1. Department of Defense Voluntary Protection Programs Center of Excellence Development, Validation, Implementation and Enhancement for a Voluntary Protection Programs Center of Excellence (VPP CX) Capability for the Department of Defense Department of Defense Voluntary Protection Programs Center of Excellence Process Management Safety Development, Validation, Implementation and Enhancement for a Voluntary Protection Programs Center of Excellence (VPP CX) Capability for the Department of Defense

2. Objectives After this training you will be able to: Understand the history behind the Process Safety Management (PSM) standard Understand key provisions of the PSM standard.

3. What is Process Safety Management? PSM is a process involving all managers, employees and contract workers, with the purpose of minimizing uncontrolled change from design and/or operating intent at their facility.

4. Why Process Safety Management? 1910.119 Federal Standard May 26,1992 1974-Flixborough, England: Explosion killed everyone at the plant 1976-Seveso, Italy: dioxin release 1984-Mexico City: 500 killed due to LPG explosion 1984-Bhopal, India: 2,000 deaths as a result of a methyl isocyanate release at Union Carbide 1985-Institute, W.V.: First major release in the States. Union Carbide Plant 1989-Pasadena, TX.: Petrochemical explosion and fire. 23 deaths, 132 injuries.

5. PSM Rule Provisions Employee Participation Process Safety Information Process Hazard Analyses Operating Procedures TrainingContractors Mechanical Integrity Pre-Startup Safety Review Hot Work Permits Management of Change Incident Investigations Emergency Planning and Response Compliance Audits Trade Secrets

6. PSM Rule Provisions Employee Participation Process Safety Information Process Hazard Analyses Operating Procedures TrainingContractors Mechanical Integrity Pre-Startup Safety Review Hot Work Permits Management of Change Incident Investigations Emergency Planning and Response Compliance Audits Trade Secrets

7. Employee Participation For a written PSM program to be successful, it must involve all employees and contractors. The employer shall develop the written plan to identify: –Who is responsible for the management of the program –How employees can be informed about the program and updates –How suggestions can be submitted for improvement.

8. Employee Participation Communicate PSM program information to employees  New comer orientation  Annual training  Safety or staff meetings  Email  Newsletters. Inform affected employees of the findings from incident investigation, audits and Process Hazard Analysis (PHA)  Involve employees in the investigation process  Involve employees in standard operating procedure updates.

9. Employee Participation Easy access to important PSM information must be available to employees. This includes:  Information on the PSM program (Process Safety information (PSI), PHAs, etc.)  Incident and near miss review information  Emergency response plans and procedures.

10. PSM Rule Provisions Employee Participation Process Safety Information Process Hazard Analyses Operating Procedures TrainingContractors Mechanical Integrity Pre-Startup Safety Review Hot Work Permits Management of Change Incident Investigations Emergency Planning and Response Compliance Audits Trade Secrets

11. Comprehensive Process Safety Information Process Equipment Hazards & Chemicals Technology & Process

12. Process Safety Information (PSI) Hazards of the chemical include:  Toxicity information  Permissible exposure limits  Physical data  Reactivity data  Corrosivity data  Thermal and chemical stability data  Hazard effects of inadvertent mixing of different materials

13. Process Safety Information (PSI) Information Pertaining to the Technology of the Chemical  Block Flow Diagram  Process Chemistry  Maximum Intended Inventory  Safe Upper/Lower Limits  Evaluation of consequences of deviations, including those affecting safety and health of employees.

14. Process Safety Information (PSI) Equipment of the chemical process includes:  Materials of Construction  Piping and Instrument Diagrams (P&IDs)  Electrical Classifications  Relief System Design and Design Basis  Ventilation System Design and Design Basis  Design Codes and Standards  Material and Energy Balances for Processes  Safety Systems  Equipment complies with recognized and generally good engineering practices.  Equipment designed/constructed to codes/standards no longer in general use.

15. PSM Rule Provisions Employee Participation Process Safety Information Process Hazard Analyses Operating Procedures TrainingContractors Mechanical Integrity Pre-Startup Safety Review Hot Work Permits Management of Change Incident Investigations Emergency Planning and Response Compliance Audits Trade Secrets

16. Process Hazard Analysis (PHA) PHA is the systematic process to identify and analyze possible hazard scenarios with a PSM covered process.  Potential causes and consequences of fires, explosions and toxic releases.  Equipment failures, human errors and external events that may cause accidents. One of the following methodologies can be used :  What-If  Checklist  What-If/Checklist  Hazard and Operability Study (HAZOP)  Failure Modes and Effects Analysis (FMEA)  Fault Tree Analysis.

17. Process Hazard Analysis (PHA) PHA is :  Identifying, evaluating and controlling process hazards involving hazardous chemicals through a systemic means  Conducted to identify scenarios (e.g., events with potential for catastrophic releases) associated with the system  Completed initially and revalidated every five years.

18. Process Hazard Analysis (PHA ) PHA Identifies:  Hazards of the process  Previous incident  Engineering & administrative controls  Consequences of failures  Facility sitting  Human factors  Possible health & safety effects on associates should there be a release.

