Applying the OSHA Process Safety Management Standard to Manufacturing Explosives at U.S. Government Facilities

The Occupational Safety and Health Administration OSHA Process Safety Management PSM standard, 29 CFR 1910.119, is in place to prevent or minimize the consequences of a release of toxic, reactive, flammable, or explosive chemicals. Although the majority of explosives do not use chemicals in excess of the threshold quantities listed in Appendix A of the standard, paragraph 1910.109k2 mandates that the manufacturers of explosives comply with the PSM standard. This paragraph refers back to 1910.109a3 which is the applicable definition of explosives. It defines explosives in accordance with the Department of Transportation DOT classification guide, and the paragraph ends with the explanation of commercial explosives. However there are letters of interpretation issued by OSHA that define the manufacture of explosives to include mixing, blending, extruding, synthesizing, assembling, disassembling and other activities involved in the making of chemical compounds, mixtures, or devices that are intended to explode. This also pertains to the storage of parts used in these processes. The inclusion of assembly and disassembly in the letter of interpretation could involve every installation in the Department of Defense DOD that trains with ammunition and explosives.