Process Safety Management of Highly Hazardous & Explosive Chemicals

Process Safety Management of Highly Hazardous & Explosive Chemicals

29CFR1910.119Clearly Understanding the Standard

29CFR1910.11929CFR1910.119Clearly Understanding the StandardClearly Understanding the Standard

Information Provided under OSHA Susan Harwood Grant#SH-17811-08-60-F-13

Susan Harwood Grant…HistorySusan Harwood Grant…History

Grants are awarded to provide training and education programs for employers and employees on the recognition, avoidance, and prevention of safety and health hazards in their workplaces.

PSM Was Chosen Given the Clear Need Past DisastersCurrent Year Disasters Perceived Weakness in PSM Program

Grants are awarded to provide training and Grants are awarded to provide training and education programs for employers and education programs for employers and employees on the recognition, avoidance, employees on the recognition, avoidance, and prevention of safety and health hazards and prevention of safety and health hazards in their workplaces. in their workplaces.

PSM Was Chosen Given the Clear Need PSM Was Chosen Given the Clear Need Past DisastersPast Disasters Current Year DisastersCurrent Year Disasters Perceived Weakness in PSM ProgramPerceived Weakness in PSM Program

GTRI PSM Susan Harwood Grant ProgramGTRI PSM Susan Harwood Grant ProgramGTRI has Offered:

Nine (9) One Day Courses Around the Southeastern United States

Eight (8) One Week In-Depth Courses Around the United States

GTRI has Offered:

Nine (9) One Day Courses Around the Southeastern United States

Eight (8) One Week In-Depth Courses Around the United States

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

(PSM) Was Promulgated Understand That Even with PSM, Catastrophes

are Still Occurring Understand Who is Covered & Exemptions Understand the Team Process to Developing a

PSM Program Understand Each of the Elements of a Properly

Designed & Implemented Program and How to Begin the Process

Understand the Basics of How PSM & RMP Work Together to Protect the Workforce & Surrounding Community

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

Understand That Even with PSM, Catastrophes Understand That Even with PSM, Catastrophes are Still Occurringare Still Occurring

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

PSM ProgramPSM Program Understand Each of the Elements of a Properly Understand Each of the Elements of a Properly

Designed & Implemented Program and How to Designed & Implemented Program and How to Begin the ProcessBegin the Process

Understand the Basics of How PSM & RMP Understand the Basics of How PSM & RMP Work Together to Protect the Workforce & Work Together to Protect the Workforce & Surrounding CommunitySurrounding Community

Summary of the One Week CourseSummary of the One Week Course

This is an In-Depth Study of the Requirements of the Standard

Students will Actually Learn through a Real Life Case Study How to Design Each Element of the Process Safety Management Standard Requirements

Students will Also Review the Basics of EPA Risk Management Plan (RMP)

This is an InThis is an In--Depth Study of the Depth Study of the Requirements of the Standard Requirements of the Standard

Students will Actually Learn through a Real Students will Actually Learn through a Real Life Case Study How to Design Each Element Life Case Study How to Design Each Element of the Process Safety Management Standard of the Process Safety Management Standard RequirementsRequirements

Students will Also Review the Basics of EPA Students will Also Review the Basics of EPA Risk Management Plan (RMP)Risk Management Plan (RMP)

Rules of the CourseRules of the Course

This is an Open Discussion Course

Relax and Learn Ask Questions Participate in Discussions Share Experiences Share Best Practices Enjoy Yourself

This is an Open Discussion CourseThis is an Open Discussion Course

Relax and LearnRelax and Learn Ask Questions Ask Questions Participate in DiscussionsParticipate in Discussions Share ExperiencesShare Experiences Share Best PracticesShare Best Practices Enjoy YourselfEnjoy Yourself

Why Did OSHA Develop PSM?Why Did OSHA Develop PSM?

