PSM Process Boundaries in the Semiconductor Industry
(Greystone Risk Management, Saratoga Springs NY)
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The OSHA PSM standard is a performance-based standard. In these standards, OSHA dictates what to do but the employer must determine applicability and how to meet the regulatory requirements based on the employer’s evaluation of their process(es). For process safety, the employer must determine the boundaries of a covered process which could result in a catastrophic release of the highly hazardous chemical (HHC). This presentation will include a regulatory overview of what interpretations exist regarding a PSM covered process boundary. The review will include interpretations available from OSHA that both support and inhibit a company’s decision on where their PSM process boundary can stop. Based on the regulatory review we will discuss what a company can do to support their decision on where to end the PSM process boundary specific to the semiconductor industry and how they can manage their risk. Managing the company’s risk when making their boundary determination must be based on a comprehensive review of the following: current industry practices, regulatory standards and interpretations, hazards of the process in the form of a process hazard analysis utilizing the hazard and operability study technique, and an evaluation of quantities of the covered chemical in the process after the end point of the covered process. At the end of the presentation attendees should have a solid understanding on how they can create a more acceptable level of risk in the event of an OSHA inspection, as it pertains to the PSM covered process boundaries at the facility.