527 CMR 33Part II

527 CMR 33Part II

Fall/Winter 2012

Division of Fire Safety

In depth look and review of Category IV and V processes and requirements

AGENDAAGENDA

• Background Information– Causes of Fire/Explosions

– Protection of Fire/Explosions

• Review of CMR 33 – Phase 1 • Review Hazard Analysis• Review OSHA PSM

– Simple questions to determine understanding

• Review Limited Process Safety Management

• Background Information– Causes of Fire/Explosions

– Protection of Fire/Explosions

• Review of CMR 33 – Phase 1 • Review Hazard Analysis• Review OSHA PSM

– Simple questions to determine understanding

• Review Limited Process Safety Management

Background InformationBackground Information

Causes of Fire and ExplosionsCauses of Fire and Explosions

• Typical causes– Electrical

• High Resistance

• Impaired Cooling

– Static Electricity– Improper electrical equipment

• Typical causes– Electrical

• High Resistance

• Impaired Cooling

– Static Electricity– Improper electrical equipment

Causes of Fire and ExplosionsCauses of Fire and Explosions

• Causes of Fire and Explosions– Hot Surfaces

• Friction

• Heating

– Hot Work– Spontaneous Ignition

• Causes of Fire and Explosions– Hot Surfaces

• Friction

• Heating

– Hot Work– Spontaneous Ignition

Fire and Explosion ProtectionFire and Explosion Protection

– Construction and location– Occupancy– Protection

• Arrangement of supplies• Drainage

– Equipment and Process• Safety equipment, interlocks

– Operation and Maintenance

– Construction and location– Occupancy– Protection

• Arrangement of supplies• Drainage

– Equipment and Process• Safety equipment, interlocks

– Operation and Maintenance

527 CMR 33527 CMR 33

ReviewReview

PurposePurpose“527 CMR 33.00 creates local fire department

permit requirements for facilities engaging in the processing of certain hazardous materials. The standards are based on a classification system

and requires disclosure and evaluation regarding a facility’s hazardous material operations.”

GOALS:•Protect public and emergency response personnel

•Enhance awareness of emergency response personnel to hazards present

•Establish permitting requirements

“527 CMR 33.00 creates local fire department permit requirements for facilities engaging in the processing of certain hazardous materials. The standards are based on a classification system

and requires disclosure and evaluation regarding a facility’s hazardous material operations.”

GOALS:•Protect public and emergency response personnel

•Enhance awareness of emergency response personnel to hazards present

•Establish permitting requirements

OSHA vs. EPA vs. 527 CMROSHA vs. EPA vs. 527 CMR

Process Safety Regulations appear to be an area of confusion

Goal of interface– 527 CMR refers to OSHA and EPA Process Safety

Requirements – no additional MASS. PSM requirements

– It does requires a permit and notification of compliance with these programs.

– 527 regulates processes not covered by OSHA/EPA

Process Safety Regulations appear to be an area of confusion

Goal of interface– 527 CMR refers to OSHA and EPA Process Safety

Requirements – no additional MASS. PSM requirements

– It does requires a permit and notification of compliance with these programs.

– 527 regulates processes not covered by OSHA/EPA

OSHA vs. EPA vs. 527 CMROSHA vs. EPA vs. 527 CMR

Clean air act required both OSHA and EPA to issue chemical process safety standards

1990 – 1992 Federal legislation to promote PSM following Bhopal, India (1984 incident)

OSHA PSM Standard (1992 to present) – no changes to OSHA PSM requirements

Thousands of new chemicals/year

Clean air act required both OSHA and EPA to issue chemical process safety standards

1990 – 1992 Federal legislation to promote PSM following Bhopal, India (1984 incident)

OSHA PSM Standard (1992 to present) – no changes to OSHA PSM requirements

Thousands of new chemicals/year

OSHA vs. EPA vs. 527 CMROSHA vs. EPA vs. 527 CMR

OSHA’s PSM Standard 29 CFR 1910.119

Protects employees in the workplace from releases of highly hazardous chemicals

EPA’s Chemical Accident Prevention Provisions 40 CFR 68 - RMP Rule (Risk Management Plan)

EPA’s parallel regulation to OSHA’s PSM standard

Protects the public and the environment from the offsite effects of accidental chemical releases.

OSHA’s PSM Standard 29 CFR 1910.119

Protects employees in the workplace from releases of highly hazardous chemicals

EPA’s Chemical Accident Prevention Provisions 40 CFR 68 - RMP Rule (Risk Management Plan)

EPA’s parallel regulation to OSHA’s PSM standard

Protects the public and the environment from the offsite effects of accidental chemical releases.

OSHA vs. EPA vs. 527 CMROSHA vs. EPA vs. 527 CMR

Contains a list of applicable chemicals– Flammables, toxic explosives

Threshold quantities (TQs) for inventory in a single process

Approach is difficult for the average fire inspector– Why 527 CMR broke from OSHA/EPA approach

Contains a list of applicable chemicals– Flammables, toxic explosives

Threshold quantities (TQs) for inventory in a single process

Approach is difficult for the average fire inspector– Why 527 CMR broke from OSHA/EPA approach

OSHA vs. EPA vs. 527 CMROSHA vs. EPA vs. 527 CMR

OSHA/EPA Applicability– Review their list of chemicals– Review minimum thresholds

• Vary amongst the chemicals

• Determine overall threshold– Includes possibly: piping, storage arrangements, multiple

vessels

• Difficult to determine applicability unless you are an expert in the area

OSHA/EPA Applicability– Review their list of chemicals– Review minimum thresholds

• Vary amongst the chemicals

• Determine overall threshold– Includes possibly: piping, storage arrangements, multiple

vessels

• Difficult to determine applicability unless you are an expert in the area

OSHA vs. EPA vs. 527 CMROSHA vs. EPA vs. 527 CMR

OSHA PSM Standard– 14 elements to the program

EPA RMP Standard- Has a tiered approach- Hazard Assessment- Prevention Program Emergency Response

