3. Outline of Standard
• Application • Pre-Start up Safety
• Employee Review
Participation • Mechanical Integrity
• Process Safety • Hot Work (Non-routine
Information Work Authorizations)
• Process Hazard • Management of
Analysis Change
• Operating Procedures • Incident Investigation
• Employee Training • Emergency Planning
• Contractors and Response
• Compliance Audits
5. P&IDs
• 119(d)(3)(i)(B)
• Relief Valves not in P&ID
• P&ID indicated flame arrestors that did not
exist.
• P&ID did not indicate correct piping
connections to vessels. Incorrect
diameters of piping.
• P&ID did not show LEL detectors and
interlocks.
6. P&IDs
• 119(d)(3)(i)(B)
• No design basis for relief valves on reactor
• Valve tags were reversed, mislabeled
• HF vent line was not marked
• HF dump tank was not identified.
• Three way valves were not identified
• Equipment were transposed on the
diagrams
7. Process Safety Information
• 119(d)(3)(i)(H)
PSI did not list:
• Cutout devices and Interlocks
• High and low level sensors
• Ammonia detectors
• High and low pressure devices
• Emergency Stop Buttons
• Electrical Classification of Equipment
8. RAGAGEP
• 119(d)(3)(ii)
• U-1 Form missing for pressure vessel
• Mechanical room for ammonia had no emergency ventilation
• Electrical Classification of equipment missing
• Venting Flanges not meet ANSI/ASME 31.3
• No documentation that piping fit for service per API 570
• Manual block valves were located down stream of automatic dump
valves (Hydrogen Fluoride Industry Practice Institute or HFIPI)
• HF tanks not sized 1.5x for anticipated deliveries. HFIPI
• HF dump tank did not have capacity of largest HF tank. HFIPI
• HF liquid flow velocity exceeded 5.9 feet/second
• Eye wash and shower were not configured to sound in the control
room. HFIPI
• No valve capping kit for HF rail car unloading
• High pressure vent lines were not labeled.
• Relief valve discharge 3.5` above platform vs. 15 feet. (IIAR 2-2008)
9. PHA
• 119(e)(1)
• No PHA on the Hydrogen Storage tank
• PHA missing several elements
• PHA did not address failure of ventilation
• PHA did not address previous fires.
• PHA did not previous piping failures.
• PHA did not address previous failures of
cooling systems
10. PHA
• 119(e)(3)(i) The hazards of the process;
• The hazard of power failure was not discussed in the
PHA.
• The Hazard of natural gas draining to the surge drum too
long.
• The hazard of releasing material in the neutralization pits
• The hazard of weight of hoses on pipe nipples was not
addressed
• The Hazards of venting flanges was not addressed in the
PHA.
• The hazard of forklift traffic was not addressed.
11. PHA
• 119(e)(3)(v)
• No analysis of facility siting issues related
to formaldehyde dispersion
• Building siting and how affected by the
ammonia process
• Ammonia system including piping,
recirculator, chiller, receiver, and
condensors were located to the roadway
and subject to vehicle impact.
12. PHA
• 119(e)(3)(vi)
• Human factor
• Fatigue
• No consider of opening block valves
downstream of remote operated dump valve
• Second and third shift training
• People on vacation leave
• Operational overload during emergencies
• Operation interactions
13. PHA
• 119(e)(5)
• PHA items not resolved for years
• PHA did not address team finding and
recommendations such as
• Installing back flow prevention when adding
flammable liquids in a tank
• Automatic Pressure controls for Nitrogen
• Adding relief valves
• Facility siting for control rooms
• Reconfigurations of valves issue on PHA was
not resolved.
14. Operating Procedures
• 119(f)(1)
• No written procedures for maintaining the ammonia
systems
• No procedures for communicating issues during shift
changes
• No procedures for upset condition or avoiding deviations
beyond operating limits.
