Process Safety Management of Highly Hazardous & Explosive Chemicals Contractor Pre-Qualification,...

Process Safety Management of Highly Hazardous & Explosive Chemicals

Process Safety Management of Highly Hazardous & Explosive Chemicals

Contractor Pre-Qualification, Emergency Preparedness, Incident Investigation, Audits

& EPA Risk Management Plans (RMP)

Contractor Pre-Qualification, Emergency Preparedness, Incident Investigation, Audits

& EPA Risk Management Plans (RMP)

Now That We’ve Developed Now That We’ve Developed

Process Safety InformationProcess Safety Information Process Material Toxicity InformationProcess Material Toxicity Information Process Hazard Analysis (PHA’s)Process Hazard Analysis (PHA’s) Mechanical Integrity CertificatesMechanical Integrity Certificates Management of ChangeManagement of Change Inspection/Testing/Maintenance Inspection/Testing/Maintenance Operating ProceduresOperating Procedures Safe Work ProceduresSafe Work Procedures Training ProgramsTraining Programs Training for ContractorsTraining for Contractors

Now…Now…

Process Safety InformationProcess Safety Information Process Material Toxicity InformationProcess Material Toxicity Information Process Hazard Analysis (PHA’s)Process Hazard Analysis (PHA’s) Mechanical Integrity CertificatesMechanical Integrity Certificates Management of ChangeManagement of Change Inspection/Testing/Maintenance Inspection/Testing/Maintenance Operating ProceduresOperating Procedures Safe Work ProceduresSafe Work Procedures Training ProgramsTraining Programs Training for ContractorsTraining for Contractors

Now…Now…

Contractor ManagementContractor Management

1910.119(h)1910.119(h)1910.119(h)1910.119(h)

PSM ContractorsPSM Contractors

The employer, when selecting a The employer, when selecting a contractor, shall obtain and contractor, shall obtain and evaluate information regarding evaluate information regarding the contract employer's safety the contract employer's safety performance and programs.performance and programs.

The employer shall inform The employer shall inform contract employers of the contract employers of the known potential fire, explosion, known potential fire, explosion, or toxic release hazards related or toxic release hazards related to the contractor's work and the to the contractor's work and the processprocess

The employer, when selecting a The employer, when selecting a contractor, shall obtain and contractor, shall obtain and evaluate information regarding evaluate information regarding the contract employer's safety the contract employer's safety performance and programs.performance and programs.

The employer shall inform The employer shall inform contract employers of the contract employers of the known potential fire, explosion, known potential fire, explosion, or toxic release hazards related or toxic release hazards related to the contractor's work and the to the contractor's work and the processprocess

Contractor Pre-Qualification & AuthorizationContractor Pre-Qualification & Authorization The Standard Requires You to:The Standard Requires You to:

Explain contractor qualification requirementsExplain contractor qualification requirements List what is required for contractor pre-bid List what is required for contractor pre-bid

awareness - pre-qualificationawareness - pre-qualification List what is required for contractor post-bid List what is required for contractor post-bid

awareness - training & orientationawareness - training & orientation Specify contractor responsibilitiesSpecify contractor responsibilities Describe contractor 300 Log RequirementsDescribe contractor 300 Log Requirements Evaluate Contractor PerformanceEvaluate Contractor Performance List documentation requirements for contractors to List documentation requirements for contractors to

completecomplete Explain the use of a work authorization systemExplain the use of a work authorization system

The Standard Requires You to:The Standard Requires You to: Explain contractor qualification requirementsExplain contractor qualification requirements List what is required for contractor pre-bid List what is required for contractor pre-bid

awareness - pre-qualificationawareness - pre-qualification List what is required for contractor post-bid List what is required for contractor post-bid

awareness - training & orientationawareness - training & orientation Specify contractor responsibilitiesSpecify contractor responsibilities Describe contractor 300 Log RequirementsDescribe contractor 300 Log Requirements Evaluate Contractor PerformanceEvaluate Contractor Performance List documentation requirements for contractors to List documentation requirements for contractors to

completecomplete Explain the use of a work authorization systemExplain the use of a work authorization system

Typical Pre-Qualification Elements:Typical Pre-Qualification Elements: Years Experience in Work ProcessYears Experience in Work Process Experience Modification Rate (EMR)Experience Modification Rate (EMR) OSHA Total Recordable Incident Rate and OSHA Total Recordable Incident Rate and

Lost Work day Case Rate InformationLost Work day Case Rate Information Safety ProgramsSafety Programs Training DocumentationTraining Documentation

