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Process Safety Management

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Improper management of highly hazardous chemicals, including toxic, reactive or flammable liquids, can cause accidental releases and emergency responses. OSHA’s Process Safety Management of Highly Hazardous Chemicals standard (29 CFR 1910.119) regulates the management of highly hazardous chemicals. Violations can carry fines of up to $126,000. Do you have a PSM program in place?

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Process Safety Management

  1. 1. Process Safety Management Triumvirate Environmental Presents
  2. 2. Meet Your Moderator: James Ciccone
  3. 3. During this Webinar  All lines will be muted – please communicate via the questions tab in your webinar panel.  There will be a Q&A session at the end of the presentation – submit your question(s) anytime throughout the webinar.  Stick around for an exclusive offer at the end of the webinar.  Slide deck and webinar recording will be sent to you tomorrow.
  4. 4. Meet Your Presenter Rick Foote
  5. 5. OSHA Has Been Busy • Since 2010 OSHA has issued more than 69 enforcement cases regarding PSM • A recent fine was just issued for $264,000 • A new National Emphasis Program was issued in January 2017
  6. 6. Why Did OSHA Develop PSM? Past disasters Current disasters Perceived weakness and lack of understanding of PSM program
  7. 7. Why Did OSHA Develop PSM? Bhopal, India (1984)  2,000 deaths, Isocyanate release Pasadena, TX (1989)  23 deaths, 132 injuries, Petroleum explosion Cincinnati, OH (1990)  2 deaths, Explosion Sterlington, LA (1991)  8 deaths, 128 injuries, Chemical release
  8. 8. Why Did OSHA Develop PSM? In 1991, OSHA and EPA released both the Process Safety Management and the Risk Management Program
  9. 9. Why Did OSHA Develop PSM? • PSM is a regulation that is intended to prevent an incident like the 1984 Bhopal disaster • And…to prevent release of:  Toxic,  Reactive,  Flammable, or  Explosive chemicals
  10. 10. What is Required in a Process Safety Management Program?
  11. 11. Elements of the Standard • Application • Exclusions • Definitions • Employee Participation • Hazards of the Process • Toxicity • Technology of the Process • Equipment in the Process • Mechanical Integrity • Inspection & Testing • Quality Assurance • Process Hazard Analysis • Management of Change • Operating Procedures • Safe Work Practices • Training • Contractor Management • Emergency Planning & Response • Incident Investigation • Compliance Audits • Trade Secrets
  12. 12. 1910.119(a) Application
  13. 13. What Facilities are Covered? • Companies that use chemicals found in Appendix A of the standard • The Appendix contains a listing of toxic and reactive highly hazardous chemicals which present a potential for a catastrophic event at or above the threshold quantity
  14. 14. Appendix A Some example chemicals include: • Anhydrous Ammonia – 10,000 pounds • Chlorine – 1,500 pounds • Hydrogen Fluoride – 1,000 pounds • Important to check and verify the CAS #
  15. 15. What Facilities are Covered? • Important Interpretation: 2007 - 06/11/2007 - OSHA defines "on-site in one location" for Process Safety Management of Highly Hazardous Chemicals standard • OSHA interprets "on-site in one location" to mean that the standard applies when a threshold quantity of a highly hazardous chemical (HHC) exists within an area under the control of an employer or group of affiliated employers. It also applies to any group of vessels that are interconnected, or in separate vessels that are close enough in proximity that the HHC could be involved in a potential catastrophic release.
  16. 16. What Types of Industries? Industries that process chemicals such as: • Industrial organics & inorganics • Paints • Pharmaceuticals • Adhesives • Sealants and fibers • Petrochemical facilities • Paper mills • Food processing with Anhydrous Ammonia over the TQ
  17. 17. 1910.119(a)(1)(ii)(A) Exclusions
  18. 18. What are some Exclusions? A company is exempt from the requirements of PSM when: • A threshold quantity of flammable liquids is stored in atmospheric tanks or transferred without the benefit of chilling or refrigeration • Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling), • If such fuels are not a part of a process containing another highly hazardous chemical covered by this standard
  19. 19. 1910.119(c) Employee Participation
  20. 20. So Now You are in PSM? Form a committee, with members such as: • Process engineers • Operators • Safety • Maintenance • Management • Consultants
  21. 21. • Responsibilities of members • Duties of members • Reporting So Now You are in PSM? • Document control • Progress reports • Tracking changes Develop a written plan that details:
  22. 22. Conduct a Hazard Assessment Determine: • Chemicals in your process • Process chemistry • Quantity of chemicals in pounds • Compare to Appendix A List with Threshold Quantities (TQ’s)
  23. 23. 1910.119(d)(1)(i) Toxicity Information
  24. 24. Need to Collect Toxicity Information Standard requires the facility to determine the toxicity of each of the regulated materials. Some sources to help with this include: Safety Data Sheets NIOSH Pocket Guide ACGIH Other web resources
  25. 25. What Toxicity Information Do I Need to Collect? • Permissible Exposure Limits • Physical Data • Reactivity Data • Corrosivity Data • Thermal and chemical stability data • Hazardous effects of inadvertent mixing of different materials that could foreseeably occur
  26. 26. 1910.119(d)(2) Process Technology
  27. 27. Facility Needs to Develop • Block flow diagram or process flow diagram • Process chemistry • Maximum intended inventory • Upper and lower limits • Consequences of deviations
  28. 28. 1910.119(d)(3) Equipment in Process
  29. 29. Facility Needs to Review: • Materials of construction • Process and instrument drawings (P&ID’s) • Electrical classification • Relief system design • Ventilation system design • Design codes • Material and energy balances • Safety systems
  30. 30. 1910.119(j) Mechanical Integrity