• Transferring chemicals from pit to pit
• Neutralization of chemicals
15. Operating Procedures
• 119(f)(1)(i)(E)
• No procedures for when discharge pressure, suction
pressure, discharge temperature, lubrication oil
pressure, and lubrication oil temperature exceed normal
operating range
• No Specific steps to stop an emergency
• No identification of emergency upset conditions and
procedures to take to resolve it.
• No procedure for emergency operations for transfer of
chemicals out a Surge tank
• No clear procedures for emptying HF tanks with isolating
nitrogen systems
17. Safe Work Practices
• 119(f)(4)
• No safe work procedures developed for
contractors or maintenance employees
working on PSM covered processes for
• Lockout
• Confined space
• Hot works
18. Mechanical Integrity
• 119(j)(2) No inspection procedures
• Pressure Vessels
• Piping, components, Hose adapters
• Pump
• Venting Flanges
• Compressors and cutout switches
• Relief Systems and change out schedule
• Emergency Shutdown Systems
• Valves requiring Carseals
• No Procedures for torquing bolts
19. Mechanical Integrity
• 119(j)(4)(i) No inspection of
• Relief valves
• Pressure vessels (Oil pot, Accumulator,
Receiver, and Transfer Drum)
• Ammonia Feed Pumps
• Venting flanges
• Pipe Nipples, Deadlegs, Inspection ports, hose
adapters
• High Level alarms and emergency shutdown
systems.
20. Mechanical Integrity
• 119(j)(4)(ii)
• No authorized API 570/574 piping inspector or piping
inspections
• No API 510 pressure vessel inspector
• No corrosion rates established for pressure vessels
• Pump not maintained and lubricated per manufacturer’s
recommendations
• Rupture Disk was not replaced per manufacturer’s
recommendations
• No 100% Radiography or Ultrasonic testing on process
pipe weld repair per ANSI B31.1
• No fitness for service for repairs per API 579 for tanks
undergoing repair at head nozzles
21. Mechanical Integrity
• 119(j)(4)(iii)
• No annual piping inspection
• No API internal pressure vessel inspection
• No inspection testing of the condensate vapor
system for buildup that might clog the system.
• No hydrostatic testing of HF tanks
• No testing or exercising of HF vent valves/dump
valves
• Not testing compressor cutout switches
• Blast Evaporators, heat exchangers not
inspected
• No pump inspections
22. Management of Change
• 119(L)(1)
• No implementation of procedures after
• Replacing manual valves with pneumatic actuated
valves.
• Installing a LEL detector
• Disconnection of the Cooling water System
• Installing an alarm on the quench system
• Expanding Toulene tank system
• Leak at Relief Header Rupture disk
• Bolt torquing procedure change
• After making changes in the Ammonia system
• No MOC for condenser removed from process
23. Incident Investigation
• 119(m)(1)
• No incident investigation for
• Ice buildup and cracks in evaporator coils
• Prior incident of adding high temperature
product to flammables
• Prior ammonia release.
• Prior corrosion in pipes
24. Compliance Audits
• 119(o)(1)
• No PSM evaluation audits were conducted
• No audits of Mechanical integrity,
Management of Change, PHA, and
Emergency Response.
25. Other Issues
• Lockout
• Emergency Response
• Confined Space Rescue
• Electrical Classification
• Hot Works
• Boiler Safety
26. Two Investigators
• In most of the cases that we investigate, we
have found that most firms completely ignore the
1910.119(j)(5) requirement, and don’t even
consider doing an MOC for a temporary change
that meets the requirements of 1910.119(l).
• We have two or three cases in our backlog of
open cases that deal exactly with these issues.
Guess the refinery NEP is having some impact.
27. More Comments
• I fully agree on the MOC’s; they are called by the workers “Matter of
Convenience” because they believe they are used to justify
exceptions and deviations.
• I would add a couple to your list; PSSR (Pre Start-up Safety
Review) and organizational issues.
• I just reviewed a couple of investigations where there was an
unexpected shutdown on a portion of the unit and in a rush to get
the unit back up (they did not fully understand why it had shutdown)
and they ended up in a more serious situation.
