 

will be used. 

(ii) Appropriate checks and inspections shall be performed to assure that 

equipment is installed properly and 

consistent with design specifications 

and the manufacturer’s instructions. 

(iii) The employer shall assure that 

maintenance materials, spare parts and 

equipment are suitable for the process 

application for which they will be used. 


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§ 1910.119 29 CFR Ch. XVII (7–1–15 Edition) 

(k) Hot work permit. (1) The employer 

shall issue a hot work permit for hot 

work operations conducted on or near a 

covered process. 

(2) The permit shall document that 

the fire prevention and protection requirements in 29 CFR 1910.252(a) have 

been implemented prior to beginning 

the hot work operations; it shall indicate the date(s) authorized for hot 

work; and identify the object on which 

hot work is to be performed. The permit shall be kept on file until completion of the hot work operations. 

(l) Management of change. (1) The employer shall establish and implement 

written procedures to manage changes 

(except for ‘‘replacements in kind’’) to 

process chemicals, technology, equipment, and procedures; and, changes to 

facilities that affect a covered process. 

(2) The procedures shall assure that 

the following considerations are addressed prior to any change: 

(i) The technical basis for the proposed change; 

(ii) Impact of change on safety and 

health; 

(iii) Modifications to operating procedures; 

(iv) Necessary time period for the 

change; and, 

(v) Authorization requirements for 

the proposed change. 

(3) Employees involved in operating a 

process and maintenance and contract 

employees whose job tasks will be affected by a change in the process shall 

be informed of, and trained in, the 

change prior to start-up of the process 

or affected part of the process. 

(4) If a change covered by this paragraph results in a change in the process 

safety information required by paragraph (d) of this section, such information shall be updated accordingly. 

(5) If a change covered by this paragraph results in a change in the operating procedures or practices required 

by paragraph (f) of this section, such 

procedures or practices shall be updated accordingly. 

(m) Incident investigation. (1) The employer shall investigate each incident 

which resulted in, or could reasonably 

have resulted in a catastrophic release 

of highly hazardous chemical in the 

workplace. 

(2) An incident investigation shall be 

initiated as promptly as possible, but 

not later than 48 hours following the 

incident. 

(3) An incident investigation team 

shall be established and consist of at 

least one person knowledgeable in the 

process involved, including a contract 

employee if the incident involved work 

of the contractor, and other persons 

with appropriate knowledge and experience to thoroughly investigate and 

analyze the incident. 

(4) A report shall be prepared at the 

conclusion of the investigation which 

includes at a minimum: 

(i) Date of incident; 

(ii) Date investigation began; 

(iii) A description of the incident; 

(iv) The factors that contributed to 

the incident; and, 

(v) Any recommendations resulting 

from the investigation. 

(5) The employer shall establish a 

system to promptly address and resolve 

the incident report findings and recommendations. Resolutions and corrective actions shall be documented. 

(6) The report shall be reviewed with 

all affected personnel whose job tasks 

are relevant to the incident findings including contract employees where applicable. 

(7) Incident investigation reports 

shall be retained for five years. 

(n) Emergency planning and response. 

The employer shall establish and implement an emergency action plan for 

the entire plant in accordance with the 

provisions of 29 CFR 1910.38. In addition, the emergency action plan shall 

include procedures for handling small 

releases. Employers covered under this 

standard may also be subject to the 

hazardous waste and emergency response provisions contained in 29 CFR 

1910.120 (a), (p) and (q). 

(o) Compliance Audits. (1) Employers 

shall certify 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. 

(2) The compliance audit shall be 

conducted by at least one person 

knowledgeable in the process. 

(3) A report of the findings of the 

audit shall be developed. 


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Occupational Safety and Health Admin., Labor § 1910.119 

(4) The employer shall promptly determine and document an appropriate 

response to each of the findings of the 

compliance audit, and document that 

deficiencies have been corrected. 

(5) Employers shall retain the two (2) 

most recent compliance audit reports. 

(p) Trade secrets. (1) Employers shall 

make all information necessary to 

comply with the section available to 

those persons responsible for compiling 

the process safety information (required by paragraph (d) of this section), 

those assisting in the development of 

the process hazard analysis (required 

by paragraph (e) of this section), those 

responsible for developing the operating procedures (required by paragraph (f) of this section), and those involved in incident investigations (required by paragraph (m) of this section), emergency planning and response 

(paragraph (n) of this section) and compliance audits (paragraph (o) of this 

section) without regard to possible 

trade secret status of such information. 

(2) Nothing in this paragraph shall 

preclude the employer from requiring 

the persons to whom the information is 

made available under paragraph (p)(1) 

of this section to enter into confidentiality agreements not to disclose the 

information as set forth in 29 CFR 

1910.1200. 

(3) Subject to the rules and procedures set forth in 29 CFR 1910.1200(i)(1) 

through 1910.1200(i)(12), employees and 

their designated representatives shall 

have access to trade secret information 

contained within the process hazard 

analysis and other documents required 

to be developed by this standard. 

APPENDIX A TO §1910.119—LIST OF HIGHLY

HAZARDOUS CHEMICALS, TOXICS AND

REACTIVES (MANDATORY) 

This appendix contains a listing of toxic 

and reactive highly hazardous chemicals 

which present a potential for a catastrophic 

event at or above the threshold quantity. 

CHEMICAL name CAS* TQ** 

Acetaldehyde ....................................... 75–07–0 2500 

Acrolein (2-Propenal) .......................... 107–02–8 150 

Acrylyl Chloride ................................... 814–68–6 250 

Allyl Chloride ....................................... 107–05–1 1000 

Allylamine ............................................ 107–11–9 1000 

Alkylaluminums .................................... Varies 5000 

Ammonia, Anhydrous .......................... 7664–41–7 10000 

Ammonia solutions (>44% ammonia 

by weight) ........................................ 7664–41–7 15000 

CHEMICAL name CAS* TQ** 

Ammonium Perchlorate ....................... 7790–98–9 7500 

Ammonium Permanganate .................. 7787–36–2 7500 

Arsine (also called Arsenic Hydride) ... 7784–42–1 100 

Bis(Chloromethyl) Ether ...................... 542–88–1 100 

Boron Trichloride ................................. 10294–34–5 2500 

Boron Trifluoride .................................. 7637–07–2 250 

Bromine ............................................... 7726–95–6 1500 

Bromine Chloride ................................. 13863–41–7 1500 

Bromine Pentafluoride ......................... 7789–30–2 2500 

Bromine Trifluoride .............................. 7787–71–5 15000 

3–Bromopropyne (also called Propargyl Bromide) ............................... 106–96–7 100 

Butyl Hydroperoxide (Tertiary) ............ 75–91–2 5000 

Butyl Perbenzoate (Tertiary) ............... 614–45–9 7500 

Carbonyl Chloride (see Phosgene) ..... 75–44–5 100 

Carbonyl Fluoride ................................ 353–50–4 2500 

Cellulose Nitrate (concentration 

>12.6% nitrogen ............................... 9004–70–0 2500 

Chlorine ............................................... 7782–50–5 1500 

Chlorine Dioxide .................................. 10049–04–4 1000 

Chlorine Pentrafluoride ........................ 13637–63–3 1000 

Chlorine Trifluoride .............................. 7790–91–2 1000 

Chlorodiethylaluminum (also called 

Diethylaluminum Chloride) ............... 96–10–6 5000 

1-Chloro-2,4-Dinitrobenzene ............... 97–00–7 5000 

Chloromethyl Methyl Ether .................. 107–30–2 500 

Chloropicrin ......................................... 76–06–2 500 

Chloropicrin and Methyl Bromide mixture ................................................... None 1500 

Chloropicrin and Methyl Chloride mixture ................................................... None 1500 

