Major changes are in prospect for the compression industry if the Occupational Safety
and Health Administration (OSHA)
proceeds to include all oil and gas
production facilities under its Process
Safety Management standard (PSM).
Jargon that field compressor mechanics use such as standard operating procedures (SOP), monthly
preventive maintenance (PM) and
standard service tickets may be supplemented by terms such as management of change (MOC), process
hazard analysis (PHA), hazard and
operability study (HAZOP), and mechanical integrity (MI).
OSHA placed the Process Safety
Management (PSM) of Highly Hazardous Chemicals (HHC) Standard ( 29
CFR 1910.119) into effect on May 26,
1992, in an attempt to provide safer
and healthier workplaces for employees by making employers responsible
for ensuring certain safe conditions
are met and processes instituted, specifically with regard to employees who
work in highly hazardous industries.
Chiefly, the PSM standard was draft-
ed in response to chemical plant acci-
dents like those in 1984 at Bhopal, India,
and in 1989 at Pasadena, Texas, where
a combined 2023 people lost their lives
and hundreds more were injured. There
have been many other incidents since,
including in 2013 in an explosion at a
fertilizer plant in West, Texas.
The PSM standard provides a
structural basis including 14 critical
elements (Table 1: [C] through [P])
to prevent releases of toxic, reactive,
flammable or explosive chemicals.
The Environmental Protection Agen-
cy (EPA) followed suit by instituting a
similar regulation named Risk Man-
agement Program (RMP) that attempts
to protect the public from the same
toxic or flammable releases by utiliz-
ing a somewhat modified version of the
14 elements of the PSM program. It
has been surmised that OSHA’s PSM
regulation addressed safety concerns
inside the facility fence and EPA’s RMP
outside the facility fence.
Originally, the PSM standard was
developed from the best practices in
the industry at the time (late 1980s
and early 1990s). However, concerns
later evolved that these practices did
not necessarily protect the workers
directly involved with the processes.
PSM did require a continual training
program and specific measures for
competency, thus ensuring that ade-
quate and current process information
is available and that proper applica-
tion is demonstrated with full under-
standing of each element.
On Dec. 3, 2011, OSHA requested
public comment on 17 significant revisions it may implement to the current
PSM standard ( 29 CFR 1910.119),
in an effort to prevent catastrophic
releases, or uncontrolled emissions,
fires or explosions involving one or
more highly hazardous chemicals.
These proposed changes, if promul-
gated, would expand the coverage and
compliance regulations for oil and gas
industry companies and employers op-
erating within all OSHA jurisdictions,
OSHA Considering Process Safety
Management Revisions > Changes could be costly for compression industry
BY TRAVIS DUHON
Travis Duhon is a senior health, safety and
environment manager for CDM Resource
Management. His 13 years of experience
includes service with Valero Energy, HMC
Services and Secorp Industries. Duhon is
experienced with an array of federal and
state safety requirements. Contact him at:
n This is the case study facility where compression was added
after construction and the MOC process followed along with
modified HAZOP of facility.