• Most companies only apply the PSSR part of the PSM standard to a
cold start, and even the procedures are written for a cold start and
do not work for hot restarts.
28. Summary
• Identify the top risks in the facility
• Look at corrosion monitoring on pipes and vessels,
• Pump vibration leads to failures and fires.
• Procedures related to boiler startup, hot works,
• Evaluate hydrogen sulfide monitoring, hydrofluoric acid,
• Address fatigue and control panel alarms during start
ups,
• Management of change is slipping.
• Gasket torquing procedures should be reviewed as well
as gasket compatibility for service,
• Relief valve inspection and testing is a must.
• Facility siting is ever present
29. 312-353-5977 Facebook….john newquist
johnanewquist@gmail.com Twitter is johnanewquist
Newquist.john@dol.gov
LinkedIn is john
newquist
30. Further
This was prepared as a collaborative effort several
friends as a preliminary aid for anyone in the safety and
health field.
These are just some the issues. A comprehensive job
hazard analysis should be conducted for any task where
someone can get hurt.
This is not an official OSHA publication. Those will be on
the OSHA.gov website.
If you see any errors my email is Newquist.john@dol.gov
312-353-5977
I want to thank Bryan H. Art D. Jim L. Clyde T. Mark K.
and Janet S. for all their assistance in answering
questions and providing insight to the many hazards in
this sector.
Notas do Editor
PSM is an elemental approach. These elements are (in order as they appear in the standard):
1910.119(d)(3)(i)(B) Piping and instrument diagrams (P&ID's); Cargill, Am Pack, Case farms, Loveland Products
Akzo Morris, Honeywell,
1910.119(d)(3)(i)(H) Safety systems (e.g. interlocks, detection or suppression systems). Cargill, Bostik
1910.119(d)(3)(ii) The employer shall document that equipment complies with recognized and generally accepted good engineering practices. Cargill, Bostik, Exxon-mobil, Equistar, Honeywell, Pilgrims Pride, Midwest Biofuels, Niagara Coop, Sorrento Lactals
1910.119(e)(1) The employer shall 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. The process hazard analysis shall be conducted as soon as possible, but not later than the following schedule: Azko, am pack,
1910.119(e)(3)(i) The hazards of the process; Marathon 2007 OH, Exxon Mobil 2010m midwest biofuels,
1910.119(e)(3)(vi) Human factors; and Cal OSHA, Honeywell, Case Farm
1910.119(e)(5) 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. Equistar, Honeywell many others
Bostik, cargill, marathon, QG LLC, Midwest Biofuel, Niagara Coop, 1910.119(f)(1) The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements.
QG LLC, Columbus chemical and others 1910.119(f)(3) The operating procedures shall be reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities. The employer shall certify annually that these operating procedures are current and accurate.
Am pack, QG LLC, 1910.119(f)(4) The employer shall develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. These safe work practices shall apply to employees and contractor employees.
Several and exxon mobil. QG LLC, Honeywell, Case Farm, Loveland products 1910.119(j)(2) Written procedures. The employer shall establish and implement written procedures to maintain the on-going integrity of process equipment.
Also AKZO, Exxon-mobil, Honeywell, Niagrara COOP, 1910.119(j)(4)(i) Inspections and tests shall be performed on process equipment.
Azko, ampack, 1910.119(j)(4)(ii) Inspection and testing procedures shall follow recognized and generally accepted good engineering practices.
Cargill,azko, bostik, pilgrim pride, sorrento lactals IIAR Bulletin requires annual inspections. 1910.119(j)(4)(iii) The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.
QG LLC and many others 1910.119(l)(1) The employer shall establish and implement written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.
Cargill, bostik, Case farm, Midwest Biofuels, 1910.119(m)(1) The employer shall investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemical in the workplace.
QG LLC, Columbus Chemical, Loveland Products and many others. 1910.119(o)(1) Employers shall certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed.
