1. 1
PROCESS SAFETY
MANAGEMENT
VS
RISK MANAGEMENT
An Overview
Tracy Estes, CSP
James E. Roughton, MS, CSP, CRSP, CHMM

2. 2
Process Safety Management
Required by the Environmental Protection Agency's
(EPA) Clean Air Act Amendments (CAAA),
Section 304
Promulgated - February 24, 1992
5 year implementation
Proactive identification, evaluation, and mitigation or
prevention of chemical releases that could occur as a
result of failures in processes, procedures, or
equipment
130 highly hazardous chemicals (HHC’s)

3. 3
Process Safety Management
(continued)
10,000 lb. or more of flammable materials that are
used at or above their boiling points
Pyrotechnics and explosives manufacturers
More than 28,000 facilities affected
Exemptions:
 fuels used for workplace consumption
 Comfort heating
 Gasoline for vehicles

4. 4
Risk Management Plan
Mandated by CAAA, Section 112 (r), 40 CFR
Part 68
Promulgated - May 24, 1996
Published Federal Register - June 20, 1996
More than 100,000 facilities affected
Designed to help reduce risk of accidental release of
hazardous substances
3 years to implement

5. 5
Risk Management Plan
(continued)
Affects owners of a stationary source with regulated
substances above a threshold quantity (TQ):
 77 acutely toxic
 63 flammable
 Department of Transportation (DOT) classified explosive
substances

6. 6
EPA’s Visions for Accidental
Release Prevention
Emphasize community right-to-know
Let information drive action
Focus the program at the local level
 EPA support
Coordinate communications at local level

7. 7
Key Features of RMP
Prevention program
 7-elements “mini-PSM” program
 14 elements OSHA-PSM program expanded to address
offsite effects
Emergency response program
Risk management plan
Electronic submission to state and LEPC
 Available to public
Regulatory audits

8. 8
Key Features
(continued)
3 Program levels
Management system
Offsite consequence analysis
 Worst-case scenario
 Alternative release scenario
5-year accident history

9. 9
Key Features
(continued)
Summarizes key elements of the RMP program
 Tells a story
 Hazards at the site
 Accident history
 Potential offsite consequences
 Prevention steps
 Response program

10. 10
Exemptions to Threshold
Quantity
Articles
Laboratories
Uses:
 Structural components
 Janitorial maintenance
 Foods, drugs, cosmetics, or other personal items
 Present in process water or non-contact cooling water
 Compressed air or as part of combustion

11. 11
EPA’s Regulatory Approach
Performance-based approach
 Similar to OSHA’s PSM
Build on existing programs and standards
Scale the requirements to fit the risk
Coordinate with OSHA and DOT

12. 12
Requirements of 112 (r)
Established a general duty clause to:
 Identify hazards that may result from releases
 Design and maintain a safe facility
 Minimize the consequences or releases

13. 13
Requirements of 112(r)
(continued)
Required EPA to promulgate a list of substances and
set thresholds
Required EPA to develop a risk management
program (RMP) rule
Register with EPA
Conduct a hazard assessment
Develop a prevention program
Develop an emergency response program

14. 14
Requirements of 112 (r)
(continued)
Provide a summary (RMP) to
 EPA
 States
 Locals
 Public

15. 15
Basic Principles
Build on EPCRA
Emphasize community right-to-know
Focus the program at the local level
 Where the risk is found

16. 16
Basic Principles
(continued)
Accommodate small business concerns
 Provide model RMPs
» Ammonia
» Warehouses with chemicals
» Batch processors
» Refineries/gas plants
 Provide reference tables for offsite consequences analysis

17. 17
Manufacturing Industries Affected
Chemical manufacturers
 Industrial Organics & Inorganics
 Paints
 Pharmaceuticals
 Adhesives,
 Sealants
 Fibers

18. 18
Manufacturing Industries Affected
(continued)Petrochemical Products
 Refineries
 Industrial Gases
 Plastics and Resins
 Synthetic Rubber

19. 19
Non-Manufacturing Affected
(continued)
Non-Manufacturing Facilities affected
 Utilities
» Electric and Gas
 Public Sources
» Drinking Water and Waste Water Treatment
 Agriculture
» Fertilizers, Pesticides

