Process Safety Management Process Safety Management –– 2008 Update & Review2008 Update & Review

“As if there were safety in stupidity alone.” – Thoreau

PSM PSM –– A look back to the A look back to the ‘‘9090’’ss

OSHA’s PSM Standard became effective in 1992.Greatest concern in Meat Industry was/is Anhydrous Ammonia. Lots of requirements, compliance was “phased-in” thru May, 1997.That was 11 years ago…..Let’s review where PSM came from.Then we’ll check our ongoing compliance.

Hazard Management:Hazard Management:The World as It Was Before PSMThe World as It Was Before PSM

Good people

… doing good things

The Rising Case for ChangeThe Rising Case for Change

– 2,500 immediate fatalities; 20,000+ total

– Many other offsite injuries

1984 – Bhopal, India – Toxic MaterialReleased

HAZARD:HAZARD:Highly ToxicHighly Toxic

Methyl IsocyanateMethyl Isocyanate

The Rising Case for ChangeThe Rising Case for Change

1984 – Mexico City, Mexico –Explosion– 300 fatalities

(mostly offsite)– $20M damages

HAZARD:HAZARD:Flammable LPGFlammable LPG

in tankin tank

The Rising Case for ChangeThe Rising Case for Change1988 – Norco, LA – Explosion– 7 onsite fatalities, 42 injured– $400M+ damages

HAZARD:HAZARD:FlammableFlammable

hydrocarbon vaporshydrocarbon vapors

The Rising Case for ChangeThe Rising Case for Change1989 – Pasadena, TX – Explosion and Fire– 23 fatalities, 130 injured; damage $800M+

HAZARD:HAZARD:FlammableFlammable

ethylene/isobutaneethylene/isobutanevapors in a 10vapors in a 10”” lineline

Enter Enter …… PProcessrocess SSafetyafety MManagementanagement

Integral part of OSHA Occupational Safety and Health Standards since 1992

Known formally as: Process Safety Management of Highly Hazardous Chemicals (29 CFR 1910.119)

PSM applies to most industrial processes containing threshold levels of hazardous materials;. Anhydrous Ammonia > 10,000 lbs.

In a Few Words, What is PSM?In a Few Words, What is PSM?

The proactive and systematicidentification, evaluation, and mitigation or prevention of chemical releases that could occur as a result of failures in process, procedures, or equipment.

WhatWhat’’s Covered by PSM? s Covered by PSM?

Process Safety InformationEmployee InvolvementProcess Hazard AnalysisOperating ProceduresTrainingContractorsPre-Startup Safety Review

Mechanical IntegrityHot WorkManagement of ChangeIncident InvestigationEmergency Planning and ResponseCompliance AuditsTrade Secrets

Ammonia RefrigerationAmmonia RefrigerationAnhydrous ammonia is widely used as refrigerant in many industrial facilities including the meat, poultry, and fish processing industry.Ammonia is a colorless gas with a strong, irritating smell. It is hygroscopic.Ammonia leaks can be very dangerous. These leaks can endanger all workers; therefore, it is critical to implement a structured safety approach to controlling ammonia applications. Accidental releases of ammonia from refrigeration facilities have resulted in both injuries and deaths to meat industry employees.

Proc

ess

Tech

nolo

gy Safety

Managem

ent

Personnel

Process HazardAnalysis (PHA)

Mechanical Integrity

Trade Secrets

Process SafetyInformation(PSI)

OperatingProcedures and SafeWork Practices

Employee ParticipationPersonnel Training and PerformanceIncident InvestigationCompliance AuditsEmergency Planning and ResponseContractor Training and Performance

Management ofChange (MOC)

Hot WorkPermit

Pre-Startup SafetyReview (PSSR)

Ammonia Refrigeration Ammonia Refrigeration Process Safety Management Process Safety Management (PSM) Model(PSM) Model

Emphasis on Operator InvolvementEmployee Responsibility MatrixStandardized PSM Awareness Training and DocumentationEmployees to write (or assist) with Operating Procedures

Employee ParticipationEmployee Participation

Equipment Documentation FormatP&ID drawings and Simplified Block/Flow DiagramsSystem Inventory ToolsPressure Relief Valve Sizing ToolsPressure Relief Valve Vent Piping ToolsVentilation System Calculation Tool