Typical Pre-Qualification Elements:Typical Pre-Qualification Elements: Years Experience in Work ProcessYears Experience in Work Process Experience Modification Rate (EMR)Experience Modification Rate (EMR) OSHA Total Recordable Incident Rate and OSHA Total Recordable Incident Rate and

Lost Work day Case Rate InformationLost Work day Case Rate Information Safety ProgramsSafety Programs Training DocumentationTraining Documentation

Contractor Pre-Qualification & AuthorizationContractor Pre-Qualification & Authorization

Emergency PreparednessEmergency Preparedness

1910.119(f)(1)(I)(D)1910.119(f)(1)(I)(D)1910.119(f)(1)(I)(D)1910.119(f)(1)(I)(D)


Our Written Plan Must:Our Written Plan Must:

Define an emergency action planDefine an emergency action plan Define an emergency response planDefine an emergency response plan Describe a Minimum emergency response planDescribe a Minimum emergency response plan Describe procedures for handling small releasesDescribe procedures for handling small releases List the three levels of emergency responseList the three levels of emergency response List procedures for emergency evacuationList procedures for emergency evacuation List requirements of alarm systemsList requirements of alarm systems List training requirementsList training requirements

Our Written Plan Must:Our Written Plan Must:

Define an emergency action planDefine an emergency action plan Define an emergency response planDefine an emergency response plan Describe a Minimum emergency response planDescribe a Minimum emergency response plan Describe procedures for handling small releasesDescribe procedures for handling small releases List the three levels of emergency responseList the three levels of emergency response List procedures for emergency evacuationList procedures for emergency evacuation List requirements of alarm systemsList requirements of alarm systems List training requirementsList training requirements


The Standard Requires You to:The Standard Requires You to: Develop a Early Warning Method for Releases Develop a Early Warning Method for Releases

(Sensors/Alarms)(Sensors/Alarms) Train on the Meaning of the Alarms (May be Multiple Train on the Meaning of the Alarms (May be Multiple

Alarms)Alarms) Develop Emergency Evacuation Written Plans, Develop Emergency Evacuation Written Plans,

Evacuation Maps & Assembly Points based on Evacuation Maps & Assembly Points based on Release CharacteristicsRelease Characteristics

Determine Emergency PPE RequirementsDetermine Emergency PPE Requirements Train Employees & Contractors in the Emergency Train Employees & Contractors in the Emergency

Evacuation PlansEvacuation Plans Drill The Emergency Evacuation Plan At Last Once Drill The Emergency Evacuation Plan At Last Once

Per YearPer Year

The Standard Requires You to:The Standard Requires You to: Develop a Early Warning Method for Releases Develop a Early Warning Method for Releases

(Sensors/Alarms)(Sensors/Alarms) Train on the Meaning of the Alarms (May be Multiple Train on the Meaning of the Alarms (May be Multiple

Alarms)Alarms) Develop Emergency Evacuation Written Plans, Develop Emergency Evacuation Written Plans,

Evacuation Maps & Assembly Points based on Evacuation Maps & Assembly Points based on Release CharacteristicsRelease Characteristics

Determine Emergency PPE RequirementsDetermine Emergency PPE Requirements Train Employees & Contractors in the Emergency Train Employees & Contractors in the Emergency

Evacuation PlansEvacuation Plans Drill The Emergency Evacuation Plan At Last Once Drill The Emergency Evacuation Plan At Last Once

Per YearPer Year


Warning Systems Warning Systems must:must: Clearly Notify Clearly Notify

Employees of the Employees of the Hazardous ReleaseHazardous Release

Employees & Employees & Contractors must be Contractors must be Trained in the Trained in the Meaning of the Meaning of the Alarm(s)Alarm(s)

Warning Systems Warning Systems must:must: Clearly Notify Clearly Notify

Employees of the Employees of the Hazardous ReleaseHazardous Release

Employees & Employees & Contractors must be Contractors must be Trained in the Trained in the Meaning of the Meaning of the Alarm(s)Alarm(s)

Emergency PreparednessEvacuation MapsEmergency PreparednessEvacuation Maps

Emergency PreparednessAssembly PointsEmergency PreparednessAssembly Points

Alternate Assembly Point

Alternate Assembly Points Depending on Prevailing Weather Affecting Release

Emergency PreparednessEmergency PPEEmergency PreparednessEmergency PPE

Hazardous Hazardous Chemicals May Chemicals May Require Emergency Require Emergency PPE to be WornPPE to be Worn FRPFRP Escape RespiratorsEscape Respirators Eye Protection i.e.. Eye Protection i.e..