527 CMR Cat. 4 Limited Process Safety Program– Thumb size approach for the fire service– About 7 elements of OSHA PSM Standard

OSHA PSM Standard– 14 elements to the program

EPA RMP Standard- Has a tiered approach- Hazard Assessment- Prevention Program Emergency Response

527 CMR Cat. 4 Limited Process Safety Program– Thumb size approach for the fire service– About 7 elements of OSHA PSM Standard

ApplicabilityApplicabilityApplicable for New and Existing facilities that process hazardous materials – physical or health hazards as defined by 780 CMR and 527 CMR definitions

– Physical Processes (Unit Operations)• Heating, cooling, mixing, distilling, compressing, pressurizing,

etc.– Chemical Reaction Processes

• Polymerization, oxidation, reduction, etc.– Preparation, separation, combination, purification, etc. – NOT storage or waste collection

Applicable for New and Existing facilities that process hazardous materials – physical or health hazards as defined by 780 CMR and 527 CMR definitions

– Physical Processes (Unit Operations)• Heating, cooling, mixing, distilling, compressing, pressurizing,

etc.– Chemical Reaction Processes

• Polymerization, oxidation, reduction, etc.– Preparation, separation, combination, purification, etc. – NOT storage or waste collection

ApplicabilityApplicabilityPhysical hazards

– Combustible or flammable liquid– Compressed, cryogenic or flammable gas– Flammable solid– Oxidizer or organic peroxide– Pyrophoric– Unstable (reactive)– Water-reactive

Health hazards– Toxic or highly toxic– Corrosive (damage to living tissue)

All hazards specifically defined in 527 CMR 33.02

Closes the OSHA loophole on certain classes

Physical hazards– Combustible or flammable liquid– Compressed, cryogenic or flammable gas– Flammable solid– Oxidizer or organic peroxide– Pyrophoric– Unstable (reactive)– Water-reactive

Health hazards– Toxic or highly toxic– Corrosive (damage to living tissue)

All hazards specifically defined in 527 CMR 33.02

Closes the OSHA loophole on certain classes

ExclusionsExclusionsListed in 527 CMR 33.01(3)

Many listed – must review to determineapplicability. Some are:

- Retail of pre-mixed solutions- Water treatment facilities (potable / waste)- Atmospheric vessels storing materials that are below normal boiling point without heating or cooling- Hazardous materials with a hazard rating of 2 or less per NFPA 704 (e.g. irritants)

Listed in 527 CMR 33.01(3)

Many listed – must review to determineapplicability. Some are:

- Retail of pre-mixed solutions- Water treatment facilities (potable / waste)- Atmospheric vessels storing materials that are below normal boiling point without heating or cooling- Hazardous materials with a hazard rating of 2 or less per NFPA 704 (e.g. irritants)

Intent of 527 CMR 33Intent of 527 CMR 33

Intent of RegulationIntent of Regulation• Processing

– Sequence of operations– Physical

• Heating, cooling, mixing, distilling

– Chemical• Polymerization, oxidation, reduction

• Processing– Sequence of operations– Physical

• Heating, cooling, mixing, distilling

– Chemical• Polymerization, oxidation, reduction

Intent of RegulationIntent of Regulation• Not intended to cover:

– Materials that are added to maintain a condition (cooling tower, boiler, chiller)

– Use of single products– Storage of products– Hazardous materials placed on rags for

cleaning– Mixing in vehicles covered by DOT

• Not intended to cover:– Materials that are added to maintain a

condition (cooling tower, boiler, chiller)– Use of single products– Storage of products– Hazardous materials placed on rags for

cleaning– Mixing in vehicles covered by DOT

FAQFAQ

BFPR is receiving information requests from the industry.

FAQ will be posted on the DFS website.– Many in regards to understanding what is

covered and not covered.

BFPR is receiving information requests from the industry.

FAQ will be posted on the DFS website.– Many in regards to understanding what is

covered and not covered.

527 CMR 33527 CMR 33

Review Specific PointsReview Specific Points

Vessel DefinitionVessel Definition

Per 527 CMR 33.02:

A vessel is the container in which partial or the actual process takes place.

Examples:- Beakers - Reactor kettles- Pails - Pipe reactors- Drums

The size of a vessel is its capacity.

Per 527 CMR 33.02:

A vessel is the container in which partial or the actual process takes place.

Examples:- Beakers - Reactor kettles- Pails - Pipe reactors- Drums

The size of a vessel is its capacity.

Process ClassificationProcess ClassificationCategory 1: Vessel capacity ≤ 2.5 galCategory 2: Vessel capacity ≤ 60 galCategory 3: Vessel capacity ≤ 300 gal OR Group

H occupancyCategory 4: Vessel capacity > 300 gal and not

Category 5Category 5: A Process which involves or produces

Hazardous Material which occurs in a vessel with a capacity that is equal or in excess of threshold quantities stated in 29 CFR 1910.119 or 40 CFR Part 68 and regulated by such standard.

Category 1: Vessel capacity ≤ 2.5 galCategory 2: Vessel capacity ≤ 60 galCategory 3: Vessel capacity ≤ 300 gal OR Group

H occupancyCategory 4: Vessel capacity > 300 gal and not

Category 5Category 5: A Process which involves or produces

Hazardous Material which occurs in a vessel with a capacity that is equal or in excess of threshold quantities stated in 29 CFR 1910.119 or 40 CFR Part 68 and regulated by such standard.

