Ert 312 LECTURE 4 OSHA & DOSH

OSHA Occupational Safety & Health Administration of United States Government – DOL In Malaysia, OSHA is known as DOSH – Ministry of Human Resource

Objective The department is a government agency responsible for the administration and enforcement of legislations related to Occupational Safety and Health for our nation, with a vision of becoming the organization which leads the nation in creating a safe and healthy work culture that contributes towards enhancing the quality of working life.

Roles & Functions To study and review the policies and legislations of occupational safety and health. To enforce the following legislations : a) Occupational Safety and Health Act 1994 and its regulations. b) Factories and Machinery Act 1967 and its regulations. c) Part of Petroleum Act 1984 (Safety Measures) and its regulations.

To conduct research and technical analysis on issues related to occupational safety and health at the workplace. To carry out promotional and publicity programs to employers, workers and the general public to foster and increase the awareness of occupational safety and health.

To become a secretariat for the National Council regarding occupational safety and health.

*Sharing with students – Legislative Documents of OSHA ACT 1994

OSHA ACT 1994 15 parts Sub-Laws 7 Regulations 2 Orders 4 Codes of Conduct 36 Guidelines

Industrial Hygiene ERT 312 Lecture 4 - PSM & RMP

PSM IDENTIFY MSDS RMP IH EVALUATE CONTROL

Industrial Hygiene A science devoted to the identification, evaluation and control of occupational conditions that cause sickness and injury Example: Reduce toxic airborne vapors through ventilation Select proper PPEs to prevent worker exposure Develop SOP for handling of hazardous materials Monitor and reduce noise, heat, radiation etc.

Continue… Identification – determination of the presence or possibility of workplace exposures Evaluation – determination of the magnitude of the exposure Control – application of appropriate technology to reduce workplace exposures to acceptable level

Identify Example of MSDS

OSHA: PROCESS SAFETY MANAGEMENT (PSM) Developed after Bhopal 1984 accident. Final rule published on 24th Feb, 1992 Process Safety Management of Highly Hazardous Chemicals A performance oriented standard that spell out the requirements for management of hazardous chemicals 14 sections

14 sections Employee participation Process safety information Process hazard analysis Operating procedures Training Contractors Pre-startup safety review Mechanical integrity Hot work permits Management of change Incident investigations Emergency planning and response Audits Trade secrets 14 sections

1. Employee participation PSM require active employee participation Employers must develop and document a plan of action to specify this participation 2. Process safety information Info is compiled and available for employees to help the understanding and identification of hazards BFD/PFD, process chemistry + process limitations Pre-condition for subsequent sections

3. Process hazard analysis (PHA) Perform by experts in their respective fields Revise every 5 years Complex process – HAZOP Less complex process What-if analysis Checklist Failure mode and effect analysis (FMEA) Fault tree/diagram

4. SOP SOP that facilitate the safe operation of the plant/process/equipment must be documented Content – startup, shutdown, emergency shutdown, operating limit, safety instructions, LOTO and etc. Update frequently

5. Training Effective training helps employee understand the surrounding hazards Operating personnel must competence enough to run the process/maintenance. Certification and refresher program 6. Contractors Contractors are trained to perform their tasks safely to the same extent as employees Investigate contractors’ safety history

7. Pre-startup safety review A group of reviewers System build-up is same to the design specifications Safety, maintenance, operating and emergency procedures are in place Appropriate training is completed Recommendations from PHA are implemented or resolved

8. Mechanical integrity To ensure the equipments, piping, relief systems, controls and alarms are functionable Among the requirements; Written procedures to maintain functioning systems Training on preventative maintenance Periodical inspections and testing based on vendor recommendations A process to correct deficiencies Spare parts compatibilities

9. Hot work permit 10. Management of change A system to prepare and issue hot work permit before conducting hot work activities (welding, grinding etc.) 10. Management of change Employees are required to develop and implement documented procedures to manage changes; Process chemistry Process equipment SOP Changes must be reviewed before approval to ensure it will not affect the safety of the operation

11. Incident investigation Investigation must be conducted within 48 hours Comply to investigation recommendations 12. Emergency planning and response Employees require to respond effectively to the release of highly hazardous chemicals Needed for company > 10 employees

13. Audits Employers are required that they have evaluated their compliance with the standard at least every 3 years 14. Trade secrets To ensure the contractors are given all the information relevant to operating in the plant safety Secrecy agreement - confidential

EPA: Risk Management Plan (RMP) Final rule released on June 20, 1996 A response to Bhopal accident Necessary requirement for plant that uses more than a specified threshold quantity of regulated highly hazardous chemicals 4 elements Aim: To decrease and reduce the number and magnitude of accidental releases toxic and flammable substances

Emergency response program Documentation The 4 RMP elements Hazard assessment Prevention program Emergency response program Documentation

1. Hazard assessment A consequence analysis for a range of potential hazardous chemical releases, including the history of such releases at the facility Analysis is based on the worst case scenario Likelihood of the accident occurrence is excluded; therefore the results are not a true risk determination

2. Prevention program 11 sub-elements. Process safety information Hazard evaluation SOP Training Pre-startup review Maintenance Management of change Accident investigations Emergency response Safety Audits Risk Assessment

3. Emergency response program Define the steps to be taken by the facility’s employees in response to accidental releases of hazardous materials A procedure to notify the local community and the appropriate emergency response agency Training is a must to all employees Drills to test a plan and to evacuate its effectiveness

4. Documentation Must be maintained on site and submitted to authority body. Information is shared with local community RMP document is updated when; Process/chemistry changes Governmental audits request an update

Discussion List down major comparisons between PSM and RMP?

Answers: RMP – to protect off-site people and the environment PSM – to protect on-site people Prevention program for PSM & RMP is mainly duplicated (refer to table 3-4)