Refinery GogglesRefinery Goggles

Hazardous Hazardous Chemicals May Chemicals May Require Emergency Require Emergency PPE to be WornPPE to be Worn FRPFRP Escape RespiratorsEscape Respirators Eye Protection i.e.. Eye Protection i.e..

Refinery GogglesRefinery Goggles

Emergency PreparednessDrillsEmergency PreparednessDrills At Least Annual At Least Annual

Emergency Emergency Preparedness DrillsPreparedness Drills

This is not Just an This is not Just an Emergency Emergency Evacuation…Evacuation…

but Could Include but Could Include HAZWOPR HAZWOPR ResponseResponse

Must Document Must Document ResultsResults

At Least Annual At Least Annual Emergency Emergency Preparedness DrillsPreparedness Drills

This is not Just an This is not Just an Emergency Emergency Evacuation…Evacuation…

but Could Include but Could Include HAZWOPR HAZWOPR ResponseResponse

Must Document Must Document ResultsResults

Incident InvestigationIncident Investigation

1910.119(m)1910.119(m)1910.119(m)1910.119(m)

Incident Investigation Program Must Include the FollowingIncident Investigation Program Must Include the Following Describe the purpose of incident investigationDescribe the purpose of incident investigation List the circumstances or occurrences, which require List the circumstances or occurrences, which require

formal incident investigationformal incident investigation List the major investigation procedures that should be List the major investigation procedures that should be

followedfollowed Explain the list the responsibilities of the incident Explain the list the responsibilities of the incident

investigation teaminvestigation team Explain the contents of an "Incident Summary" formExplain the contents of an "Incident Summary" form Explain the contents of an "Incident Description" formExplain the contents of an "Incident Description" form Explain the contents of an "Approvals, Follow-up and Explain the contents of an "Approvals, Follow-up and

Review" formReview" form Explain the contents of a "Close-out" formExplain the contents of a "Close-out" form Explain Corrective Actions TakenExplain Corrective Actions Taken

Describe the purpose of incident investigationDescribe the purpose of incident investigation List the circumstances or occurrences, which require List the circumstances or occurrences, which require

formal incident investigationformal incident investigation List the major investigation procedures that should be List the major investigation procedures that should be

followedfollowed Explain the list the responsibilities of the incident Explain the list the responsibilities of the incident

investigation teaminvestigation team Explain the contents of an "Incident Summary" formExplain the contents of an "Incident Summary" form Explain the contents of an "Incident Description" formExplain the contents of an "Incident Description" form Explain the contents of an "Approvals, Follow-up and Explain the contents of an "Approvals, Follow-up and

Review" formReview" form Explain the contents of a "Close-out" formExplain the contents of a "Close-out" form Explain Corrective Actions TakenExplain Corrective Actions Taken

Incidents Can Be Minor or Major - Both Require InvestigationIncidents Can Be Minor or Major - Both Require Investigation

Incident Investigation Documentation Must IncludeIncident Investigation Documentation Must Include

Date of incidentDate of incidentDate investigation beganDate investigation beganDescription of the incidentDescription of the incidentFactors contributing to the incidentFactors contributing to the incidentRecommendations resulting from Recommendations resulting from

the investigationthe investigation

Date of incidentDate of incidentDate investigation beganDate investigation beganDescription of the incidentDescription of the incidentFactors contributing to the incidentFactors contributing to the incidentRecommendations resulting from Recommendations resulting from

the investigationthe investigation


Will Include Written Will Include Written Documentation of all Documentation of all Required ElementsRequired Elements

Will Include Written Will Include Written Documentation of all Documentation of all Required ElementsRequired Elements


Might Even Include a Flow Chart

Compliance AuditsCompliance Audits

1910.119(o)1910.119(o)1910.119(o)1910.119(o)


1910.119 states, "Employers shall certify that 1910.119 states, "Employers shall certify that they have evaluated compliance with the they have evaluated compliance with the provisions of this section at least every three provisions of this section at least every three years to verify that the procedures and years to verify that the procedures and practices developed under the standard are practices developed under the standard are adequate and are being followed."adequate and are being followed."

1910.119 states, "Employers shall certify that 1910.119 states, "Employers shall certify that they have evaluated compliance with the they have evaluated compliance with the provisions of this section at least every three provisions of this section at least every three years to verify that the procedures and years to verify that the procedures and practices developed under the standard are practices developed under the standard are adequate and are being followed."adequate and are being followed."