Bhopal, India (1984) 2,000 deaths

Isocyanate release Pasadena, TX (1989)

23 deaths, 132 injuries Petroleum explosion

Cincinnati, OH (1990) 2 deaths

Explosion Sterlington, LA (1991)

8 deaths, 128 injuries Chemical release

Bhopal, India (1984)Bhopal, India (1984) 2,000 deaths 2,000 deaths

Isocyanate releaseIsocyanate release Pasadena, TX (1989)Pasadena, TX (1989)

23 deaths, 132 injuries 23 deaths, 132 injuries Petroleum explosionPetroleum explosion

Cincinnati, OH (1990)Cincinnati, OH (1990) 2 deaths 2 deaths

ExplosionExplosion Sterlington, LA (1991) Sterlington, LA (1991)

8 deaths, 128 injuries 8 deaths, 128 injuries Chemical releaseChemical release

In 1991, OSHA and EPA respectively, Released the Standards, PSM & RMP that Applies to Those Companies that are Affected by The Standards.

In 1991, OSHA and In 1991, OSHA and EPA respectively, EPA respectively, Released the Released the Standards, PSM & Standards, PSM & RMP that Applies to RMP that Applies to Those Companies Those Companies that are Affected by that are Affected by The Standards.The Standards.

Why Did OSHA Develop PSM?Why Did OSHA Develop PSM?

Process Safety Management is a regulation, promulgated by OSHA, intended to prevent an incident like the 1984 Bhopal Disaster

And…to Prevent Release of: Toxic, Reactive, Flammable, or Explosive chemicals

Process Safety Process Safety ManagementManagement is a is a regulation, promulgated regulation, promulgated by by OSHA, intended to OSHA, intended to prevent an incident like prevent an incident like the 1984 the 1984 Bhopal DisasterBhopal Disaster

AndAnd……to Prevent Release to Prevent Release of:of: Toxic, Toxic, Reactive, Reactive, Flammable, or Flammable, or Explosive chemicalsExplosive chemicals

Why Did OSHA Develop PSM?Why Did OSHA Develop PSM?

Not Only PSM, But RMPNot Only PSM, But RMP

A great many industrial facilities must comply with OSHA's Process Safety Management (PSM) regulations as well as the quite similar EPA Risk Management Program (RMP) regulations (Title 40 CFR Part 68).

A great many industrial A great many industrial facilities must comply facilities must comply with OSHA's Process with OSHA's Process Safety Management Safety Management (PSM) regulations as (PSM) regulations as well as the quite similar well as the quite similar EPA Risk Management EPA Risk Management Program (RMP) Program (RMP) regulations (Title 40 regulations (Title 40 CFR Part 68). CFR Part 68).

PSM vs. RMP - What’s the Difference?PSM vs. RMP - What’s the Difference?

RMP-Like Sara Title III Protects the

Community Protects the General

Public Around the Facility

Protects Adjacent Facilities Such as Schools & Hospitals

RMPRMP--Like Sara Title IIILike Sara Title III Protects the Protects the

CommunityCommunity Protects the General Protects the General

Public Around the Public Around the FacilityFacility

Protects Adjacent Protects Adjacent Facilities Such as Facilities Such as Schools & HospitalsSchools & Hospitals

PSM - Like HAZCOM Protects the

Workforce Protects Contractors Protects Visitors to

the Facility Basically Protects the

Workplace

PSM PSM -- Like HAZCOMLike HAZCOM Protects the Protects the

WorkforceWorkforce Protects ContractorsProtects Contractors Protects Visitors to Protects Visitors to

the Facilitythe Facility Basically Protects the Basically Protects the

Workplace Workplace

The Standard Was Promulgated in 1991 - Is it Working?The Standard Was Promulgated in 1991 - Is it Working?

BP Products Texas City - March 2005 15 Workers Killed 170 Injured Major Property

Damage $21 Million in Fines

BP Products Texas BP Products Texas City City -- March 2005March 2005 15 Workers Killed15 Workers Killed 170 Injured170 Injured Major Property Major Property

DamageDamage $21 Million in Fines$21 Million in Fines

The Standard Was Promulgated in 1991 - Is it Working?The Standard Was Promulgated in 1991 - Is it Working?

