(41x) You’Ve Met the Regulatory Guidance, but Will Your Personnel Survive a Toxic Release?

Facilities covered under OSHA 29 CFR 1910.119 for Process Safety Management (PSM) are required to evaluate the consequences of a loss of containment on site. API Recommended Practice (RP) 752 and 753 provide guidance on conducting consequence or risk-based facility siting for permanent and portable buildings, respectively. While these recommended practices provide guidance on assessments of the hazards regarding blast load, thermal flux with exposure time, and toxic concentration with exposure time, those same recommendations may fall short when it comes to mitigating the hazards of toxic releases as compared to blast or thermal hazards. Emergency response planning is required by PSM in accordance with 29 CFR 1910.38, but what would really happen in an emergency regarding toxic releases? An overview of personnel responses during a toxic release on-site and the potential consequences of decisions will be discussed in detail. Most emergency response plans have significant deficiencies that can create confusion, leading to a chaotic response if a severe toxic release were to occur. Safeguards and training that should be implemented into a site’s emergency response plan will be described to help answer the question: “Will your on-site personnel actually survive a toxic gas release?” Compliance does not always ensure safety.