1. Process Safety Management of Highly Hazardous Chemicals
Nancy J Bethea

2. Process Safety Management (PSM)
Is the proactive identification, evaluation and mitigation or prevention of chemical releases that could occur as a result of failures in processes, procedures, or equipment.

3. Purpose Prevent Catastrophic Releases of Highly Hazardous Chemicals
Minimize Consequences of Such Releases to Employees and the Community

5. Catastrophic Events 1984 Mexico City 650 -- 1984 Bhopal, India 2500 --
Deaths Injuries
1984 Mexico City
1984 Bhopal, India
1984 Chicago area
1985 West Virginia
1988 New Orleans
1988 Henderson, NV

6. Catastrophic Events 1989 Pasadena, TX 23 130 1990 Houston, TX 17 --
Deaths Injuries
1989 Pasadena, TX
1990 Houston, TX
1990 Cincinnati, OH
1991 Lake Charles, LA
1991 Sterlington, LA
1991 Charleston, SC
1991 Seadrift, TX

7. Process Safety Management
Bhopal (’84): focused OSHA’s attention
Institute, WV(’85): shows disasters can happen here
: concern of public & Congress increases with each event
Feb. 24, 1992: standard in Federal Register

8. 29 CFR
OSHA’s Process Safety
Management Standard

9. Anticipated Benefits OSHA estimated that the integrated
approach of the PSM standard would reduce
the average annual number of deaths (265)
by 200 and reduce the average annual
number of serious injuries (900) by 700 in
industries involved with highly hazardous
chemicals.

10. Resources European Economic Community (EEC) World Bank
International Labor Office (ILO)
U.S. Environmental Protection Agency
Superfund Amendments and Reauthorization Act (SARA)
States, Industry, & Labor Organizations

11. Specification Standard
PSM Standard
Performance
NOT
Specification Standard

12. PSM Standard Process Safety Information Process Hazard Analysis
Operating Procedures
Training
Contractors
Pre-startup Safety Review

13. PSM Standard Mechanical Integrity Hot-work Permits
Management of Change
Incident Investigations
Emergency Planning & Response
Compliance Safety Audits

14. What’s Covered Listed Chemicals in Appendix A
> 10,000 pounds of Flammable Liquids or Gases

15. Examples of Covered Chemicals
Acetaldehyde Chlorine
Nitromethane Ethylamine
Perchloric Acid Phosgene
Tetramethyl Lead Ketone
HF NO

16. What’s Not Covered
HC fuels used only for workplace consumption and if not a part of a covered hazardous process
Flammable liquids stored or transferred below NBP w/o chilling or refrigeration
Retail facilities
Oil, gas well drilling, servicing
Normally unmanned remote facilities

17. Process Safety Information: Chemicals
Toxicity
PEL
Physical Data
Reactivity and Corrosivity
Thermal and Chemical Stability
Effects of Mixing Chemicals

18. Process Safety Information: Process
Block flow or process flow diagram
Process chemistry
Maximum intended inventory

19. Process Safety Information: Process
Safe upper/lower limits for such items as temperatures, pressures, flows or compositions
Consequences of deviations, e.g. runaway reaction potential

20. Process Safety Information: Equipment
Materials of construction
P&IDs
Electrical Classification
Relief system design & design basis

21. Process Safety Information: Equipment
Ventilation system design
Design codes and standards
Material & energy balances
Safety systems

22. Process Hazard Analysis
Organized and systematic effort to identify and analyze the significance of potential hazards associated with the processing or handling of highly hazardous chemicals

23. Process Hazard Analysis
Causes/consequences of fires & explosions
Releases of toxic or flammable chemicals
Major spills of hazardous chemicals
Methodology depends on the process & its characteristics

24. PHA Focuses On Equipment Instrumentation Utilities Human Actions
External Factors

25. Process Hazard Analysis
What If?
Checklist
What If?/Checklist
Hazard & Operability Study (HAZOP)
Failure Mode & Effects Analysis (FMEA)
Fault Tree Analysis (FTA)

26. PHA Must Address Hazards of the process
Engineering & administrative controls
Consequences of failure of controls
Facility siting

27. PHA Must Address Human factors
Evaluate potential effects to on-site personnel from failure of controls
Identification of previous incidents

28. PHA Team Expertise in engineering & process operations
One member to have knowledge of & experience with process being evaluated

29. PHA Team
One member knowledgeable in specific PHA methodology used for evaluating the process
Other members with specific knowledge: instrumentation, chemistry, etc.