ApplicationApplication

1910.119(a)1910.119(a)1910.119(a)

What Facilities are CoveredWhat Facilities are Covered

Those Who Use Chemicals in Appendix A: A List of highly hazardous chemicals, toxics and reactive (Mandatory). Contains a listing of toxic and reactive highly hazardous chemicals which present a potential for a catastrophic event at or above the threshold quantity

Examples

Chemical Threshold Quantity (TQ) Anhydrous Ammonia: 10,000 lbs Chlorine: 1,500 lbs

Those Who Use Chemicals in Appendix A: A List of Those Who Use Chemicals in Appendix A: A List of highly hazardous chemicals, toxics and reactive highly hazardous chemicals, toxics and reactive (Mandatory). Contains a listing of toxic and reactive (Mandatory). Contains a listing of toxic and reactive highly hazardous chemicals which present a potential for highly hazardous chemicals which present a potential for a catastrophic event at or above the threshold quantitya catastrophic event at or above the threshold quantity

ExamplesExamples

Chemical Chemical Threshold Quantity (TQ)Threshold Quantity (TQ) Anhydrous Ammonia:Anhydrous Ammonia: 10,000 lbs10,000 lbs Chlorine:Chlorine: 1,500 lbs1,500 lbs

A process which involves a flammable liquid or gas (as defined in 1910.1200(c) of this part) on-site in one location, in a quantity of 10,000 pounds (4535.9 kg) or more

A process which A process which involves a involves a flammable liquid or flammable liquid or gas (as defined in gas (as defined in 1910.1200(c) of this 1910.1200(c) of this part) onpart) on--site in one site in one location, in a location, in a quantity of 10,000 quantity of 10,000 pounds (4535.9 kg) pounds (4535.9 kg) or moreor more

What Facilities are CoveredWhat Facilities are Covered

Important Interpretation: 2007 - 06/11/2007 - OSHA defines "on-site in one location" for Process Safety Management of Highly Hazardous Chemicals standard

OSHA interprets "on-site in one location" to mean that the standard applies when a threshold quantity of a highly hazardous chemical (HHC) exists within an area under the control of an employer or group of affiliated employers. It 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.

Important Interpretation: Important Interpretation: 2007 2007 -- 06/11/2007 06/11/2007 -- OSHA OSHA defines "ondefines "on--site in one location" for Process Safety site in one location" for Process Safety Management of Highly Hazardous Chemicals Management of Highly Hazardous Chemicals standardstandard

OSHA interprets "onOSHA interprets "on--site in one location" to mean that site in one location" to mean that the standard applies when a threshold quantity of a the standard applies when a threshold quantity of a highly hazardous chemical (HHC) exists within an highly hazardous chemical (HHC) exists within an area under the control of an employer or group of area under the control of an employer or group of affiliated employers. It also applies to any groupaffiliated employers. It also applies to any group of of vessels that are interconnected, or in separate vessels that are interconnected, or in separate vessels that are close enough in proximity that the vessels that are close enough in proximity that the HHC could be involved in a potential catastrophic HHC could be involved in a potential catastrophic release.release.

What Facilities are CoveredWhat Facilities are Covered

Affect of the “Meer” Decision:

MEER ruling and the MEER Memorandum addressed in the Secretary's letter, OSHA's enforcement policy that the Agency would not cite employers for violations of 1910.119 where stored flammable liquids in atmospheric tanks were connected to a process, unless the process outside of the amount in storage contained more than 10,000 pounds of the substance

Affect of the Affect of the ““MeerMeer”” Decision:Decision:

MEER MEER ruling and theruling and the MEERMEER Memorandum addressed in the Memorandum addressed in the Secretary's letter, Secretary's letter, OSHA's OSHA's enforcement policy that the Agency enforcement policy that the Agency would not cite employers forwould not cite employers for violations of 1910.119 where stored violations of 1910.119 where stored flammable liquids in atmospheric tanks were connected to a flammable liquids in atmospheric tanks were connected to a process, unless the process outside ofprocess, unless the process outside of the amount in storage the amount in storage contained more than 10,000 pounds of the substancecontained more than 10,000 pounds of the substance

What Facilities are CoveredWhat Facilities are Covered

What Types of Industries?What Types of Industries?