Cumene Hydroperoxide ...................... 80–15–9 5000 

Cyanogen ............................................ 460–19–5 2500 

Cyanogen Chloride .............................. 506–77–4 500 

Cyanuric Fluoride ................................ 675–14–9 100 

Diacetyl Peroxide (Concentration 

>70%) ............................................... 110–22–5 5000 

Diazomethane ..................................... 334–88–3 500 

Dibenzoyl Peroxide ............................. 94–36–0 7500 

Diborane .............................................. 19287–45–7 100 

Dibutyl Peroxide (Tertiary) .................. 110–05–4 5000 

Dichloro Acetylene .............................. 7572–29–4 250 

Dichlorosilane ...................................... 4109–96–0 2500 

Diethylzinc ........................................... 557–20–0 10000 

Diisopropyl Peroxydicarbonate ............ 105–64–6 7500 

Dilaluroyl Peroxide .............................. 105–74–8 7500 

Dimethyldichlorosilane ......................... 75–78–5 1000 

Dimethylhydrazine, 1,1- ....................... 57–14–7 1000 

Dimethylamine, Anhydrous ................. 124–40–3 2500 

2,4-Dinitroaniline .................................. 97–02–9 5000 

Ethyl Methyl Ketone Peroxide (also 

Methyl Ethyl Ketone Peroxide; concentration >60%) .............................. 1338–23–4 5000 

Ethyl Nitrite .......................................... 109–95–5 5000 

Ethylamine ........................................... 75–04–7 7500 

Ethylene Fluorohydrin ......................... 371–62–0 100 

Ethylene Oxide .................................... 75–21–8 5000 

Ethyleneimine ...................................... 151–56–4 1000 

Fluorine ................................................ 7782–41–4 1000 

Formaldehyde (Formalin) .................... 50–00–0 1000 

Furan ................................................... 110–00–9 500 

Hexafluoroacetone .............................. 684–16–2 5000 

Hydrochloric Acid, Anhydrous ............. 7647–01–0 5000 

Hydrofluoric Acid, Anhydrous .............. 7664–39–3 1000 

Hydrogen Bromide .............................. 10035–10–6 5000 

Hydrogen Chloride .............................. 7647–01–0 5000 

Hydrogen Cyanide, Anhydrous ........... 74–90–8 1000 

Hydrogen Fluoride ............................... 7664–39–3 1000 

Hydrogen Peroxide (52% by weight or 

greater) ............................................ 7722–84–1 7500 

Hydrogen Selenide .............................. 7783–07–5 150 

Hydrogen Sulfide ................................. 7783–06–4 1500 

Hydroxylamine ..................................... 7803–49–8 2500 

Iron, Pentacarbonyl ............................. 13463–40–6 250 


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§ 1910.119 29 CFR Ch. XVII (7–1–15 Edition) 

CHEMICAL name CAS* TQ** 

Isopropylamine .................................... 75–31–0 5000 

Ketene ................................................. 463–51–4 100 

Methacrylaldehyde .............................. 78–85–3 1000 

Methacryloyl Chloride .......................... 920–46–7 150 

Methacryloyloxyethyl Isocyanate ......... 30674–80–7 100 

Methyl Acrylonitrile .............................. 126–98–7 250 

Methylamine, Anhydrous ..................... 74–89–5 1000 

Methyl Bromide ................................... 74–83–9 2500 

Methyl Chloride ................................... 74–87–3 15000 

Methyl Chloroformate .......................... 79–22–1 500 

Methyl Ethyl Ketone Peroxide (concentration >60%) .............................. 1338–23–4 5000 

Methyl Fluoroacetate ........................... 453–18–9 100 

Methyl Fluorosulfate ............................ 421–20–5 100 

Methyl Hydrazine ................................. 60–34–4 100 

Methyl Iodide ....................................... 74–88–4 7500 

Methyl Isocyanate ............................... 624–83–9 250 

Methyl Mercaptan ................................ 74–93–1 5000 

Methyl Vinyl Ketone ............................ 79–84–4 100 

Methyltrichlorosilane ............................ 75–79–6 500 

Nickel Carbonly (Nickel Tetracarbonyl) 13463–39–3 150 

Nitric Acid (94.5% by weight or greater) ..................................................... 7697–37–2 500 

Nitric Oxide .......................................... 10102–43–9 250 

Nitroaniline (para Nitroaniline .............. 100–01–6 5000 

Nitromethane ....................................... 75–52–5 2500 

Nitrogen Dioxide .................................. 10102–44–0 250 

Nitrogen Oxides (NO; NO2; N204; 

N203) ............................................... 10102–44–0 250 

Nitrogen Tetroxide (also called Nitrogen Peroxide) .................................. 10544–72–6 250 

Nitrogen Trifluoride .............................. 7783–54–2 5000 

Nitrogen Trioxide ................................. 10544–73–7 250 

Oleum (65% to 80% by weight; also 

called Fuming Sulfuric Acid) ............ 8014–95–7 1,000 

Osmium Tetroxide ............................... 20816–12–0 100 

Oxygen Difluoride (Fluorine Monoxide) 7783–41–7 100 

Ozone .................................................. 10028–15–6 100 

Pentaborane ........................................ 19624–22–7 100 

Peracetic Acid (concentration >60% 

Acetic Acid; also called Peroxyacetic Acid) ...................................... 79–21–0 1000 

CHEMICAL name CAS* TQ** 

Perchloric Acid (concentration >60% 

by weight) ........................................ 7601–90–3 5000 

Perchloromethyl Mercaptan ................ 594–42–3 150 

Perchloryl Fluoride .............................. 7616–94–6 5000 

Peroxyacetic Acid (concentration 

>60% Acetic Acid; also called Peracetic Acid) ...................................... 79–21–0 1000 

Phosgene (also called Carbonyl Chloride) .................................................. 75–44–5 100 

Phosphine (Hydrogen Phosphide) ...... 7803–51–2 100 

Phosphorus Oxychloride (also called 

Phosphoryl Chloride) ....................... 10025–87–3 1000 

Phosphorus Trichloride ....................... 7719–12–2 1000 

Phosphoryl Chloride (also called 

Phosphorus Oxychloride) ................ 10025–87–3 1000 

Propargyl Bromide ............................... 106–96–7 100 

Propyl Nitrate ....................................... 627–3–4 2500 

Sarin .................................................... 107–44–8 100 

Selenium Hexafluoride ........................ 7783–79–1 1000 

Stibine (Antimony Hydride) ................. 7803–52–3 500 

Sulfur Dioxide (liquid) .......................... 7446–09–5 1000 

Sulfur Pentafluoride ............................. 5714–22–7 250 

Sulfur Tetrafluoride .............................. 7783–60–0 250 

Sulfur Trioxide (also called Sulfuric 

Anhydride) ........................................ 7446–11–9 1000 

Sulfuric Anhydride (also called Sulfur 

Trioxide) ........................................... 7446–11–9 1000 

Tellurium Hexafluoride ........................ 7783–80–4 250 

Tetrafluoroethylene .............................. 116–14–3 5000 

Tetrafluorohydrazine ............................ 10036–47–2 5000 

Tetramethyl Lead ................................ 75–74–1 1000 

Thionyl Chloride .................................. 7719–09–7 250 

Trichloro (chloromethyl) Silane ........... 1558–25–4 100 

Trichloro (dichlorophenyl) Silane ......... 27137–85–5 2500 

Trichlorosilane ..................................... 10025–78–2 5000 

Trifluorochloroethylene ........................ 79–38–9 10000 

Trimethyoxysilane ................................ 2487–90–3 1500 

*Chemical Abstract Service Number. 

**Threshold Quantity in Pounds (Amount necessary to be 

covered by this standard). 


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Occupational Safety and Health Admin., Labor § 1910.119 

APPENDIX B TO § 1910.119—BLOCK FLOW DIAGRAM AND SIMPLIFIED PROCESS

FLOW DIAGRAM (NONMANDATORY) 


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§ 1910.119 29 CFR Ch. XVII (7–1–15 Edition) 

APPENDIX C TO §1910.119—COMPLIANCE GUIDELINES AND RECOMMENDATIONS FOR PROCESS

SAFETY MANAGEMENT (NONMANDATORY) 

This appendix serves as a nonmandatory 

guideline to assist employers and employees 

in complying with the requirements of this 

section, as well as provides other helpful recommendations and information. Examples 

presented in this appendix are not the only 

means of achieving the performance goals in 

the standard. This appendix neither adds nor 

detracts from the requirements of the standard. 