Process Safety InformationProcess Safety Information

What If /Checklist – Standard Method for Ammonia systemsPHA Before Engineering– First Session – 30%– Second Session – 90%– Additional Session(s) Before Start-Up

PHA must be reviewed/updated whenever system changes occurRevalidate every 5 years

Process Hazard AnalysisProcess Hazard Analysis

Operating ProceduresOperating ProceduresStandard Operating Procedures Template is OSHA CompliantGood place for employee involvement by your engine room personnel.System Procedures as well as Equipment Procedures are needed.Line Break Procedure(s) (similar to safety process of “Hot Work”permits

TrainingTrainingStandardized Curriculum Design For:– All Employees– Ammonia Refrigeration Primary Operator– Ammonia Refrigeration Support Operator– Maintenance Ammonia Refrigeration

Authorized– Production Ammonia Refrigeration

Authorized– Site Facility Management– Site PSM Coordinator

Standardized Criteria for Ammonia Refrigeration Contractor QualificationsChecklist – Safety Record and ExperienceEMR < 1.0 is Green; 1.0 – 1.25 = Yellow Gatekeeper at each siteQualify your contractors

ContractorsContractors

PrePre--Startup Safety ReviewStartup Safety Review

Standardized Pre-Start Safety Review Form - ChecklistPlant Engineering Manager Sign Off

Documented Maintenance ProceduresPM’s / Work OrdersEquipment ListSafety Critical Equipment ListUse electrical Functional Location or Equipment Type PM FrequenciesNon-Destructive Testing

Mechanical IntegrityMechanical Integrity

Hot Work (Control)Hot Work (Control)

Must use Hot Work Permits for all hot work occurring on a covered process.May be used in concert with a “Line breaking permit.

Standardized MOC FormStandardized MOC ProcedureStandardized Definitions– Replacement-in-Kind (RIK)– Temporary Change– Safety Design Review Checklist

Engineering ReviewManagement Authorization

Management of ChangeManagement of Change

Emergency Planning and Emergency Planning and ResponseResponse

Specific plans – as part of 1910.38 EAP –for release of a PSM controlled substancePlan for handling small releasesMay also be covered by 1910.120, HAZWOPER Standard

Standardized Incident Investigation FormsTeams Established in AdvanceInitiate within 24 hoursInvolve Operators, Maintenance, ManagersIdentify Root CauseRetained for 5 years

Incident InvestigationIncident Investigation

Standardized Audit ProtocolAudit Teams for each areaScoring System (e.g. Green, Yellow, Red items for revision)Continuous ImprovementFormal audit report to be completed and maintained on file (most recent two audits must be kept on file).

PSM Compliance AuditPSM Compliance Audit

Now Now –– where are we where are we ““atat”” today?today?

Again, it’s been 11 years since 1997’s final “phase-in”.Are our systems still fully compliant?Let’s look at some specific requirements and consider our PSM programs in this context.

Required ongoing actions (i.e. to Required ongoing actions (i.e. to stay in compliance).stay in compliance).

Are P&ID drawings and block flow diagrams current for all changes since 1997?Has PHA been updated and validated at least once every 5 years since original completion? Should be on (at least) 3rd version by now….Is PHA updated and validated with every system change other than RIK?Are operating procedures current for existing system?

Required ongoing actions (i.e. to Required ongoing actions (i.e. to stay in compliance). Cont.stay in compliance). Cont.

Has Refresher Training been provided at least once every 3 years? Is it documented?Are Management of Change forms maintained and document appropriate changes in other areas?Have compliance audits for the PSM process been completed every 3 years? Two most recent audits must be retained.

WhatWhat’’s next?s next?Check for compliance with various “update” requirements.If all/part are missing, develop a plan to get in compliance.– Perform an update PHA on current system– Do a compliance audit on PSM items.– Complete Refresher Training– Etc.

Implement compliance actions ASAP

WhatWhat’’s next? (Cont.)s next? (Cont.)

Institute a control system where all of these items are scheduled automatically for future review/update.When OSHA checks your PSM compliance they should see a program that is truly ongoing, with scheduled elements to maintain currency.

Questions?Questions?

Is your PSM system up to date (as of April 2008)?Are your various reviews complete and available should OSHA inspect your process/system?If not, you need to identify shortcomings and fix it – ASAP.