Process Safety Management Of Highly Hazardous Chemicals OSHA 29

Process Safety Management Process Safety Management

Of Highly Hazardous Chemicals OSHA 29 Of Highly Hazardous Chemicals OSHA 29

CFR 1910.119CFR 1910.119

PSM PSM -- DefinitionDefinition

““Not all refining hazards are caused by the same factors or involNot all refining hazards are caused by the same factors or involve ve

the same degree of potential damage. Personal or occupational the same degree of potential damage. Personal or occupational

safety hazards give rise to incidents safety hazards give rise to incidents –– such as slips, falls, and such as slips, falls, and

vehicle accidents vehicle accidents –– that primarily affect one individual worker for that primarily affect one individual worker for

each occurrence. Process safety hazards can give rise to major each occurrence. Process safety hazards can give rise to major

accidents involving release of potentially dangerous materials, accidents involving release of potentially dangerous materials, the the

release of energy (such as fires and explosions), or both.. Prorelease of energy (such as fires and explosions), or both.. Process cess

safety incidents can have catastrophic effects and can result insafety incidents can have catastrophic effects and can result in

multiple injuries and fatalities, as well as substantial economimultiple injuries and fatalities, as well as substantial economic, c,

property, and environmental damage...The Texas City tragedy in property, and environmental damage...The Texas City tragedy in

March 2005 was a process safety incidentMarch 2005 was a process safety incident””

The Report of The U.S. Refineries Independent Safety Review PaneThe Report of The U.S. Refineries Independent Safety Review Panel, l, January 2007January 2007

PSM PSM -- DefinitionDefinition

““Process safety in a refinery involves the Process safety in a refinery involves the

prevention of leaks, spills, equipment prevention of leaks, spills, equipment

malfunctions, over pressures, excessive malfunctions, over pressures, excessive

temperatures, corrosion, metal fatigue, and other temperatures, corrosion, metal fatigue, and other

similar conditionssimilar conditions”” The Report of The U.S. Refineries The Report of The U.S. Refineries

Independent Safety Review Panel, Independent Safety Review Panel, January 2007January 2007

Year Company Location Deaths Injuries

1984 Union Carbide Bhopal 2000+ ?

1989 Phillips 66 Pasadena, TX 24 132

1990 Arco Channelview, TX 17 --

1990 BSAF Cincinnati, OH 2 41

1991 IMC Sterlington, LA 8 128

Accidents That Affected The Accidents That Affected The

PSM Regulation DevelopmentPSM Regulation Development

Objective of OSHA PSMObjective of OSHA PSM

PreventPrevent catastrophiccatastrophic releases of releases of

hazardous chemicals in areas where hazardous chemicals in areas where

employees could be exposed to serious employees could be exposed to serious

harmharm

Catastrophic ReleaseCatastrophic Release

�� A major uncontrolled A major uncontrolled emissionemission, , firefire, or , or explosionexplosion, ,

involving highly hazardous chemicalsinvolving highly hazardous chemicals

�� A Substance A Substance

possessing :possessing :

–– toxic reactivetoxic reactive

–– flammable flammable

–– explosive propertiesexplosive properties

�� Specific list of Specific list of

chemicals specified by chemicals specified by

OSHAOSHA

–– Hydrogen SulfideHydrogen Sulfide

–– Ammonia Ammonia

–– Chlorine Chlorine

Highly Hazardous ChemicalHighly Hazardous Chemical

Flammable LiquidFlammable Liquid

�� Any liquid having a flash point below 100 FAny liquid having a flash point below 100 F

–– LPG (Propane, Butane, Ethane, etc)LPG (Propane, Butane, Ethane, etc)

–– NaphthaNaphtha

–– CyclohexaneCyclohexane

–– Aromatic CompoundsAromatic Compounds

(Benzene, Toluene, etc)(Benzene, Toluene, etc)

Who Must Comply?Who Must Comply?

