1. Ert 312
LECTURE 4
OSHA & DOSH

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

3. 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.

4. 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.

5. 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.

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

7. *Sharing with students – Legislative Documents of OSHA ACT 1994

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

17. Industrial Hygiene ERT 312
Lecture 4 - PSM & RMP

18. PSM
IDENTIFY
MSDS
RMP IH
EVALUATE
CONTROL

19. 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.

20. 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

21. Identify Example of MSDS

22. 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

23. 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

24. 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

25. 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

26. 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

27. 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

28. 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

29. 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

30. 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

31. 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

32. 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

33. 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

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

35. 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

36. 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

37. 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

38. 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

39. Discussion
List down major comparisons between PSM and RMP?

40. 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)