MPP management team is not familiar with the requirements of OSHA’s PSM standard. Although it will be several weeks before OSHA provides the formal PSM inspection report and findings, you plan to proactively schedule an internal follow-up meeting with your management team and operations supervisors to prepare them for what to expect, including possible citations and fines for violations of the PSM standard. At a minimum, the questions below need to be addressed at this meeting.
Discuss the purpose of OSHA’s PSM standard, including why it was initially implemented and its scope. Explain why MPP’s pulp mill manufacturing process is considered a covered facility under OSHA’s PSM standard. Identify which hazardous material(s) used at the pulp mill facility exceed the threshold quantities (TQ) shown in 29 C.F.R. § 1910.119 Appendix A.
Describe an oxidizer. Identify at least three oxidizers used at this MPP facility, and discuss their potential hazards to human health and the environment. Based on the OSHA 8-hour permissible exposure limit (PEL)/time-weighted average (TWA) for your three identified oxidizers, which one would pose the greatest threat to human health? Explain why, and elaborate on how you should respond if this oxidizer is accidentally released.
Review the OSHA inspector’s preliminary observations, and provide recommendations regarding how MPP can improve their compliance with at least three elements of OSHA’s PSM standard. Each recommendation you provide must discuss the noncompliance issue(s) observed, the specific PSM standard requirement, and what program changes need to be implemented to improve your company’s PSM compliance.