OSHA List of Highly HazardousChemicals, Toxics and Reactive

Any flammable liquid or gas on sitein one location, in quantities of 10,000 lbs or more

14 ELEMENTSEmployee

Participation

Operating

Procedures

Process

Safety

Information

Process

Hazard

Analysis

TrainingMechanical

Integrity

Management

of Change

Pre-startup

Safety

Review

Contractor

Program

Safe Work

Practices

Incident

Investigation

Emergency

Planning

Compliance

Audits

Trade

Secrets

PSM Elements PSM Elements ---- Building Blocks for Reducing RiskBuilding Blocks for Reducing Risk

Element 1Element 1

Employee ParticipationEmployee Participation

Pre-Startup Safety Review

Mechanical Integrity

Management Of Change

Employee ParticipationCompliance Audits

Procedures

Training

Incident Investigation

Hot Work Permits

Contractor Plan

Process Hazard AnalysesEmergency Planning

Trade Secrets

Process Safety Information

Element 2Element 2

ProcessProcess SafetySafety InformationInformation

Process Technology

Chemical HazardsInformation

Process Equipment

Design Codes

Chemical Hazards InformationChemical Hazards Information

�� Information typically found on MSDSInformation typically found on MSDS

–– HazcomHazcom InformationInformation

–– Exposure GuidelinesExposure Guidelines

–– Physical DataPhysical Data

–– Chemical StabilityChemical Stability

�� CorrosivityCorrosivity DataData

�� Chemical IncompatibilityChemical Incompatibility

�� Hazardous Effects of Inadvertent MixingHazardous Effects of Inadvertent Mixing

�� Thermal and Chemical StabilityThermal and Chemical Stability

Process Technology InformationProcess Technology Information

�� Block Flow Or Process Flow DiagramsBlock Flow Or Process Flow Diagrams

�� Process ChemistryProcess Chemistry

�� Maximum Intended InventoryMaximum Intended Inventory

�� Safe Upper and Lower Limits for Process Safe Upper and Lower Limits for Process

ParametersParameters

�� Consequences of DeviationConsequences of Deviation

Process Equipment InformationProcess Equipment Information

�� Materials of ConstructionMaterials of Construction

�� Piping and Instrumentation Diagrams (P&ID)Piping and Instrumentation Diagrams (P&ID)

�� Electrical ClassificationElectrical Classification

�� Relief System DesignRelief System Design

�� Ventilation system designVentilation system design

�� Design Codes and StandardsDesign Codes and Standards

�� Material and Energy Balances Material and Energy Balances (Processes built after 1992)(Processes built after 1992)

�� Safety Systems Safety Systems

�� Design CodesDesign Codes

Element 3Element 3

ProcessProcess Hazard Analysis (PHA)Hazard Analysis (PHA)

Identify And Control Process Hazards

PHA PrioritizationPHA Prioritization

�� Extent of the Process HazardsExtent of the Process Hazards

�� Number of Potential Affected EmployeesNumber of Potential Affected Employees

�� Age of the Process Age of the Process

�� Operating History of the ProcessOperating History of the Process

PHA RequirementsPHA Requirements

�� Hazards of the processHazards of the process

�� Identify previous incidentsIdentify previous incidents

�� Engineering and administrative controls Engineering and administrative controls

(Safeguards)(Safeguards)

�� Failure of safeguardsFailure of safeguards

�� Facility Facility SitingSiting

�� Human FactorsHuman Factors

�� Evaluation of safety and health impactsEvaluation of safety and health impacts

PHA TeamPHA Team

�� One person One person

knowledgeable in the knowledgeable in the

process process ---- OperatorOperator

�� One person One person

knowledgeable in the knowledgeable in the

analysis methodanalysis method

�� Other members as Other members as

necessarynecessary

–– EngineeringEngineering

–– MaintenanceMaintenance

–– SupervisorsSupervisors

–– OperationsOperations

PHA ReportPHA Report

�� Document recommendations to reduce Document recommendations to reduce

hazardshazards

�� PHA results must be reviewed with PHA results must be reviewed with

employeesemployees

�� Must be filed for life of the processMust be filed for life of the process

�� Reviewed every 5 yearsReviewed every 5 years

Element 4Element 4

Operating ProceduresOperating Procedures

Objective

Develop, implement, and maintain clearly

written detailed procedures for safely

operating and maintaining a process during

all operating modes


Modes of OperationModes of Operation

�� Initial StartupInitial Startup

�� Normal OperationNormal Operation

�� Temporary OperationsTemporary Operations

�� Emergency ShutEmergency Shut--DownDown

�� Normal ShutNormal Shut--DownDown

�� StartStart--up following a turn around or after up following a turn around or after emergency shutemergency shut--downdown