A List of factors that may increase the A List of factors that may increase the frequency of compliance auditsfrequency of compliance audits

Results of Any OSHA Compliance Results of Any OSHA Compliance Audits Performed & Citations/Action Audits Performed & Citations/Action Items DevelopedItems Developed

An Explanation of audit certificationAn Explanation of audit certification List Compliance Audit documentationList Compliance Audit documentation

A List of factors that may increase the A List of factors that may increase the frequency of compliance auditsfrequency of compliance audits

Results of Any OSHA Compliance Results of Any OSHA Compliance Audits Performed & Citations/Action Audits Performed & Citations/Action Items DevelopedItems Developed

An Explanation of audit certificationAn Explanation of audit certification List Compliance Audit documentationList Compliance Audit documentation


Employers shall certify that they have evaluated Employers shall certify that they have evaluated compliance with the provisions of this section at least compliance with the provisions of this section at least every three years to verify that the procedures and every three years to verify that the procedures and practices developed under the standard are adequate practices developed under the standard are adequate and are being followedand are being followed

The compliance audit shall be conducted by at least The compliance audit shall be conducted by at least one person knowledgeable in the processone person knowledgeable in the process

A report of the findings of the audit shall be A report of the findings of the audit shall be developeddeveloped

Compliance Audits Must be Performed Every 3 YearsCompliance Audits Must be Performed Every 3 Years

Employers shall certify that they have evaluated Employers shall certify that they have evaluated compliance with the provisions of this section at least compliance with the provisions of this section at least every three years to verify that the procedures and every three years to verify that the procedures and practices developed under the standard are adequate practices developed under the standard are adequate and are being followedand are being followed

The compliance audit shall be conducted by at least The compliance audit shall be conducted by at least one person knowledgeable in the processone person knowledgeable in the process

A report of the findings of the audit shall be A report of the findings of the audit shall be developeddeveloped

Compliance Audits Must be Performed Every 3 YearsCompliance Audits Must be Performed Every 3 Years

The Compliance Audit Process Typically The Compliance Audit Process Typically Includes the Following:Includes the Following:

Definition of the guidelines for an audit teamDefinition of the guidelines for an audit team A List the PSM elements that must be auditedA List the PSM elements that must be audited A List of the minimum contents of a final report of an A List of the minimum contents of a final report of an

auditaudit An An Explanation and list the Compliant Audit reports Explanation and list the Compliant Audit reports

that must be retained by the facilitythat must be retained by the facility

The Compliance Audit Process Typically The Compliance Audit Process Typically Includes the Following:Includes the Following:

Definition of the guidelines for an audit teamDefinition of the guidelines for an audit team A List the PSM elements that must be auditedA List the PSM elements that must be audited A List of the minimum contents of a final report of an A List of the minimum contents of a final report of an

auditaudit An An Explanation and list the Compliant Audit reports Explanation and list the Compliant Audit reports

that must be retained by the facilitythat must be retained by the facility



OSHA PSM CitationsOSHA PSM Citations

## Initial PenaltyInitial Penalty Final Penalty Final Penalty

13931393$25,058,853$25,058,853 $18,884,463$18,884,463

OSHA PSM CitationsOSHA PSM Citations

## Initial PenaltyInitial Penalty Final Penalty Final Penalty

13931393$25,058,853$25,058,853 $18,884,463$18,884,463


Typical Types of OSHA Serious CitationsTypical Types of OSHA Serious Citations failure to maintain and follow normal operating failure to maintain and follow normal operating

proceduresprocedures failure to provide refresher training to process failure to provide refresher training to process

operatorsoperators failure to correct deficiencies in process equipment in failure to correct deficiencies in process equipment in

a safe mannera safe manner failure to provide necessary training to emergency failure to provide necessary training to emergency

responders and fire brigade membersresponders and fire brigade members Failure to perform audits as required every 3 yearsFailure to perform audits as required every 3 years

Typical Types of OSHA Serious CitationsTypical Types of OSHA Serious Citations failure to maintain and follow normal operating failure to maintain and follow normal operating

proceduresprocedures failure to provide refresher training to process failure to provide refresher training to process

operatorsoperators failure to correct deficiencies in process equipment in failure to correct deficiencies in process equipment in

a safe mannera safe manner failure to provide necessary training to emergency failure to provide necessary training to emergency

responders and fire brigade membersresponders and fire brigade members Failure to perform audits as required every 3 yearsFailure to perform audits as required every 3 years


There are Companies that have There are Companies that have Covered Process, but have not Covered Process, but have not implemented any PSM Program.implemented any PSM Program.