20. 20
Other Manufacturing
Electronics
Semiconductors
Paper
Fabricated metals
Industrial machinery
Furniture
Textiles

21. 21
Other Industries
Food and Cold Storage
Propane Retail
Warehousing
Wholesalers
Federal sources
 Military and Energy Installations

22. 22
PSM vs. RMP Requirements
PSM’s concern - potential hazard and protection of
employees inside a regulated area
RMP’s concern - potential incidents that may cause
environmental and health hazards outside facility
boundaries
Editorial changes to PSM to make text consistent
with the CAAA's language

23. 23
Hazard Assessment
Offsite consequence data
 Population estimate
 Public receptors
 Environmental receptors
Every 5 years
Within 6 months of a change that increases or
decreased distance by a factor of 2 or more

24. 24
Overview Worst-Case Scenario
(WCS)
Greatest quantity from vessel or piping
 May include administrative controls
Toxic gases
 Quantity released in 10 minutes
Toxic liquids
 Instantaneous spill to ground; volatilization; passive
mitigation
Toxic gases liquefied by refrigeration

25. 25
Worst-Case Scenario
(continued)
All flammable substances
 Quantity for vapor cloud explosion
One worst case for each process
One worse case representing all toxic substances
Additional worst case(s) different public receptors
Other considerations
 Smaller quantities at higher temperature or pressure
 Source boundary proximity

26. 26
Alternative Release Scenario
(ARS)
More likely than a worst case scenario
Much reach endpoint offsite
One scenario representative of all flammables

27. 27
ARS Selection
Accident history events
Process hazard analysis events
Worse case with mitigation
Example scenarios:
 Piping or hose failures
 Seal failures
 Vessel overfilling or venting

28. 28
List of Substances and
Thresholds
Focuses on lethal effects resulting from acute
exposures
Includes mandated substances

29. 29
Mandated Substances
Ammonia
Anhydrous Ammonia
Anhydrous Hydrogen Chloride
Anhydrous Sulfur Dioxide
Bromine
Chlorine
Ethylene Oxide
Hydrogen Cyanide
Hydrogen Fluoride
Hydrogen Sulfide
Methyl Chloride
Methyl Isocyanate
Phosgene
Sulfur Trioxide
Toluene Diisocyanate
Vinyl Chloride

30. 30
Toxic Substances
Extremely hazardous substances under SARA
Gases and highly volatile liquids
Vapor pressure > 10 mmHg
Thresholds ranging from 500-2,000 lbs.
Thresholds based on toxicity and volatility

31. 31
Flammable Substances
NFPA 4
 Most dangerous
Flammable gases and volatile flammable liquids that
could create vapor cloud explosions
Thresholds set at 10,000 lbs.

32. 32
Threshold Quantity Determination
Total quantity of a regulated substances contained in
a process at any one time
Process included interconnected vessels or separate
vessels that could be involved in a release (OSHA
PSM definition)

33. 33
Offsite Consequence Analysis
Toxic endpoint
Flammable endpoints
Use appropriate models or guidance
Within circle, identify
 Public receptors and population
 Environmental receptors

34. 34
Registration and Submittal
Submit a comprehensive RMP to:
 EPA
 State Emergency Response Commission (SERC)
 Local Emergency Planning Committee (LEPC)
 The Chemical Safety and Hazard Investigation Board

35. 35
Registration and Submittal
(Continued)
Name, mailing address, telephone of stationary
source
CAS number of all regulated substances greater than
TQ
SIC code
Dun and Bradstreet number
Certification signed by owner or operator

36. 36
Auditing the Program
Conduct audits of the management system

37. 37
Program Eligibility Criteria
Three Programs

38. 38
Program 1 - No impact
Register
Conduct worst-case hazard assessments
Certify no off-site consequences for worst-case
scenario
Ensure inclusion in LEPC plan
Submit RMP document above

39. 39
Program 3 - Full RMP
One comprehensive prevention program that:
 Protects workers
 The public
 The environment
Hazard review information
 Hazards
 Controls
 Mitigation
 Changes

40. 40
Program 3
(continued)
Register
Conduct worst-case and other hazard assessments
Implement comprehensive prevention steps (OSHA
PSM plus...)
Develop emergency response plan
Submit RMP