30. Employer PHA Actions Establish system for prompt response
Ensure timely resolution of findings & recommendations
Document actions taken

31. Employer PHA Actions Develop written schedule for completions
Complete actions ASAP
Communicate actions to affected employees

32. Operating Procedures
Provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information
Address at least the listed elements

33. Operating Procedures: Steps for Each Operating Phase
Initial startup, operation, shutdown
Temporary & emergency operations, emergency shutdown
Startup following shutdowns

34. Operating Procedures: Operating limits
consequences of deviations
prevention of deviations

35. Operating Procedures: Safety & Health Considerations
Chemical properties and hazards
Precautions to prevent exposure
Control measures if contact or airborne exposure occurs

36. Operating Procedures: Safety & Health Considerations
Quality controls for raw materials
Control of hazardous chemical inventories
Special or unique hazards
Safety systems & their functions

37. Operating Procedures Operating procedures readily accessible
Reviewed as necessary to reflect current procedures and changes
Certified annually as current & accurate

38. Operating Procedures
Develop & implement safe work practices to provide for the control of hazards during operations, e.g. lockout/tagout/ confined space entry, opening equipment & pipes, facility entry
Apply to employees & contractor employees

39. Training Process overview Process hazards Operating procedures
Emergency procedures
Refresher training at least every 3 yrs
Documentation

40. Employer Responsibilities
Evaluate contractor’s safety performance & programs
Inform contractor of potential hazards: fire, explosion, toxic release, applicable plant safety rules
Develop/Implement safe work practices
Evaluate contractor performance

41. Contractor Responsibilities
Advise employer of any unique work hazards of contracted work
Each employee follow all applicable work practices & safety rules of the facility
Ensure each employee is trained in necessary work practices

42. Contractor Responsibilities
Ensure each employee is instructed in known fire, explosion, or toxic release problems related to his/her job
Document that understanding of training has been evaluated, verified

43. Pre-startup Safety Review
Done when:
New processes
Modified process

44. Pre-startup Review Verifies
Construction: conforms to design
Procedures: adequate, in place
PHA recommendations resolved or implemented
Management of change requirements met
All affected workers trained

45. PSM Mechanical Integrity
Pressure vessels, storage tanks
Piping systems, components
Relief & vent systems, devices
Emergency shutdown systems
Controls: monitoring devices, sensors, alarms, interlocks
Pumps

46. Mechanical Integrity Written procedures
Training: process hazards, job tasks
Inspections
Testing
Corrective action
Records

47. Hot Work Permits Welding, cutting, brazing Control of ignition sources
Verify safe conditions
Authorization

48. Management of Change Establish written procedures
Develop management support
Evaluate safety of any changes to:
process chemicals facility
technology equipment

49. MOC Procedures Must Address
Everything except “replacement in kind”
Temporary as well as permanent changes
Technical basis for change
Safety & health effects

50. MOC Procedures Must Address
Modified operation procedures
Time necessary for change
Authorization for change
Ways to inform & train workers before change

51. Incident Investigation Goals
Identify incident causes and implement steps to prevent reoccurence

52. Incident Investigation
Every incident
Prompt investigation
Knowledgeable team
Documentation & report
Recommendations & findings
Resolutions & corrective actions

53. Emergency Planning & Response
Develop Emergency Action Plans
Pre-plan for catastrophe
Train & equip workers
Drills

54. Compliance Safety Audits
Certify all elements of standard
Knowledgeable audit team
Report & recommendations
Address all finding & recommendations
Conduct every three years

55. Appendices A: List of chemicals B: Sample block & flow diagrams
C: Compliance guidelines
D: References