Process ClassificationProcess Classification

Most facilities will fall under either Category 3 or Category 4:

- Category 3: Vessel capacity ≤ 300 gal OR Group H

occupancy

- Category 4:Vessel capacity > 300 gallons and not covered by OSHA PSM or EPA RMP

Most facilities will fall under either Category 3 or Category 4:

- Category 3: Vessel capacity ≤ 300 gal OR Group H

occupancy

- Category 4:Vessel capacity > 300 gallons and not covered by OSHA PSM or EPA RMP

Process ClassificationProcess Classification

Multiple Processes may be present in a single building; category requirements apply separatelyMultiple Processes may be present in a single facility – one permitPermit are covered by MGL 148 sec. 10A

$25 or $50 with approval

Initial implementation would have multiple permits. After full implementation need to combine into 1 permit.

Multiple Processes may be present in a single building; category requirements apply separatelyMultiple Processes may be present in a single facility – one permitPermit are covered by MGL 148 sec. 10A

$25 or $50 with approval

Initial implementation would have multiple permits. After full implementation need to combine into 1 permit.

527 CMR 33 Covers527 CMR 33 Covers

527 CMR 33.00:– Looks at it from the processes at the facility,

not the facility with processes

– A facility (group of buildings) will generally have multiple processes

– Each process will comply with CMR 33.

– It does not default to the highest for the facility

527 CMR 33.00:– Looks at it from the processes at the facility,

not the facility with processes

– A facility (group of buildings) will generally have multiple processes

– Each process will comply with CMR 33.

– It does not default to the highest for the facility

527 CMR 33 Permits527 CMR 33 Permits

During phase-in approach:– Facility can have multiple permits– Based on processes at the facility– Based on the dates of compliance

After phase-in approach:– Highly recommend – consolidation of permits

into a single permit for all of the processes at the facility.

During phase-in approach:– Facility can have multiple permits– Based on processes at the facility– Based on the dates of compliance

After phase-in approach:– Highly recommend – consolidation of permits

into a single permit for all of the processes at the facility.

Permit RequirementsPermit RequirementsCategory 1 – no permit, but facility is responsible

for compliance with the requirements

Categories 2-5- New permit issued by FD, renewed annually (527 CMR 33.04(1)); SEPARATE FROM STORAGE PERMIT!

- FD can deny permit in writing if protection measures deemed insufficient (527 CMR 33.04(4b))

- FD can require a 3rd party Competent Professional evaluation following the denial for Category 3 and Category 4 facility (527 CMR 33.04(4c))

Category 1 – no permit, but facility is responsible for compliance with the requirements

Categories 2-5- New permit issued by FD, renewed annually (527 CMR 33.04(1)); SEPARATE FROM STORAGE PERMIT!

- FD can deny permit in writing if protection measures deemed insufficient (527 CMR 33.04(4b))

- FD can require a 3rd party Competent Professional evaluation following the denial for Category 3 and Category 4 facility (527 CMR 33.04(4c))

Competent ProfessionalCompetent ProfessionalPer 527 CMR 33.02:

A Competent Professional is a person who based upon education, training, skill, experience or professional licensure or a combination thereof, has a specialized knowledge beyond that of an average person about risk assessment, process hazard analysis, and/or PSM management principles for the process or processes being evaluated.

Per 527 CMR 33.02:

A Competent Professional is a person who based upon education, training, skill, experience or professional licensure or a combination thereof, has a specialized knowledge beyond that of an average person about risk assessment, process hazard analysis, and/or PSM management principles for the process or processes being evaluated.

Permit RequirementsPermit RequirementsPermit deadlines:

– Category 5 by January 1, 2013– Category 4 by June 1, 2013– Category 2 & 3 by January 1, 2014

New permit application required if Hazard Category increases.

Trade secrets may be excluded from public records in accordance with 527 CMR 33.08.

Permit deadlines:– Category 5 by January 1, 2013– Category 4 by June 1, 2013– Category 2 & 3 by January 1, 2014

New permit application required if Hazard Category increases.

Trade secrets may be excluded from public records in accordance with 527 CMR 33.08.

Documentation RequirementsDocumentation RequirementsRequired documentation, policies and practices increase with category levels.

Must comply with requirements for each lower category level, as applicable.

Required documentation, policies and practices increase with category levels.

Must comply with requirements for each lower category level, as applicable.

DocumentationDocumentationFacilities complying with typical “process safety management” will have many policies and procedures.

– Goal is to review any necessary items on site– Policies and procedures can overwhelm a

department– Best rule: ask questions and see what

employees know about a process

Facilities complying with typical “process safety management” will have many policies and procedures.

– Goal is to review any necessary items on site– Policies and procedures can overwhelm a

department– Best rule: ask questions and see what

employees know about a process

Category 1 Requirements(Vessel Capacity ≤ 2.5 gal)

Category 1 Requirements(Vessel Capacity ≤ 2.5 gal)

Compliance with:● OSHA 1910.1200 (Hazard communication to

employees)● OSHA 1910.1450 (Occupational exposure to

hazardous chemicals in labs, if applicable)● 527 CMR 14.00 (Flammable gases, liquids, solids)● 527 CMR 33.06 (Emergency Response Plan)

Compliance with:● OSHA 1910.1200 (Hazard communication to

employees)● OSHA 1910.1450 (Occupational exposure to

hazardous chemicals in labs, if applicable)● 527 CMR 14.00 (Flammable gases, liquids, solids)● 527 CMR 33.06 (Emergency Response Plan)

Category 2 Requirements(Vessel Capacity ≤ 60 gal)

Category 2 Requirements(Vessel Capacity ≤ 60 gal)

Compliance with:● All requirements of Category 1● Permit per 527 CMR 33.04

Compliance with:● All requirements of Category 1● Permit per 527 CMR 33.04

Category 3 Requirements(Vessel Capacity ≤ 300 gal OR Group H Occupancy)

Category 3 Requirements(Vessel Capacity ≤ 300 gal OR Group H Occupancy)