1. Introduction to Process Safety Management. The major objective of process safety 

management of highly hazardous chemicals 

is to prevent unwanted releases of hazardous 

chemicals especially into locations which 

could expose employees and others to serious 

hazards. An effective process safety management program requires a systematic approach to evaluating the whole process. 

Using this approach the process design, process technology, operational and maintenance 

activities and procedures, nonroutine activities and procedures, emergency preparedness 

plans and procedures, training programs, and 

other elements which impact the process are 

all considered in the evaluation. The various 

lines of defense that have been incorporated 

into the design and operation of the process 

to prevent or mitigate the release of hazardous chemicals need to be evaluated and 

strengthened to assure their effectiveness at 

each level. Process safety management is the 

proactive identification, evaluation and 

mitigation or prevention of chemical releases that could occur as a result of failures 

in process, procedures or equipment. 

The process safety management standard 

targets highly hazardous chemicals that 


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Occupational Safety and Health Admin., Labor § 1910.119 

have the potential to cause a catastrophic 

incident. This standard as a whole is to aid 

employers in their efforts to prevent or mitigate episodic chemical releases that could 

lead to a catastrophe in the workplace and 

possibly to the surrounding community. To 

control these types of hazards, employers 

need to develop the necessary expertise, experiences, judgement and proactive initiative within their workforce to properly implement and maintain an effective process 

safety management program as envisioned in 

the OSHA standard. This OSHA standard is 

required by the Clean Air Act Amendments 

as is the Environmental Protection Agency’s 

Risk Management Plan. Employers, who 

merge the two sets of requirements into 

their process safety management program, 

will better assure full compliance with each 

as well as enhancing their relationship with 

the local community. 

While OSHA believes process safety management will have a positive effect on the 

safety of employees in workplaces and also 

offers other potential benefits to employers 

(increased productivity), smaller businesses 

which may have limited resources available 

to them at this time, might consider alternative avenues of decreasing the risks associated with highly hazardous chemicals at 

their workplaces. One method which might 

be considered is the reduction in the inventory of the highly hazardous chemical. This 

reduction in inventory will result in a reduction of the risk or potential for a catastrophic incident. Also, employers including 

small employers may be able to establish 

more efficient inventory control by reducing 

the quantities of highly hazardous chemicals 

on site below the established threshold quantities. This reduction can be accomplished 

by ordering smaller shipments and maintaining the minimum inventory necessary for efficient and safe operation. When reduced inventory is not feasible, then the employer 

might consider dispersing inventory to several locations on site. Dispersing storage 

into locations where a release in one location will not cause a release in another location is a practical method to also reduce the 

risk or portential for catastrophic incidents. 

2. Employee Involvement in Process Safety 

Management. Section 304 of the Clean Air Act 

Amendments states that employers are to 

consult with their employees and their representatives regarding the employers efforts 

in the development and implementation of 

the process safety management program elements and hazard assessments. Section 304 

also requires employers to train and educate 

their employees and to inform affected employees of the findings from incident investigations required by the process safety management program. Many employers, under 

their safety and health programs, have already established means and methods to 

keep employees and their representatives informed about relevant safety and health 

issues and employers may be able to adapt 

these practices and procedures to meet their 

obligations under this standard. Employers 

who have not implemented an occupational 

safety and health program may wish to form 

a safety and health committee of employees 

and management representatives to help the 

employer meet the obligations specified by 

this standard. These committees can become 

a significant ally in helping the employer to 

implement and maintain an effective process 

safety management program for all employees. 

3. Process Safety Information. Complete and 

accurate written information concerning 

process chemicals, process technology, and 

process equipment is essential to an effective 

process safety management program and to a 

process hazards analysis. The compiled information will be a necessary resource to a variety of users including the team that will 

perform the process hazards analysis as required under paragraph (e); those developing 

the training programs and the operating procedures; contractors whose employees will be 

working with the process; those conducting 

the pre-startup reviews; local emergency 

preparedness planners; and insurance and enforcement officials. 

The information to be compiled about the 

chemicals, including process intermediates, 

needs to be comprehensive enough for an accurate assessment of the fire and explosion 

characteristics, reactivity hazards, the safety and health hazards to workers, and the 

corrosion and erosion effects on the process 

equipment and monitoring tools. Current 

safety data sheet (SDS) information can be 

used to help meet this requirement which 

must be supplemented with process chemistry information including runaway reaction and over pressure hazards if applicable. 

Process technology information will be a 

part of the process safety information package and it is expected that it will include 

diagrams of the type shown in appendix B of 

this section as well as employer established 

criteria for maximum inventory levels for 

process chemicals; limits beyond which 

would be considered upset conditions; and a 

qualitative estimate of the consequences or 

results of deviation that could occur if operating beyond the established process limits. 

Employers are encouraged to use diagrams 

which will help users understand the process. 

A block flow diagram is used to show the 

major process equipment and interconnecting process flow lines and show flow 

rates, stream composition, temperatures, 

and pressures when necessary for clarity. 

The block flow diagram is a simplified diagram. 

Process flow diagrams are more complex 

and will show all main flow streams including valves to enhance the understanding of 


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§ 1910.119 29 CFR Ch. XVII (7–1–15 Edition) 

the process, as well as pressures and temperatures on all feed and product lines within all major vessels, in and out of headers 

and heat exchangers, and points of pressure 

and temperature control. Also, materials of 

construction information, pump capacities 

and pressure heads, compressor horsepower 

and vessel design pressures and temperatures 

are shown when necessary for clarity. In addition, major components of control loops 

are usually shown along with key utilities 

on process flow diagrams. 

Piping and instrument diagrams (P&IDs) 

may be the more appropriate type of diagrams to show some of the above details and 

to display the information for the piping designer and engineering staff. The P&IDs are 

to be used to describe the relationships between equipment and instrumentation as 

well as other relevant information that will 

enhance clarity. Computer software programs which do P&IDs or other diagrams 

useful to the information package, may be 

used to help meet this requirement. 

The information pertaining to process 

equipment design must be documented. In 

other words, what were the codes and standards relied on to establish good engineering 

practice. These codes and standards are published by such organizations as the American 

Society of Mechanical Engineers, American 

Petroleum Institute, American National 

Standards Institute, National Fire Protection Association, American Society for Testing and Materials, National Board of Boiler 

and Pressure Vessel Inspectors, National Association of Corrosion Engineers, American 

Society of Exchange Manufacturers Association, and model building code groups. 

In addition, various engineering societies 

issue technical reports which impact process 

design. For example, the American Institute 

of Chemical Engineers has published technical reports on topics such as two phase 

flow for venting devices. This type of technically recognized report would constitute 

good engineering practice. 

For existing equipment designed and constructed many years ago in accordance with 

the codes and standards available at that 

time and no longer in general use today, the 

employer must document which codes and 

standards were used and that the design and 

construction along with the testing, inspection and operation are still suitable for the 

intended use. Where the process technology 

requires a design which departs from the applicable codes and standards, the employer 

must document that the design and construction is suitable for the intended purpose. 

4. Process Hazard Analysis. A process hazard 

analysis (PHA), sometimes called a process 

hazard evaluation, is one of the most important elements of the process safety management program. A PHA is an organized and 

systematic effort to identify and analyze the 

significance of potential hazards associated 

with the processing or handling of highly 

hazardous chemicals. A PHA provides information which will assist employers and employees in making decisions for improving 

safety and reducing the consequences of unwanted or unplanned releases of hazardous 

chemicals. A PHA is directed toward analyzing potential causes and consequences of 

fires, explosions, releases of toxic or flammable chemicals and major spills of hazardous chemicals. The PHA focuses on equipment, instrumentation, utilities, human actions (routine and nonroutine), and external 

factors that might impact the process. These 

considerations assist in determining the hazards and potential failure points or failure 

modes in a process. 

