Process Safety Management of Highly Hazardous & Explosive Chemicals Contractor Pre-Qualification, Emergency Preparedness, Incident Investigation, Audits & EPA Risk Management Plans (RMP)

Now That We’ve Developed Process Safety Information Process Safety Information Process Material Toxicity Information Process Material Toxicity Information Process Hazard Analysis (PHA’s) Process Hazard Analysis (PHA’s) Mechanical Integrity Certificates Mechanical Integrity Certificates Management of Change Management of Change Inspection/Testing/Maintenance Inspection/Testing/Maintenance Operating Procedures Operating Procedures Safe Work Procedures Safe Work Procedures Training Programs Training Programs Training for Contractors Training for Contractors Now… Now… Process Safety Information Process Safety Information Process Material Toxicity Information Process Material Toxicity Information Process Hazard Analysis (PHA’s) Process Hazard Analysis (PHA’s) Mechanical Integrity Certificates Mechanical Integrity Certificates Management of Change Management of Change Inspection/Testing/Maintenance Inspection/Testing/Maintenance Operating Procedures Operating Procedures Safe Work Procedures Safe Work Procedures Training Programs Training Programs Training for Contractors Training for Contractors Now… Now…

Contractor Management (h) (h)

PSM Contractors The employer, when selecting a contractor, shall obtain and evaluate information regarding the contract employer's safety performance and programs. The employer, when selecting a contractor, shall obtain and evaluate information regarding the contract employer's safety performance and programs. The employer shall inform contract employers of the known potential fire, explosion, or toxic release hazards related to the contractor's work and the process The employer shall inform contract employers of the known potential fire, explosion, or toxic release hazards related to the contractor's work and the process The employer, when selecting a contractor, shall obtain and evaluate information regarding the contract employer's safety performance and programs. The employer, when selecting a contractor, shall obtain and evaluate information regarding the contract employer's safety performance and programs. The employer shall inform contract employers of the known potential fire, explosion, or toxic release hazards related to the contractor's work and the process The employer shall inform contract employers of the known potential fire, explosion, or toxic release hazards related to the contractor's work and the process

Contractor Pre-Qualification & Authorization The Standard Requires You to: The Standard Requires You to: Explain contractor qualification requirements Explain contractor qualification requirements List what is required for contractor pre-bid awareness - pre-qualification List what is required for contractor pre-bid awareness - pre-qualification List what is required for contractor post-bid awareness - training & orientation List what is required for contractor post-bid awareness - training & orientation Specify contractor responsibilities Specify contractor responsibilities Describe contractor 300 Log Requirements Describe contractor 300 Log Requirements Evaluate Contractor Performance Evaluate Contractor Performance List documentation requirements for contractors to complete List documentation requirements for contractors to complete Explain the use of a work authorization system Explain the use of a work authorization system The Standard Requires You to: The Standard Requires You to: Explain contractor qualification requirements Explain contractor qualification requirements List what is required for contractor pre-bid awareness - pre-qualification List what is required for contractor pre-bid awareness - pre-qualification List what is required for contractor post-bid awareness - training & orientation List what is required for contractor post-bid awareness - training & orientation Specify contractor responsibilities Specify contractor responsibilities Describe contractor 300 Log Requirements Describe contractor 300 Log Requirements Evaluate Contractor Performance Evaluate Contractor Performance List documentation requirements for contractors to complete List documentation requirements for contractors to complete Explain the use of a work authorization system Explain the use of a work authorization system

Typical Pre-Qualification Elements: Typical Pre-Qualification Elements: Years Experience in Work Process Years Experience in Work Process Experience Modification Rate (EMR) Experience Modification Rate (EMR) OSHA Total Recordable Incident Rate and Lost Work day Case Rate Information OSHA Total Recordable Incident Rate and Lost Work day Case Rate Information Safety Programs Safety Programs Training Documentation Training Documentation Typical Pre-Qualification Elements: Typical Pre-Qualification Elements: Years Experience in Work Process Years Experience in Work Process Experience Modification Rate (EMR) Experience Modification Rate (EMR) OSHA Total Recordable Incident Rate and Lost Work day Case Rate Information OSHA Total Recordable Incident Rate and Lost Work day Case Rate Information Safety Programs Safety Programs Training Documentation Training Documentation Contractor Pre-Qualification & Authorization

