ASP question of the day
A chemical plant certified its operating procedures for a covered process as current and accurate eight months ago. Last month the plant replaced a feed pump with a different design and began using a new process chemical. The supervisor proposes leaving the procedures as they are until the next annual certification in four months, since they were certified within the past year. What does the standard require?
OSHA's process safety management standard, 29 CFR 1910.119(f)(3), requires operating procedures to be reviewed as often as necessary to reflect current practice, including changes in process chemicals and equipment. The annual certification is a separate requirement, so a recent certification does not delay the update. Waiting for refresher training or updating only contractor-entry sections leaves the procedures outdated.
Source: 29 CFR 1910.119(f)(3)