LECTURE 4

OSHA & DOSH

OSHA Occupational Safety & Health

Administration of United States Government – DOL

In Malaysia, OSHA is known as DOSH – Ministry of Human Resource

Objective

The department is a government agency responsible for the administration and enforcement of legislations related to Occupational Safety and Health for our nation, with a vision of becoming the organization which leads the nation in creating a safe and healthy work culture that contributes towards enhancing the quality of working life.

Roles & Functions

To study and review the policies and legislations of occupational safety and health.

To enforce the following legislations : ◦ a) Occupational Safety and Health Act

1994 and its regulations.◦ b) Factories and Machinery Act 1967 and

its regulations.◦ c) Part of Petroleum Act 1984 (Safety

Measures) and its regulations.

To conduct research and technical analysis on issues related to occupational safety and health at the workplace.

To carry out promotional and publicity programs to employers, workers and the general public to foster and increase the awareness of occupational safety and health.

To become a secretariat for the National Council regarding occupational safety and health.

*Sharing with students – Legislative Documents of OSHA ACT 1994

OSHA ACT 1994

15 parts Sub-Laws

i. 7 Regulationsii. 2 Ordersiii. 4 Codes of Conductiv. 36 Guidelines

Lecture 4 - PSM & RMP

PSM

RMPEVALUAT

E

IDENTIFY

MSDS

CONTROL

IH

Industrial Hygiene

A science devoted to the identification, evaluation and control of occupational conditions that cause sickness and injury

Example: Reduce toxic airborne vapors through ventilation Select proper PPEs to prevent worker exposure Develop SOP for handling of hazardous materials Monitor and reduce noise, heat, radiation etc.

Continue…

Identification – determination of the presence or possibility of workplace exposures

Evaluation – determination of the magnitude of the exposure

Control – application of appropriate technology to reduce workplace exposures to acceptable level

IdentifyExample of MSDS

OSHA: PROCESS SAFETY MANAGEMENT (PSM)

Developed after Bhopal 1984 accident. Final rule published on 24th Feb, 1992 Process Safety Management of Highly

Hazardous Chemicals A performance oriented standard that

spell out the requirements for management of hazardous chemicals

14 sections

1. Employee participation2. Process safety information3. Process hazard analysis4. Operating procedures5. Training6. Contractors7. Pre-startup safety review8. Mechanical integrity9. Hot work permits10.Management of change11.Incident investigations12.Emergency planning and response13.Audits14.Trade secrets

14 sections

1. Employee participation PSM require active employee participation Employers must develop and document a

plan of action to specify this participation

2. Process safety information• Info is compiled and available for employees

to help the understanding and identification of hazards

• BFD/PFD, process chemistry + process limitations

• Pre-condition for subsequent sections

3. Process hazard analysis (PHA) Perform by experts in their

respective fields Revise every 5 years Complex process – HAZOP Less complex process

What-if analysis Checklist Failure mode and effect analysis (FMEA) Fault tree/diagram

4. SOP

SOP that facilitate the safe operation of the plant/process/equipment must be documented

Content – startup, shutdown, emergency shutdown, operating limit, safety instructions, LOTO and etc.

Update frequently

5. Training Effective training helps employee

understand the surrounding hazards Operating personnel must competence

enough to run the process/maintenance. Certification and refresher program

6. Contractors

• Contractors are trained to perform their tasks safely to the same extent as employees

• Investigate contractors’ safety history

7. Pre-startup safety review A group of reviewers System build-up is same to the

design specifications Safety, maintenance, operating and

emergency procedures are in place Appropriate training is completed Recommendations from PHA are

implemented or resolved

8. Mechanical integrity

• To ensure the equipments, piping, relief systems, controls and alarms are functionable

• Among the requirements;– Written procedures to maintain functioning

systems– Training on preventative maintenance– Periodical inspections and testing based on

vendor recommendations– A process to correct deficiencies– Spare parts compatibilities

9. Hot work permit A system to prepare and issue hot

work permit before conducting hot work activities (welding, grinding etc.)10. Management of change

• Employees are required to develop and implement documented procedures to manage changes;– Process chemistry– Process equipment– SOP

• Changes must be reviewed before approval to ensure it will not affect the safety of the operation

11. Incident investigation

Investigation must be conducted within 48 hours Comply to investigation recommendations

12. Emergency planning and response• Employees require to respond effectively to the

release of highly hazardous chemicals• Needed for company > 10 employees

13. Audits Employers are required that they have evaluated their

compliance with the standard at least every 3 years

14. Trade secrets• To ensure the contractors are given all the

information relevant to operating in the plant safety• Secrecy agreement - confidential

EPA: Risk Management Plan (RMP)

Final rule released on June 20, 1996 A response to Bhopal accident Necessary requirement for plant that

uses more than a specified threshold quantity of regulated highly hazardous chemicals

4 elements Aim:

To decrease and reduce the number and magnitude of accidental releases toxic and flammable substances

The 4 RMP elements

Hazard assessment Prevention program Emergency response program

Documentation

1. Hazard assessment

A consequence analysis for a range of potential hazardous chemical releases, including the history of such releases at the facility

Analysis is based on the worst case scenario

Likelihood of the accident occurrence is excluded; therefore the results are not a true risk determination

2. Prevention program 11 sub-elements. Process safety information Hazard evaluation SOP Training Pre-startup review Maintenance Management of change Accident investigations Emergency response Safety Audits Risk Assessment

3. Emergency response program Define the steps to be taken by the

facility’s employees in response to accidental releases of hazardous materials

A procedure to notify the local community and the appropriate emergency response agency

Training is a must to all employees Drills to test a plan and to evacuate its

effectiveness

4. Documentation

Must be maintained on site and submitted to authority body.

Information is shared with local community

RMP document is updated when; Process/chemistry changes Governmental audits request an update

Discussion

List down major comparisons between PSM and RMP?

Answers:

RMP – to protect off-site people and the environment

PSM – to protect on-site people Prevention program for PSM & RMP is

mainly duplicated (refer to table 3-4)