Process Safety Management of Highly Hazardous Chemicals

Process Safety Management (PSM)

Review the need for PSM Review facilities covered by the rule Review the 14 points of PSM Review some results and perceived limitations of PSM

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A lot more often than you might thinkor want to know

HOW OFTEN DO CHEMICAL PROCESS INDUSTRY INCIDENTS OCCUR?

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BASF Ludwigshafen, Germany (1948)

Chemical Explosion 300 deaths 3800 injuries Cause: Catastrophic failure of railway car carrying 30 tons dimethyl ether gas Third major incident at site in 25 years

Nypro UK
(a joint venture between Dutch State Mines and the British National Coal Board)

Flixborough, UK (1971)
Chemical Vapor Cloud Explosion 28 deaths 36 serious injuries Cause: Rupture of a bypass pipe, releasing 40 tonnes cyclohexane

ICMESA
(subsidiary of Hoffmann-LaRoche)

Seveso, Italy (1976)

Dioxin Release 193 injuries Indirect Increase in Human Mortality of those exposed 3000 pets and farm animals killed by release 70,000 animals slaughtered to prevent dioxin entry into food chain Cause: Runaway Chemical Reaction

Union Carbide Bhopal, India (1984)

Methyl Isocyanate release 500,000 Exposed 2,000-8000 deaths Causes:
Dangerous Process Poor Maintenance Safety System Disabled Poor Worker Training Dependance on manual controls

Phillips Petroleum Pasadena, TX (1989)

Petroleum explosion 23 deaths 314 injuries Cause: Improperly connected controls allowed an isolation valve to open and release 85,000 pounds of highly flammable gases

Summary of Chemical Accidents

1994-1999

Source: Kleindorfer, P., Belke, J., Elliott, M., Lee, K., Lowe, R., Feldman, H.,"Accident Epidemiology & U.S. Chemical Industry: Accident History & Worst-Case Data from RMP*Info", Risk Analysis, Vol.23, No 4, 2003, pp 865-881.

Why Did OSHA Develop PSM?

To prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals that may result in toxic, fire or explosion hazards OSHA Reference: 29 CFR 1910.119 July 17, 1990 Notice of Proposed Rule Feb. 24, 1992- Final Standard Published

What Is Process Safety Management?

Integration of:
Product Design & Process Chemical Selection Engineering Manufacturing Technology Operating Procedures
Inventory Management Startup, shutdown, etc.

Standard management protocols

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What Processes & Facilities must comply with PSM?

Who Must Comply
Processes that use any listed Highly Hazardous Chemical (pp. 168-169) Facilities that involve flammable liquids or gasses and have 10,000 lb. on premises (aggregate?) Pyrotechnics and explosives manufacturers covered under other OSHA rules Special provisions for contractors working in covered facilities

Excluded Hydrocarbon fuels used solely as a fuel Flammable liquids stored in unrefrigerated atmospheric tanks Retail Facilities Oil or gas well drilling or servicing operations Normally unoccupied remote facilities

What Types of Industries?

Industrial Organic & Inorganic Chemicals Paints Pharmaceuticals Adhesives Sealants and Fibers Petrochemical Paper Mills And many others

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The Elements of the PSM Standard

Employee Participation Process Safety Information Process Hazard Analysis Operating Procedures Employee Training Contractor Involvement Pre-Startup Safety Review

Mechanical Integrity Hot Work Permit System Management of Change Incident Investigation Emergency Planning and Response Compliance Audits Trade Secret Protections
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What impact is PSM Having?

Some Known Effects Some evidence of fewer incidents in the US Wide adoption of the PSM standard worldwide Limitations
Complexity of requirement can lead to resistance and haphazard implementation Only applies to worksite does not address potential off site effects (EPA RMP program, 1999)

Some Major Incidents since Implementation

Imperial Sugar - 2008 BP Texas City TX -2005 Deepwater Horizon Spill2010 Offshore:
Julin City, China 2005 Toulouse, France 2001

Process Safety Management

Comprehensive, 14 point performance standard to manage risks associated with hazardous, flammable, and explosive chemicals Governs design, operation, maintenance and modification of covered facilities from initial star design through decommissioning PSM applies to any operation that uses, stores, manufactures, handles, or moves on-site any dangerous chemical above its threshold value.