41. 41
Program 3
(continued)
Process is subject to OSHA's PSM
Processes in specific SIC codes
 Pulp Mills (2611)
 Chlor-Alkali (2812)
 Industrial Inorganic (2819)
 Plastics and Resins (2821)
 Cyclic Crudes (2865)
 Industrial Organics (2869)
 Nitrogen Fertilizers (2873)
 Agricultural Chemicals (2879)
 Petroleum Refineries (2911)

42. 42
Program 2 - Streamlined
Prevention Program
The process is not eligible for Program 1 or 3

43. 43
Program 2
(continued)
Statutory requirements
 Training
 Maintenance
 Safety Precautions
 Monitoring

44. 44
Program 2
(continued)
Types of sources:
 Less complex; fewer changes
 Ideal model program and plans
Capture good management practices from PSM but
less documentation
Take advantages of other rules and standards
Take advantages of equipment manufacturer or
vendor information

45. 45
Program 2
(continued)
Process information (SIC, chemicals)
List rules, standards, design codes
Hazard review information
 Hazards
 Controls
 Mitigation
 Changes

46. 46
Program 2
(continued)
Register
Conduct worst-case and other hazard assessments
Implement seven elements of prevention program
Develop emergency response plan
Submit RMP

47. 47
Comparison of Program
Requirements
Hazard Assessment
Program 1 Program 2 Program 3
Worst-case analysis Worst-case analysis Worst-case analysis
Alternative releases Alternative releases
5-year accident history 5-year accident history 5-year accident history

48. 48
Comparison
(continued)
Management Program Document
Program 1 Program 2 Program 3
Management System Management System

49. 49
Comparison
(continued)
Prevention Program
Program 1 Program 2 Program 3
Certify no additional Safety Information Process Safety Information
steps Required Hazard Review Process Hazard Review
Operating Procedures Operating Procedures
Training Training
Maintenance Mechanical Integrity
Incident Investigation Incident Investigation

50. 50
Comparison
(continued)
Prevention Program (continued)
Program 1 Program 2 Program 3
Compliance Audit Compliance Audit
Management of Change
Pre-Startup Review
Contractors
Employee Participation
Hot Work Permits

51. 51
Comparison
(continued)
Emergency Response Program
Program 1 Program 2 Program 3
Coordinate with Local Develop Plan Develop Plan
Responders and Program and Program

52. 52
Comparison
(continued)
Risk Management Plan Content
Program 1 Program 2 Program 3
Executive Summary Executive Summary Executive Summary
Registration Registration Registration
Worst-Case Data Worst-Case Data Worst-Case Data
5-Year Accident History Alternative Release Data Alternative Release Data
Certification. 5-Year Accident History 5-Year Accident History

53. 53
Comparison
(continued)
Risk Management Plan Content (continued)
Program 1 Program 2 Program 3
Prevention Program Data Prevention Program Data
Emergency Response Data Emergency Response Data
Certification Certification

54. 54
OSHA PSM Requirements EPA Program 3 Requirements
An evaluation of the consequences An evaluation of the consequences
of deviations, including those of deviations
affecting the safety and health
of employees
The identification of any previous The identification of any previous
incident which had a likely potential incident which had a likely potential
for catastrophic consequences in for catastrophic consequences
the workplace
Editorial Changes
(continued)

55. 55
Editorial Changes
(continued)
OSHA PSM Requirements EPA Program 3
Requirements
A qualitative evaluation of a range A qualitative evaluation of a range
of possible safety and health effects of possible safety and health
of failure of controls on employees effects of failure of controls
in the workplace
The employer shall investigate each The owner or operator shall
incident which resulted in, or could investigate each incident which
reasonably have resulted in a catastrophic resulted in, or could reasonably
release of a highly hazardous chemical have resulted in a catastrophic
in the workplace release of a regulated substance

56. 56
Language Comparison
OSHA’s - PSM EPA’s - RMP
Employer Owner or Operator
Highly Hazardous Chemicals Regulated Substances
Facility Stationary Source
Standard Rule
Workplace Impact Off-Site Consequences

