Process Safety Management &

the Semi-Conductor Industry

Greystone Risk Management (Saratoga Springs, NY)

Jim Testo, CSP, CIH

Ashley Moll

Why Did OSHA Develop PSM?

Bhopal, India (1984)

– 2,000 deaths

Isocyanate release

Pasadena, TX (1989)

– 23 deaths, 132 injuries

Petroleum explosion

Cincinnati, OH (1990)

– 2 deaths

Explosion

Sterlington, LA (1991)

– 8 deaths, 128 injuries

Chemical release

Why Did OSHA Develop PSM?

OSHA Process Safety Management Overview OSHA 1910 Subpart: H 1910.119

Purpose:

– Preventing or minimizing the consequences of catastrophic releases of

toxic, reactive, flammable, or explosive chemicals.

Applicability:

– PSM applies to those companies that use any of the 130 specific toxic and

reactive chemicals in listed quantities; it also includes flammable liquids

and gases in quantities of 10,000 pounds (4,535.9 Kg) or more.

Key points of the regulation(s):

– Requires employer to develop, implement and maintain an ongoing 14

element program to prevent and/or mitigate an accidental release.

– Worker/Employee focus.

– Performance based standard.

– Process focus.

BP Products Texas City - March

2005

– 15 Workers Killed

– 170 Injured

– Major Property Damage

– $50.6 Million in Fines

Costs & Damages Associated with

Non-Compliance

Costs & Damages Associated with

Non-Compliance

Bostik Inc. - Middleton, MA –

March 2011

– Process safety information for

the process was incomplete.

– The employer's analysis of

hazards related to the process

did not address previous

incidents with a potential for

catastrophic results.

– As a result, OSHA has issued

Bostik nine willful citations,

with $630,000 in proposed fines,

for these conditions.

Real Time Example:

– PSM Audit in the Petroleum

Industry

Two Incidents:

Relief Valve

– PHA Finding

– Boat Covers

Chemical Delivery

– Management of Change

– Injuries

Costs & Damages Associated with

Non-Compliance

Reduce probability of incidents or

catastrophic accident

Control of regulatory risk

Cost avoidance

Business continuity

Benefits of Compliance with PSM

Common Covered Materials in Semi-

Conductor Manufacturing

Nitrogen Triflouride (NF3)

‒ Threshold Quantity: 5,000 lbs.

Silane

‒ Threshold Quantity: 10,000 lbs.

Hydrogen

‒ Threshold Quantity: 10,000 lbs.

Ammonia

‒ Threshold Quantity: 10,000 lbs.

Hydrogen Chloride (HCl)

‒ Threshold Quantity: 5,000 lbs.

Employee Participation

Process Safety Information

Mechanical Integrity, Inspection & Testing

Process Hazard Analysis (PHA)

Management of Change (MOC)

Operating Procedures (SOPs)

Pre-Start up Safety Review (PSSR)

The Elements of the PSM Standard

Hot Work Permit

Training

Contractor Management

Emergency Planning & Response

Incident Investigation

Compliance Audits

Trade Secrets

Employee Participation

Written plan of action must be developed.

Employees must participate in the PSM program.

This can be achieved multiple ways, for example:

‒ Through participation in PHA’s, reviews of SOPs, etc.

Form a Team in your organization.

Process Safety Information

Chemical Toxicity Information

– MSDSs

– Other References

Technology of the process

– Block flow diagram

– Materials of construction

– Process and instrument drawings

– Specific component design codes

– Safety systems

Challenges:

– Multiple parties involved in initial system design and build out.

– Applicability to PSM after the system has been in service.

– Expansions to existing systems.

Mechanical Integrity

The employer shall establish and implement written

procedures to maintain the on-going integrity of process

equipment.

Inspections and tests shall be performed on process

equipment and records shall be retained.

Semi-conductor industry currently has a good handle

on mechanical integrity.

Challenges:

‒ Documenting the basis for mechanical integrity

procedures.

‒ Documentation meeting the specifications of the

standard.

‒ Maintaining inspection documentation.

Process Hazard Analysis (PHA)

Arguably the most difficult part of performing the standard.

PHA process is dynamic and subject to revision

whenever changes are made.

PHA must be updated anytime a change is made

to the process that will affect the PHA or at least

every 5 years.

Challenges:

‒ Documentation and timely closure of recommendations.

‒ Reflective of actual process conditions.

‒ Significant time and effort required.

Management of Change (MOC)

Procedures to manage changes to the covered process.

‒ Exception: “replacement in kind”

Management of Change includes:

‒ Process chemicals

‒ Technology

‒ Equipment

‒ Operating Procedures

‒ Facilities

Challenges:

‒ Delays if coverage were to extend to the tool.

