Emergency Planning and Response

If, despite the best planning, an incident occurs, it is essential that emergency preplanning and training make employees aware of, and able to execute, proper actions. For this reason, an emergency action plan for the entire plant must be developed and implemented in accordance with the provisions of other OSHA rules [29 CFR 1910.38(a)]. In addition, the emergency action plan must include procedures for handling small releases of hazardous chemicals. Employers covered under PSM also may be subject to the OSHA hazardous waste and emergency response regulation [29 CFR 1910.120(a), (p), and (q)].

Compliance Audits

To be certain that PSM is effective, employers must certify that they have evaluated compliance with the provisions of PSM at least every 3 years. This will verify that the procedures and practices developed under the standard are adequate and are being followed. The compliance audit must be conducted by at least one person knowledgeable in the process, and a report of the findings of the audit must be developed and documented noting deficiencies that have been corrected. The two most recent compliance audit reports must be kept on file.

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