When OSHA's Process Safety Management (PSM) Standard Doesn't Apply to Airports

OSHA's Process Safety Management (PSM) of Highly Hazardous Chemicals standard, codified under 29 CFR 1910.119, is a critical regulation aimed at preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. However, its application in airports can be nuanced due to the unique operations and regulatory environment of these facilities.

Understanding OSHA's PSM Scope

The PSM standard primarily applies to facilities that use, store, manufacture, handle, or move highly hazardous chemicals in quantities that exceed the threshold values listed in Appendix A of the standard. Airports, while they do handle various types of fuels and chemicals, often operate under different federal regulations and guidelines that can impact the direct applicability of PSM.

When PSM Might Not Apply to Airports

1. Regulatory Oversight: Airports fall under the jurisdiction of the Federal Aviation Administration (FAA), which has its own set of safety regulations and guidelines. The FAA's oversight might supersede OSHA's PSM requirements in certain contexts, especially concerning aviation fuel and related operations.

2. Chemical Thresholds: If an airport does not store or use highly hazardous chemicals in quantities that meet or exceed the PSM thresholds, then the standard does not apply. For instance, jet fuel, while hazardous, is not listed in Appendix A of the PSM standard, thus potentially exempting airports from PSM requirements related to jet fuel storage.

3. Other Applicable Regulations: Airports are subject to a variety of other regulations, such as the Environmental Protection Agency's (EPA) Spill Prevention, Control, and Countermeasure (SPCC) rule, which might address similar safety concerns as PSM but in a different manner.

Real-World Considerations

In my experience consulting with airports, I've seen that while PSM might not directly apply, the principles of PSM—such as hazard analysis, operating procedures, and emergency planning—are often integrated into airport safety management systems. This integration helps ensure that the safety of workers and the public is maintained, even if the formal PSM standard isn't in play.

It's also worth noting that while PSM may not be the primary regulatory framework at an airport, elements of it can still be beneficial. For example, conducting a Process Hazard Analysis (PHA) can be invaluable for identifying potential hazards in fuel storage and handling, even if it's not required by PSM.

Limitations and Gaps

Despite the robust safety measures in place, there can be gaps where PSM's absence is felt. For instance, the PSM standard requires detailed mechanical integrity programs for equipment used in processes involving highly hazardous chemicals. Airports might not have the same level of scrutiny for their fuel handling equipment, which could lead to safety oversights.

Moreover, the training requirements under PSM are quite specific and comprehensive. While airports have their own training programs, they might not cover the same breadth and depth as PSM, potentially leaving workers less prepared for certain types of chemical emergencies.

Third-Party Resources and Further Reading

For those looking to delve deeper into the intersection of PSM and airport safety, the following resources are highly recommended:

• OSHA's PSM Standard - Full text of the regulation.
• FAA Website - For detailed information on FAA regulations and guidelines.
• EPA's SPCC Rule - Information on spill prevention and control measures.

Based on available research, individual results may vary, and it's crucial for each airport to assess its unique situation and regulatory environment to ensure comprehensive safety management.