Industries that Process Chemicals Such As: Industrial Organics & Inorganics Paints Pharmaceuticals Adhesives Sealants and Fibers Petrochemical facilities Paper Mills Food Processing with Anhydrous Ammonia over

the TQ

Industries that Process Chemicals Such As:Industries that Process Chemicals Such As: Industrial Organics & InorganicsIndustrial Organics & Inorganics PaintsPaints PharmaceuticalsPharmaceuticals AdhesivesAdhesives Sealants and FibersSealants and Fibers Petrochemical facilitiesPetrochemical facilities Paper MillsPaper Mills Food Processing with Anhydrous Ammonia over Food Processing with Anhydrous Ammonia over

the TQthe TQ

ExclusionsExclusions

1910.119(a)(1)(ii)(A)1910.119(a)(1)(ii)(A)1910.119(a)(1)(ii)(A)

There are ExclusionsThere are Exclusions

An employer is exempt from the requirements of PSM when:

A threshold quantity of flammable liquids is stored in atmospheric tanks or transferred without the benefit of chilling or refrigeration

Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling), If such fuels are not a part of a process containing

another highly hazardous chemical covered by this standard

An employer is exempt from the requirements of PSM An employer is exempt from the requirements of PSM when:when:

A threshold quantity of flammable liquids is stored in A threshold quantity of flammable liquids is stored in atmospheric tanks or transferred without the benefit of atmospheric tanks or transferred without the benefit of chilling or refrigeration chilling or refrigeration

Hydrocarbon fuels used solely for workplace Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling), heating, gasoline for vehicle refueling), If such fuels are not a part of a process containing If such fuels are not a part of a process containing

another highly hazardous chemical covered by this another highly hazardous chemical covered by this standardstandard

Retail facilities;

Oil or gas well drilling or

servicing operations; or,

Normally unoccupied

remote facilities

Retail facilities;Retail facilities;

Oil or gas well drilling or Oil or gas well drilling or

servicing operations; or,servicing operations; or,

Normally unoccupied Normally unoccupied

remote facilitiesremote facilities

There are ExclusionsThere are Exclusions

DefinitionsDefinitions

1910.119(b)1910.119(b)1910.119(b)

DefinitionsDefinitions

Atmospheric tank means a storage tank which has been designed to operate at pressures from atmospheric through 0.5 p.s.i.g. (pounds per square inch gauge, 3.45 Kpa).

Boiling point means the boiling point of a liquid at a pressure of 14.7 pounds per square inch absolute (p.s.i.a.) (760 mm.).

Catastrophic release means a major uncontrolled emission, fire, or explosion, involving one or more highly hazardous chemicals, that presents serious danger to employees in the workplace.

Atmospheric tank means a storage tank which has been designed to operate at pressures from atmospheric through 0.5 p.s.i.g. (pounds per square inch gauge, 3.45 Kpa).

Boiling point means the boiling point of a liquid at a pressure of 14.7 pounds per square inch absolute (p.s.i.a.) (760 mm.).

Catastrophic release means a major uncontrolled emission, fire, or explosion, involving one or more highly hazardous chemicals, that presents serious danger to employees in the workplace.

DefinitionsDefinitions Facility means the buildings, containers or equipment

which contain a process. Highly hazardous chemical means a substance

possessing toxic, reactive, flammable, or explosive properties and specified by paragraph (a)(1) of this section.

Hot work means work involving electric or gas welding, cutting, brazing, or similar flame or spark-producing operations.

Normally unoccupied remote facility means a facility which is operated, maintained or serviced by employees who visit the facility only periodically to check its operation and to perform necessary operating or maintenance tasks. No employees are permanently stationed at the facility.

Facility means the buildings, containers or equipment Facility means the buildings, containers or equipment which contain a process. which contain a process.

Highly hazardous chemical means a substance Highly hazardous chemical means a substance possessing toxic, reactive, flammable, or explosive possessing toxic, reactive, flammable, or explosive properties and specified by paragraph (a)(1) of this properties and specified by paragraph (a)(1) of this section. section.

