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Process Safety Management (PSM)

Safety and Security ConferenceApril 21, 2010

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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 § 1910.119

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The Law – Intent

To prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals

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29 CFR 1910.119 Covered Processes

• Materials on site at or above threshold quantitiesof 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 1910.119).

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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.

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Employee Participation

1. Employers shall develop a written plan of action regarding the implementation of the employee participation required by this paragraph.

2. 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.

3. 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.

§ 1910.119 Process safety management of highly hazardous chemicals

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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.”

§ 1910.119 Process safety management of highly hazardous chemicals

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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.

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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

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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 5-26-92)

• Safety systems / interlocks 

V-001

P-001

HE-001

xxx

?!

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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 § 1910.119

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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 C TO § 1910.119

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PHA ScopeThe 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.

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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.

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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 1910.119

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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.

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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.”

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Corrective Action Tracking Process – Basic Process

New Action Added

Person Assigned To Action

Person Assigned Emailed

Action Complete

d

Action Taken

Verified By Owner

Action Closed

Re-opened If

Not Effective

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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

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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

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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

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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

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Mechanical Integrity Requirements

• Written procedures

• Training program

• Inspections / testing

• Records / documentation

• Corrective action program

• Quality assurance in new installations

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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

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MOC/PSSR Process – Basic Process

Process Change

Request Form (PCRF)

Head Of Area (HOA)

ApprovalTR Approval

Technical Representative (TR) Assigned

Pre Startup Safety Review

(PSSR)

Task Creation And

Assignment

Approval And Authorisation

For Startup

Tasks Completed

Originator emailed if rejected

Originator and HOA emailed if

rejected

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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

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AIIMS Process – Basic Process

New Accident / Incident

Added

Investigation Team And

Actions Setup

Team Leader Ammends & Submits To

Head Of Area (HOA)

Submitted For Review By

Team Leader

HOA Approves AIIMS Plan

Actions Created And Responsible

Persons Emailed

AIIMS Complete

All Tasks Completed

Status Set As Disputed If Not Aproved

Tasks Completed

Tasks Re Opened

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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 1910.38a, 1910.119, & 1910.120

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Thank You for Your Time

Shawn Blenis

Intertek USA

251-610-1337

Shawn.blenis@intertek.com