Emergency Preparedness (f)(1)(I)(D) (f)(1)(I)(D)

Our Written Plan Must: Our Written Plan Must: Define an emergency action plan Define an emergency action plan Define an emergency response plan Define an emergency response plan Describe a Minimum emergency response plan Describe a Minimum emergency response plan Describe procedures for handling small releases Describe procedures for handling small releases List the three levels of emergency response List the three levels of emergency response List procedures for emergency evacuation List procedures for emergency evacuation List requirements of alarm systems List requirements of alarm systems List training requirements List training requirements Our Written Plan Must: Our Written Plan Must: Define an emergency action plan Define an emergency action plan Define an emergency response plan Define an emergency response plan Describe a Minimum emergency response plan Describe a Minimum emergency response plan Describe procedures for handling small releases Describe procedures for handling small releases List the three levels of emergency response List the three levels of emergency response List procedures for emergency evacuation List procedures for emergency evacuation List requirements of alarm systems List requirements of alarm systems List training requirements List training requirements

Emergency Preparedness The Standard Requires You to: The Standard Requires You to: Develop a Early Warning Method for Releases (Sensors/Alarms) Develop a Early Warning Method for Releases (Sensors/Alarms) Train on the Meaning of the Alarms (May be Multiple Alarms) Train on the Meaning of the Alarms (May be Multiple Alarms) Develop Emergency Evacuation Written Plans, Evacuation Maps & Assembly Points based on Release Characteristics Develop Emergency Evacuation Written Plans, Evacuation Maps & Assembly Points based on Release Characteristics Determine Emergency PPE Requirements Determine Emergency PPE Requirements Train Employees & Contractors in the Emergency Evacuation Plans Train Employees & Contractors in the Emergency Evacuation Plans Drill The Emergency Evacuation Plan At Last Once Per Year Drill The Emergency Evacuation Plan At Last Once Per Year The Standard Requires You to: The Standard Requires You to: Develop a Early Warning Method for Releases (Sensors/Alarms) Develop a Early Warning Method for Releases (Sensors/Alarms) Train on the Meaning of the Alarms (May be Multiple Alarms) Train on the Meaning of the Alarms (May be Multiple Alarms) Develop Emergency Evacuation Written Plans, Evacuation Maps & Assembly Points based on Release Characteristics Develop Emergency Evacuation Written Plans, Evacuation Maps & Assembly Points based on Release Characteristics Determine Emergency PPE Requirements Determine Emergency PPE Requirements Train Employees & Contractors in the Emergency Evacuation Plans Train Employees & Contractors in the Emergency Evacuation Plans Drill The Emergency Evacuation Plan At Last Once Per Year Drill The Emergency Evacuation Plan At Last Once Per Year

Emergency Preparedness Warning Systems must: Warning Systems must: Clearly Notify Employees of the Hazardous Release Clearly Notify Employees of the Hazardous Release Employees & Contractors must be Trained in the Meaning of the Alarm(s) Employees & Contractors must be Trained in the Meaning of the Alarm(s) Warning Systems must: Warning Systems must: Clearly Notify Employees of the Hazardous Release Clearly Notify Employees of the Hazardous Release Employees & Contractors must be Trained in the Meaning of the Alarm(s) Employees & Contractors must be Trained in the Meaning of the Alarm(s)

Emergency Preparedness Evacuation Maps

Emergency Preparedness Assembly Points Alternate Assembly Point Alternate Assembly Points Depending on Prevailing Weather Affecting Release

Emergency Preparedness Emergency PPE Hazardous Chemicals May Require Emergency PPE to be Worn Hazardous Chemicals May Require Emergency PPE to be Worn FRP FRP Escape Respirators Escape Respirators Eye Protection i.e.. Refinery Goggles Eye Protection i.e.. Refinery Goggles Hazardous Chemicals May Require Emergency PPE to be Worn Hazardous Chemicals May Require Emergency PPE to be Worn FRP FRP Escape Respirators Escape Respirators Eye Protection i.e.. Refinery Goggles Eye Protection i.e.. Refinery Goggles

