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Process Safety

Management for General

Industry

David Rice

• Bhopal, India (1994)– 2,000 deaths from isocynate

release• Pasadena, TX (1989)

– 23 deaths, 132 injuries from petroleum explosion

• Cincinnati, OH (1990)– 2 deaths from explosion

• Sterlington, LA (1991)– 8 deaths, 128 injuries from a

chemical release

PSM History

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• Promulgated by OSHA with the intent to prevent a Bhopal-like incident from happening.

• Developed to prevent the release of a:– Toxic,– Reactive,– Flammable, or– Explosive chemical

PSM Development

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• PSM – Protects the workforce– Protects contractors– Protects visitors

• RMP– Protects the community– Protects the general public– Protects adjacent facilities

PSM vs. RMP

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• 29 CFR 1910.119– Contains requirements for the management of

hazards associated with processes using highly hazardous chemicals.

– Contains requirements for preventing or minimizing the consequences of a catastrophic release of toxic, reactive, flammable, or explosive chemicals.

PSM Standard

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• 25 states, Puerto Rico, and the U.S. Virgin Islands have OSHA-approved State Plans and have adopted their own standards and enforcement policies.

PSM Standard

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• Facilities who use chemicals listed in 29 CFR 1910.119 Appendix A (136 chemicals) and are above the threshold quantity.

• Examples:– Anhydrous Ammonia – 10,000 lbs– Chlorine – 1,500 lbs

Covered Facilities

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• A process which involves a flammable liquid or gas on-site in one location, in a quantity of 10,000 lbs or greater.– OHSA interprets “on-site in one location” to mean that

the standard applies when a threshold quantity of a HHC exists within an area under the control of an employer or group of employers.

– Also applies to any group of vessels that are interconnected, or in separate vessels that are close enough in proximity that the HHC.

Covered Facilities

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– OHSA interprets to mean that the standard applies when a threshold quantity of a HHC exists within an area under the control of an employer or group of employers.

– 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.

“On-site in one location”

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“On-site in one location”

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• Industrial organics and inorganics• Paints• Pharmaceuticals• Adhesives• Sealants and fibers• Petrochemical facilities• Paper mills

Covered Industries

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• A TQ of flammable liquids is stored in atmospheric tanks or transferred without the chilling or refrigeration.

• Hydrocarbon fuels used solely for workplace consumption (propane for heaters; gas for vehicles).– Provided fuels are not a part of a process

containing an additional HHC.

Exclusions

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• Create a PSM Team (legal requirement):– Engineers– Operators– EHS personnel– Maintenance– Management– Consultants

Applicable, Now What?

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• Create a Plan:– Responsibilities– Duties– Reporting– Document control– Progress reports– Tracking changes

Applicable, Now What?

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• Process Safety Information (PSI)

• Process Hazard Analysis (PHA)

• Operating Procedures• Employee Participation• Training• Contractors• Pre-startup Safety Review

(PSSR)

14 Elements of PSM

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• Mechanical Integrity (MI)• Hot Work• Management of Change

(MOC)• Incident Investigation• Emergency Planning• Compliance Audits• Trade Secrets

• Complete a compilation of written PSI, prior to conducting any PHA.

• Helps to identify and understand the hazards posed by the process.

• Includes:– Information on hazards associated with the

process,– Information on technology of the process, and– Information on the equipment in the process.

Process Safety Information

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• Thorough, orderly, systematic approach for identifying, evaluating, and controlling the hazards of the process.

• Must conduct an initial PHA on all processes.• Must be appropriate to the complexity of the

process.• Updated and revalidated, based on completion

date, at least every 5 years.

Process Hazard Analysis

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• Must develop and implement written operating procedures, consistent with the PSI.

• Provides clear instructions for safely conducting activities involved in the covered process.

• Includes:– Steps for each operating phase,– Operating limits, and– Safety and health considerations

• Must be certified at least annually.

Operating Procedures

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• Employers are to consult with the employees and their representatives regarding the development and implementation of a PSM program.

• Required to train employees and inform them of the findings of an incident investigation, required by the PSM program.