  31. 31. Applies to the Following: • Pressure vessels and storage tanks • Piping systems (including piping components such as valves) • Relief and vent systems and devices • Emergency shutdown systems • Controls (including monitoring devices and sensors, alarms, and interlocks) • Pumps
  32. 32. What Do You Have to Do? • The facility must establish and implement written procedures to maintain the ongoing integrity of process equipment • Train employees involved in maintaining the on-going integrity of process equipment • Conduct inspections and test on equipment • Document all of the above
  33. 33. 1910.119(e) Process Hazard Analysis (PHA)
  34. 34. The Hardest Part • The facility must perform an initial process hazard analysis (hazard evaluation) on processes covered by this standard. • The process hazard analysis shall be appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process. • Employers shall determine and document the priority order for conducting process hazard analyses based on a rationale which includes such considerations as extent of the process hazards, number of potentially affected employees, age of the process, and operating history of the process.
  35. 35. Facilities must determine and document the priority order for conducting process hazard analyses based on a rationale which includes such considerations as: • Extent of the process hazards • Number of potentially affected employees • Age of the process • Operating history of the process The Hardest Part
  36. 36. How Do You Do This? The facility must use one or more of the following: • What-if scenarios • Develop a checklist • What if/checklist • Hazard and Operability Study (HAZOP) • Failure Mode and Effects Analysis (FMEA) • An appropriate equivalent methodology
  37. 37. Wait, There’s More? • Inspection & Testing • Quality Assurance • Management of Change • Operating Procedures • Safe Work Practices • Training • Contractor Management • Emergency Planning & Response • Incident Investigation • Compliance Audits • Trade Secrets
  38. 38. Management of Change • Procedures to manage changes to the covered process  Exception: “replacement in kind” • Management of Change includes:  Process chemicals  Technology  Equipment  Operating procedures  Facilities
  39. 39. Management of Change Addresses: 1. Technical basis of the change 2. Impact to employee safety and health 3. Modification to operating procedures 4. Time period for change 5. Authorization of change
  40. 40. Operating Procedures • Develop and implement written operating procedures that are clear instructions for all expected phases of operations • AKA – Standard Operating Procedures (SOPs) • Must cover:  Operation phase  Operational limits  Safety & health considerations
  41. 41. OPs Must Address: • Initial start-up • Normal operations • Temporary operations • Emergency shutdown • Emergency operations • Normal shutdown • Start-up following turnaround • Consequences of deviation • Steps required to correct or avoid deviation
  42. 42. SOPs: • Must be readily available to employees • Must be reviewed as needed to ensure they reflect current operating practice • Must cover:  Process chemicals  Technology and equipment  Facilities • SOPs must be certified annually that they are correct and accurate
  43. 43. Safe Work Practices (SWPs) Must be developed and implemented to provide for the control of hazards during work activities such as:  Lock-out/Tag-out  Confined space entry  Opening processes, piping or equipment
  44. 44. Training • PSM specific training is required • Must cover:  Safety and health hazards associated with the covered process  Safe work practices • Refresher training is required every 3 years or as needed to ensure employees are complying with all PSM requirements
  45. 45. Contractors • Contractors involved in or around a covered process must be informed of required PSM elements • Contract work includes:  Maintenance and repair  Turn around  Major renovations  Specialty knowledge or services  Does not include support services not involved with the covered process, like laundry or vending machine supply
  46. 46. Emergency Action Plans (EAP) • Must have EAP for entire facility • EAP must have provisions for small releases of HHCs • Develop an early warning method for releases • Train on the meaning of the alarms • Develop emergency evacuation written plans, evacuation maps & assembly points
  47. 47. Incident Investigations • Must be initiated ASAP, but within 48 hours • Team must include:  Person knowledgeable in the process involved  Includes contractor if work of the contractor involved  Other persons with appropriate knowledge of the covered process
  48. 48. Incident Investigation Report Report must be produced with the following:  Date of incident  Date of start of investigation  Description of incident  Factors contributing to incident  Recommendations
  49. 49. Incident Investigation Report • System must be established to promptly address recommendations and findings of report • Resolutions and corrective action must be documented
  50. 50. Trade Secrets • Employers must make all necessary information required to comply with PSM, regardless of trade secrets, available to persons involved in developing or creating:  Compiling process safety information  PHAs  SOPs  Incident investigations  Emergency planning and response  Compliance audits • Confidentiality agreements are allowed
  51. 51. Compliance Audit • To ensure that PSM is effective, employers must certify every 3 years that they have evaluated compliance with the standard • Must be completed by at least one person knowledgeable in the process • Report must be developed and documented • Deficiency corrections must be documented • Last two compliance audits must be kept on file
  52. 52. Tools for Additional PSM Assistance • PSM Checklist  www.oshainfo.gatech.edu • OSHA Website  www.osha.gov • Chemical Safety Board Website  www.csb.gov
  53. 53. QUESTIONS?
  54. 54. Thank You For Attending! Request a Free Compliance Audit: http://info.triumvirate.com/osha-compliance-review-webinar Rick Foote: rfoote@triumvirate.com Director of Industrial Practice Triumvirate Environmental Call Us! 1-888-834-9697 www.triumvirate.com