Emergency Preparedness Drills At Least Annual Emergency Preparedness Drills At Least Annual Emergency Preparedness Drills This is not Just an Emergency Evacuation… This is not Just an Emergency Evacuation… but Could Include HAZWOPR Response but Could Include HAZWOPR Response Must Document Results Must Document Results At Least Annual Emergency Preparedness Drills At Least Annual Emergency Preparedness Drills This is not Just an Emergency Evacuation… This is not Just an Emergency Evacuation… but Could Include HAZWOPR Response but Could Include HAZWOPR Response Must Document Results Must Document Results

Incident Investigation (m) (m)

Incident Investigation Program Must Include the Following Describe the purpose of incident investigation Describe the purpose of incident investigation List the circumstances or occurrences, which require formal incident investigation List the circumstances or occurrences, which require formal incident investigation List the major investigation procedures that should be followed List the major investigation procedures that should be followed Explain the list the responsibilities of the incident investigation team Explain the list the responsibilities of the incident investigation team Explain the contents of an "Incident Summary" form Explain the contents of an "Incident Summary" form Explain the contents of an "Incident Description" form Explain the contents of an "Incident Description" form Explain the contents of an "Approvals, Follow-up and Review" form Explain the contents of an "Approvals, Follow-up and Review" form Explain the contents of a "Close-out" form Explain the contents of a "Close-out" form Explain Corrective Actions Taken Explain Corrective Actions Taken Describe the purpose of incident investigation Describe the purpose of incident investigation List the circumstances or occurrences, which require formal incident investigation List the circumstances or occurrences, which require formal incident investigation List the major investigation procedures that should be followed List the major investigation procedures that should be followed Explain the list the responsibilities of the incident investigation team Explain the list the responsibilities of the incident investigation team Explain the contents of an "Incident Summary" form Explain the contents of an "Incident Summary" form Explain the contents of an "Incident Description" form Explain the contents of an "Incident Description" form Explain the contents of an "Approvals, Follow-up and Review" form Explain the contents of an "Approvals, Follow-up and Review" form Explain the contents of a "Close-out" form Explain the contents of a "Close-out" form Explain Corrective Actions Taken Explain Corrective Actions Taken

Incidents Can Be Minor or Major - Both Require Investigation

Incident Investigation Documentation Must Include Date of incident Date of incident Date investigation began Date investigation began Description of the incident Description of the incident Factors contributing to the incident Factors contributing to the incident Recommendations resulting from the investigation Recommendations resulting from the investigation Date of incident Date of incident Date investigation began Date investigation began Description of the incident Description of the incident Factors contributing to the incident Factors contributing to the incident Recommendations resulting from the investigation Recommendations resulting from the investigation

Incident Investigation Will Include Written Documentation of all Required Elements Will Include Written Documentation of all Required Elements

Incident Investigation Might Even Include a Flow Chart

Compliance Audits (o) (o)

states, "Employers shall certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed." states, "Employers shall certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed."

Compliance Audits A List of factors that may increase the frequency of compliance audits A List of factors that may increase the frequency of compliance audits Results of Any OSHA Compliance Audits Performed & Citations/Action Items Developed Results of Any OSHA Compliance Audits Performed & Citations/Action Items Developed An Explanation of audit certification An Explanation of audit certification List Compliance Audit documentation List Compliance Audit documentation A List of factors that may increase the frequency of compliance audits A List of factors that may increase the frequency of compliance audits Results of Any OSHA Compliance Audits Performed & Citations/Action Items Developed Results of Any OSHA Compliance Audits Performed & Citations/Action Items Developed An Explanation of audit certification An Explanation of audit certification List Compliance Audit documentation List Compliance Audit documentation

Compliance Audits Employers shall certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed Employers shall certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed The compliance audit shall be conducted by at least one person knowledgeable in the process The compliance audit shall be conducted by at least one person knowledgeable in the process A report of the findings of the audit shall be developed A report of the findings of the audit shall be developed Compliance Audits Must be Performed Every 3 Years Compliance Audits Must be Performed Every 3 Years Employers shall certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed Employers shall certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed The compliance audit shall be conducted by at least one person knowledgeable in the process The compliance audit shall be conducted by at least one person knowledgeable in the process A report of the findings of the audit shall be developed A report of the findings of the audit shall be developed Compliance Audits Must be Performed Every 3 Years Compliance Audits Must be Performed Every 3 Years