57. 57
Compliance Procedures
Develop an inventory of substances used, stored,
manufactured, processed, handled or moved, or any
combination of the listed activities
Compare the inventory with the TQ, as required

58. 58
Management System
Develop a management system to oversee the
implementation of the RMP elements
Identify single person or position who has overall
responsibility for:
 Development
 Implementation
 Integration of the RMP

59. 59
Elements of the Program

60. 60
Process Safety Information
Block flow or process flow diagrams
Maximum intended inventory
Establish safe limits of the operating parameters

61. 61
Process Safety Information
(continued)
Evaluate consequences in deviations of process
conditions
Equipment information
Verify equipment design with regulatory
requirements/standard

62. 62
Process Hazard Analysis
Document hazard analysis:
 Nature of the hazard
 Cause of the hazard
 Consequences of the hazard
 Actions to be considered to further protect personnel
Document follow-up steps based on
recommendations

63. 63
Process Hazard Analysis
(continued)
Document previous incidents with the potential to
cause catastrophic conditions
Document hazards associated with human factors
and facility siting

64. 64
Operating Procedures
Develop clear operating procedures addressing steps
for each process regarding
 Safe operating limits of processes
 Equipment
Provide precautionary instructions to prevent
exposure to hazards

65. 65
Operating Procedures
(continued)
Develop operating procedures for safety systems
Conduct annual review of operating procedures
Develop procedures for lockout/tagout, confined
space entry, etc.

66. 66
Employee Training
Document training for personnel in the process,
operating procedures, and safe work practices
applicable to the job tasks
Maintain records of training indicating the means
used to verify that the employee understood the
training

67. 67
Maintenance
(Mechanical Integrity)
Provide written procedures to maintain the structural
integrity of process equipment
Document training for employees involved in
maintenance of the process equipment
Verify inspections and testing of equipment and
deficiencies are corrected
Document that spare parts are suitable for the
appropriate application

68. 68
Incident Investigation
(Accident Investigation)
Incident reporting:
 The date of the incident
 Date of the investigation
 Description of the incident
 Factors contributing to the incident, and recommendations
that resulted
Verify that the recommendations in the incident
report were promptly addressed and resolved
Identify root causes as well as initiating events

69. 69
Compliance Audits
Evaluate compliance with program every three years
Conduct with at least one person knowledgeable in
process
Develop report of findings Determine/develop a
response to each finding, document that deficiencies
have been corrected
Retain two most recent audit reports

70. 70
Management of Change
Provide written procedures to manage change to
process chemicals, technology, equipment, and
procedures, and changes to facilities that affect a
covered process
Verify that employees in operations and maintenance
are trained accordingly
Provide evidence that changes are documented

71. 71
Pre-Startup Review
Document that construction and equipment is in
accordance with design specifications
Review documentation showing that safety,
operating, maintenance, and emergency procedures
are in place and adequate
Document that a PHA was performed, and
recommendations were resolved and implemented

72. 72
Pre-Startup Review
(continued)
Verify that modified facilities meet requirements in
Management of Change procedures
Verify that employee training is completed

73. 73
Contractors
Must established a screening process when hiring
and use contractors
A site injury and illness log for contractors must be
maintained
The contractor must ensure that each contract
employee is trained in the work practices necessary
to safely perform his/her job

74. 74
Employee Participation
Must develop a written plan of action regarding the
implementation of employee participation.
Required to train and educate employees and to
inform all affected employees of the findings from
any incident investigations.

75. 75
Employee Participation
(continued)
Must consult with employees and employee
representatives:
 Development of PHA and other elements
 Hazard assessments
 The development of chemical accident prevention
Must provide access to these records.

76. 76
Permit Systems
A work authorization notice or permit system should
be developed
 To describe the steps the maintenance supervisor,
contractor representative or other person need to follow in
order to obtain the necessary clearance to get the job done.
These procedures need to address such issues as
 Lockout/tagout procedures
 Line breaking procedures
 Confined space entry procedures
 Hot work permits

77. 77
Permit Systems
(continued)
Procedures must provide clear steps to follow once
the job is completed to provide closure for those that
need to know the job is completed and equipment
can be returned to normal operations.

