NIOSH Testimony on Process Safety Management of Highly Hazardous Chemicals by J. D. Millar, November 27, 1990.
This testimony offers support from NIOSH to OSHA in proposing regulation in the area of hazardous chemicals. NIOSH presents specific comments dealing with purpose, application, and definitions contained in the proposal. NIOSH suggests that the proposed rule is too narrow and would recommend that the practices and requirements of the proposed rule should be in general applicable to all chemical processing operations. In the section dealing with process safety information and process hazard analysis, NIOSH recommends that OSHA delete the mention of checklists as other hazard analysis techniques have been demonstrated to possess a greater degree of anticipation of hazards. NIOSH recommends the concept of intrinsically safe controls as the preferred approach for reducing hazards. Additional comments in the testimony refer to sections of the proposal dealing with training, contractors, prestartup safety review, mechanical integrity, hot work permit, management of change, incident investigation, and compliance safety audits.