1. Process Safety Management (PSM)
Safety and Security Conference
April 21, 2010 1
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The Law – Intent
“The process safety management standard targets highly hazardous chemicals that have the potential to cause a catastrophic incident. This standard as a whole is to aid employers in their efforts to prevent or mitigate episodic chemical releases that could lead to a catastrophe in the workplace and possibly to the surrounding community.”
APPENDIX C TO § 2
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The Law – Intent
To prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals
“This section contains requirements for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. These releases may result in toxic, fire or explosion hazards.”
OSHA interprets “catastrophic” as an incident that results in:
A fatality
Three or more are hospitalized. 3
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29 CFR Covered Processes
Materials on site at or above threshold quantities of chemicals listed in appendix A of the standard.
Flammable liquids / gases onsite in one location in quantities greater than 10,000 lbs. (Certain exemptions apply)
Manufacture of explosives.
Manufacture of pyrotechnics
List of highly hazardous chemicals (appendix A to 29 CFR ).
§ Process safety management of highly hazardous chemicals.
Purpose. This section contains requirements for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. These releases may result in toxic, fire or explosion hazards.
Section 14 has a copy of the regulation. 4
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5. Elements OSHA Standard 29 CFR 1910.119
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
Compliance Audit Every 3 Years
Trade Secrets.
Unions pushed for employee participation (since it was operations personnel that were getting injured / killed by the incidents. OSHA is proactive in supporting union labor participation. However, due to shift rotations, getting bargaining unit employees involved in a risk assessment project is not an easy task.
Shift-to-shift variations in operating procedure, particularly in manual operations, is often uncovered during the team risk assessment sessions. 5
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6. Employee Participation
Employers shall develop a written plan of action regarding the implementation of the employee participation required by this paragraph.
Employers shall consult with employees and their representatives on the conduct and development of process hazards analyses and on the development of the other elements of process safety management in this standard.
Employers shall provide to employees and their representatives access to process hazard analyses and to all other information required to be developed under this standard.
OSHA’s intent – involve operators in the RA. Particularly bargaining unit employees.
§ Process safety management of highly hazardous chemicals 6
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7. Process Safety Information (PSI)
“In accordance with the schedule set forth in paragraph (e)(1) of this section, the employer shall complete a compilation of written process safety information before conducting any process hazard analysis required by the standard.”
§ Process safety management of highly hazardous chemicals 7
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PSI – The Chemicals
Information Pertinent to the Highly Hazardous Chemicals of the Process (used or produced):
Toxicity
Permissible Exposure Limits
Physical Data
Reactivity Data
Corrosivity Data
Thermal and Chemical Stability Data
Incompatibility data. 8
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Chemicals – The Intent
“The information to be compiled about the chemicals, including process intermediates, needs to be comprehensive enough for an accurate assessment of the fire and explosion characteristics, reactivity hazards, the safety and health hazards to workers, and the corrosion and erosion effects on the process equipment and monitoring tools. Current material safety data sheet (MSDS) information can be used to help meet this requirement which must be supplemented with process chemistry information including runaway reaction and over pressure hazards if applicable.”
The Ciba Guidance notes and subsequent material presented in this course is consistent with the laws intent.
APPENDIX C TO § —COMPLIANCE GUIDELINES AND RECOMMENDATIONS FOR PROCESS SAFETY MANAGEMENT (NONMANDATORY)
APPENDIX C TO § 9
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PSI – The Process
Information Pertinent to the Technology of the Process:
Block Flow Diagrams or simplified Process Flow Diagram
Process Chemistry
Maximum Intended Inventory
Safe upper and lower limits such as temperature, pressure, flows
An evaluation of the consequences of deviation including those affecting safety and health of employees
The following items are included Process Technology section of the Ciba McIntosh site SAFETY POLICY AND PROCEDURE 15-X-11.00, “Process Safety Information, but are not explicitly required in the OSHA standard:
Data on previous incidents related to the process or operation
Ecotoxicity. 10
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What is a Process?
“Process means any activity involving a highly hazardous chemical including any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or combination of these activities. For purposes of this definition, any group of vessels which are inter-connected and separate vessels which are located such that a highly hazardous chemical could be involved in a potential release shall be considered a single process.”
§ Process safety management of highly hazardous chemicals, Definitions 11
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PSI -- Equipment
Materials of construction
P & id's
Electrical classifications
Relief systems & design basis
Ventilation systems
Design codes
Material / energy balances (for processes built after )
Safety systems / interlocks  12
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13. PSI – Incidents (Intent)
The intent of an incident investigation is for employers to learn from past experiences and thus avoid repeating past mistakes. The incidents for which OSHA expects employers to become aware and to investigate are the types of events which result in or could reasonably have resulted in a catastrophic release.
Some of the events are sometimes referred to as ‘‘near misses,’’ meaning that a serious consequence did not occur, but could have.
APPENDIX C TO § 13
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14. Critical Limits – The Law’s Intent
“Process technology information will be a part of the process safety information package and it is expected that it will include diagrams of the type shown in appendix B of this section as well as employer established criteria for maximum inventory levels for process chemicals; limits beyond which would be considered upset conditions; and a qualitative estimate of the consequences or results of deviation that could occur if operating beyond the established process limits.”
