Process Safety Management of Highly Hazardous & Explosive Chemicals

29CFR1910.119 Clearly Understanding the Standard

Information Provided under OSHA Susan Harwood Grant #SH-17811-08-60-F-13

Susan Harwood GrantHistory

Grants are awarded to provide training and education programs for employers and employees on the recognition, avoidance, and prevention of safety and health hazards in their workplaces. PSM Was Chosen Given the Clear Need Past Disasters Current Year Disasters Perceived Weakness in PSM Program

GTRI PSM Susan Harwood Grant Program

GTRI has Offered:
Nine (9) One Day Courses Around the

Southeastern United States Eight (8) One Week In-Depth Courses Around the United States

Goals of the One Day Course

Understand Why Process Safety Management (PSM) Was Promulgated Understand That Even with PSM, Catastrophes are Still Occurring Understand Who is Covered & Exemptions Understand the Team Process to Developing a PSM Program Understand Each of the Elements of a Properly Designed & Implemented Program and How to Begin the Process Understand the Basics of How PSM & RMP Work Together to Protect the Workforce & Surrounding Community

Summary of the One Week Course

In-Depth Study of the This is an In-Depth Requirements of the Standard Students will Actually Learn through a Real Life Case Study How to Design Each Element of the Process Safety Management Standard Requirements Students will Also Review the Basics of EPA Risk Management Plan (RMP)

Rules of the Course

This is an Open Discussion Course
Relax and Learn Ask Questions Participate in Discussions Share Experiences Share Best Practices Enjoy Yourself

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?

In 1991, OSHA and EPA respectively, Released the Standards, PSM & RMP that Applies to Those Companies that are Affected by The Standards.

Why Did OSHA Develop PSM?

Process Safety Management is a regulation, promulgated by OSHA, intended to prevent an incident like the 1984 Bhopal Disaster Andto Prevent Release Andto of: Toxic, Reactive, Flammable, or Explosive chemicals

Not Only PSM, But RMP

A great many industrial facilities must comply with OSHA's Process Safety Management (PSM) regulations as well as the quite similar EPA Risk Management Program (RMP) regulations (Title 40 CFR Part 68).

PSM vs. RMP - Whats the Difference?

PSM - Like HAZCOM

Protects the Workforce Protects Contractors Protects Visitors to the Facility Basically Protects the Workplace

RMP-Like Sara Title III RMP-Like

Protects the Community Protects the General Public Around the Facility Protects Adjacent Facilities Such as Schools & Hospitals

The Standard Was Promulgated in 1991 - Is it Working?

The Standard Was Promulgated in 1991 - Is it Working?

BP Products Texas City - March 2005

15 Workers Killed 170 Injured Major Property Damage $21 Million in Fines

Application
1910.119(a)

What Facilities are Covered

Those Who Use Chemicals in Appendix A: A List of highly hazardous chemicals, toxics and reactive (Mandatory). Contains a listing of toxic and reactive highly hazardous chemicals which present a potential for a catastrophic event at or above the threshold quantity Examples Chemical Anhydrous Ammonia: Chlorine: Threshold Quantity Quantity (TQ) (TQ) Threshold 10,000 lbs 10,000 1,500 lbs

What Facilities are Covered

A process which involves a flammable liquid or gas (as defined in 1910.1200(c) of this part) on-site on-site in one location, in a quantity of 10,000 pounds (4535.9 kg) or more

What Facilities are Covered

06/11/2007 - OSHA OSHA Important Interpretation: 2007 - 06/11/2007 "on-site in one location" for Process Safety defines "on-site Management of Highly Hazardous Chemicals standard

"on-site in one location" to mean that OSHA interprets "on-site the standard applies when a threshold quantity of a highly hazardous chemical (HHC) exists within an area under the control of an employer or group of any group group of of affiliated employers. It also applies to any vessels that are interconnected, or in separate vessels that are close enough in proximity that the HHC could be involved in a potential catastrophic release.

What Facilities are Covered

Affect of the Meer Meer Decision:
MEER ruling ruling and and the the MEER MEER Memorandum Memorandum addressed addressed in in the the MEER Secretary's letter, OSHA's enforcement policy that the Agency would not not cite cite employers employers for for violations violations of of 1910.119 1910.119 where where stored stored would flammable liquids in atmospheric tanks were connected to a process, unless unless the the process process outside outside of of the the amount amount in in storage storage process, contained more than 10,000 pounds of the substance

What Types of Industries?

Industries that Process Chemicals Such As:

Industrial Organics & Inorganics Paints Pharmaceuticals Adhesives Sealants and Fibers Petrochemical facilities Paper Mills Food Processing with Anhydrous Ammonia over the TQ

Exclusions
1910.119(a)(1)(ii)(A)

There are Exclusions

An employer is exempt from the requirements of PSM when: A threshold quantity of flammable liquids is stored in atmospheric tanks or transferred without the benefit of chilling or refrigeration Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling), If such fuels are not a part of a process containing another highly hazardous chemical covered by this standard

There are Exclusions

Retail facilities; Oil or gas well drilling or servicing operations; or,

Normally unoccupied remote facilities

Definitions
1910.119(b)

Definitions

Atmospheric tank means a storage tank which has been designed to operate at pressures from atmospheric through 0.5 p.s.i.g. (pounds per square inch gauge, 3.45 Kpa). Boiling point means the boiling point of a liquid at a pressure of 14.7 pounds per square inch absolute (p.s.i.a.) (760 mm.). Catastrophic release means a major uncontrolled emission, fire, or explosion, involving one or more highly hazardous chemicals, that presents serious danger to employees in the workplace.

Definitions

Facility means the buildings, containers or equipment which contain a process. Highly hazardous chemical means a substance possessing toxic, reactive, flammable, or explosive properties and specified by paragraph (a)(1) of this section. Hot work means work involving electric or gas welding, cutting, brazing, or similar flame or sparksparkproducing operations. Normally unoccupied remote facility means a facility which is operated, maintained or serviced by periodically to facility only only periodically to employees who visit the facility check its operation and to perform necessary operating or maintenance tasks. No employees are permanently stationed at the facility.

Definitions

Process means any activity involving a highly hazardous chemical including any use, storage, on-site movement of manufacturing, handling, or the on-site such chemicals, or combination of these activities. For purposes of this definition, any group of vessels which are are interconnected interconnected and separate vessels which which are located such that a highly hazardous chemical could be involved in a potential release shall be considered a single process. Replacement in kind" means a replacement which Replacement satisfies the design specification. "Trade secret" means any confidential formula, pattern, process, device, information or compilation of information that is used in an employer's business

Employee Participation
1910.119(c)

Now that we are required to comply, then what? First

Form a Team in Your Company, i.e..

Process Engineers Operators Safety Maintenance Management Consultants

RememberYou Cant Do it Alone!

Now that we are required to comply, then what? Second

Form a Plan, Determine:

Responsibilities Duties Reporting Document Control Progress Reports Tracking Changes

Now that we are required to comply, then what? Third

Review Scope of the Project:

Application Exclusions Definitions Employee Participation Hazards of the Process Toxicity Technology of the Process Equipment in the Process Mechanical Integrity Inspection & Testing Quality Assurance

Process Hazard Analysis Management of Change Operating Procedures Safe Work Practices Training Contractor Management Emergency Planning & Response Incident Investigation Compliance Audits Trade Secrets

Now that we are required to comply, then what? Lets Begin

In the Next Session, we will Begin to Explore Each Element of the Standard and What is Required to Comply