Applying the OSHA Process Safety Management Standard to Manufacturing Explosives at U.S. Government Facilities
Abstract
The Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) standard, 29 CFR 1910.119, is in place to prevent or minimize the consequences of a release of toxic, reactive, flammable, or explosive chemicals. Although the majority of explosives do not use chemicals in excess of the threshold quantities listed in Appendix A of the standard, paragraph 1910.109(k)(2) mandates that the manufacturers of explosives comply with the PSM standard. This paragraph refers back to 1910.109(a)(3) which is the applicable definition of "explosives". It defines "explosives" in accordance with the Department of Transportation (DOT) classification guide, and the paragraph ends with the explanation of commercial explosives. However; there are letters of interpretation issued by OSHA that define the manufacture of explosives to include mixing, blending, extruding, synthesizing, assembling, disassembling and other activities involved in the making of chemical compounds, mixtures, or devices that are intended to explode. This also pertains to the storage of parts used in these processes. The inclusion of assembly and disassembly in the letter of interpretation could involve every installation in the Department of Defense (DOD) that trains with ammunition and explosives.
Document Details
- Document Type
- Technical Report
- Publication Date
- Jul 01, 2010
- Accession Number
- ADA532198
Entities
People
- James Hammonds