The selection of a PHA methodology or 

technique will be influenced by many factors 

including the amount of existing knowledge 

about the process. Is it a process that has 

been operated for a long period of time with 

little or no innovation and extensive experience has been generated with its use? Or, is 

it a new process or one which has been 

changed frequently by the inclusion of innovative features? Also, the size and complexity of the process will influence the decision as to the appropriate PHA methodology 

to use. All PHA methodologies are subject to 

certain limitations. For example, the checklist methodology works well when the process is very stable and no changes are made, 

but it is not as effective when the process 

has undergone extensive change. The checklist may miss the most recent changes and 

consequently the changes would not be evaluated. Another limitation to be considered 

concerns the assumptions made by the team 

or analyst. The PHA is dependent on good 

judgement and the assumptions made during 

the study need to be documented and understood by the team and reviewer and kept for 

a future PHA. 

The team conducting the PHA need to understand the methodology that is going to be 

used. A PHA team can vary in size from two 

people to a number of people with varied 

operational and technical backgrounds. 

Some team members may only be a part of 

the team for a limited time. The team leader 

needs to be fully knowledgeable in the proper 

implementation of the PHA methodology 

that is to be used and should be impartial in 

the evaluation. The other full or part time 

team members need to provide the team with 

expertise in areas such as process technology, process design, operating procedures 

and practices, including how the work is actually performed, alarms, emergency procedures, instrumentation, maintenance procedures, both routine and nonroutine tasks, including how the tasks are authorized, procurement of parts and supplies, safety and 

health, and any other relevant subject as the 


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Occupational Safety and Health Admin., Labor § 1910.119 

need dictates. At least one team member 

must be familiar with the process. 

The ideal team will have an intimate 

knowledge of the standards, codes, specifications and regulations applicable to the process being studied. The selected team members need to be compatible and the team 

leader needs to be able to manage the team, 

and the PHA study. The team needs to be 

able to work together while benefiting from 

the expertise of others on the team or outside the team, to resolve issues, and to forge 

a consensus on the findings of the study and 

recommendations. 

The application of a PHA to a process may 

involve the use of different methodologies 

for various parts of the process. For example, 

a process involving a series of unit operation 

of varying sizes, complexities, and ages may 

use different methodologies and team members for each operation. Then the conclusions can be integrated into one final study 

and evaluation. A more specific example is 

the use of a checklist PHA for a standard 

boiler or heat exchanger and the use of a 

Hazard and Operability PHA for the overall 

process. Also, for batch type processes like 

custom batch operations, a generic PHA of a 

representative batch may be used where 

there are only small changes of monomer or 

other ingredient ratios and the chemistry is 

documented for the full range and ratio of 

batch ingredients. Another process that 

might consider using a generic type of PHA 

is a gas plant. Often these plants are simply 

moved from site to site and therefore, a generic PHA may be used for these movable 

plants. Also, when an employer has several 

similar size gas plants and no sour gas is 

being processed at the site, then a generic 

PHA is feasible as long as the variations of 

the individual sites are accounted for in the 

PHA. Finally, when an employer has a large 

continuous process which has several control 

rooms for different portions of the process 

such as for a distillation tower and a blending operation, the employer may wish to do 

each segment separately and then integrate 

the final results. 

Additionally, small businesses which are 

covered by this rule, will often have processes that have less storage volume, less capacity, and less complicated than processes 

at a large facility. Therefore, OSHA would 

anticipate that the less complex methodologies would be used to meet the process hazard analysis criteria in the standard. These 

process hazard analyses can be done in less 

time and with a few people being involved. A 

less complex process generally means that 

less data, P&IDs, and process information is 

needed to perform a process hazard analysis. 

Many small businesses have processes that 

are not unique, such as cold storage lockers 

or water treatment facilities. Where employer associations have a number of members with such facilities, a generic PHA, 

evolved from a checklist or what-if questions, could be developed and used by each 

employer effectively to reflect his/her particular process; this would simplify compliance for them. 

When the employer has a number of processes which require a PHA, the employer 

must set up a priority system of which PHAs 

to conduct first. A preliminary or gross hazard analysis may be useful in prioritizing the 

processes that the employer has determined 

are subject to coverage by the process safety 

management standard. Consideration should 

first be given to those processes with the potential of adversely affecting the largest 

number of employees. This prioritizing 

should consider the potential severity of a 

chemical release, the number of potentially 

affected employees, the operating history of 

the process such as the frequency of chemical releases, the age of the process and any 

other relevant factors. These factors would 

suggest a ranking order and would suggest 

either using a weighing factor system or a 

systematic ranking method. The use of a 

preliminary hazard analysis would assist an 

employer in determining which process 

should be of the highest priority and thereby 

the employer would obtain the greatest improvement in safety at the facility. 

Detailed guidance on the content and application of process hazard analysis methodologies is available from the American Institute of Chemical Engineers’ Center for 

Chemical Process Safety (see appendix D). 

5. Operating Procedures and Practices. Operating procedures describe tasks to be performed, data to be recorded, operating conditions to be maintained, samples to be collected, and safety and health precautions to 

be taken. The procedures need to be technically accurate, understandable to employees, and revised periodically to ensure that 

they reflect current operations. The process 

safety information package is to be used as 

a resource to better assure that the operating procedures and practices are consistent 

with the known hazards of the chemicals in 

the process and that the operating parameters are accurate. Operating procedures 

should be reviewed by engineering staff and 

operating personnel to ensure that they are 

accurate and provide practical instructions 

on how to actually carry out job duties safely. 

Operating procedures will include specific 

instructions or details on what steps are to 

be taken or followed in carrying out the 

stated procedures. These operating instructions for each procedure should include the 

applicable safety precautions and should 

contain appropriate information on safety 

implications. For example, the operating 

procedures addressing operating parameters 

will contain operating instructions about 

pressure limits, temperature ranges, flow 

rates, what to do when an upset condition 


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§ 1910.119 29 CFR Ch. XVII (7–1–15 Edition) 

occurs, what alarms and instruments are 

pertinent if an upset condition occurs, and 

other subjects. Another example of using operating instructions to properly implement 

operating procedures is in starting up or 

shutting down the process. In these cases, 

different parameters will be required from 

those of normal operation. These operating 

instructions need to clearly indicate the distinctions between startup and normal operations such as the appropriate allowances for 

heating up a unit to reach the normal operating parameters. Also the operating instructions need to describe the proper method for increasing the temperature of the unit 

until the normal operating temperature parameters are achieved. 

Computerized process control systems add 

complexity to operating instructions. These 

operating instructions need to describe the 

logic of the software as well as the relationship between the equipment and the control 

system; otherwise, it may not be apparent to 

the operator. 

Operating procedures and instructions are 

important for training operating personnel. 

The operating procedures are often viewed as 

the standard operating practices (SOPs) for 

operations. Control room personnel and operating staff, in general, need to have a full understanding of operating procedures. If workers are not fluent in English then procedures 

and instructions need to be prepared in a second language understood by the workers. In 

addition, operating procedures need to be 

changed when there is a change in the process as a result of the management of change 

procedures. The consequences of operating 

procedure changes need to be fully evaluated 

and the information conveyed to the personnel. For example, mechanical changes to 

the process made by the maintenance department (like changing a valve from steel to 

brass or other subtle changes) need to be 

evaluated to determine if operating procedures and practices also need to be changed. 

All management of change actions must be 

coordinated and integrated with current operating procedures and operating personnel 

must be oriented to the changes in procedures before the change is made. When the 

process is shut down in order to make a 

change, then the operating procedures must 

be updated before startup of the process. 

Training in how to handle upset conditions 

must be accomplished as well as what operating personnel are to do in emergencies 

such as when a pump seal fails or a pipeline 

ruptures. Communication between operating 

personnel and workers performing work 

within the process area, such as nonroutine 

tasks, also must be maintained. The hazards 

of the tasks are to be conveyed to operating 

personnel in accordance with established 

procedures and to those performing the actual tasks. When the work is completed, operating personnel should be informed to provide closure on the job. 

6. Employee Training. All employees, including maintenance and contractor employees, 

involved with highly hazardous chemicals 

need to fully understand the safety and 

health hazards of the chemicals and processes they work with for the protection of 

themselves, their fellow employees and the 

citizens of nearby communities. Training 

conducted in compliance with §1910.1200, the 

Hazard Communication standard, will help 

employees to be more knowledgeable about 

the chemicals they work with as well as familiarize them with reading and understanding SDSs. However, additional training 

in subjects such as operating procedures and 

safety work practices, emergency evacuation 

and response, safety procedures, routine and 

nonroutine work authorization activities, 

and other areas pertinent to process safety 

and health will need to be covered by an employer’s training program. 