The Compliance Audit Process Typically Includes the Following: The Compliance Audit Process Typically Includes the Following: Definition of the guidelines for an audit team Definition of the guidelines for an audit team A List the PSM elements that must be audited A List the PSM elements that must be audited A List of the minimum contents of a final report of an audit A List of the minimum contents of a final report of an audit An Explanation and list the Compliant Audit reports that must be retained by the facility An Explanation and list the Compliant Audit reports that must be retained by the facility The Compliance Audit Process Typically Includes the Following: The Compliance Audit Process Typically Includes the Following: Definition of the guidelines for an audit team Definition of the guidelines for an audit team A List the PSM elements that must be audited A List the PSM elements that must be audited A List of the minimum contents of a final report of an audit A List of the minimum contents of a final report of an audit An Explanation and list the Compliant Audit reports that must be retained by the facility An Explanation and list the Compliant Audit reports that must be retained by the facility Compliance Audits

OSHA PSM Citations OSHA PSM Citations #Initial Penalty Final Penalty 1393$25,058,853$18,884, $25,058,853$18,884,463 OSHA PSM Citations OSHA PSM Citations #Initial Penalty Final Penalty 1393$25,058,853$18,884, $25,058,853$18,884,463

Compliance Audits Typical Types of OSHA Serious Citations Typical Types of OSHA Serious Citations failure to maintain and follow normal operating procedures failure to maintain and follow normal operating procedures failure to provide refresher training to process operators failure to provide refresher training to process operators failure to correct deficiencies in process equipment in a safe manner failure to correct deficiencies in process equipment in a safe manner failure to provide necessary training to emergency responders and fire brigade members failure to provide necessary training to emergency responders and fire brigade members Failure to perform audits as required every 3 years Failure to perform audits as required every 3 years Typical Types of OSHA Serious Citations Typical Types of OSHA Serious Citations failure to maintain and follow normal operating procedures failure to maintain and follow normal operating procedures failure to provide refresher training to process operators failure to provide refresher training to process operators failure to correct deficiencies in process equipment in a safe manner failure to correct deficiencies in process equipment in a safe manner failure to provide necessary training to emergency responders and fire brigade members failure to provide necessary training to emergency responders and fire brigade members Failure to perform audits as required every 3 years Failure to perform audits as required every 3 years

Compliance Audits There are Companies that have Covered Process, but have not implemented any PSM Program. There are Companies that have Covered Process, but have not implemented any PSM Program. The Regulatory Exposure is to: The Regulatory Exposure is to: Willful Citations Willful Citations Criminal Willful Citations Criminal Willful Citations Serious Citations Serious Citations Major Citation Penalties Major Citation Penalties There are Companies that have Covered Process, but have not implemented any PSM Program. There are Companies that have Covered Process, but have not implemented any PSM Program. The Regulatory Exposure is to: The Regulatory Exposure is to: Willful Citations Willful Citations Criminal Willful Citations Criminal Willful Citations Serious Citations Serious Citations Major Citation Penalties Major Citation Penalties

PSM Audit Example Checklist Items (Partial) Management Commitment to the PSM Program Management Commitment to the PSM Program Is there evidence that an effective process safety management program has been set up and that explicit expectations, objectives and goals have been set with clear-cut, desired outputs? Is there evidence that an effective process safety management program has been set up and that explicit expectations, objectives and goals have been set with clear-cut, desired outputs? Have resources been provided in the form of personnel assigned to provide implementation and continuation of each element? Have resources been provided in the form of personnel assigned to provide implementation and continuation of each element? Have clear lines of responsibility been established and roles and responsibilities assigned? Have clear lines of responsibility been established and roles and responsibilities assigned? Is management commitment to using all available resources for enhancing process safety knowledge at all levels of the organization clearly demonstrated by actions? Is management commitment to using all available resources for enhancing process safety knowledge at all levels of the organization clearly demonstrated by actions? Does management encourage active participation in professional and trade associations for key PSM personnel to ensure the PSM system keeps pace withTest Practices? Does management encourage active participation in professional and trade associations for key PSM personnel to ensure the PSM system keeps pace withTest Practices? Management Commitment to the PSM Program Management Commitment to the PSM Program Is there evidence that an effective process safety management program has been set up and that explicit expectations, objectives and goals have been set with clear-cut, desired outputs? Is there evidence that an effective process safety management program has been set up and that explicit expectations, objectives and goals have been set with clear-cut, desired outputs? Have resources been provided in the form of personnel assigned to provide implementation and continuation of each element? Have resources been provided in the form of personnel assigned to provide implementation and continuation of each element? Have clear lines of responsibility been established and roles and responsibilities assigned? Have clear lines of responsibility been established and roles and responsibilities assigned? Is management commitment to using all available resources for enhancing process safety knowledge at all levels of the organization clearly demonstrated by actions? Is management commitment to using all available resources for enhancing process safety knowledge at all levels of the organization clearly demonstrated by actions? Does management encourage active participation in professional and trade associations for key PSM personnel to ensure the PSM system keeps pace withTest Practices? Does management encourage active participation in professional and trade associations for key PSM personnel to ensure the PSM system keeps pace withTest Practices?