For each process, comply with:● All requirements of Category 2● Category 3 Hazard Evaluation

o Implement process safety controls as identified in hazard evaluation

o Ensure hazard evaluation modified prior to each process change

● Potential third party review if permit is rejected in writing

● Post-Incident Analysis per 527 CMR 33.07

For each process, comply with:● All requirements of Category 2● Category 3 Hazard Evaluation

o Implement process safety controls as identified in hazard evaluation

o Ensure hazard evaluation modified prior to each process change

● Potential third party review if permit is rejected in writing

● Post-Incident Analysis per 527 CMR 33.07

Required for all Category 3 (and 4) processes:

- Written evaluation to identify hazards including adjacent vessels

- Determine required preventive, protective and safety control measures

- Conform to good engineering practice and safe work practice

Required for all Category 3 (and 4) processes:

- Written evaluation to identify hazards including adjacent vessels

- Determine required preventive, protective and safety control measures

- Conform to good engineering practice and safe work practice

Category 3 Hazard Evaluation(Vessel Capacity ≤ 300 gal OR Group H Occupancy)

Category 3 Hazard Evaluation(Vessel Capacity ≤ 300 gal OR Group H Occupancy)

Per 527 CMR 33.02:

Category 3 Hazard Evaluation: A written evaluation performed or procedure conducted to identify hazards, including adjacent vessels that contain hazardous materials, and determine the required preventive, protective, and safety control measures in conformance with recognized and generally accepted good engineering and safe work practices associated with a particular process or condition and the facility wherein such process or condition is taking place.

Per 527 CMR 33.02:

Category 3 Hazard Evaluation: A written evaluation performed or procedure conducted to identify hazards, including adjacent vessels that contain hazardous materials, and determine the required preventive, protective, and safety control measures in conformance with recognized and generally accepted good engineering and safe work practices associated with a particular process or condition and the facility wherein such process or condition is taking place.

Category 3 Hazard EvaluationCategory 3 Hazard Evaluation

A written evaluation (Category 4 Limited Process Safety Program) to ensure compliance with:

● Process informationo MSDS, P&ID, process control safety alarms, safety relief

valves● Facility suitability

o Building code compliance, electrical hazard classification, ventilation design, secondary containment / spill control, fire alarm / fire protection

● Process hazard safety analysis (FMEA, what-if analysis, HAZOP)● Written procedures for startup, shutdown, routine operating /

maintenance, emergency response measures● Training program for employees and contractors● Records management protocol including management of change● Internal review every 3 years

A written evaluation (Category 4 Limited Process Safety Program) to ensure compliance with:

● Process informationo MSDS, P&ID, process control safety alarms, safety relief

valves● Facility suitability

o Building code compliance, electrical hazard classification, ventilation design, secondary containment / spill control, fire alarm / fire protection

● Process hazard safety analysis (FMEA, what-if analysis, HAZOP)● Written procedures for startup, shutdown, routine operating /

maintenance, emergency response measures● Training program for employees and contractors● Records management protocol including management of change● Internal review every 3 years

Category 4 Requirements(Vessel Capacity > 300 gal and not Category 5)

Category 4 Requirements(Vessel Capacity > 300 gal and not Category 5)

Category 4 – Facility SuitabilityCategory 4 – Facility SuitabilityBuilding Code Compliance

- Height and area, construction type- Control Area layout and separation - Group H occupancy classification and location- Exhaust separation and routing- Fire suppression and alarm systems- Means of egress

Difficulties in facilities with mission creep- Changed process, vessels, quantities without benefit of a building permit

Building Code Compliance- Height and area, construction type- Control Area layout and separation - Group H occupancy classification and location- Exhaust separation and routing- Fire suppression and alarm systems- Means of egress

Difficulties in facilities with mission creep- Changed process, vessels, quantities without benefit of a building permit

High Hazard Features:– Explosion control– Spill control, secondary containment, drainage for

sprinkler discharge– Monitor controls, standby/e-power, haz-mat alarm

system– Smoke and heat venting for >15,000 sq.ft. areas– Fire detection

Review to code at time of construction, not new code.

High Hazard Features:– Explosion control– Spill control, secondary containment, drainage for

sprinkler discharge– Monitor controls, standby/e-power, haz-mat alarm

system– Smoke and heat venting for >15,000 sq.ft. areas– Fire detection

Review to code at time of construction, not new code.

Category 4 – Facility SuitabilityCategory 4 – Facility Suitability

Electrical Classification:• Massachusetts Electrical Code - amended• NFPA 70 (2011) – National Electrical Code• Article 500 – hazardous locations

– Class I – flammable gases and vapors– Class II – combustible dusts– Division 1 – hazard under normal operation– Division 2 – hazard due to spill, leak, etc– Class I Groups – A (acetylene), B (hydrogen), C (ethylene),

D (propane)– Class II Groups – E (aluminum), F (carbon black), G

(wood)

Electrical Classification:• Massachusetts Electrical Code - amended• NFPA 70 (2011) – National Electrical Code• Article 500 – hazardous locations

– Class I – flammable gases and vapors– Class II – combustible dusts– Division 1 – hazard under normal operation– Division 2 – hazard due to spill, leak, etc– Class I Groups – A (acetylene), B (hydrogen), C (ethylene),

D (propane)– Class II Groups – E (aluminum), F (carbon black), G

(wood)

Category 4 – Facility SuitabilityCategory 4 – Facility Suitability

Good Engineering/Safe Work Practices

Good Engineering/Safe Work Practices

American Institute of Chemical Engineers (AIChE)■ Example: ….result in a safe, operable, and cost effective process...….

The development of such instincts requires experience, which is frequently based on failures…..means for development professionals to discuss experiences in the hope that, collectively, we can refine our predictive abilities and repeat good habits while rejecting bad ones.

Building Codes■ High Hazard Use Groups

National Consensus Standards■ NFPA standards

American Institute of Chemical Engineers (AIChE)■ Example: ….result in a safe, operable, and cost effective process...….

