October 17, 2025

Your Checklist for OSHA 1910.119 Compliance in Fire and Emergency Services

Compliance with OSHA's Process Safety Management (PSM) standard, specifically 1910.119, is crucial for organizations handling acutely hazardous materials. This checklist will guide you through the necessary steps to ensure your fire and emergency services are up to standard.

Understanding OSHA 1910.119

OSHA 1910.119, known as the Process Safety Management of Highly Hazardous Chemicals standard, is designed to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. These regulations apply to any workplace where these materials are present in quantities that could pose a significant risk.

Key Elements of PSM Compliance for Fire and Emergency Services

Here's a comprehensive checklist to ensure your organization meets the PSM requirements:

1. Process Safety Information

Compile detailed information about your hazardous materials, including their properties and potential hazards. This should include safety data sheets, process flow diagrams, and detailed process chemistry.

2. Process Hazard Analysis (PHA)

Conduct a thorough PHA to identify potential hazards and assess the risks associated with your processes. This should be updated every five years or whenever there are significant changes to the process.

3. Operating Procedures

Develop and maintain clear operating procedures that include steps for normal operations, emergency shutdown, and emergency operations. Ensure these procedures are readily accessible to employees.

4. Employee Training

Provide comprehensive training for all employees involved in operating a process. This training should cover the hazards of the chemicals they work with, safe work practices, and emergency response procedures.

5. Contractors

Ensure that any contractors working on or near the process are informed of the hazards and trained accordingly. Evaluate their safety performance and ensure they follow your safety protocols.

6. Pre-Startup Safety Review

Conduct a pre-startup safety review for new facilities and modified facilities to confirm that the construction and equipment are in accordance with design specifications and that safety procedures are in place.

7. Mechanical Integrity

Establish written procedures to maintain the ongoing integrity of process equipment. This includes regular inspections, testing, and maintenance to prevent equipment failures.

8. Hot Work Permit

Implement a hot work permit system to control and manage welding, cutting, or brazing operations conducted on or near a covered process.

9. Management of Change

Develop a system to manage changes to processes, including technical basis for the change, impact of the change on safety and health, and necessary authorization.

10. Incident Investigation

Investigate any incident that resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical. Document findings and implement corrective actions.

11. Emergency Planning and Response

Develop and implement an emergency action plan. This should include procedures for handling releases of hazardous chemicals, evacuation procedures, and emergency response training for employees.

12. Compliance Audits

Conduct compliance audits at least every three years to ensure that the PSM program is functioning properly. Address any deficiencies found during the audit.

By following this checklist, your organization can ensure that your fire and emergency services are fully compliant with OSHA 1910.119. Remember, compliance is not just about meeting regulations; it's about safeguarding your employees and your community.

For further resources on OSHA compliance, consider visiting the official OSHA website or consulting with safety experts who can provide tailored guidance based on your specific operations.

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