‒ Update of all affected documentation (process safety information,

operating procedures, etc.)

‒ Significant amount of time and resources involved in document

management.

Operating Procedures (SOP’s)

SOP’s Must cover operation phase/limits and safety & health considerations.

SOP’s Must Address:

– Initial start-up

– Normal/Temporary operations

– Emergency shutdown/operations

– Normal shutdown/Start-up following shutdown

– Consequences of deviation (correct or avoid deviation)

SOPs must be certified annually that they are correct and accurate.

Challenges:

‒ Parties operating bulk systems may be contractors.

‒ Alignment and approval of operating procedures annually.

‒ Coverage of all elements called out in the standard.

Training

Employees involved in operating a process, and each employee before being

involved in operating a newly assigned process, shall be trained in an

overview of the process and in the operating procedures.

Refresher training is required every 3 years or as needed to ensure

employees are complying with all PSM requirements.

Contractors

Must supply information on safety performance and programs.

Documentation that contractors working on covered processes have received and understood training on:

‒ Safe work practices, known fire / explosion / toxic release hazards

‒ Emergency Action Plan for the site, facility safety rules and work practices

Challenges:

‒ Could have a number of different contractors that perform work on the PSM covered systems.

‒ Verification that contractors are qualified to perform work on PSM systems.

‒ PSM becomes applicable after contractors have already been qualified to work on site.

Emergency Action Plan (EAP)

Must have EAP for entire facility.

EAP must have provisions for releases of highly hazardous chemicals.

Develop a Early Warning Method for Releases.

‒ Air monitoring, windsocks, etc.

Train on the Meaning of the Alarms.

Develop Emergency Evacuation Written Plans, Evacuation Maps & Assembly Points.

Incident Investigations

Must be initiated as soon as possible, but within 48 hours.

Team must include:

‒ Person knowledgeable in the process involved

‒ Includes contractor if work of the contractor involved

‒ Other persons with appropriate knowledge of the covered process

Report must be produced with the following:

‒ Date of incident and investigation

‒ Description of incident

‒ Factors contributing to incident

‒ Recommendations

System must be established to promptly address recommendations.

Resolutions and corrective action must be documented.

Compliance Audits

To ensure that PSM is effective, employers must certify every 3 years that they have evaluated compliance with the standard.

Must be completed by at least on person knowledgeable in the process.

Report must be developed and documented.

Deficiency corrections must be documented.

Last two compliance audits must be kept on file.

Trade Secrets

Employers must make all necessary information required to comply with PSM, regardless of trade secrets, available to persons involved in developing or creating:

‒ Compiling process safety information

‒ PHAs

‒ SOPs

‒ Incident investigations

‒ Emergency planning and response

‒ Compliance audits

Confidentiality agreements are allowed.

Most Frequent PSM Citations

Operating procedures

PSI pertaining to equipment

PHA specific criteria

Mechanical Integrity, Inspection & Testing

PHA recommendations

MOC implementation

Specifically challenging that the standard was not written to include unique processes used within the semi-conductor industry.

‒ Small quantities of the chemical used after the bulk distribution system.

‒ Highly specialized tools with built in controls and interlocks to prevent potential incidents.

Fast paced manufacturing environment with processes that are installed and uninstalled within a relatively short time period due to new process designs.

Limited experience with PSM applicability within the industry.

Various interpretations of PSM coverage applicability.

‒ Tool level coverage creates a significant financial and resource allocation burden that could cripple operations.

PSM and the Semi-conductor Industry

Risk Management Plan (RMP)

(EPA: 40 CFR 68)

If a facility applies to OSHA’s PSM standard they are more than likely going

to apply to the EPA’s Risk Management Plan (RMP) regulation.

After the Bhopal tragedy, the EPA and OSHA issued these rules which are

meant, in most cases, to be implemented together.

RMP provisions focus on off-site impacts.

Requirements of RMP include:

‒ Offsite Consequence Assessment

‒ 5-Year Accident History

‒ Risk Management Program

‒ EPA Submittal

Even with new technologies and designs there is

still a risk of catastrophic incidents, interrupted

operations, and overall cost to the business if

compliance with the PSM elements are not

adhered to.

In addition to regulatory compliance It’s important

to analyze your facilities risk of a catastrophic

incident when determining the application of

PSM.

By complying with the elements of the PSM

standard, companies can:

‒ Control their regulatory risk

‒ Minimize their risk of major incidents

‒ Achieve a higher level of business continuity

‒ Reduce future costs to the business

Summary

Questions