The Regulatory Exposure is to:The Regulatory Exposure is to: Willful CitationsWillful Citations Criminal Willful CitationsCriminal Willful Citations Serious CitationsSerious Citations Major Citation PenaltiesMajor Citation Penalties

There are Companies that have There are Companies that have Covered Process, but have not Covered Process, but have not implemented any PSM Program.implemented any PSM Program.

The Regulatory Exposure is to:The Regulatory Exposure is to: Willful CitationsWillful Citations Criminal Willful CitationsCriminal Willful Citations Serious CitationsSerious Citations Major Citation PenaltiesMajor Citation Penalties

PSM Audit Example Checklist Items (Partial)PSM Audit Example Checklist Items (Partial) Management Commitment to the PSM ProgramManagement Commitment to the PSM Program Is there evidence that an effective process safety management Is there evidence that an effective process safety management

program has been set up and that explicit expectations, program has been set up and that explicit expectations, objectives and goals have been set with clear-cut, desired objectives and goals have been set with clear-cut, desired outputs? outputs?

Have resources been provided in the form of personnel assigned Have resources been provided in the form of personnel assigned to provide implementation and continuation of each element? to provide implementation and continuation of each element?

Have clear lines of responsibility been established and roles and Have clear lines of responsibility been established and roles and responsibilities assigned? responsibilities assigned?

Is managementIs management commitment to using all available resources for commitment to using all available resources for enhancing process safety knowledge at all levels of the enhancing process safety knowledge at all levels of the organization clearly demonstrated by actions? organization clearly demonstrated by actions?

Does management encourage active participation in professional Does management encourage active participation in professional and trade associations for key PSM personnel to ensure the and trade associations for key PSM personnel to ensure the PSM system keeps pace withTest Practices?PSM system keeps pace withTest Practices?

Management Commitment to the PSM ProgramManagement Commitment to the PSM Program Is there evidence that an effective process safety management Is there evidence that an effective process safety management

program has been set up and that explicit expectations, program has been set up and that explicit expectations, objectives and goals have been set with clear-cut, desired objectives and goals have been set with clear-cut, desired outputs? outputs?

Have resources been provided in the form of personnel assigned Have resources been provided in the form of personnel assigned to provide implementation and continuation of each element? to provide implementation and continuation of each element?

Have clear lines of responsibility been established and roles and Have clear lines of responsibility been established and roles and responsibilities assigned? responsibilities assigned?

Is managementIs management commitment to using all available resources for commitment to using all available resources for enhancing process safety knowledge at all levels of the enhancing process safety knowledge at all levels of the organization clearly demonstrated by actions? organization clearly demonstrated by actions?

Does management encourage active participation in professional Does management encourage active participation in professional and trade associations for key PSM personnel to ensure the and trade associations for key PSM personnel to ensure the PSM system keeps pace withTest Practices?PSM system keeps pace withTest Practices?

PSM Audit Example Checklist Items (Partial)PSM Audit Example Checklist Items (Partial) Process Hazard Analysis Process Hazard Analysis Does the PSM program establish a process hazard analysis Does the PSM program establish a process hazard analysis

procedure in accordance with the PSM rule? procedure in accordance with the PSM rule? Have personnel, who will take part in PHAHave personnel, who will take part in PHA 痴痴 ,, been provided with been provided with

training in the PHA technique that will be used for their study? training in the PHA technique that will be used for their study? Does the PHA procedure establish that the hazard identification team Does the PHA procedure establish that the hazard identification team

be multi-disciplined in nature, capable of covering such issues as be multi-disciplined in nature, capable of covering such issues as maintenance, operations, design, inspection & testing, safety, health maintenance, operations, design, inspection & testing, safety, health and environment, etc? and environment, etc?

Does the PHA procedure require that the PHA team leader be Does the PHA procedure require that the PHA team leader be specially trained in the technique that will be used? specially trained in the technique that will be used?

Does documentation of the hazard identification process include all Does documentation of the hazard identification process include all issues, not only those resulting in findings or recommendations? issues, not only those resulting in findings or recommendations?

Have PHAHave PHA been conducted on all PSM-covered processes and if not, been conducted on all PSM-covered processes and if not, is there an established schedule for completing all PHAis there an established schedule for completing all PHA’s?’s?

Process Hazard Analysis Process Hazard Analysis Does the PSM program establish a process hazard analysis Does the PSM program establish a process hazard analysis

procedure in accordance with the PSM rule? procedure in accordance with the PSM rule? Have personnel, who will take part in PHAHave personnel, who will take part in PHA 痴痴 ,, been provided with been provided with

training in the PHA technique that will be used for their study? training in the PHA technique that will be used for their study? Does the PHA procedure establish that the hazard identification team Does the PHA procedure establish that the hazard identification team

be multi-disciplined in nature, capable of covering such issues as be multi-disciplined in nature, capable of covering such issues as maintenance, operations, design, inspection & testing, safety, health maintenance, operations, design, inspection & testing, safety, health and environment, etc? and environment, etc?