In establishing their training programs, 

employers must clearly define the employees 

to be trained and what subjects are to be 

covered in their training. Employers in setting up their training program will need to 

clearly establish the goals and objectives 

they wish to achieve with the training that 

they provide to their employees. The learning goals or objectives should be written in 

clear measurable terms before the training 

begins. These goals and objectives need to be 

tailored to each of the specific training modules or segments. Employers should describe 

the important actions and conditions under 

which the employee will demonstrate competence or knowledge as well as what is acceptable performance. 

Hands-on-training where employees are 

able to use their senses beyond listening, 

will enhance learning. For example, operating personnel, who will work in a control 

room or at control panels, would benefit by 

being trained at a simulated control panel or 

panels. Upset conditions of various types 

could be displayed on the simulator, and 

then the employee could go through the 

proper operating procedures to bring the 

simulator panel back to the normal operating parameters. A training environment 

could be created to help the trainee feel the 

full reality of the situation but, of course, 

under controlled conditions. This realistic 

type of training can be very effective in 

teaching employees correct procedures while 

allowing them to also see the consequences 

of what might happen if they do not follow 

established operating procedures. Other 

training techniques using videos or on-thejob training can also be very effective for 

teaching other job tasks, duties, or other important information. An effective training 

program will allow the employee to fully 

participate in the training process and to 

practice their skill or knowledge. 


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Occupational Safety and Health Admin., Labor § 1910.119 

Employers need to periodically evaluate 

their training programs to see if the necessary skills, knowledge, and routines are 

being properly understood and implemented 

by their trained employees. The means or 

methods for evaluating the training should 

be developed along with the training program goals and objectives. Training program 

evaluation will help employers to determine 

the amount of training their employees understood, and whether the desired results 

were obtained. If, after the evaluation, it appears that the trained employees are not at 

the level of knowledge and skill that was expected, the employer will need to revise the 

training program, provide retraining, or provide more frequent refresher training sessions until the deficiency is resolved. Those 

who conducted the training and those who 

received the training should also be consulted as to how best to improve the training 

process. If there is a language barrier, the 

language known to the trainees should be 

used to reinforce the training messages and 

information. 

Careful consideration must be given to assure that employees including maintenance 

and contract employees receive current and 

updated training. For example, if changes 

are made to a process, impacted employees 

must be trained in the changes and understand the effects of the changes on their job 

tasks (e.g., any new operating procedures 

pertinent to their tasks). Additionally, as already discussed the evaluation of the employee’s absorption of training will certainly 

influence the need for training. 

7. Contractors. Employers who use contractors to perform work in and around processes 

that involve highly hazardous chemicals, 

will need to establish a screening process so 

that they hire and use contractors who accomplish the desired job tasks without compromising the safety and health of employees at a facility. For contractors, whose safety performance on the job is not known to 

the hiring employer, the employer will need 

to obtain information on injury and illness 

rates and experience and should obtain contractor references. Additionally, the employer must assure that the contractor has 

the appropriate job skills, knowledge and 

certifications (such as for pressure vessel 

welders). Contractor work methods and experiences should be evaluated. For example, 

does the contractor conducting demolition 

work swing loads over operating processes or 

does the contractor avoid such hazards? 

Maintaining a site injury and illness log 

for contractors is another method employers 

must use to track and maintain current 

knowledge of work activities involving contract employees working on or adjacent to 

covered processes. Injury and illness logs of 

both the employer’s employees and contract 

employees allow an employer to have full 

knowledge of process injury and illness experience. This log will also contain information which will be of use to those auditing 

process safety management compliance and 

those involved in incident investigations. 

Contract employees must perform their 

work safely. Considering that contractors 

often perform very specialized and potentially hazardous tasks such as confined space 

entry activities and nonroutine repair activities it is quite important that their activities be controlled while they are working on 

or near a covered process. A permit system 

or work authorization system for these activities would also be helpful to all affected 

employers. The use of a work authorization 

system keeps an employer informed of contract employee activities, and as a benefit 

the employer will have better coordination 

and more management control over the work 

being performed in the process area. A well 

run and well maintained process where employee safety is fully recognized will benefit 

all of those who work in the facility whether 

they be contract employees or employees of 

the owner. 

8. Pre-Startup Safety. For new processes, 

the employer will find a PHA helpful in improving the design and construction of the 

process from a reliability and quality point 

of view. The safe operation of the new process will be enhanced by making use of the 

PHA recommendations before final installations are completed. P&IDs are to be completed along with having the operating procedures in place and the operating staff 

trained to run the process before startup. 

The initial startup procedures and normal 

operating procedures need to be fully evaluated as part of the pre-startup review to assure a safe transfer into the normal operating mode for meeting the process parameters. 

For existing processes that have been shutdown for turnaround, or modification, etc., 

the employer must assure that any changes 

other than ‘‘replacement in kind’’ made to 

the process during shutdown go through the 

management of change procedures. P&IDs 

will need to be updated as necessary, as well 

as operating procedures and instructions. If 

the changes made to the process during shutdown are significant and impact the training 

program, then operating personnel as well as 

employees engaged in routine and nonroutine work in the process area may need some 

refresher or additional training in light of 

the changes. Any incident investigation recommendations, compliance audits or PHA 

recommendations need to be reviewed as 

well to see what impacts they may have on 

the process before beginning the startup. 

9. Mechanical Integrity. Employers will need 

to review their maintenance programs and 

schedules to see if there are areas where 

‘‘breakdown’’ maintenance is used rather 

than an on-going mechanical integrity program. Equipment used to process, store, or 


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§ 1910.119 29 CFR Ch. XVII (7–1–15 Edition) 

handle highly hazardous chemicals needs to 

be designed, constructed, installed and maintained to minimize the risk of releases of 

such chemicals. This requires that a mechanical integrity program be in place to assure 

the continued integrity of process equipment. Elements of a mechanical integrity 

program include the identification and categorization of equipment and instrumentation, inspections and tests, testing and inspection frequencies, development of maintenance procedures, training of maintenance 

personnel, the establishment of criteria for 

acceptable test results, documentation of 

test and inspection results, and documentation of manufacturer recommendations as to 

meantime to failure for equipment and instrumentation. 

The first line of defense an employer has 

available is to operate and maintain the 

process as designed, and to keep the chemicals contained. This line of defense is backed 

up by the next line of defense which is the 

controlled release of chemicals through 

venting to scrubbers or flares, or to surge or 

overflow tanks which are designed to receive 

such chemicals, etc. These lines of defense 

are the primary lines of defense or means to 

prevent unwanted releases. The secondary 

lines of defense would include fixed fire protection systems like sprinklers, water spray, 

or deluge systems, monitor guns, etc., dikes, 

designed drainage systems, and other systems which would control or mitigate hazardous chemicals once an unwanted release 

occurs. These primary and secondary lines of 

defense are what the mechanical integrity 

program needs to protect and strengthen 

these primary and secondary lines of defenses where appropriate. 

The first step of an effective mechanical 

integrity program is to compile and categorize a list of process equipment and instrumentation for inclusion in the program. 

This list would include pressure vessels, storage tanks, process piping, relief and vent 

systems, fire protection system components, 

emergency shutdown systems and alarms 

and interlocks and pumps. For the categorization of instrumentation and the listed 

equipment the employer would prioritize 

which pieces of equipment require closer 

scrutiny than others. Meantime to failure of 

various instrumentation and equipment 

parts would be known from the manufacturers data or the employer’s experience with 

the parts, which would then influence the inspection and testing frequency and associated procedures. Also, applicable codes and 

standards such as the National Board Inspection Code, or those from the American Society for Testing and Material, American Petroleum Institute, National Fire Protection 

Association, American National Standards 

Institute, American Society of Mechanical 

Engineers, and other groups, provide information to help establish an effective testing 

and inspection frequency, as well as appropriate methodologies. 