PSM Audit Example Checklist Items (Partial) Process Hazard Analysis Process Hazard Analysis Does the PSM program establish a process hazard analysis procedure in accordance with the PSM rule? Does the PSM program establish a process hazard analysis procedure in accordance with the PSM rule? Have personnel, who will take part in PHA 痴, been provided with training in the PHA technique that will be used for their study? Have personnel, who will take part in PHA 痴, been provided with training in the PHA technique that will be used for their study? Does the PHA procedure establish that the hazard identification team be multi-disciplined in nature, capable of covering such issues as maintenance, operations, design, inspection & testing, safety, health and environment, etc? Does the PHA procedure establish that the hazard identification team be multi-disciplined in nature, capable of covering such issues as maintenance, operations, design, inspection & testing, safety, health and environment, etc? Does the PHA procedure require that the PHA team leader be specially trained in the technique that will be used? Does the PHA procedure require that the PHA team leader be specially trained in the technique that will be used? Does documentation of the hazard identification process include all issues, not only those resulting in findings or recommendations? Does documentation of the hazard identification process include all issues, not only those resulting in findings or recommendations? Have PHA been conducted on all PSM-covered processes and if not, is there an established schedule for completing all PHA’s? Have PHA been conducted on all PSM-covered processes and if not, is there an established schedule for completing all PHA’s? Process Hazard Analysis Process Hazard Analysis Does the PSM program establish a process hazard analysis procedure in accordance with the PSM rule? Does the PSM program establish a process hazard analysis procedure in accordance with the PSM rule? Have personnel, who will take part in PHA 痴, been provided with training in the PHA technique that will be used for their study? Have personnel, who will take part in PHA 痴, been provided with training in the PHA technique that will be used for their study? Does the PHA procedure establish that the hazard identification team be multi-disciplined in nature, capable of covering such issues as maintenance, operations, design, inspection & testing, safety, health and environment, etc? Does the PHA procedure establish that the hazard identification team be multi-disciplined in nature, capable of covering such issues as maintenance, operations, design, inspection & testing, safety, health and environment, etc? Does the PHA procedure require that the PHA team leader be specially trained in the technique that will be used? Does the PHA procedure require that the PHA team leader be specially trained in the technique that will be used? Does documentation of the hazard identification process include all issues, not only those resulting in findings or recommendations? Does documentation of the hazard identification process include all issues, not only those resulting in findings or recommendations? Have PHA been conducted on all PSM-covered processes and if not, is there an established schedule for completing all PHA’s? Have PHA been conducted on all PSM-covered processes and if not, is there an established schedule for completing all PHA’s?

Compliance Audits Audit Findings must be Documented Audit Findings must be Documented Actions must be Taken on All Exceptions Actions must be Taken on All Exceptions All Actions Affecting P&ID’s, PHA’s, Mechanical Integrity Certificates, Inspection/Testing/Maintenance, Operating Procedures & Training Procedures will Require Revision of All Actions Affecting P&ID’s, PHA’s, Mechanical Integrity Certificates, Inspection/Testing/Maintenance, Operating Procedures & Training Procedures will Require Revision of All of the Above All of the Above Audit Findings must be Documented Audit Findings must be Documented Actions must be Taken on All Exceptions Actions must be Taken on All Exceptions All Actions Affecting P&ID’s, PHA’s, Mechanical Integrity Certificates, Inspection/Testing/Maintenance, Operating Procedures & Training Procedures will Require Revision of All Actions Affecting P&ID’s, PHA’s, Mechanical Integrity Certificates, Inspection/Testing/Maintenance, Operating Procedures & Training Procedures will Require Revision of All of the Above All of the Above

Compliance Audits Remember, Remember, The Audit Process is Determine if there are any weaknesses in the system or PSM Program and to provide a report an method to take action. These actions can prevent catastrophic release, injury and death. Remember, Remember, The Audit Process is Determine if there are any weaknesses in the system or PSM Program and to provide a report an method to take action. These actions can prevent catastrophic release, injury and death.