Does the PHA procedure require that the PHA team leader be Does the PHA procedure require that the PHA team leader be specially trained in the technique that will be used? specially trained in the technique that will be used?

Does documentation of the hazard identification process include all Does documentation of the hazard identification process include all issues, not only those resulting in findings or recommendations? issues, not only those resulting in findings or recommendations?

Have PHAHave PHA been conducted on all PSM-covered processes and if not, been conducted on all PSM-covered processes and if not, is there an established schedule for completing all PHAis there an established schedule for completing all PHA’s?’s?


Audit Findings must be DocumentedAudit Findings must be DocumentedActions must be Taken on All Actions must be Taken on All

Exceptions Exceptions All Actions Affecting P&ID’s, PHA’s, All Actions Affecting P&ID’s, PHA’s,

Mechanical Integrity Certificates, Mechanical Integrity Certificates, Inspection/Testing/Maintenance, Inspection/Testing/Maintenance, Operating Procedures & Training Operating Procedures & Training Procedures will Require Revision of Procedures will Require Revision of

All of the AboveAll of the Above

Audit Findings must be DocumentedAudit Findings must be DocumentedActions must be Taken on All Actions must be Taken on All

Exceptions Exceptions All Actions Affecting P&ID’s, PHA’s, All Actions Affecting P&ID’s, PHA’s,

Mechanical Integrity Certificates, Mechanical Integrity Certificates, Inspection/Testing/Maintenance, Inspection/Testing/Maintenance, Operating Procedures & Training Operating Procedures & Training Procedures will Require Revision of Procedures will Require Revision of

All of the AboveAll of the Above


Remember,Remember, The Audit Process is Determine if there are The Audit Process is Determine if there are

any weaknesses in the system or PSM any weaknesses in the system or PSM Program and to provide a report an Program and to provide a report an method to take action.method to take action.

These actions can prevent catastrophic These actions can prevent catastrophic release, injury and death.release, injury and death.

Remember,Remember, The Audit Process is Determine if there are The Audit Process is Determine if there are

any weaknesses in the system or PSM any weaknesses in the system or PSM Program and to provide a report an Program and to provide a report an method to take action.method to take action.

These actions can prevent catastrophic These actions can prevent catastrophic release, injury and death.release, injury and death.

Trade SecretsTrade Secrets

1910.119(p)1910.119(p)1910.119(p)1910.119(p)

Trade SecretsTrade Secrets

All Information Regarding the Process All Information Regarding the Process Must be Made Available to Persons Must be Made Available to Persons Involved in the PSM Program Including Involved in the PSM Program Including Trade SecretsTrade Secrets

Confidentiality Agreements are AllowedConfidentiality Agreements are Allowed

All Information Regarding the Process All Information Regarding the Process Must be Made Available to Persons Must be Made Available to Persons Involved in the PSM Program Including Involved in the PSM Program Including Trade SecretsTrade Secrets

Confidentiality Agreements are AllowedConfidentiality Agreements are Allowed

Summary of PSM ElementsSummary of PSM Elements Process Safety Information Process Safety Information Equipment ii the ProcessEquipment ii the Process Process Hazard AnalysisProcess Hazard Analysis Operating ProceduresOperating Procedures Employee TrainingEmployee Training Training ContractorsTraining Contractors Pre-Startup Safety ReviewPre-Startup Safety Review Mechanical Integrity of Equipment Mechanical Integrity of Equipment Management of ChangeManagement of Change Incident InvestigationIncident Investigation Emergency PreparednessEmergency Preparedness Compliance Audits Compliance Audits Trade SecretsTrade Secrets

Process Safety Information Process Safety Information Equipment ii the ProcessEquipment ii the Process Process Hazard AnalysisProcess Hazard Analysis Operating ProceduresOperating Procedures Employee TrainingEmployee Training Training ContractorsTraining Contractors Pre-Startup Safety ReviewPre-Startup Safety Review Mechanical Integrity of Equipment Mechanical Integrity of Equipment Management of ChangeManagement of Change Incident InvestigationIncident Investigation Emergency PreparednessEmergency Preparedness Compliance Audits Compliance Audits Trade SecretsTrade Secrets

EPA Risk Management Plans (RMP) Basics

EPA Risk Management Plans (RMP) Basics

CAA 112(r)CAA 112(r)CAA 112(r)CAA 112(r)

One More Thing to Discuss…EPA Risk Management Plans(RMP)

One More Thing to Discuss…EPA Risk Management Plans(RMP)Many Times Companies Who Must Many Times Companies Who Must

Comply with PSM, must also Comply Comply with PSM, must also Comply with the Requirements of EPA Risk with the Requirements of EPA Risk Management Plans (RMP)Management Plans (RMP)

The RMP Standard was to be a Mirror The RMP Standard was to be a Mirror of the PSM Standard…Didn’t happen!of the PSM Standard…Didn’t happen!