The development of such instincts requires experience, which is frequently based on failures…..means for development professionals to discuss experiences in the hope that, collectively, we can refine our predictive abilities and repeat good habits while rejecting bad ones.

Building Codes■ High Hazard Use Groups

National Consensus Standards■ NFPA standards

Category 5 Requirements(Vessel Contains Chemical Exceeding Threshold Stated in 29

CFR 1910.119 or 40 CFR part 68 )

Category 5 Requirements(Vessel Contains Chemical Exceeding Threshold Stated in 29

CFR 1910.119 or 40 CFR part 68 )

Compliance with:■ Emergency Response Plan per 527 CMR 33.06● Self-certify compliance with 29 CFR 1910.119

(OSHA PSM HHM) or 40 CFR Part 68 (US EPA CAPP)

Compliance with:■ Emergency Response Plan per 527 CMR 33.06● Self-certify compliance with 29 CFR 1910.119

(OSHA PSM HHM) or 40 CFR Part 68 (US EPA CAPP)

Example Chemicals & Threshold Quantities from 29 CFR 1910.119Chemical Name Threshold Quantity (lbs)

Chlorine 1500Formaldehyde (Formalin) 1000

Hydrochloric Acid, Anhydrous 5000Hydrofluoric Acid, Anhydrous 1000

Hydrogen Peroxide (≥52% by weight) 7500Nitric Acid (≥94.5% by weight) 500

Emergency Response PlanningEmergency Response PlanningApplicable to all categories

■ Complexity increases by category

Submitted to local FD; updates to FD within 2 weeks

Identify emergency coordinator to be on-site within 1 hour of emergency

Facility floor plan locating hazardous materials and emergency equipment

Applicable to all categories■ Complexity increases by category

Submitted to local FD; updates to FD within 2 weeks

Identify emergency coordinator to be on-site within 1 hour of emergency

Facility floor plan locating hazardous materials and emergency equipment

Emergency Response PlanningEmergency Response PlanningEstablish protocol with FD for equipment/process shutdown where loss of control poses a risk to the public

Pre-planning important:■ Some cases may require special shutdowns

procedures. Improper shutdown can expose first responders and adjacent areas to catastrophic incidents

Establish protocol with FD for equipment/process shutdown where loss of control poses a risk to the public

Pre-planning important:■ Some cases may require special shutdowns

procedures. Improper shutdown can expose first responders and adjacent areas to catastrophic incidents

Post-Incident AnalysisPost-Incident AnalysisApplicable to Categories 3 through 5

Report initiated within 48 hours of FD or EMS response, or release of hazardous materials

Report completed within 45 days

Report to include:● Summary of cause and contributing factors● Recommendations to prevent recurrence● Dates of implementation of recommendations/corrective actions● Reassessment of facility/process category

- Apply for new permit if necessary

Applicable to Categories 3 through 5

Report initiated within 48 hours of FD or EMS response, or release of hazardous materials

Report completed within 45 days

Report to include:● Summary of cause and contributing factors● Recommendations to prevent recurrence● Dates of implementation of recommendations/corrective actions● Reassessment of facility/process category

- Apply for new permit if necessary

Public RecordsPublic Records

527 CMR 33.08 – Trade Secrets– Goal is not to require submission of “extra”

paperwork. FD encouraged to review on site.

Must be aware of public records laws that may “trump” this regulation.

527 CMR 33.08 – Trade Secrets– Goal is not to require submission of “extra”

paperwork. FD encouraged to review on site.

Must be aware of public records laws that may “trump” this regulation.

Quick ReviewQuick Review

Process ClassificationProcess Classification

• Category 1: Vessel capacity ≤ 2.5 gal• Category 2: Vessel capacity ≤ 60 gal• Category 3: Vessel capacity ≤ 300 gal OR Group H

occupancy• Category 4: Vessel capacity > 300 gal and not Category 5• Category 5:

– Vessel capacity exceeds chemical threshold quantity of • 29 CFR 1910.119 (OSHA Process Safety

Management for Highly Hazardous Materials) or • 40 CFR part 68 (US EPA Chemical Accident

Prevention Protocol)• Multiple Processes may be present in a single building;

category requirements apply separately• Initial implementation would have multiple permits. After

full implementation need to combine into 1 permit.

• Category 1: Vessel capacity ≤ 2.5 gal• Category 2: Vessel capacity ≤ 60 gal• Category 3: Vessel capacity ≤ 300 gal OR Group H

occupancy• Category 4: Vessel capacity > 300 gal and not Category 5• Category 5:

– Vessel capacity exceeds chemical threshold quantity of • 29 CFR 1910.119 (OSHA Process Safety

Management for Highly Hazardous Materials) or • 40 CFR part 68 (US EPA Chemical Accident

Prevention Protocol)• Multiple Processes may be present in a single building;

category requirements apply separately• Initial implementation would have multiple permits. After

full implementation need to combine into 1 permit.

Permit RequirementsPermit Requirements

• Permit deadlines– Category 5 by January 1, 2013– Category 4 by June 1, 2013– Category 2 & 3 by January 1, 2014

• New permit application required if Hazard Category increases

• Permit deadlines– Category 5 by January 1, 2013– Category 4 by June 1, 2013– Category 2 & 3 by January 1, 2014

• New permit application required if Hazard Category increases

CMR 33CMR 33• Round 1

– Category V processes– January 1, 2013– OSHA covered processes

• Round 2– Category IV processes

• Reduced PSM system

• Round 1– Category V processes– January 1, 2013– OSHA covered processes

• Round 2– Category IV processes

• Reduced PSM system

Hazard AnalysisHazard Analysis

• Category 3 Hazard Evaluation: A written evaluation performed or procedure conducted to identify hazards, including adjacent vessels that contain hazardous materials, and determine the required preventive, protective, and safety control measures in conformance with recognized and generally accepted good engineering and safe work practices associated with a particular process or condition and the facility wherein such process or condition is taking place.