Trade Secrets (p) (p)

All Information Regarding the Process Must be Made Available to Persons Involved in the PSM Program Including Trade Secrets All Information Regarding the Process Must be Made Available to Persons Involved in the PSM Program Including Trade Secrets Confidentiality Agreements are Allowed Confidentiality Agreements are Allowed All Information Regarding the Process Must be Made Available to Persons Involved in the PSM Program Including Trade Secrets All Information Regarding the Process Must be Made Available to Persons Involved in the PSM Program Including Trade Secrets Confidentiality Agreements are Allowed Confidentiality Agreements are Allowed

Summary of PSM Elements Process Safety Information Process Safety Information Equipment ii the Process Equipment ii the Process Process Hazard Analysis Process Hazard Analysis Operating Procedures Operating Procedures Employee Training Employee Training Training Contractors Training Contractors Pre-Startup Safety Review Pre-Startup Safety Review Mechanical Integrity of Equipment Mechanical Integrity of Equipment Management of Change Management of Change Incident Investigation Incident Investigation Emergency Preparedness Emergency Preparedness Compliance Audits Compliance Audits Trade Secrets Trade Secrets Process Safety Information Process Safety Information Equipment ii the Process Equipment ii the Process Process Hazard Analysis Process Hazard Analysis Operating Procedures Operating Procedures Employee Training Employee Training Training Contractors Training Contractors Pre-Startup Safety Review Pre-Startup Safety Review Mechanical Integrity of Equipment Mechanical Integrity of Equipment Management of Change Management of Change Incident Investigation Incident Investigation Emergency Preparedness Emergency Preparedness Compliance Audits Compliance Audits Trade Secrets Trade Secrets

EPA Risk Management Plans (RMP) Basics CAA 112(r)

One More Thing to Discuss… EPA Risk Management Plans (RMP) Many Times Companies Who Must Comply with PSM, must also Comply with the Requirements of EPA Risk Management Plans (RMP) Many Times Companies Who Must Comply with PSM, must also Comply with the Requirements of EPA Risk Management Plans (RMP) The RMP Standard was to be a Mirror of the PSM Standard…Didn’t happen! The RMP Standard was to be a Mirror of the PSM Standard…Didn’t happen! Remember…PSM Protects the Workforce, RMP Protects the Community Remember…PSM Protects the Workforce, RMP Protects the Community Many Times Companies Who Must Comply with PSM, must also Comply with the Requirements of EPA Risk Management Plans (RMP) Many Times Companies Who Must Comply with PSM, must also Comply with the Requirements of EPA Risk Management Plans (RMP) The RMP Standard was to be a Mirror of the PSM Standard…Didn’t happen! The RMP Standard was to be a Mirror of the PSM Standard…Didn’t happen! Remember…PSM Protects the Workforce, RMP Protects the Community Remember…PSM Protects the Workforce, RMP Protects the Community

EPA RMP Basic Requirements Basic Requirements Executive summary Executive summary Registration Registration Off-site consequence analysis Off-site consequence analysis Five-year accident history Five-year accident history Emergency response plan Emergency response plan Prevention program summary information Prevention program summary information Certification Certification Sound Much Easier than PSM…Right? Basic Requirements Basic Requirements Executive summary Executive summary Registration Registration Off-site consequence analysis Off-site consequence analysis Five-year accident history Five-year accident history Emergency response plan Emergency response plan Prevention program summary information Prevention program summary information Certification Certification Sound Much Easier than PSM…Right?