78. 78
Emergency Planning and
Response
Document that an emergency plan has been
established and implemented in accordance with 29
CFR 1910.38 and 1910.120, as applicable
Emergency action plan that include procedures for
handling releases
Document specific actions to be taken in response to
an accidental release of a regulated substance to
protect humans and the environment
 Conduct drills
 Exercise to test plan

79. 79
Emergency Response Plan -
Basic Requirements
Emergency response plan
Procedures for use of emergency response equipment
and for it inspection, testing, and maintenance
Training for all employees in relevant procedures
Procedures to review and update of the plan to reflect
changes at the facility and ensure that employees are
informed of changes

80. 80
Elements - Legislative
Requirements
Procedures for informing the public and local
emergency response agencies
Documentation of proper first-aid and emergency
medical treatment necessary to treat accidental human
exposures
Procedures and measures for emergency response after
a release
Written plan must comply with other federal
regulations
Coordinate with local LEPC

81. 81
Planning Option - One-Plan Guidance
for Integrated Contingency Plan (ICP)
Intended to:
 Provide a mechanism for consolidating multiple facility
response plans
 Improve coordination of response activities
 Minimize duplication and simplify plan development and
maintenance
 Ensure regulatory compliance with all relevant federal
requirements

82. 82
Communicating RMP to Public

83. 83
Communication
Rule does not specify
 How communication should take place
 When it should take place
 How much risk communication
Anyone putting public at risk must show how risk is
addressed/prevented and responded to

84. 84
Regulatory Approach
Industry tells government and the public how it will
address risk for preventing major accidents
Government and public can review what industry has
presented
Government and community can respond to industry,
communicate concerns, and make recommendation

85. 85
Communicating the RMP
Start now
Explain the program
Tell the public what to expect with your WCS and
when to expect it
Explain your WCS
Detail chemical(s) on site that can cause explosions,
environmental impacts, etc.
Explain why you can’t reduce your inventory of
regulated substances

86. 86
Community Outreach
Suggestions
Open house/plant tours
Local citizen groups/civic organization
High school programs
Community survey
 What does the community think about you?
Neighborhood meetings
Plant newsletter
Community advisory panels

87. 87
Audience
Neighbors
Implementing agencies
LEPC
Emergency responders
City and county officials

88. 88
Audience
(continued)
Business and community leaders
Educators
Local media
State legislators

89. 89
Other Programs
Risk communications training
Training on handling the with media
Informing industrial neighbors

90. 90
Summary - Developing an RMP
Implementation Plan

91. 91
Implementation Strategy -
Technical
Acquire/understand regulatory information
Determine coverage
Determine technical capabilities/needs
Prepare RMP implementation plan

92. 92
Implementation Strategy -
Technical (continued)
Perform program level screening
Develop hazard assessment protocol
Perform hazard assessment
Compile 5-year accident history

93. 93
Implementation Strategy -
Technical (continued)
Implement/upgrade PSM program to consider offsite
effects
Review/upgrade emergency response activities and
plan
Prepare and submit the RMP

94. 94
Implementation Strategy -
Communication
Determine internal risk communication
capabilities/needs
Survey community outreach status
Establish/improve community outreach
Prepare communication plan
Improve internal risk communication capabilities
Communicate the RMP to the public

95. 95
Available Resources
Chemical Emergency Preparedness and Prevention
Office (CEPPO)
 Internet - (http://www.epa.gov/swercepp/acc-pre.html)

96. 96
Suggested Team Members
Health and safety Professionals
 Program development and review
Chemical, electrical, and mechanical engineering
 Process safety information and hazard analysis
development
Air Quality Specialist/Industrial Hygienist
 Air modeling dispersion.
 Identify acute health effects

97. 97
Suggested Team Members
(continued)
Risk Assessment Specialist
 Population exposure and environmental effects
Communications Specialists
 Communicating with the public

98. 98
Summary - Final Word
PSM and RMP outlines requirements for facilities to
reduce risks associated with accidental releases
A good communications program will help reduce
misinformation, distrust, and build good community
relations
Reduction in inventory will result in a reduction of
the risk and potential for a catastrophic incident

99. 99
Summary - Final Word
(continued)
Audits are to be comprehensive, involving
systematic assessment of all elements of the program