• Category 3 Hazard Evaluation: A written evaluation performed or procedure conducted to identify hazards, including adjacent vessels that contain hazardous materials, and determine the required preventive, protective, and safety control measures in conformance with recognized and generally accepted good engineering and safe work practices associated with a particular process or condition and the facility wherein such process or condition is taking place.

Hazard AnalysisHazard Analysis

• Identify hazards– How does one identify hazards?– What are these?

• Identify hazards– How does one identify hazards?– What are these?

 Incoming Materials 

Processing 

 Packaging 

 Storage 

Distribution 

 Incoming Materials 

Processing 

 Packaging 

 Storage 

Distribution 

Identify potential hazards introduced, controlled or enhanced at this step (1)

What preventative measures can be applied to prevent the significant hazards?

Critical Limits for each Preventive Measure

Identify potential hazards introduced, controlled or enhanced at this step (1)

What preventative measures can be applied to prevent the significant hazards?

Critical Limits for each Preventive Measure

Hazard AnalysisHazard Analysis

• Determine the required preventive, protective, and safety control measures in conformance with recognized and generally accepted good engineering and safe work practices– Sprinkler Protection– High temperature limit switch– Alarms– Explosion Venting

• Determine the required preventive, protective, and safety control measures in conformance with recognized and generally accepted good engineering and safe work practices– Sprinkler Protection– High temperature limit switch– Alarms– Explosion Venting

OSHA PSM StandardOSHA PSM Standard

1. Review 14 components

2. Discuss components

3. Look at questions to “get a feel” for compliance

1. Review 14 components

2. Discuss components

3. Look at questions to “get a feel” for compliance

OSHA PSM StandardOSHA PSM Standard

• Fourteen (14) Points to PSM Standard1. Employee Participation2. Process Safety Information3. Process Hazard Analysis4. Operating Procedures5. Training6. Contractors7. Pre-Start up Safety Review

• Fourteen (14) Points to PSM Standard1. Employee Participation2. Process Safety Information3. Process Hazard Analysis4. Operating Procedures5. Training6. Contractors7. Pre-Start up Safety Review

OSHA PSM StandardOSHA PSM Standard

• Fourteen (14) Points to PSM Standard8. Mechanical Integrity9. Hot Work Permit10. Management of Change11. Incident Investigation12. Emergency Planning & Response13. Compliance Audit14. Trade Secrets

• Fourteen (14) Points to PSM Standard8. Mechanical Integrity9. Hot Work Permit10. Management of Change11. Incident Investigation12. Emergency Planning & Response13. Compliance Audit14. Trade Secrets

OSHA PSM StandardOSHA PSM Standard

1. Employee Participation- Employers are required to develop a written

plan of action.- Are to consult with employees on

development of PHA & other elements- Are to provide employees with PHA & other

elements

1. Employee Participation- Employers are required to develop a written

plan of action.- Are to consult with employees on

development of PHA & other elements- Are to provide employees with PHA & other

elements

Compliance with Question 1Compliance with Question 1

• Verify written plan

• Pick a piece to verify

• Ask an employee to walk you through the process and concerns/hazards associated with process

• Verify written plan

• Pick a piece to verify

• Ask an employee to walk you through the process and concerns/hazards associated with process

OSHA PSM StandardOSHA PSM Standard

2. Process Safety Information- Written Process Safety Information- Used to identify and understand the hazards

posed by the process.- PSI must include:

- Hazards of chemicals used or produced by process

- Technology of the process

- Equipment used in the process

2. Process Safety Information- Written Process Safety Information- Used to identify and understand the hazards

posed by the process.- PSI must include:

- Hazards of chemicals used or produced by process

- Technology of the process

- Equipment used in the process

OSHA PSM Standard – Part 2OSHA PSM Standard – Part 2

• Possible items– Block flow diagram/Process and Instrumentation

Diagrams

– Process Chemistry

– Safe Upper and lower limits (temperature/pressure/flows, etc..)

– Materials of construction

– Electrical Classifications

– Relief system design and basis

• Possible items– Block flow diagram/Process and Instrumentation

Diagrams

– Process Chemistry

– Safe Upper and lower limits (temperature/pressure/flows, etc..)

– Materials of construction

– Electrical Classifications

– Relief system design and basis

Compliance with Question 2Compliance with Question 2

• Verify MSDS sheets are available for review

• Ask to see block flow diagram

• Ask what the upper/lower temperature/pressures limits

• Ask about electrical classifications

• Verify MSDS sheets are available for review

• Ask to see block flow diagram

• Ask what the upper/lower temperature/pressures limits

• Ask about electrical classifications

OSHA PSM StandardOSHA PSM Standard

3.Process Hazard Analysis– Is to: identify, evaluate and control hazards – What-if; checklist– Hazard and Operability Study (HAZOP)– Failure Mode & Effects Analysi (FMEA)– Fault Tree analysis

3.Process Hazard Analysis– Is to: identify, evaluate and control hazards – What-if; checklist– Hazard and Operability Study (HAZOP)– Failure Mode & Effects Analysi (FMEA)– Fault Tree analysis

OSHA PSM StandardOSHA PSM Standard

3.Process Hazard Analysis– Team approach with expertise in engineering

and process operations.– Establish a system to address teams findings– Every 5 years re-evaluate PHA

3.Process Hazard Analysis– Team approach with expertise in engineering

and process operations.– Establish a system to address teams findings– Every 5 years re-evaluate PHA

Compliance with Question 3Compliance with Question 3

• Ask what method of process hazard analysis was used

• Ask what team members were involved and their specialties

• Ask what was discovered and how they resolved issues

• Ask what method of process hazard analysis was used

• Ask what team members were involved and their specialties

• Ask what was discovered and how they resolved issues

OSHA PSM StandardOSHA PSM Standard

4. Operating Procedures for each phase– Initial Start-up

– Normal Operations

– Temporary Operations

– Normal Shutdown

– Emergency Shutdown• Including conditions which will require emergency shutdown.

