Post on 23-Dec-2015
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)
Emergency PreparednessEmergency Preparedness
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
Emergency PreparednessEmergency Preparedness
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
Emergency PreparednessEmergency Preparedness
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
Incident InvestigationIncident 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
Incident InvestigationIncident Investigation
Might Even Include a Flow Chart
Compliance AuditsCompliance Audits
1910.119(o)1910.119(o)1910.119(o)1910.119(o)
Compliance AuditsCompliance Audits
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."
Compliance AuditsCompliance Audits
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
Compliance AuditsCompliance Audits
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
Compliance AuditsCompliance Audits
Compliance AuditsCompliance Audits
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
Compliance AuditsCompliance Audits
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
Compliance AuditsCompliance Audits
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?
Compliance AuditsCompliance Audits
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
Compliance AuditsCompliance Audits
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
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_________________.