Process Safety Management

Joe Grills, C.I.H, C.S.P., P.E. Perdue Pharma

Objectives

• Provide Historical Perspective on

Process Safety Management

(PSM)

• Overview of the PSM Standard

and Elements

• Contrast with Risk Management

Plan (RMP)

• Review Major Practices o

Process Hazards Analysis (PHA)

• Present List of External

References

Major Disasters

• December, 1984 Bhopal, India, incident resulting in more than 2,000 deaths (Design Reviews, - scrubber system not operating- Emergency Procedures, etc.)

• October, 1989 Phillips Petroleum Company, Pasadena, TX, incident resulting in 23 deaths and 132 injuries (Process Safety Reviews – locked valve not installed properly)

• July, 1976 Sevaso, Italy 600 people evacuated(TCDD Release)

• June, 1974 Flixboro, UK Incident (Management of Change)

Clean Air Act Amendments of 1990

• This standard was required under

the Clean Air Act Amendments of

1990

• Because of this, OSHA had to

promulgate the standard

• Required EPA to establish RMP

standard

• Also established Chemical Safety

Board

• Authorized by the Clean Air Act

Amendments of 1990 and became

operational in January 1998.

• "The principal role of the new chemical

safety board is to investigate accidents to

determine the conditions and circumstances

which led up to the event and to identify the

cause or causes so that similar events

might be prevented.“

• Congress gave the CSB a unique statutory

mission and provided in law that no other

agency or executive branch official may

direct the activities of the Board

• Congress directed that the CSB's

investigative function be completely

independent of the rulemaking, inspection,

and enforcement authorities of the EPA and

OSHA

Chemical Safety Board

Risk Management Plan (RMP)

• Mandated by CAAA, Section

112 (r), 40 CFR Part 68

• Promulgated - May 24, 1996

• Published Federal Register -

June 20, 1996

• More than 100,000 (1992)

facilities affected

• Designed to help reduce risk

of accidental release of

hazardous substances

• 3 years to implement

Hazard Assessment

• Offsite Consequence

• Population estimate

• Public receptors

• Environmental

receptors

EPA’s Visions for Accidental Release Prevention

• Emphasize community right-

to-know

• Let information drive action

• Focus the program at the

local level

• EPA support

• Coordinate communications

at local level

Process Safety Management (PSM)

• On July 17, 1990, OSHA published in the Federal Register a proposed standard, - ”Process Safety Management of Highly Hazardous Chemicals” - containing requirements for the management of hazards associated with processes using highly hazardous chemicals to help assure safe and healthful workplaces

• OSHA's proposed standard emphasized the management of hazards associated with highly hazardous chemicals and established a comprehensive management program that integrated technologies, procedures, and management practices

• The full text of the final OSHA standard was issued in the Federal Register on February 24, 1992, including the list of covered chemicals and threshold amounts

PSM applies to those companies that deal with:

• Any of more than 130 specific toxic and reactive

chemicals in listed quantities;

• Also includes flammable liquids and gases in

quantities of 10,000 pounds (4,535.9 Kg) or

more.

PSM Coverage

PSM vs. RMP Requirements

• PSM’s concern - potential hazard and protection

of employees inside a regulated area

• RMP’s concern - potential incidents that may

cause environmental and health hazards outside

facility boundaries

• OSHA issued citations to Meer Corporation for not including tanks

storing flammable materials stored at atmospheric pressure in their

PSM program because the tanks were connected to blending

vessels

• Meer appealed the citations, and when the Occupational Safety and

Health Review Commission (OSHRC) issued its final order in May

1997,

• Administrative law judge ruled that the OSHA failed to prove that

Meer's flammable material storage tanks were connected to a

process within the definition of a process in the PSM Standard.

• Ruling also extended beyond Meer by stating that the definition of a

process in the Standard was unconstitutional because it is vague and

does not give a facility the necessary information on whether it is

required to comply.

Meer Decision

OSHA Request for Information (RFI)

• OSHA announced 12/9/13 RFI seeking public

comment on potential revisions to PSM and related

standards, as well as other policy options to prevent

major chemical incidents

• RFI is in response to executive order 13650, which

seeks to improve chemical facility safety and

security, issued in the wake of the April 2013 West,

Texas, tragedy that killed 15 in an ammonium nitrate

explosion

• OSHA will use the information received in response

to RFI to determine what actions, if any, it may take

West Fertilizer Explosion and Fire

Specific Public Information Requests • Clarifying the PSM exemption for atmospheric storage tanks (Meer)

• Expanding PSM Coverage and Requirements for Reactivity Hazards;

• Updating the List of Highly Hazardous Chemicals in Appendix A of the PSM Standard

• Revising the PSM Standard to Require Additional Management-System Elements

• Amending PSM Standard to Require Evaluation of Updates to Applicable recognized and generally accepted good engineering practices (RAGAGEP)

• Clarifying the PSM Standard by Adding a Definition for RAGAGEP

• Expanding the Scope of PSM Standard to Cover the Mechanical Integrity of Any Safety-Critical Equipment

Specific Public Information Requests

(continued) • Clarifying Explicit Requirement that Employers Manage Organizational

Changes

• Revising PSM Standard to Require Coordination of Emergency Planning with

Local Emergency-Response Authorities

• Revising PSM Standard to Require Third-Party Compliance Audits

• Updating the Regulations Addressing the Storage, Handling, and

Management of Ammonium Nitrate

• Changing Enforcement Policy of the PSM Exemption for Retail Facilities

• Changing Enforcement Policy for Highly Hazardous Chemicals Listed in

Appendix A of the PSM Standard without Specific Concentrations.