– Emergency Operations

– Start-up following emergency shutdown

4. Operating Procedures for each phase– Initial Start-up

– Normal Operations

– Temporary Operations

– Normal Shutdown

– Emergency Shutdown• Including conditions which will require emergency shutdown.

– Emergency Operations

– Start-up following emergency shutdown

OSHA PSM StandardOSHA PSM Standard

4. Operating Procedures continued– Operating limits– Safety and health considerations– Safety systems and their functions

4. Operating Procedures continued– Operating limits– Safety and health considerations– Safety systems and their functions

Compliance with Question 4Compliance with Question 4

• Ask them how they start the process and issues to watch for during start up

• When would they do an emergency shutdown

• How would they do an emergency shutdown

• What are the operating limits of the process• What safety features are on the process

• Ask them how they start the process and issues to watch for during start up

• When would they do an emergency shutdown

• How would they do an emergency shutdown

• What are the operating limits of the process• What safety features are on the process

OSHA PSM StandardOSHA PSM Standard

5. Training– Each employee and each employee before being

involved in a process • Trained in overview of process and operating procedures

– Refresher training • At least every 3 years

– Ascertain each employee has received, understood• Need a record

• Identifies: Employee, date of training, means used to verify

5. Training– Each employee and each employee before being

involved in a process • Trained in overview of process and operating procedures

– Refresher training • At least every 3 years

– Ascertain each employee has received, understood• Need a record

• Identifies: Employee, date of training, means used to verify

Compliance with Question 5Compliance with Question 5

• Ask the employee the last time they had training and in what

• Review records of training and possibly with the specific employee

• Ask the employee the last time they had training and in what

• Review records of training and possibly with the specific employee

OSHA PSM StandardOSHA PSM Standard

6. Contractors– Inform contractors of potential fire/explosion

hazards– Maintain employee injury/illness log &

evaluate safety performance– Contractors shall ensure employees are trained

in fire/explosion hazards– Document they have received and understood

training & document as in item 5.

6. Contractors– Inform contractors of potential fire/explosion

hazards– Maintain employee injury/illness log &

evaluate safety performance– Contractors shall ensure employees are trained

in fire/explosion hazards– Document they have received and understood

training & document as in item 5.

Compliance with Question 6Compliance with Question 6

• Review records of training and possibly with the specific company

• Ask a contractor what the fire/explosion hazards are where they are working

• See if they have an injury/illness log

• Review records of training and possibly with the specific company

• Ask a contractor what the fire/explosion hazards are where they are working

• See if they have an injury/illness log

OSHA PSM StandardOSHA PSM Standard

7. Pre-Start Up Safety Review– For new, modified or change in process safety

information• Verify equipment to design specs.

• Safety, operating, maintenance and emergency procedures are in place

• PHA performed and issues resolved

• Initial/refresher training complete

7. Pre-Start Up Safety Review– For new, modified or change in process safety

information• Verify equipment to design specs.

• Safety, operating, maintenance and emergency procedures are in place

• PHA performed and issues resolved

• Initial/refresher training complete

Compliance with Question 7Compliance with Question 7

• Ask the plant how they handle changes such as, new equipment installations

• Ask how they handle new chemicals – or the last time a new chemical was introduced and what was done to use it

• Ask if they have increased production and how that was handled

• Ask the plant how they handle changes such as, new equipment installations

• Ask how they handle new chemicals – or the last time a new chemical was introduced and what was done to use it

• Ask if they have increased production and how that was handled

OSHA PSM StandardOSHA PSM Standard

8. Mechanical Integrity

• Application areas:– Pressure vessels and storage tanks– Piping systems– Relief and vent designs– Emergency Shutdown systems– Controls (sensors, alarms, interlocks)

8. Mechanical Integrity

• Application areas:– Pressure vessels and storage tanks– Piping systems– Relief and vent designs– Emergency Shutdown systems– Controls (sensors, alarms, interlocks)

OSHA PSM StandardOSHA PSM Standard

8. Mechanical Integrity continued– Implement written procedures to maintain

integrity– Train employee on maintaining systems– Inspections and tests on equipment– Document each inspection and test– Correct deficiencies

8. Mechanical Integrity continued– Implement written procedures to maintain

integrity– Train employee on maintaining systems– Inspections and tests on equipment– Document each inspection and test– Correct deficiencies

Compliance with Question 8Compliance with Question 8• Ask them how often they calibrate gauges,

sensors, controls• How do they know they are up? How do they

track the testing, maintenance of equipment• Ask them to see records of recent calibrations and

see if they are within times specified• Ask them went the pressure vessel are next due

for inspection• Ask them if they have pressure relief vents and

when they are due for replacement

• Ask them how often they calibrate gauges, sensors, controls

• How do they know they are up? How do they track the testing, maintenance of equipment

• Ask them to see records of recent calibrations and see if they are within times specified

• Ask them went the pressure vessel are next due for inspection

• Ask them if they have pressure relief vents and when they are due for replacement

OSHA PSM StandardOSHA PSM Standard

9. Hot Work Permit• Permit required for all Hot Work

– Document all fire prevention/protection requirements have been implemented

– Hot work: cutting/welding, soldering, torches, grinding, etc..

• Note: These requirements are greater than currently covered by 527 CMR 39– Covers only cutting/welding

9. Hot Work Permit• Permit required for all Hot Work

– Document all fire prevention/protection requirements have been implemented

– Hot work: cutting/welding, soldering, torches, grinding, etc..