19. PSM Rule Provisions Employee Participation Process Safety Information Process Hazard Analyses Operating Procedures TrainingContractors Mechanical Integrity Pre-Startup Safety Review Hot Work Permits Management of Change Incident Investigations Emergency Planning and Response Compliance Audits Trade Secrets

20. Standard Operating Procedures (SOP) Operating procedures must implement safe work practices:  Lockout/tagout  Confined space entry  Line Breaks  Opening process equipment or piping  Control over facility entrance Operating procedures must be annually certified that they are current and accurate with the process. Operating procedures must be specific to the covered process and be developed by the employees operating the process Operating procedures must be accessible to employees that work the process.

21. Standard Operating Procedures (SOP) Procedures must include steps for each operating phase:  Initial startup  Normal operations  Temporary operations  Emergency shutdown  Emergency operations  Normal shutdown  Startup following a turnaround.

22. Standard Operating Procedures (SOP) Operating Limits  Consequences of deviation  Steps required to correct or avoid deviation.

23. Standard Operating Procedures (SOP) Safety & Health Considerations  Properties of & hazards presented by the chemicals used  Precautions necessary to prevent exposure  Control measures to be taken if physical contact or airborne exposure occurs  Quality control for raw materials  Any special or unique hazards  Safety systems & their functions.

24. Standard Operating Procedures (SOP) The employer shall:  Be readily available to refrigeration associates  Be reviewed as often as necessary for accuracy  Be certified as being current and accurate at least annually  Develop and implement safe work practices such as LOTO, confined space entry, line opening, and control over entrance into the facility by maintenance, contractors, laboratory or other support personnel.

25. PSM Rule Provisions Employee Participation Process Safety Information Process Hazard Analyses Operating Procedures TrainingContractors Mechanical Integrity Pre-Startup Safety Review Hot Work Permits Management of Change Incident Investigations Emergency Planning and Response Compliance Audits Trade Secrets

26. Training Initial Training  Employees shall be trained in an overview of the process and in the operating procedures, which includes: »Emphasis on the specific safety and health hazards »Emergency operations including shutdown »Safe work practices Refresher Training  Shall be provided every three years to assure the employee understands and adheres to the current operating procedures of the process.  Consult with employees to determine the appropriate frequency of refresher training.

27. PSM Rule Provisions Employee Participation Process Safety Information Process Hazard Analyses Operating Procedures TrainingContractors Mechanical Integrity Pre-Startup Safety Review Hot Work Permits Management of Change Incident Investigations Emergency Planning and Response Compliance Audits Trade Secrets

28. Contractors Contractor Provisions:  Apply to contractors performing maintenance, repair, turnaround, major renovation or specialty work on or adjacent to a covered process  Require that process owners screen and hire contractors that perform work safely  Contractors should implement their own safety programs  All must work to ensure good communication.

29. Contractors Process Owners Responsibilities:  Ensure that contract employees are trained in the work practices necessary to perform their job safely  Ensure that contract employees follows the safety rules of the facility including the required safe work practices required in the operating procedures of the standard  Document that each contract employee has received and understood the training required.

30. Contractors Contractor Responsibilities  Assure each employee is trained in practices necessary to safely perform their job.  Assure each employee is instructed in the known potential fire, explosion, or toxic release hazards and the applicable provisions of the emergency action plan.  Document that each employee received and understood the training required. Prepare a record, which identifies the employee, date of training and means used to verify employee understood the training.  Assure employee follows the safety rules of the facility.  Advise employee of any unique hazards presented by employer’s work or of any hazards found by employer’s work.

31. PSM Rule Provisions Employee Participation Process Safety Information Process Hazard Analyses Operating Procedures TrainingContractors Mechanical Integrity Pre-Startup Safety Review Hot Work Permits Management of Change Incident Investigations Emergency Planning and Response Compliance Audits Trade Secrets

32. Mechanical Integrity Mechanical Integrity strives to ensure all equipment, piping, instrumentation, electrical systems and other items are designed, constructed and maintained to the appropriate standards thus decreasing the probability of failure. Mechanical integrity applies to:  Pressure vessels and storage tanks  Piping systems including valves an other components  Relief, vent systems and devices  Emergency shutdown systems  Controls  Pumps.

33. Mechanical Integrity Written procedures must be established and implemented to maintain the integrity of the equipment. Employees involved in maintaining the equipment muse receive training on:  The process and its hazards  Maintenance procedures  Safe work practices  Proper use of equipment.

34. Mechanical Integrity Equipment must be inspected and tested and documented to include:  Date  Name of person performing the inspection or test  Identification of equipment  Test/Inspection description  Test/Inspection results. Treat mechanical integrity procedures like operating procedures. Annual certification.