Operating Procedures Operating Procedures ---- ContentContent

�� Operating LimitsOperating Limits

–– Consequences of Consequences of

deviationdeviation

–– Steps to correct or Steps to correct or

avoid deviations avoid deviations ----

Trouble ShootingTrouble Shooting

�� Safety and Health MeasuresSafety and Health Measures

–– Precautions to prevent over Precautions to prevent over

exposureexposure

–– Action to take if exposure Action to take if exposure

occursoccurs

–– HazardsHazards

�� Safety SystemsSafety Systems


�� Safe Work PracticesSafe Work Practices

–– Lockout / Lockout / tagouttagout

–– Confined space entryConfined space entry

–– Opening process equipmentOpening process equipment

–– Control over entrance into facilityControl over entrance into facility

�� Annual CertificationAnnual Certification

–– Current and accurateCurrent and accurate

Element 5Element 5

TrainingTraining

�� Initial TrainingInitial Training

Conducted for each current employee and Conducted for each current employee and

each new employee before working in a each new employee before working in a

newly assigned processnewly assigned process

–– Process OverviewProcess Overview

–– Operating ProceduresOperating Procedures

–– Specific Safety and Health HazardsSpecific Safety and Health Hazards

–– Safe Work PracticesSafe Work Practices

TrainingTraining

�� Refresher TrainingRefresher Training

–– Assures operators understand and follow Assures operators understand and follow

current operating procedurescurrent operating procedures

–– Every 3 years Every 3 years ---- More often if necessaryMore often if necessary

Training DocumentationTraining Documentation

��Verify each employee has received trainingVerify each employee has received training

��Verify each employee has understood trainingVerify each employee has understood training

Written Tests Verbal Tests

Observations

Element 6Element 6

Contractor PlanContractor Plan

Purpose

Define responsibilities of facility employers and

contract employers to ensure safe operation

Contractor PlanContractor Plan -- FHR ResponsibilitiesFHR Responsibilities

�� Evaluate safety performance and programs Evaluate safety performance and programs

�� Inform contract employers of hazardsInform contract employers of hazards

�� Train contract employers on emergency action planTrain contract employers on emergency action plan

�� Control the entrance, presence and exit of Control the entrance, presence and exit of

contractors in covered process areascontractors in covered process areas

�� Periodically evaluate contract employers in meeting Periodically evaluate contract employers in meeting

their obligationstheir obligations

�� Maintain an injury and illness logMaintain an injury and illness log

Contractor PlanContractor Plan -- FHR ResponsibilitiesFHR Responsibilities

�� Train employees on how to safely perform their jobTrain employees on how to safely perform their job

�� Instruct employees in the hazardsInstruct employees in the hazards

�� Train employees in emergency action planTrain employees in emergency action plan

�� Document that each employee has received and Document that each employee has received and understood the trainingunderstood the training

�� Assure that employees follow FHR safety rules Assure that employees follow FHR safety rules including safe work practicesincluding safe work practices

�� Advise FHR of unique hazards associated with their Advise FHR of unique hazards associated with their workwork

Element 7Element 7

PrePre--Startup Safety Review (PSSR)Startup Safety Review (PSSR)

Emergency Procedures

Operating Procedures

Process Hazard Analysis

Design Specifications

Training

Safety Procedures

Don’t Start That Machine !

Element 8Element 8

Mechanical IntegrityMechanical Integrity

A strong mechanical integrity program and

proper operations form the first line of

defense against accidental releases from

process equipment


Covered Equipment

Tanks

Vessels

Piping

Systems

Pumps

Furnaces / heaters

ControlsRelief vent

systems

Emergency

Shutdown

Systems


�� Assure new or modified equipment is suitable Assure new or modified equipment is suitable

�� Assure that equipment is correctly installed or Assure that equipment is correctly installed or

modified modified

�� Assure that maintenance materials, spare parts, Assure that maintenance materials, spare parts,

and equipment are suitableand equipment are suitable

Quality Assurance


Written procedures to maintain

the on-going integrity of process

equipment:

�� Preventive maintenancePreventive maintenance

�� Equipment RepairEquipment Repair

�� Inspection and TestingInspection and Testing


�� Process overviewProcess overview

�� Hazards associated with the processHazards associated with the process

�� Maintenance proceduresMaintenance procedures

Maintenance Employee Training

Element 9Element 9

Hot Work PermitHot Work Permit

Establish hot work permit system that complies with

29 CFR 1910.252 (a)

Element 10Element 10

Management Of Change (MOC)Management Of Change (MOC)

Objective

Prevent changes in the process from

introducing unacceptable hazards to workers

Management of Change ProgramManagement of Change Program

Written Procedure for managing changes to:Written Procedure for managing changes to:

Process ChemicalsProcess Chemicals

TechnologyTechnology

EquipmentEquipment

ProceduresProcedures

FacilitiesFacilitiesProcess Safety Information

Management of ChangeManagement of Change

�� Technical Basis Technical Basis ----

Why?Why?

�� Safety and Health Safety and Health

ImpactsImpacts

�� Time Period for Time Period for

ChangeChange

�� Authorization Authorization

RequirementsRequirements

Specific Items To Be Addressed For Each Change


Incident Investigation Incident Investigation

Investigate each

incident that resulted

or could have resulted

in a catastrophic

release

Incident InvestigationIncident Investigation

�� Incident investigation must be started as soon Incident investigation must be started as soon

as possible, but no later than 48 hours after the as possible, but no later than 48 hours after the

incidentincident

�� Incident investigation teamIncident investigation team

–– At least one person knowledgeable in the process At least one person knowledgeable in the process

including contract employees where applicableincluding contract employees where applicable

Incident Investigation ReportIncident Investigation Report

�� Incident Investigation ReportIncident Investigation Report

–– Date of incidentDate of incident

–– A description of the incidentA description of the incident

–– Factors contributing to the incidentFactors contributing to the incident

–– RecommendationsRecommendations

�� Report must be reviewed with all affected employees Report must be reviewed with all affected employees

including contract employees if necessaryincluding contract employees if necessary

�� System to resolve report recommendationsSystem to resolve report recommendations


Emergency Planning And ResponseEmergency Planning And Response

Institute an emergency response plan Institute an emergency response plan

according to 29 CFR 1910.38(a)according to 29 CFR 1910.38(a)

Plan must be reviewed Plan must be reviewed

with each employeewith each employee

Emergency Planning And Response / Emergency Planning And Response /

Emergency PlanEmergency Plan

Emergency escape Emergency escape

procedures and routesprocedures and routes

Accounting for all Accounting for all

employees after evacuationemployees after evacuation

Procedures for employees Procedures for employees

who remain to perform who remain to perform

critical plant operationscritical plant operations

Emergency Planning And Response / Emergency Planning And Response /

Emergency PlanEmergency Plan

�� Rescue and medical dutiesRescue and medical duties

�� Preferred means of reporting fires and Preferred means of reporting fires and

emergenciesemergencies

�� Emergency drills are not required, but are Emergency drills are not required, but are

recommendedrecommended


Compliance AuditsCompliance Audits

�� Evaluate compliance with the PSM standard Evaluate compliance with the PSM standard

every 3 yearsevery 3 years

�� Audit team must include at least one person Audit team must include at least one person

knowledgeable in the processknowledgeable in the process

�� Audit report documents findingsAudit report documents findings

Compliance AuditsCompliance Audits

�� Document responses to each of the findings Document responses to each of the findings

listed in the audit reportlisted in the audit report

�� Document that all findings have been Document that all findings have been

correctedcorrected

�� Keep the two most recent compliance auditsKeep the two most recent compliance audits


Trade SecretsTrade Secrets

�� Employer must make available all necessary Employer must make available all necessary

information available to employeesinformation available to employees

–– Process Safety InformationProcess Safety Information

–– PHAsPHAs

–– Operating ProceduresOperating Procedures

–– Incident InvestigationsIncident Investigations

–– Emergency Planning and ResponseEmergency Planning and Response

–– Compliance AuditsCompliance Audits

Process Safety Management Of Highly Hazardous Chemicals OSHA 29

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