• Note: These requirements are greater than currently covered by 527 CMR 39– Covers only cutting/welding

OSHA PSM StandardOSHA PSM Standard

10. Management of Change

• Written Procedures to manage changes to:– Process Chemicals– Technology– Equipment– Procedures– Changes to facilities that affect process

10. Management of Change

• Written Procedures to manage changes to:– Process Chemicals– Technology– Equipment– Procedures– Changes to facilities that affect process

OSHA PSM StandardOSHA PSM Standard10. Management of Change continued• Procedures cover at a minimum:

– Technical basis for proposed change– Impact on safety and health– Modifications to operating procedures– Necessary time period for change– Authorization requirements for change

• Employees/Contractors – Prior to start up– Informed of change– Trained on changes

10. Management of Change continued• Procedures cover at a minimum:

– Technical basis for proposed change– Impact on safety and health– Modifications to operating procedures– Necessary time period for change– Authorization requirements for change

• Employees/Contractors – Prior to start up– Informed of change– Trained on changes

Compliance with Question 10Compliance with Question 10

• Who is ultimately responsible to sign off on a change in chemical, pressure, temperature, etc.

• Who ensures the PHA is updated and training has taken place

• What is the communication between the groups

• Who is ultimately responsible to sign off on a change in chemical, pressure, temperature, etc.

• Who ensures the PHA is updated and training has taken place

• What is the communication between the groups

OSHA PSM StandardOSHA PSM Standard

11. Incident Investigation

Employers to investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of hazardous chemical.

To be initiated within 48 hours and include: date (incident/investigation), description, contributing factors, recommendations resulting from investigation

11. Incident Investigation

Employers to investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of hazardous chemical.

To be initiated within 48 hours and include: date (incident/investigation), description, contributing factors, recommendations resulting from investigation

OSHA PSM StandardOSHA PSM Standard

12. Emergency Planning and Response• Establish and implement an emergency

action plan for the facility under 29 CFR 1910.38(a)

12. Emergency Planning and Response• Establish and implement an emergency

action plan for the facility under 29 CFR 1910.38(a)

OSHA PSM StandardOSHA PSM Standard

13. Compliance Audits• Employers certify and have evaluated

compliance with the OSHA regulation at least every 3 years to verify procedures/practices developed are still adequate

• Report of findings shall be developed and written responses developed and deficiencies corrected

13. Compliance Audits• Employers certify and have evaluated

compliance with the OSHA regulation at least every 3 years to verify procedures/practices developed are still adequate

• Report of findings shall be developed and written responses developed and deficiencies corrected

Compliance with Question 13Compliance with Question 13

• Ask when the process was started

• Ask when the last compliance audit took place

• What were the findings and what was done with the findings

• Ask when the process was started

• Ask when the last compliance audit took place

• What were the findings and what was done with the findings

OSHA PSM StandardOSHA PSM Standard

14. Trade Secrets• Employers to provide all information

necessary to comply

14. Trade Secrets• Employers to provide all information

necessary to comply

Review of OSHA PSMReview of OSHA PSM

14 points14 points

OSHA PSM StandardOSHA PSM Standard

• Fourteen (14) Points to PSM Standard1. Employee Participation2. Process Safety Information3. Process Hazard Analysis4. Operating Procedures5. Training6. Contractors7. Pre-Start up Safety Review

• Fourteen (14) Points to PSM Standard1. Employee Participation2. Process Safety Information3. Process Hazard Analysis4. Operating Procedures5. Training6. Contractors7. Pre-Start up Safety Review

OSHA PSM StandardOSHA PSM Standard

• Fourteen (14) Points to PSM Standard8. Mechanical Integrity9. Hot Work Permit10. Management of Change11. Incident Investigation12. Emergency Planning & Response13. Compliance Audit14. Trade Secrets

• Fourteen (14) Points to PSM Standard8. Mechanical Integrity9. Hot Work Permit10. Management of Change11. Incident Investigation12. Emergency Planning & Response13. Compliance Audit14. Trade Secrets

CMR 33 – Category IVCMR 33 – Category IV(a) Process information including, but not limited to: MSDS for the chemicals and products being processed, process chemistry, piping and instrumentation diagram, safety relief design, process control safety alarms and interlocks; and

(b) Facility suitability including, but not limited to: building code compliance, electrical hazard (Check article 500) classification, ventilation design, fire alarm and fire protection, spill containment and control; and

(a) Process information including, but not limited to: MSDS for the chemicals and products being processed, process chemistry, piping and instrumentation diagram, safety relief design, process control safety alarms and interlocks; and

(b) Facility suitability including, but not limited to: building code compliance, electrical hazard (Check article 500) classification, ventilation design, fire alarm and fire protection, spill containment and control; and

CMR 33 – Category IVCMR 33 – Category IV(c) A process hazard safety analysis including but not limited to: effects in the event of failure, suitable administrative and engineering controls to minimize failure and to control unanticipated releases, and emergency responses to safeguard life and property; and

(d) Written procedures, including routine operating and maintenance, as well as precautionary, shut-down and emergency response measures; and

(c) A process hazard safety analysis including but not limited to: effects in the event of failure, suitable administrative and engineering controls to minimize failure and to control unanticipated releases, and emergency responses to safeguard life and property; and

(d) Written procedures, including routine operating and maintenance, as well as precautionary, shut-down and emergency response measures; and

CMR 33 – Category IVCMR 33 – Category IV(e) A written training program for operating and maintenance personnel and outside contractors whose work or activity may affect process safety; and(f) A written records management protocol which tracks any changes, including but not limited to changes to chemicals, equipment, operating procedures training program. Such records shall include the date of such change and the name of the manager responsible for such change;

(e) A written training program for operating and maintenance personnel and outside contractors whose work or activity may affect process safety; and(f) A written records management protocol which tracks any changes, including but not limited to changes to chemicals, equipment, operating procedures training program. Such records shall include the date of such change and the name of the manager responsible for such change;

Emergency response is not our first line of defense from harm. It's just the only option remaining after prevention and education fail.