35. PSM Rule Provisions Employee Participation Process Safety Information Process Hazard Analyses Operating Procedures TrainingContractors Mechanical Integrity Pre-Startup Safety Review Hot Work Permits Management of Change Incident Investigations Emergency Planning and Response Compliance Audits Trade Secrets

36. Pre-Start Safety Review (PSSR) Before the chemical is introduced into the system, the process owner must confirm:  Construction and equipment are in accordance with design specs  Safety, operating, maintenance and emergency procedures are in place  A PHA has been performed and recommendations have been resolved or implemented before start-up.

37. Pre-Start Safety Review (PSSR) In existing facilities Management of Change requirements must be met Training for each employee involved in operating the process must be completed.

38. PSM Rule Provisions Employee Participation Process Safety Information Process Hazard Analyses Operating Procedures TrainingContractors Mechanical Integrity Pre-Startup Safety Review Hot Work Permits Management of Change Incident Investigations Emergency Planning and Response Compliance Audits Trade Secrets

39. Hot Work Permits Hot work involves:  Cutting  Brazing  Grinding  Electric or gas welding  Burning  Exposure of energized electrical conductors. Any work that creates a spark and is outside of designated hot work shops.

40. PSM Rule Provisions Employee Participation Process Safety Information Process Hazard Analyses Operating Procedures TrainingContractors Mechanical Integrity Pre-Startup Safety Review Hot Work Permits Management of Change Incident Investigations Emergency Planning and Response Compliance Audits Trade Secrets

41. Management of Change (MOC) Shall establish written procedures to manage changes to:  Process chemicals  Process technology  Equipment  Procedures  Facilities that affect a covered process. Does not apply to replacements in kind  Are replacements that satisfy the design specifications.

42. Management of Change (MOC) Written procedures must address prior to the change:  Technical basis for the change  Impact the change will have on safety and health  Modifications to operating procedures  Necessary time period for the change  Authorization requirements for proposed change Employees involved in operating the process, maintenance and contract employees shall be informed of and trained in the change prior to start-up.

43. PSM Rule Provisions Employee Participation Process Safety Information Process Hazard Analyses Operating Procedures TrainingContractors Mechanical Integrity Pre-Startup Safety Review Hot Work Permits Management of Change Incident Investigations Emergency Planning and Response Compliance Audits Trade Secrets

44. Incident Investigations Investigate each incident, which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemical. Incident investigation shall be initiated as promptly as possible, but no later than 48 hours following the incident. Incident investigation team:  One person knowledgeable in the process  Contract employee if incident involved their work  People with knowledge and experience to thoroughly investigate and analyze the incident.

45. PSM Rule Provisions Employee Participation Process Safety Information Process Hazard Analyses Operating Procedures TrainingContractors Mechanical Integrity Pre-Startup Safety Review Hot Work Permits Management of Change Incident Investigations Emergency Planning and Response Compliance Audits Trade Secrets

46. Emergency Planning and Response Establish and implement an emergency action plan per 29 CFR 1910.38 Emergency action plan at a minimum, must have procedures for:  Reporting a fire or other emergency  Emergency evacuation, including type of evacuation and exit route assignments  Employees to remain to operate critical plant operations before they evacuate  Accounting for all employees after evacuation  Employees performing rescue or medical duties  The name and job title of every employee who may be contacted by employees who need more information about the plan.

47. Emergency Planning and Response Emergency action plan must be in writing and kept in the workplace and made available to employees for review. Must have and maintain an employee alarm system, which uses a distinctive signal for each purpose and complies with 29 CFR 1910.165 Must review the emergency action plan with each employee covered by the plan.

48. PSM Rule Provisions Employee Participation Process Safety Information Process Hazard Analyses Operating Procedures TrainingContractors Mechanical Integrity Pre-Startup Safety Review Hot Work Permits Management of Change Incident Investigations Emergency Planning and Response Compliance Audits Trade Secrets

49. Compliance Audits Audit the compliance of your PSM program every 3 years to verify PSM procedures are adequate and being followed. The audit must be conducted by at least one person knowledgeable in the process. Develop a report of the audit findings and document appropriate response to each finding. Document when deficiencies have been corrected. Retain two most recent compliance audit reports.

50. PSM Rule Provisions Employee Participation Process Safety Information Process Hazard Analyses Operating Procedures TrainingContractors Mechanical Integrity Pre-Startup Safety Review Hot Work Permits Management of Change Incident Investigations Emergency Planning and Response Compliance Audits Trade Secrets

51. A trade secret could be a formula, device, pattern or compilation of information used in one’s business and provides them the opportunity for advantage over competitors. Employers shall make information available to comply with the PSM standard to:  Compile PSI  Assist the development of PHA(s)  Developing operating procedures  Individuals involved with incident investigations, emergency planning and compliance audits.

52. PSM Rule Provisions Employee Participation Process Safety Information Process Hazard Analyses Operating Procedures TrainingContractors Mechanical Integrity Pre-Startup Safety Review Hot Work Permits Management of Change Incident Investigations Emergency Planning and Response Compliance Audits Trade Secrets

53. Department of Defense Voluntary Protection Programs Center of Excellence Development, Validation, Implementation and Enhancement for a Voluntary Protection Programs Center of Excellence (VPP CX) Capability for the Department of Defense Questions?