Appendix B has the block flow and and process flow diagrams.
APPENDIX C TO § 14
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PHA Scope
The process hazard analysis shall address:
The hazards of the process.
The identification of any previous incident which had a likely potential for catastrophic consequences in the workplace.
Engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases.
Consequences of failure of engineering and administrative controls.
Facility siting.
Human factors.
A qualitative evaluation of a range of the possible safety and health effects of failure of controls on employees in the workplace. 15
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PHA Requirements
(e)(1)
Prioritize processes and perform initial PHAs within 5 years.
(e)(2)
Use specified methodologies or equivalent
(e)(3)
Address hazards of the process and six specific concerns in the PHA.
(e)(4)
Include proper expertise and experience on the PHA team.
(e)(5)
Establish a system to track the handling of the PHA recommendations.
(e)(6)
Update and revalidate PHAs every 5 years.
(e)(7)
Retain PHA documentation for the life of the process. 16
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The RA Team
“The process hazard analysis shall be performed by a team with expertise in engineering and process operations, and the team shall include at least one employee who has experience and knowledge specific to the process being evaluated. Also, one member of the team must be knowledgeable in the specific process hazard analysis methodology being used.”
OSHA 17
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Methodology
What-If
Checklist
What-If/Checklist
Hazard and Operability Study, (HAZOP)
Failure Mode and Effects Analysis (FMEA)
Fault Tree Analysis, or
An appropriate equivalent methodology.
The PHA output (record) should indicate why a particular method or method(s) were chosen.
FMEA supports quantification risk assessments.
Three methodologies that are defensible for regulatory compliance:
What-If/Checklist
Hazard and Operability Study, (HAZOP)
Failure Mode and Effects Analysis (FMEA) 18
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Corrective Action
“The employer shall establish a system to promptly address the team’s findings and recommendations:
Assure that the recommendations are resolved in a timely manner and that the resolution is documented
Document what actions are to be taken;
Complete actions as soon as possible;
Develop a written schedule of when these actions are to be completed;
Communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions.”
An employer can justifiably decline to adopt a recommendation when the employer can document, in writing and based upon adequate evidence that:
The analysis upon which the recommendation is based contains material factual errors;
The recommendation is not necessary to protect the health and safety of the employer’s own employees, or the employees of contractors (I do not think this is currently applicable with EPA’s RMP regulation that extends responsibility beyond the plant fence line, LDF).
An alternative measure would provide a sufficient level of protection; or
The recommendation is infeasible.
OSHA considers an employer to have “resolved” the team’s findings and recommendations when the employer either has adopted the recommendations or has justifiably declined to do so. When a recommendation is rejected, the employer must communicate this to the team, and expeditiously resolve any subsequent recommendations to the team. 19
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20. Corrective Action Tracking Process – Basic Process
Re-opened If Not Effective
New Action Added
Person Assigned To Action
Person Assigned ed
Action Completed
Action Taken Verified By Owner
Action Closed 20
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Contractors
Contractor Safety
Train on Work Practices
Inform Contractor
Hazards
Emergency Action Plan
Control and Track
Evaluate
Maintain Injury and Illness Log 21
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22. Written Operating Procedures Requirements
Steps for each operating phase
Initial startup
Normal operations
Temporary shutdowns
Emergency shutdowns
Emergency operations
Normal shutdowns
Startup after shutdowns
Operating limits / deviations
Safety & health considerations
Safety systems & their functions 22
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23. Pre-startup Safety Review Requirements
Construction is in accordance with design specifications
Safety, operating, maintenance, and emergency procedures are in place and adequate
Process hazards analysis recommendations have been addressed
Employee training completed 23
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24. Mechanical Integrity Scope
Pressure vessels
Storage tanks
Piping systems
Relief / vent systems & devices
Emergency shutdown systems
Process Controls (e.G.: Sensors, alarms, interlocks, etc.)
Pumps 24
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25. Mechanical Integrity Requirements
Written procedures
Training program
Inspections / testing
Records / documentation
Corrective action program
Quality assurance in new installations 25
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26. Management Of Change Procedure Requirements
Technical basis of change
Impact of change on safety, health & ecology
Modifications to operating procedures
Necessary time period for change
Authorization requirements
Employee training requirements 26
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27. MOC/PSSR Process – Basic Process27
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28. Incident Investigations
Scope: incidents which resulted in, or could reasonably have resulted in a catastrophic release of a highly hazardous chemical in the workplace.
Investigation initiated within 48 hours
Investigation by knowledgeable team
Report content:
Date of incident
Date investigation began
Incident description
Contributing factors
Recommendations
Corrective action systems
Communication of report
Retention of report for 5 years 28
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29. AIIMS Process – Basic Process29
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30. Emergency Planning & Response Requirements
Evacuation procedures / routes
Critical equipment operation
Head count procedures
Rescue & medical duties
Notification
Alarm systems
Types of evacuation
Training
Procedures for handling small releases
As per OSHA 29 CFR a, , & 30
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Thank You for Your Time
Shawn Blenis
Intertek USA 31
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