Remember…PSM Protects the Remember…PSM Protects the Workforce, RMP Protects the Workforce, RMP Protects the CommunityCommunity

Many Times Companies Who Must Many Times Companies Who Must Comply with PSM, must also Comply Comply with PSM, must also Comply with the Requirements of EPA Risk with the Requirements of EPA Risk Management Plans (RMP)Management Plans (RMP)

The RMP Standard was to be a Mirror The RMP Standard was to be a Mirror of the PSM Standard…Didn’t happen!of the PSM Standard…Didn’t happen!

Remember…PSM Protects the Remember…PSM Protects the Workforce, RMP Protects the Workforce, RMP Protects the CommunityCommunity

EPA RMPEPA RMP

Basic RequirementsBasic Requirements Executive summaryExecutive summary RegistrationRegistration Off-site consequence analysisOff-site consequence analysis Five-year accident historyFive-year accident history Emergency response planEmergency response plan Prevention program summary informationPrevention program summary information CertificationCertification

Sound Much Easier than PSM…Right?Sound Much Easier than PSM…Right?

Basic RequirementsBasic Requirements Executive summaryExecutive summary RegistrationRegistration Off-site consequence analysisOff-site consequence analysis Five-year accident historyFive-year accident history Emergency response planEmergency response plan Prevention program summary informationPrevention program summary information CertificationCertification

Sound Much Easier than PSM…Right?Sound Much Easier than PSM…Right?

Release Plume

All Public Facilities in this Release Plume Must be Identified & Surveyed

EPA RMPEPA RMP

Emergency Response Plan & Emergency Response Plan & Prevention Plans Must Be Developed to Prevention Plans Must Be Developed to Prevent Accidental Release of the Prevent Accidental Release of the Covered ChemicalCovered Chemical

Emergency Response Plan & Emergency Response Plan & Prevention Plans Must Be Developed to Prevention Plans Must Be Developed to Prevent Accidental Release of the Prevent Accidental Release of the Covered ChemicalCovered Chemical

EPA RMP 1998 ChangesCompliance ElementsEPA RMP 1998 ChangesCompliance ElementsFollow-up / completion of PHA Follow-up / completion of PHA

recommendationrecommendationRe-validation of your PHA every 5 Re-validation of your PHA every 5

yearsyearsCompliance audits (required every Compliance audits (required every

3 years)3 years)Follow-up / completion of Follow-up / completion of

compliance audit compliance audit recommendationsrecommendations

Follow-up / completion of PHA Follow-up / completion of PHA recommendationrecommendation

Re-validation of your PHA every 5 Re-validation of your PHA every 5 yearsyears

Compliance audits (required every Compliance audits (required every 3 years)3 years)

Follow-up / completion of Follow-up / completion of compliance audit compliance audit recommendationsrecommendations

EPA RMP 1998 ChangesCompliance ElementsEPA RMP 1998 ChangesCompliance Elements

Annual review and certification of Annual review and certification of operating proceduresoperating procedures

Employee trainingEmployee trainingUpdates related to system Updates related to system

modifications, inventory changes, modifications, inventory changes, operational changesoperational changes

Off-site consequence analysisOff-site consequence analysis

Annual review and certification of Annual review and certification of operating proceduresoperating procedures

Employee trainingEmployee trainingUpdates related to system Updates related to system

modifications, inventory changes, modifications, inventory changes, operational changesoperational changes

Off-site consequence analysisOff-site consequence analysis

Process Safety Management of Highly Hazardous & Explosive

Chemicals & EPA Risk Management Plans

Process Safety Management of Highly Hazardous & Explosive

Chemicals & EPA Risk Management Plans

SummarySummarySummarySummary

Goals of the One Day CourseGoals of the One Day Course Understand Why Process Safety Management (PSM) Understand Why Process Safety Management (PSM)

Was PromulgatedWas Promulgated Understand That Even with PSM, Catastrophes are Still Understand That Even with PSM, Catastrophes are Still