• Provide access to PHA and all other information developed under the PSM program.

Employee Participation

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• Initial– Each employee presently involved in a covered

process or newly assigned must be trained in an overview of the process and its operating procedures.

– Emphasis on specific safety and health hazards.– Employers may certify in writing that employees

have the required knowledge, skills, and abilities to safely carry out duties specified in operating procedures.

Training

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• Refresher– At least every 3 years

• Documentation– Employee name,– Date of training, and– How training comprehension was verified.

Training

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• PSM applies to contractors performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process.– Does not apply to incidental services that do not

influence the process safety.

Contractors

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• Must obtain and evaluate contractor’s safety performance and programs.

• Must inform contractors of the known potential hazards associated with their work and the process.

• Explain applicable EAP information.• Develop and implement safe work practices.• Periodically evaluate contractor’s safety

performance.• Maintain a contractor injury and illness log.

– for work in the process area

Contractors

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• Safety review must take place before the introduction of any HHC to a process.

• Must conduct a PSSR for new facilities and modified facilities where the change is significant enough to require a change in the PSI.

Pre-startup Safety Review

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• Includes:– Construction and equipment;– Safety, operating, maintenance, and emergency

procedures;– PHA; and,– Training.

Pre-startup Safety Review

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• Must establish and implement written procedures to maintain the ongoing integrity of the process equipment.

• Inspection and testing using recognized and generally accepted good engineering practices.– Frequency must conform to manufacture’s

recommendations and good engineering practices.

– Inspections and testing must be documented.

Mechanical Integrity

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• Equipment deficiencies outside the acceptable limits, as defined by the PSI, must be corrected before further use.

• New facilities, must make sure that equipment is fabricated so it is suitable for the process.

• Must ensure that maintenance materials, spare parts, and equipment are suitable for the process.

Mechanical Integrity

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• Permit must be issued for hot work conducted on or near a covered process.

• Must document that the fire prevention and protection requirements have been implemented prior to beginning hot work.

Hot Work

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• Written procedures to manage changes to process chemicals, technology, equipment, and procedures.

• Employees involved in the process must be informed of and trained in the change prior to startup of the affected process (or part thereof).

• If change requires a change to PSI, the PSI must be updated.

Management of Change

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• Must conduct an investigation of each incident that resulted in, or could have reasonably resulted in, a catastrophic release of a HHC.

• Must be initiated as soon as possible, but no later than 48 hours after the incident.

• Investigation must be conducted by a team:– Knowledgeable in the process, and– Knowledgeable and experienced in investigating

and analyzing incidents.

Incident Investigations

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• Must establish a system to promptly address and resolve the incident report findings and recommendations.

• Resolutions and corrective actions must be documented and reviewed by all affected personnel.

• Incident investigations must be retained on file for 5 years.

Incident Investigations

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• An Emergency Action Plan must be developed and implemented for the entire facility if you are PSM applicable.

• EAP must include procedures for handling small releases of hazardous chemicals.

Emergency Planning

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• Employers must certify that they have evaluated PSM compliance at least every 3 years.

• Must be conducted by at least one person knowledgeable in the process.

• Must conclude with a report of findings documenting any deficiencies, and any corrected deficiencies.

• The 2 most recent compliance audits must be kept on file.

Compliance Audits

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• Employers must make available all information necessary to comply with PSM, without regard to possible trade secret status, to those responsible for:– Compiling PSI;– Developing PHAs;– Developing operating procedures; and,– Performing incident investigations, emergency

planning and response, and compliance audits.• Confidentiality agreements can be required.

Trade Secrets

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• PSM applies to 136 specific toxic and reactive chemicals.

• PSM applies to flammable liquids and gases in quantities over 10,000 lbs.

• There are 14 elements of a PSM program.

Overview

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• PSM is a monster!• It is too big to tackle on your

own, you must get a team to help you.

• The health and safety of your personnel is dependant on having a solid and functioning PSM program in place.

Overview

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Dave RiceProject Manager

drice@augustmack.com

Nancy WadeCorporate Health & Safety Manager

nwade@augustmack.com

Questions?

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