The applicable codes and standards provide 

criteria for external inspections for such 

items as foundation and supports, anchor 

bolts, concrete or steel supports, guy wires, 

nozzles and sprinklers, pipe hangers, grounding connections, protective coatings and insulation, and external metal surfaces of piping and vessels, etc. These codes and standards also provide information on methodologies for internal inspection, and a frequency 

formula based on the corrosion rate of the 

materials of construction. Also, erosion both 

internal and external needs to be considered 

along with corrosion effects for piping and 

valves. Where the corrosion rate is not 

known, a maximum inspection frequency is 

recommended, and methods of developing 

the corrosion rate are available in the codes. 

Internal inspections need to cover items 

such as vessel shell, bottom and head; metallic linings; nonmetallic linings; thickness 

measurements for vessels and piping; inspection for erosion, corrosion, cracking and 

bulges; internal equipment like trays, baffles, sensors and screens for erosion, corrosion or cracking and other deficiencies. 

Some of these inspections may be performed 

by state of local government inspectors 

under state and local statutes. However, 

each employer needs to develop procedures 

to ensure that tests and inspections are conducted properly and that consistency is 

maintained even where different employees 

may be involved. Appropriate training is to 

be provided to maintenance personnel to ensure that they understand the preventive 

maintenance program procedures, safe practices, and the proper use amd application of 

special equipment or unique tools that may 

be required. This training is part of the overall training program called for in the standard. 

A quality assurance system is needed to 

help ensure that the proper materials of construction are used, that fabrication and inspection procedures are proper, and that installation procedures recognize field installation concerns. The quality assurance program is an essential part of the mechanical 

integrity program and will help to maintain 

the primary and secondary lines of defense 

that have been designed into the process to 

prevent unwanted chemical releases or those 

which control or mitigate a release. ‘‘As 

built’’ drawings, together with certifications 

of coded vessels and other equipment, and 

materials of construction need to be verified 

and retained in the quality assurance documentation. Equipment installation jobs need 

to be properly inspected in the field for use 

of proper materials and procedures and to assure that qualified craftsmen are used to do 

the job. The use of appropriate gaskets, 

packing, bolts, valves, lubricants and welding rods need to be verified in the field. Also 


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Occupational Safety and Health Admin., Labor § 1910.119 

procedures for installation of safety devices 

need to be verified, such as the torque on the 

bolts on ruptured disc installations, uniform 

torque on flange bolts, proper installation of 

pump seals, etc. If the quality of parts is a 

problem, it may be appropriate to conduct 

audits of the equipment supplier’s facilities 

to better assure proper purchases of required 

equipment which is suitable for its intended 

service. Any changes in equipment that may 

become necessary will need to go through 

the management of change procedures. 

10. Nonroutine Work Authorizations. Nonroutine work which is conducted in process 

areas needs to be controlled by the employer 

in a consistent manner. The hazards identified involving the work that is to be accomplished must be communicated to those 

doing the work, but also to those operating 

personnel whose work could affect the safety 

of the process. A work authorization notice 

or permit must have a procedure that describes the steps the maintenance supervisor, contractor representative or other person needs to follow to obtain the necessary 

clearance to get the job started. The work 

authorization procedures need to reference 

and coordinate, as applicable, lockout/tagout 

procedures, line breaking procedures, confined space entry procedures and hot work 

authorizations. This procedure also needs to 

provide clear steps to follow once the job is 

completed in order to provide closure for 

those that need to know the job is now completed and equipment can be returned to normal. 

11. Managing Change. To properly manage 

changes to process chemicals, technology, 

equipment and facilities, one must define 

what is meant by change. In this process 

safety management standard, change includes all modifications to equipment, procedures, raw materials and processing conditions other than ‘‘replacement in kind’’. 

These changes need to be properly managed 

by identifying and reviewing them prior to 

implementation of the change. For example, 

the operating procedures contain the operating parameters (pressure limits, temperature ranges, flow rates, etc.) and the importance of operating within these limits. While 

the operator must have the flexibility to 

maintain safe operation within the established parameters, any operation outside of 

these parameters requires review and approval by a written management of change 

procedure. 

Management of change covers such as 

changes in process technology and changes 

to equipment and instrumentation. Changes 

in process technology can result from 

changes in production rates, raw materials, 

experimentation, equipment unavailability, 

new equipment, new product development, 

change in catalyst and changes in operating 

conditions to improve yield or quality. 

Equipment changes include among others 

change in materials of construction, equipment specifications, piping pre-arrangements, experimental equipment, computer 

program revisions and changes in alarms and 

interlocks. Employers need to establish 

means and methods to detect both technical 

changes and mechanical changes. 

Temporary changes have caused a number 

of catastrophes over the years, and employers need to establish ways to detect temporary changes as well as those that are permanent. It is important that a time limit for 

temporary changes be established and monitored since, without control, these changes 

may tend to become permanent. Temporary 

changes are subject to the management of 

change provisions. In addition, the management of change procedures are used to insure 

that the equipment and procedures are returned to their original or designed conditions at the end of the temporary change. 

Proper documentation and review of these 

changes is invaluable in assuring that the 

safety and health considerations are being 

incorporated into the operating procedures 

and the process. 

Employers may wish to develop a form or 

clearance sheet to facilitate the processing 

of changes through the management of 

change procedures. A typical change form 

may include a description and the purpose of 

the change, the technical basis for the 

change, safety and health considerations, 

documentation of changes for the operating 

procedures, maintenance procedures, inspection and testing, P&IDs, electrical classification, training and communications, prestartup inspection, duration if a temporary 

change, approvals and authorization. Where 

the impact of the change is minor and well 

understood, a check list reviewed by an authorized person with proper communication 

to others who are affected may be sufficient. 

However, for a more complex or significant 

design change, a hazard evaluation procedure 

with approvals by operations, maintenance, 

and safety departments may be appropriate. 

Changes in documents such as P&IDs, raw 

materials, operating procedures, mechanical 

integrity programs, electrical classifications, etc., need to be noted so that these revisions can be made permanent when the 

drawings and procedure manuals are updated. Copies of process changes need to be 

kept in an accessible location to ensure that 

design changes are available to operating 

personnel as well as to PHA team members 

when a PHA is being done or one is being updated. 

12. Investigation of Incidents. Incident investigation is the process of identifying the underlying causes of incidents and implementing steps to prevent similar events from 

occurring. The intent of an incident investigation is for employers to learn from past 

experiences and thus avoid repeating past 


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§ 1910.119 29 CFR Ch. XVII (7–1–15 Edition) 

mistakes. The incidents for whicn OSHA expects employers to become aware and to investigate are the types of events which result in or could reasonably have resulted in 

a catastrophic release. Some of the events 

are sometimes referred to as ‘‘near misses,’’ 

meaning that a serious consequence did not 

occur, but could have. 

Employers need to develop in-house capability to investigate incidents that occur in 

their facilities. A team needs to be assembled by the employer and trained in the techniques of investigation including how to conduct interviews of witnesses, needed documentation and report writing. A multi-disciplinary team is better able to gather the 

facts of the event and to analyze them and 

develop plausible scenarios as to what happened, and why. Team members should be selected on the basis of their training, knowledge and ability to contribute to a team effort to fully investigate the incident. Employees in the process area where the incident occurred should be consulted, interviewed or made a member of the team. Their 

knowledge of the events form a significant 

set of facts about the incident which occurred. The report, its findings and recommendations are to be shared with those 

who can benefit from the information. The 

cooperation of employees is essential to an 

effective incident investigation. The focus of 

the investigation should be to obtain facts, 

and not to place blame. The team and the investigation process should clearly deal with 

all involved individuals in a fair, open and 

consistent manner. 

13. Emergency Preparedness. Each employer 

must address what actions employees are to 

take when there is an unwanted release of 

highly hazardous chemicals. Emergency preparedness or the employer’s tertiary (third) 

lines of defense are those that will be relied 

on along with the secondary lines of defense 

when the primary lines of defense which are 

used to prevent an unwanted release fail to 

stop the release. Employers will need to decide if they want employees to handle and 

stop small or minor incidental releases. 

