Process Safety Management: What OSHA 1910.119 Says About Valves

OSHA fines recently skyrocketed, which means companies can no longer afford to take a “wait and see” approach to compliance.

One of the most-cited OSHA standards across a variety of industries is 1910.119: Process Safety Management of Highly Hazardous Chemicals. This standard “contains requirements for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals [which] may result in toxic, fire, or explosion hazards.” It’s the No. 1 most-cited standard in both chemical manufacturing and oil and gas extraction, to name just a few.

During the period between October 2014 and September 2015, OSHA handed out more than $2.5 million in penalties related to OSHA 1910.119. The table below shows the top 10 industry offenders, along with what the penalties might look like for the same violations now that fines have increased.

Industry

Citations

Penalty

Equivalent Penalty After 8/2/2016

Chemical Manufacturing 167 $955,725 $1,701,191
Food Manufacturing 165 $750,747 $1,336,330
Merchant Wholesalers, Nondurable Goods 60 $295,605 $526,177
Warehousing and Storage 49 $179,960 $320,329
Oil and Gas Extraction 26 $63,000 $112,140
Utilities 20 $119,925 $213,467
Plastics and Rubber Products Manufacturing 14 $10,575 $18,824
Fabricated Metal Product Manufacturing 13 $23,667 $42,127
Professional, Scientific, and Technical Services 9 $30,000 $53,400
Waste Management and Remediation Services 9 $18,552 $33,023

As you can see, small penalties can quickly become big ones, and big ones can become astronomical.

Standard 1910.119 is extensive, covering many aspects of process safety management. Here is a summary of the requirements for process equipment including relief devices like pressure relief valves.

  • Written procedures. Employers must put down in writing their procedures to maintain their process equipment.
  • Training. All employees involved in process equipment maintenance must receive training about the process and its hazards, as well as the procedures they need to perform their job safely.
  • Inspections and testing. All process equipment must be inspected and testing using proper procedures and following a schedule determined by the OEM’s recommendations, good engineering practices, and operating experience.
  • Recordkeeping. All inspections and tests — and their results — must be documented.
  • Repair and/or replacement. Deficiencies must be corrected before the equipment returns to use.

Don’t get caught unawares by OSHA inspectors. If you haven’t inspected your valves lately or your documentation isn’t complete, we can help. Contact us today to schedule a maintenance consultation and learn more about ValvKeep, a valve management solution to help you keep track of valve maintenance schedules and test results.

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