Release Plume All Public Facilities in this Release Plume Must be Identified & Surveyed

EPA RMP Emergency Response Plan & Prevention Plans Must Be Developed to Prevent Accidental Release of the Covered Chemical Emergency Response Plan & Prevention Plans Must Be Developed to Prevent Accidental Release of the Covered Chemical

EPA RMP 1998 Changes Compliance Elements Follow-up / completion of PHA recommendation Follow-up / completion of PHA recommendation Re-validation of your PHA every 5 years Re-validation of your PHA every 5 years Compliance audits (required every 3 years) Compliance audits (required every 3 years) Follow-up / completion of compliance audit recommendations Follow-up / completion of compliance audit recommendations Follow-up / completion of PHA recommendation Follow-up / completion of PHA recommendation Re-validation of your PHA every 5 years Re-validation of your PHA every 5 years Compliance audits (required every 3 years) Compliance audits (required every 3 years) Follow-up / completion of compliance audit recommendations Follow-up / completion of compliance audit recommendations

EPA RMP 1998 Changes Compliance Elements Annual review and certification of operating procedures Annual review and certification of operating procedures Employee training Employee training Updates related to system modifications, inventory changes, operational changes Updates related to system modifications, inventory changes, operational changes Off-site consequence analysis Off-site consequence analysis Annual review and certification of operating procedures Annual review and certification of operating procedures Employee training Employee training Updates related to system modifications, inventory changes, operational changes Updates related to system modifications, inventory changes, operational changes Off-site consequence analysis Off-site consequence analysis

Process Safety Management of Highly Hazardous & Explosive Chemicals & EPA Risk Management Plans SummarySummary

Goals of the One Day Course Understand Why Process Safety Management (PSM) Was Promulgated Understand Why Process Safety Management (PSM) Was Promulgated Understand That Even with PSM, Catastrophes are Still Occurring Understand That Even with PSM, Catastrophes are Still Occurring Understand Who is Covered & Exemptions Understand Who is Covered & Exemptions Understand the Team Process to Developing a PSM Program Understand the Team Process to Developing a PSM Program Understand Each of the Elements of a Properly Designed & Implemented Program and How to Begin the Process Understand Each of the Elements of a Properly Designed & Implemented Program and How to Begin the Process Understand the Basics of How PSM & RMP Work Together to Protect the Workforce & Surrounding Community Understand the Basics of How PSM & RMP Work Together to Protect the Workforce & Surrounding Community Understand Why Process Safety Management (PSM) Was Promulgated Understand Why Process Safety Management (PSM) Was Promulgated Understand That Even with PSM, Catastrophes are Still Occurring Understand That Even with PSM, Catastrophes are Still Occurring Understand Who is Covered & Exemptions Understand Who is Covered & Exemptions Understand the Team Process to Developing a PSM Program Understand the Team Process to Developing a PSM Program Understand Each of the Elements of a Properly Designed & Implemented Program and How to Begin the Process Understand Each of the Elements of a Properly Designed & Implemented Program and How to Begin the Process Understand the Basics of How PSM & RMP Work Together to Protect the Workforce & Surrounding Community Understand the Basics of How PSM & RMP Work Together to Protect the Workforce & Surrounding Community

Resources GTRI - GTRI OSHA PSM Compliance Guidelines - OSHA PSM Compliance Guidelines OSHA PSM for Construction s/psm.html OSHA PSM for Construction s/psm.html GTRI - GTRI OSHA PSM Compliance Guidelines - OSHA PSM Compliance Guidelines OSHA PSM for Construction s/psm.html OSHA PSM for Construction s/psm.html

PSM One Day Review

1. The Process Safety Management Standard was drafted as a requirement of the Clean Air Act. True or False 2.The PSM program must include a list of highly hazardous chemicals. True or False 3.The initial start-up of a process is not included as an operating phase under the PSM Standard. True or False 4.List three items that the process hazard analysis must address. ___________, __________ and __________. 5.PSM does not apply to contractors, regardless of the work they are doing. True or False

PSM One Day Review (cont.) 6. The PSM Standard applies to companies that either process highly _____________ materials or use _____________ liquids and gases in excess of 10,000 pounds. 7.Process safety information includes: ______________, _____________ and _____________. 8.Fault tree analysis is one form of an approved method of performing a process hazard analysis. True or False 9.A technical basis is not required to change a process covered by the PSM Standard. True or False 10.Two types of training required by the PSM standard are ________________ and_________________.