Last but not Least

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Employee Participation
Written plan of action to insure employee participation Required to consult with employees and their representatives during:
Development of process hazard analysis Development of other elements of the standard

Must provide employees access to all information developed under the standard

Hazards of the Process Chemicals

Toxicity Permissible Exposure Limits Physical Data Reactivity Data Corrosivity Data Thermal & Chemical Stability Data Hazardous Effects of inadvertent mixing
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Process Technology Information

Block flow diagram or process flow diagram Process chemistry Maximum intended inventory Upper and lower limits Consequences of deviations
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Process Equipment Information

Materials of construction Process and instrument drawings (P&IDs) Electrical classification Relief system design Ventilation system design Design codes Material and energy balances Safety systems

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Process & Instrumentation Diagram

Schematic diagram of process Identifies all:
Equipment Motors Instruments Pipelines Valves Equipment Sequencing Physical Interlocks Control Relationships

A simple P&ID Diagram

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Process Hazard Analysis (PHAs)

Arguably the Most Difficult requirement of the Standard PHA process is dynamic and subject to revision whenever changes are made Performed by Your PSM Team Takes Significant Time & Effort PHAs are Never Complete

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PHA Requirements
Appropriate Methodologies What-if, Checklist, What-lf/checklist, Hazard and operability study (HAZOP), Failure mode and effects analysis (FMEA), Fault tree analysis, or An appropriate equivalent method Analysis Must Identify
The hazards of the process; The identification of any previous incident that had a 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 on employees in the workplace if there is a failure of controls

Operating Procedures
A/K/A Standard Operating Procedures (SOPs) Employer must develop and implement written operating procedures that are clear instructions for all expected phases of operations. Must cover:
Operation phase Operational limits Safety & health considerations
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Operating Procedures Must Address

Initial start-up Normal operations Temporary operations Emergency shutdown Emergency operations Normal shutdown Start-up following turnaround Consequences of deviation Steps required to correct or avoid deviation Must be readily available to employees Must be reviewed as needed to ensure they reflect current operating practicce. Must cover:
Process chemicals Technology and equipment Facilities

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

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Safe Work Practices (SWPs)

Must be developed and implemented to provide for the control of hazards during work activities such as:
Lock-out/Tag-out Confined space entry Opening processes, piping or equipment
SWPs are for: Operators Maintenance personnel Contractors Lab personnel Other support personnel
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Training
Operator training specific to the process is required Must cover:
Safety and health hazards associated with the covered process Safe work practices

Refresher training is required every 3 years or as needed to ensure employees are complying with PSM requirements
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Contractors
Contractors involved in or around a covered process must be informed of required PSM elements. Contract work includes:
Maintenance and repair Turn around Major renovations Specialty knowledge or services

Does not include support services not involved with the covered process, like laundry or vending machine supply
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Pre-Startup Safety Review (PSSR)

Confirmation that new and modified equipment:
Has been installed correctly All safety systems are functioning correctly Safety, operating, and emergency procedures in place PHA analysis complete and recommendations implemented

Must be done prior to introduction of hazardous chemicals

Mechanical Integrity
Change maintenance philosophy:
Reduce/eliminate BREAKDOWN maintenance Promote on-going equipment, piping, and instrument integrity philosophy

Ensures that process equipment is maintained to minimize the risk of hazardous releases. A strong mechanical integrity program and proper operations forms the first line of defense against accidental releases from process equipment

Mechanical Integrity Focus

Pressure Vessels and process storage tanks Piping Systems and components Relief and vent systems Emergency shutdown systems Controls including monitoring devices, sensors, alarms, and interlocks Pumps

Hot Work
Hot Work is frequently the source of ignition at catastrophe sites Hot work Program:
Required to implement the fire prevention requirements of 1910.252(a)

Permit must indicate:

The authorized hot work Object on which the hot work is performed

Management of Change
Procedures to manage changes to the covered process.
Exception: replacement in kind

Management of Change includes:

Process chemicals Technology Equipment Operating Procedures Facilities
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Management of Change Addresses

1. 2. 3. 4. 5. Technical basis of the change Impact to employee safety and health Modification to operating procedures Time period for change Authorization of change

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Incident Investigations
Must be initiated within 48 hours of an incident Team must include:
Person knowledgeable in the process involved Other persons with appropriate knowledge of the covered process Contractor if work of the contractor involved

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Incident Investigation Report

Report must be produced with the following:
Date of incident Date of start of investigation Description of incident Factors contributing to incident Recommendations

System must be established to promptly address recommendations and findings of report Resolutions and corrective action must be documented
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Emergency Action Plans (EAP)

Must have EAP for entire facility EAP must have provisions for small releases of HHCs Develop a Early Warning Method for Releases Train on the Meaning of the Alarms Develop Emergency Evacuation Written Plans, Evacuation Maps & Assembly Points
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Compliance Audit
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
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 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

Trade Secrets

Confidentiality agreements are allowed

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Tools for Additional PSM Assistance

PSM Checklist
www.oshainfo.gatech.edu

OSHA Website
www.osha.gov

Chemical Safety Board Website

www.csb.gov

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