OccurringOccurring Understand Who is Covered & ExemptionsUnderstand Who is Covered & Exemptions Understand the Team Process to Developing a PSM Understand the Team Process to Developing a PSM

ProgramProgram Understand Each of the Elements of a Properly Designed Understand Each of the Elements of a Properly Designed

& Implemented Program and How to Begin the Process& Implemented Program and How to Begin the Process Understand the Basics of How PSM & RMP Work Understand the Basics of How PSM & RMP Work

Together to Protect the Workforce & Surrounding Together to Protect the Workforce & Surrounding CommunityCommunity

Understand Why Process Safety Management (PSM) Understand Why Process Safety Management (PSM) Was PromulgatedWas Promulgated

Understand That Even with PSM, Catastrophes are Still Understand That Even with PSM, Catastrophes are Still OccurringOccurring

Understand Who is Covered & ExemptionsUnderstand Who is Covered & Exemptions Understand the Team Process to Developing a PSM Understand the Team Process to Developing a PSM

ProgramProgram Understand Each of the Elements of a Properly Designed Understand Each of the Elements of a Properly Designed

& Implemented Program and How to Begin the Process& Implemented Program and How to Begin the Process Understand the Basics of How PSM & RMP Work Understand the Basics of How PSM & RMP Work

Together to Protect the Workforce & Surrounding Together to Protect the Workforce & Surrounding CommunityCommunity

ResourcesResources

GTRI - GTRI - http://www.oshainfo.gatech.edu/index.htmlhttp://www.oshainfo.gatech.edu/index.html

OSHA PSM Compliance Guidelines -OSHA PSM Compliance Guidelines - http://www.osha.gov/Publications/osha3133.htmlhttp://www.osha.gov/Publications/osha3133.html

OSHA PSM for Construction 1926.64 - OSHA PSM for Construction 1926.64 - http://www.osha.gov/doc/outreachtraining/htmlfilehttp://www.osha.gov/doc/outreachtraining/htmlfiles/psm.htmls/psm.html

GTRI - GTRI - http://www.oshainfo.gatech.edu/index.htmlhttp://www.oshainfo.gatech.edu/index.html

OSHA PSM Compliance Guidelines -OSHA PSM Compliance Guidelines - http://www.osha.gov/Publications/osha3133.htmlhttp://www.osha.gov/Publications/osha3133.html

OSHA PSM for Construction 1926.64 - OSHA PSM for Construction 1926.64 - http://www.osha.gov/doc/outreachtraining/htmlfilehttp://www.osha.gov/doc/outreachtraining/htmlfiles/psm.htmls/psm.html

http://www.oshainfo.gatech.edu/index.html

http://www.osha.gov/Publications/osha3133.html

http://www.oshainfo.gatech.edu/index.html

http://www.osha.gov/Publications/osha3133.html

PSM One Day ReviewPSM One Day Review

PSM One Day Review

1.1. The Process Safety Management The Process Safety Management Standard was drafted as a requirement Standard was drafted as a requirement of the Clean Air Act. of the Clean Air Act. True or FalseTrue or False

2.2. The PSM program must include a list The PSM program must include a list of highly hazardous chemicals. of highly hazardous chemicals. True or FalseTrue or False

3.3. The initial start-up of a process is not The initial start-up of a process is not included as an operating phase under included as an operating phase under the PSM Standard. the PSM Standard. True or FalseTrue or False

4.4. List three items that the process hazard analysis must List three items that the process hazard analysis must address. address. ______________________, , __________ __________ and _ and ___________________..

5.5. PSM does not apply to contractors, PSM does not apply to contractors, regardless of the work they are doing. regardless of the work they are doing. True or FalseTrue or False

PSM One Day Review (cont.)

6.6. The PSM Standard applies to companies that either process highly The PSM Standard applies to companies that either process highly _____________ materials or use _____________ liquids and gases _____________ materials or use _____________ liquids and gases in excess of 10,000 pounds.in excess of 10,000 pounds.

7.7. Process safety information includes:Process safety information includes:______________, _____________ and _____________.______________, _____________ and _____________.

8.8. Fault tree analysis is one form of an Fault tree analysis is one form of an approved method of performing a process approved method of performing a process hazard analysis. hazard analysis. True or FalseTrue or False

9.9. A technical basis is not required to change A technical basis is not required to change a process covered by the PSM Standard. a process covered by the PSM Standard. True or FalseTrue or False

10.10. Two types of training required by the PSM Two types of training required by the PSM standard are ________________ and_________________.standard are ________________ and_________________.

Process Safety Management of Highly Hazardous & Explosive Chemicals Contractor Pre-Qualification,...

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