Internet Reference for OSHA RFI

• https://www.federalregister.gov/articles/2013/12/09/2013-

29197/process-safety-management-and-prevention-of-

major-chemical-accidents

PHA Partners

ab Chemical

Development

d

e

f

g

PHA

EHS

Engineering

PHA Pro ® Software

Team Members and Attendance

• Written plan of action

regarding implementation of

the employee participation

• Consult with employees on the

conduct and development of

process hazards analyses and

on the development of the

other elements of PSM

• Provide to employees access

to process hazard analyses

and to all other information

Employee Participation

• The employer shall develop and implement

safe work practices to provide for the control

of hazards during operations such as

Lockout/tagout;

Confined space entry;

Opening process equipment or piping;

and

Control over entrance into a facility by

maintenance, contractor, laboratory, or

other support personnel.

Safe Work Practices

Thermal Hazards Assessment: Runaway Reactions

• An exothermic reaction can lead to thermal runaway,

which begins when the heat produced by the reaction

exceeds the heat removed.

• The surplus heat raises the temperature of the reaction

mass, which causes the rate of reaction to increase. This

in turn accelerates the rate of heat production.

• Thermal runaway can occur because, as the temperature

increases, the rate at which heat is removed increases

linearly but the rate at which heat is produced increases

exponentially.

Differential Scanning Calorimetry (DSC)

Accelerating Rate Calorimeter (ARC)

PHAs Per OSHA PSM Standard 29 CFR 1910.119

A PHA is required for covered process systems

Allowable PHA methods are:

–What-If;

–Checklist;

–What-If/Checklist;

–Hazard and Operability Study (HAZOP);

–Failure Mode and Effects Analysis (FMEA);

–Fault Tree Analysis; or

–An appropriate equivalent methodology

Items PHAs Must Address

• The hazards of the process

• The identification of any previous incident which had a likely

potential for catastrophic consequences

• Engineering and administrative controls applicable to the

hazards

• Consequences of failure of engineering and administrative

controls;

• Facility siting

• Human factors

• A qualitative evaluation of a range of the possible safety and

health effects of failure of controls on employees

HAZOP

• Directed Creative Brainstorming Method

• Based on experience and knowledge of PHA Team

• Use Guide Words to Control the PHA Team Discussions

• Focuses on one small part of the system at a time

• Very Widely Used in Process, Chemical, Refining and

Pharmaceutical Industries

Design Deviations

Fault Tree Analysis and Quantitative Risk

Assessment

Events in a fault tree are associated with statistical

probabilities. In this simplest case, failure probability

depends on the rate λ and the exposure time t:

P = 1 - exp(-λt)

P ≈ λt, λt < 0.1

An AND gate represents a combination of

independent events.

P (A and B) = P (A ∩ B) = P(A) P(B)

An OR gate, on the other hand, corresponds to set

union:

Mutually exclusive events:

P (A or B) ≈ P(A) + P(B), P (A ∩ B) ≈ 0

What-If Example

Drawings and Other Documentation

Materials Compatibility Matrix - NOAA

Materials Compatibility Matrix (continued)

Materials Compatibility Matrix

MOC Matrix

PPE Assessment

• Perform a pre-startup safety review for new

facilities and for modified facilities when the

modification is significant

• The pre-startup safety review shall confirm that

prior to the introduction of highly hazardous

chemicals to a process

Construction and equipment is in accordance

with design specifications

Safety, operating, maintenance, and

emergency procedures are in place and are

adequate

Pre-startup Safety Review

• Certify that site has evaluated compliance with the

provisions of PSM at least every three years

• Verify that the procedures and practices are

adequate and are being followed.

• The compliance audit shall be conducted by at least

one person knowledgeable in the process

• A report of the findings of the audit shall be

developed

• Promptly determine and document an appropriate

response to each of the findings and document that

deficiencies have been corrected

Compliance Audits

PSM Resources

• Major PSM Contractors, some have

testing capability others have expertise in

engineering design, Thermal Hazards

Assessment or PSM Management

Systems

• Printed Resources available on-line and in

libraries

Books on Process Safety

Hyperlinks for Internet References

• ioMosaic Process Safety Consultants

• http://www.iomosaic.com/

• Superchem™ Software

• http://www.ioiq.com/superchems/overview.aspx

• ABB Process Safety Management

• http://www.abb.us/service/seitp335/657a872cca71d550c12574e200356c0b.aspx

• HEL Process Safety Consultants and Testing

• http://www.helgroup.com/consultancy/

• DIERS

• http://www.iomosaic.com/diersweb/htdocs/minutes/minutes.htm

• Chemical Reactivity Worksheet

• http://response.restoration.noaa.gov/reactivityworksheet

• PHA Pro ® Software

• http://www.ihs.com/products/ehs-sustainability/operational-risk/pha-

pro.aspx