Whether they wish to mobilize the available 

resources at the plant and have them 

brought to bear on a more significant release. Or whether employers want their employees to evacuate the danger area and 

promptly escape to a preplanned safe zone 

area, and allow the local community emergency response organizations to handle the 

release. Or whether the employer wants to 

use some combination of these actions. Employers will need to select how many different emergency preparedness or tertiary 

lines of defense they plan to have and then 

develop the necessary plans and procedures, 

and appropriately train employees in their 

emergency duties and responsibilities and 

then implement these lines of defense. 

Employers at a minimum must have an 

emergency action plan which will facilitate 

the prompt evacuation of employees due to 

an unwanted release of a highly hazardous 

chemical. This means that the employer will 

have a plan that will be activated by an 

alarm system to alert employees when to 

evacuate and, that employees who are physically impaired, will have the necessary support and assistance to get them to the safe 

zone as well. The intent of these requirements is to alert and move employees to a 

safe zone quickly. Delaying alarms or confusing alarms are to be avoided. The use of 

process control centers or similar process 

buildings in the process area as safe areas is 

discouraged. Recent catastrophes have 

shown that a large life loss has occurred in 

these structures because of where they have 

been sited and because they are not necessarily designed to withstand over-pressures 

from shockwaves resulting from explosions 

in the process area. 

Unwanted incidental releases of highly 

hazardous chemicals in the process area 

must be addressed by the employer as to 

what actions employees are to take. If the 

employer wants employees to evacuate the 

area, then the emergency action plan will be 

activated. For outdoor processes where wind 

direction is important for selecting the safe 

route to a refuge area, the employer should 

place a wind direction indicator such as a 

wind sock or pennant at the highest point 

that can be seen throughout the process 

area. Employees can move in the direction of 

cross wind to upwind to gain safe access to 

the refuge area by knowing the wind direction. 

If the employer wants specific employees 

in the release area to control or stop the 

minor emergency or incidental release, these 

actions must be planned for in advance and 

procedures developed and implemented. 

Preplanning for handling incidental releases 

for minor emergencies in the process area 

needs to be done, appropriate equipment for 

the hazards must be provided, and training 

conducted for those employees who will perform the emergency work before they respond to handle an actual release. The employer’s training program, including the 

Hazard Communication standard training is 

to address the training needs for employees 

who are expected to handle incidental or 

minor releases. 

Preplanning for releases that are more serious than incidental releases is another important line of defense to be used by the employer. When a serious release of a highly 

hazardous chemical occurs, the employer 

through preplanning will have determined in 

advance what actions employees are to take. 

The evacuation of the immediate release 

area and other areas as necessary would be 

accomplished under the emergency action 


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Occupational Safety and Health Admin., Labor § 1910.119 

plan. If the employer wishes to use plant personnel such as a fire brigade, spill control 

team, a hazardous materials team, or use 

employees to render aid to those in the immediate release area and control or mitigate 

the incident, these actions are covered by 

§1910.120, the Hazardous Waste Operations 

and Emergency Response (HAZWOPER) 

standard. If outside assistance is necessary, 

such as through mutual aid agreements between employers or local government emergency response organizations, these emergency responders are also covered by 

HAZWOPER. The safety and health protections required for emergency responders are 

the responsibility of their employers and of 

the on-scene incident commander. 

Responders may be working under very 

hazardous conditions and therefore the objective is to have them competently led by 

an on-scene incident commander and the 

commander’s staff, properly equipped to do 

their assigned work safely, and fully trained 

to carry out their duties safely before they 

respond to an emergency. Drills, training exercises, or simulations with the local community emergency response planners and responder organizations is one means to obtain 

better preparedness. This close cooperation 

and coordination between plant and local 

community emergency preparedness managers will also aid the employer in complying with the Environmental Protection 

Agency’s Risk Management Plan criteria. 

One effective way for medium to large facilities to enhance coordination and communication during emergencies for on plant operations and with local community organizations is for employers to establish and equip 

an emergency control center. The emergency 

control center would be sited in a safe zone 

area so that it could be occupied throughout 

the duration of an emergency. The center 

would serve as the major ccommunication 

link between the on-scene incident commander and plant or corporate management 

as well as with the local community officials. The communication equipment in the 

emergency control center should include a 

network to receive and transmit information 

by telephone, radio or other means. It is important to have a backup communication 

network in case of power failure or one communication means fails. The center should 

also be equipped with the plant layout and 

community maps, utility drawings including 

fire water, emergency lighting, appropriate 

reference materials such as a government 

agency notification list, company personnel 

phone list, SARA Title III reports and safety 

data sheets, emergency plans and procedures 

manual, a listing with the location of emergency response equipment, mutual aid information, and access to meteorological or 

weather condition data and any dispersion 

modeling data. 

14. Compliance Audits. Employers need to 

select a trained individual or assemble a 

trained team of people to audit the process 

safety management system and program. A 

small process or plant may need only one 

knowledgeable person to conduct an audit. 

The audit is to include an evaluation of the 

design and effectiveness of the process safety 

management system and a field inspection of 

the safety and health conditions and practices to verify that the employer’s systems 

are effectively implemented. The audit 

should be conducted or lead by a person 

knowledgeable in audit techniques and who 

is impartial towards the facility or area 

being audited. The essential elements of an 

audit program include planning, staffing, 

conduting the audit, evaluation and corrective action, follow-up and documentation. 

Planning in advance is essential to the success of the auditing process. Each employer 

needs to establish the format, staffing, 

scheduling and verification methods prior to 

conducting the audit. The format should be 

designed to provide the lead auditor with a 

procedure or checklist which details the requirements of each section of the standard. 

The names of the audit team members 

should be listed as part of the format as well. 

The checklist, if properly designed, could 

serve as the verification sheet which provides the auditor with the necessary information to expedite the review and assure 

that no requirements of the standard are 

omitted. This verification sheet format 

could also identify those elements that will 

require evaluation or a response to correct 

deficiencies. This sheet could also be used for 

developing the follow-up and documentation 

requirements. 

The selection of effective audit team members is critical to the success of the program. 

Team members should be chosen for their experience, knowledge, and training and should 

be familiar with the processes and with auditing techniques, practices and procedures. 

The size of the team will vary depending on 

the size and complexity of the process under 

consideration. For a large, complex, highly 

instrumented plant, it may be desirable to 

have team members with expertise in process engineering and design, process chemistry, instrumentation and computer controls, electrical hazards and classifications, 

safety and health disciplines, maintenance, 

emergency preparedness, warehousing or 

shipping, and process safety auditing. The 

team may use part-time members to provide 

for the depth of expertise required as well as 

for what is actually done or followed, compared to what is written. 

An effective audit includes a review of the 

relevant documentation and process safety 

information, inspection of the physical facilities, and interviews with all levels of 

plant personnel. Utilizing the audit procedure and checklist developed in the 


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§ 1910.119 29 CFR Ch. XVII (7–1–15 Edition) 

preplanning stage, the audit team can systematically analyze compliance with the 

provisions of the standard and any other corporate policies that are relevant. For example, the audit team will review all aspects of 

the training program as part of the overall 

audit. The team will review the written 

training program for adequacy of content, 

frequency of training, effectiveness of training in terms of its goals and objectives as 

well as to how it fits into meeting the standard’s requirements, documentation, etc. 

Through interviews, the team can determine 

the employee’s knowledge and awareness of 

the safety procedures, duties, rules, emergency response assignments, etc. During the 

inspection, the team can observe actual 

practices such as safety and health policies, 

procedures, and work authorization practices. This approach enables the team to 

identify deficiencies and determine where 

corrective actions or improvements are necessary. 

An audit is a technique used to gather sufficient facts and information, including statistical information, to verify compliance 

with standards. Auditors should select as 

part of their preplanning a sample size sufficient to give a degree of confidence that the 

audit reflects the level of compliance with 

the standard. The audit team, through this 

systematic analysis, should document areas 

which require corrective action as well as 

those areas where the process safety management system is effective and working in 

an effective manner. This provides a record 

of the audit procedures and findings, and 

serves as a baseline of operation data for future audits. It will assist future auditors in 

determining changes or trends from previous 

audits. 

Corrective action is one of the most important parts of the audit. It includes not only 

addressing the identified deficiencies, but 

also planning, followup, and documentation. 