Hot work meansHot work means work involving electric or gas work involving electric or gas welding, cutting, brazing, or similar flame or sparkwelding, cutting, brazing, or similar flame or spark--producing operations. producing operations.

Normally unoccupied remote facility means a facility Normally unoccupied remote facility means a facility which is operated, maintained or serviced by which is operated, maintained or serviced by employees who visit the facility only periodicallemployees who visit the facility only periodically to y to check its operation and to perform necessary check its operation and to perform necessary operating or maintenance tasks. No employees are operating or maintenance tasks. No employees are permanently stationed at the facility.permanently stationed at the facility.

DefinitionsDefinitions Process means any activity involving a highly

hazardous chemical including any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or combination of these activities. For purposes of this definition, any group of vessels which are interconnected and separate vessels which are located such that a highly hazardous chemical could be involved in a potential release shall be considered a single process.

“Replacement in kind" means a replacement which satisfies the design specification.

"Trade secret" means any confidential formula, pattern, process, device, information or compilation of information that is used in an employer's business

Process means any activity involving a highly Process means any activity involving a highly hazardous chemical including any use, storage, hazardous chemical including any use, storage, manufacturing, handling, or the onmanufacturing, handling, or the on--site movement of site movement of such chemicals, or combination of these activities. such chemicals, or combination of these activities. For purposes of this definition, any group of vessels For purposes of this definition, any group of vessels whichwhich are interconnected and separate vessels which are interconnected and separate vessels which are located such that a highly hazardous chemical are located such that a highly hazardous chemical could be involved in a potential release shall be could be involved in a potential release shall be considered a single process.considered a single process.

““Replacement in kind" means a replacement which Replacement in kind" means a replacement which satisfies the design specification.satisfies the design specification.

"Trade secret" means any confidential formula, "Trade secret" means any confidential formula, pattern, process, device, information or compilation of pattern, process, device, information or compilation of information that is used in an employer's businessinformation that is used in an employer's business

Employee ParticipationEmployee Participation

1910.119(c)1910.119(c)1910.119(c)

Now that we are required to comply, then what? First…Now that we are required to comply, then what? First… Form a Team in

Your Company, i.e.. Process Engineers Operators Safety Maintenance Management Consultants

Form a Team in Form a Team in Your Company, i.e..Your Company, i.e.. Process EngineersProcess Engineers OperatorsOperators SafetySafety MaintenanceMaintenance ManagementManagement ConsultantsConsultants

Remember…You Can’t Do it Alone!

Form a Plan, Determine: Responsibilities Duties Reporting Document Control Progress Reports Tracking Changes

Form a Plan, Form a Plan, Determine:Determine: ResponsibilitiesResponsibilities DutiesDuties ReportingReporting Document ControlDocument Control Progress ReportsProgress Reports Tracking ChangesTracking Changes

Now that we are required to comply, then what? Second…Now that we are required to comply, then what? Second…

Now that we are required to comply, then what? Third…Review Scope of the Project:

Now that we are required to comply, then what? Third…Review Scope of the Project: Application Exclusions Definitions Employee Participation Hazards of the Process Toxicity Technology of the

Process Equipment in the

Process Mechanical Integrity Inspection & Testing Quality Assurance

ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the Technology of the

ProcessProcess Equipment in the Equipment in the

ProcessProcess Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance

Process Hazard Analysis

Management of Change Operating Procedures Safe Work Practices Training Contractor

Management Emergency Planning &

Response Incident Investigation Compliance Audits Trade Secrets

Process Hazard Process Hazard AnalysisAnalysis

Management of ChangeManagement of Change Operating ProceduresOperating Procedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor Contractor

ManagementManagement Emergency Planning & Emergency Planning &

ResponseResponse Incident InvestigationIncident Investigation Compliance AuditsCompliance Audits Trade SecretsTrade Secrets

In the Next Session, we will Begin to Explore Each Element of the Standard and What is Required to Comply

In the Next Session, In the Next Session, we will Begin to we will Begin to Explore Each Explore Each Element of the Element of the Standard and What Standard and What is Required to is Required to ComplyComply

Now that we are required to comply, then what? …Let’s BeginNow that we are required to comply, then what? …Let’s Begin