The corrective action process normally begins with a management review of the audit 

findings. The purpose of this review is to determine what actions are appropriate, and to 

establish priorities, timetables, resource allocations and requirements and responsibilities. In some cases, corrective action may 

involve a simple change in procedure or 

minor maintenance effort to remedy the concern. Management of change procedures need 

to be used, as appropriate, even for what 

may seem to be a minor change. Many of the 

deficiencies can be acted on promptly, while 

some may require engineering studies or indepth review of actual procedures and practices. There may be instances where no action is necessary and this is a valid response 

to an audit finding. All actions taken, including an explanation where no action is 

taken on a finding, needs to be documented 

as to what was done and why. 

It is important to assure that each deficiency identified is addressed, the corrective 

action to be taken noted, and the audit person or team responsible be properly documented by the employer. To control the corrective action process, the employer should 

consider the use of a tracking system. This 

tracking system might include periodic status reports shared with affected levels of 

management, specific reports such as completion of an engineering study, and a final 

implementation report to provide closure for 

audit findings that have been through management of change, if appropriate, and then 

shared with affected employees and management. This type of tracking system provides 

the employer with the status of the corrective action. It also provides the documentation required to verify that appropriate corrective actions were taken on deficiencies 

identified in the audit. 

APPENDIX D TO §1910.119—SOURCES OF

FURTHER INFORMATION (NONMANDATORY) 

1. Center for Chemical Process Safety, 

American Institute of Chemical Engineers, 

345 East 47th Street, New York, NY 10017, 

(212) 705–7319. 

2. ‘‘Guidelines for Hazard Evaluation Procedures,’’ American Institute of Chemical 

Engineers; 345 East 47th Street, New York, 

NY 10017. 

3. ‘‘Guidelines for Technical Management 

of Chemical Process Safety,’’ Center for 

Chemical Process Safety of the American Institute of Chemical Engineers; 345 East 47th 

Street, New York, NY 10017. 

4. ‘‘Evaluating Process Safety in the Chemical Industry,’’ Chemical Manufacturers Association; 2501 M Street NW, Washington, DC 

20037. 

5. ‘‘Safe Warehousing of Chemicals,’’ 

Chemical Manufacturers Association; 2501 M 

Street NW, Washington, DC 20037. 

6. ‘‘Management of Process Hazards,’’ 

American Petroleum Institute (API Recommended Practice 750); 1220 L Street, N.W., 

Washington, D.C. 20005. 

7. ‘‘Improving Owner and Contractor Safety Performance,’’ American Petroleum Institute (API Recommended Practice 2220); API, 

1220 L Street N.W., Washington, D.C. 20005. 

8. Chemical Manufacturers Association 

(CMA’s Manager Guide), First Edition, September 1991; CMA, 2501 M Street, N.W., 

Washington, D.C. 20037. 

9. ‘‘Improving Construction Safety Performance,’’ Report A–3, The Business Roundtable; The Business Roundtable, 200 Park Avenue, New York, NY 10166. (Report includes 

criteria to evaluate contractor safety performance and criteria to enhance contractor 

safety performance). 

10. ‘‘Recommended Guidelines for Contractor Safety and Health,’’ Texas Chemical 

Council; Texas Chemical Council, 1402 

Nueces Street, Austin, TX 78701–1534. 


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Occupational Safety and Health Admin., Labor § 1910.120 

11. ‘‘Loss Prevention in the Process Industries,’’ Volumes I and II; Frank P. Lees, 

Butterworth; London 1983. 

12. ‘‘Safety and Health Program Management Guidelines,’’ 1989; U.S. Department of 

Labor, Occupational Safety and Health Administration. 

13. ‘‘Safety and Health Guide for the Chemical Industry,’’ 1986, (OSHA 3091); U.S. Department of Labor, Occupational Safety and 

Health Administration; 200 Constitution Avenue, N.W., Washington, D.C. 20210. 

14. ‘‘Review of Emergency Systems,’’ June 

1988; U.S. Environmental Protection Agency 

(EPA), Office of Solid Waste and Emergency 

Response, Washington, DC 20460. 

15. ‘‘Technical Guidance for Hazards Analysis, Emergency Planning for Extremely 

Hazardous Substances,’’ December 1987; U.S. 

Environmental Protection Agency (EPA), 

Federal Emergency Management Administration (FEMA) and U.S. Department of 

Transportation (DOT), Washington, DC 20460. 

16. ‘‘Accident Investigation * * * A New 

Approach,’’ 1983, National Safety Council; 444 

North Michigan Avenue, Chicago, IL 60611– 

3991. 

17. ‘‘Fire & Explosion Index Hazard Classification Guide,’’ 6th Edition, May 1987, Dow 

Chemical Company; Midland, Michigan 48674. 

18. ‘‘Chemical Exposure Index,’’ May 1988, 

Dow Chemical Company; Midland, Michigan 

48674. 

[57 FR 6403, Feb. 24, 1992; 57 FR 7847, Mar. 4, 

1992, as amended at 61 FR 9238, Mar. 7, 1996; 

67 FR 67964, Nov. 7, 2002; 76 FR 80738, Dec. 27, 

2011; 77 FR 17776, Mar. 26, 2012; 78 FR 9313, 

Feb. 8, 2013] 

§ 1910.120 Hazardous waste operations 

and emergency response. 

(a) Scope, application, and definitions— 

(1) Scope. This section covers the following operations, unless the employer 

can demonstrate that the operation 

does not involve employee exposure or 

the reasonable possibility for employee 

exposure to safety or health hazards: 

(i) Clean-up operations required by a 

governmental body, whether Federal, 

state, local or other involving hazardous substances that are conducted 

at uncontrolled hazardous waste sites 

(including, but not limited to, the 

EPA’s National Priority Site List 

(NPL), state priority site lists, sites 

recommended for the EPA NPL, and 

initial investigations of government 

identified sites which are conducted before the presence or absence of hazardous substances has been 

ascertained); 

(ii) Corrective actions involving 

clean-up operations at sites covered by 

the Resource Conservation and Recovery Act of 1976 (RCRA) as amended (42 

U.S.C. 6901 et seq.); 

(iii) Voluntary clean-up operations at 

sites recognized by Federal, state, local 

or other governmental bodies as uncontrolled hazardous waste sites; 

(iv) Operations involving hazardous 

wastes that are conducted at treatment, storage, and disposal (TSD) facilities regulated by 40 CFR parts 264 

and 265 pursuant to RCRA; or by agencies under agreement with U.S.E.P.A. 

to implement RCRA regulations; and 

(v) Emergency response operations 

for releases of, or substantial threats of 

releases of, hazardous substances without regard to the location of the hazard. 

(2) Application. (i) All requirements of 

part 1910 and part 1926 of title 29 of the 

Code of Federal Regulations apply pursuant to their terms to hazardous 

waste and emergency response operations whether covered by this section 

or not. If there is a conflict or overlap, 

the provision more protective of employee safety and health shall apply 

without regard to 29 CFR 1910.5(c)(1). 

(ii) Hazardous substance clean-up operations within the scope of paragraphs 

(a)(1)(i) through (a)(1)(iii) of this section must comply with all paragraphs 

of this section except paragraphs (p) 

and (q). 

(iii) Operations within the scope of 

paragraph (a)(1)(iv) of this section 

must comply only with the requirements of paragraph (p) of this section. 

NOTES AND EXCEPTIONS: (A) All provisions 

of paragraph (p) of this section cover any 

treatment, storage or disposal (TSD) operation regulated by 40 CFR parts 264 and 265 

or by state law authorized under RCRA, and 

required to have a permit or interim status 

from EPA pursuant to 40 CFR 270.1 or from 

a state agency pursuant to RCRA. 

(B) Employers who are not required to 

have a permit or interim status because they 

are conditionally exempt small quantity 

generators under 40 CFR 261.5 or are generators who qualify under 40 CFR 262.34 for exemptions from regulation under 40 CFR parts 

264, 265 and 270 (‘‘excepted employers’’) are 

not covered by paragraphs (p)(1) through 

(p)(7) of this section. Excepted employers 

who are required by the EPA or state agency 


lpowell on DSK54DXVN1OFR with $$_JOB