Improper management of highly hazardous chemicals, including toxic, reactive or flammable liquids, can cause accidental releases and emergency responses. OSHA’s Process Safety Management of Highly Hazardous Chemicals standard (29 CFR 1910.119) regulates the management of highly hazardous chemicals. Violations can carry fines of up to $126,000. Do you have a PSM program in place?
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5. OSHA Has
Been Busy
• Since 2010 OSHA has issued more
than 69 enforcement cases
regarding PSM
• A recent fine was just issued for
$264,000
• A new National Emphasis Program
was issued in January 2017
6. Why Did OSHA
Develop PSM?
Past disasters
Current disasters
Perceived weakness and lack of
understanding of PSM program
8. Why Did OSHA
Develop PSM?
In 1991, OSHA and EPA
released both the Process Safety
Management and the Risk
Management Program
9. Why Did OSHA
Develop PSM?
• PSM is a regulation that is intended to
prevent an incident like the 1984
Bhopal disaster
• And…to prevent release of:
Toxic,
Reactive,
Flammable, or
Explosive
chemicals
11. Elements of the Standard
• 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
13. What Facilities are Covered?
• Companies that use chemicals found in Appendix A
of the standard
• The Appendix contains a listing of toxic and reactive
highly hazardous chemicals which present a potential
for a catastrophic event at or above the threshold
quantity
14. Appendix A
Some example chemicals include:
• Anhydrous Ammonia – 10,000
pounds
• Chlorine – 1,500 pounds
• Hydrogen Fluoride – 1,000
pounds
• Important to check and verify
the CAS #
15. What Facilities are Covered?
• Important Interpretation: 2007 - 06/11/2007 - OSHA defines "on-site in
one location" for Process Safety Management of Highly Hazardous
Chemicals standard
• OSHA interprets "on-site in one location" to mean that 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 affiliated
employers. It also applies to any group of 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.
16. 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
18. What are some Exclusions?
A company 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
20. So Now You are
in PSM?
Form a committee, with members such as:
• Process engineers
• Operators
• Safety
• Maintenance
• Management
• Consultants
21. • Responsibilities of
members
• Duties of members
• Reporting
So Now You are
in PSM?
• Document control
• Progress reports
• Tracking changes
Develop a written plan that details:
22. Conduct a Hazard
Assessment
Determine:
• Chemicals in your process
• Process chemistry
• Quantity of chemicals in pounds
• Compare to Appendix A List with
Threshold Quantities (TQ’s)
24. Need to Collect
Toxicity Information
Standard requires the facility to determine the
toxicity of each of the regulated materials.
Some sources to help with this include:
Safety Data Sheets
NIOSH Pocket Guide
ACGIH
Other web resources
25. What Toxicity Information
Do I Need to Collect?
• Permissible Exposure
Limits
• Physical Data
• Reactivity Data
• Corrosivity Data
• Thermal and chemical
stability data
• Hazardous effects of
inadvertent mixing of
different materials that
could foreseeably occur
27. Facility Needs
to Develop
• Block flow diagram or process
flow diagram
• Process chemistry
• Maximum intended inventory
• Upper and lower limits
• Consequences of deviations
29. Facility Needs
to Review:
• Materials of
construction
• Process and instrument
drawings (P&ID’s)
• Electrical classification
• Relief system design
• Ventilation
system design
• Design codes
• Material and
energy balances
• Safety systems
31. Applies to
the Following:
• Pressure vessels and storage tanks
• Piping systems (including piping
components such as valves)
• Relief and vent systems and devices
• Emergency shutdown systems
• Controls (including monitoring devices
and sensors, alarms, and interlocks)
• Pumps
32. What Do You
Have to Do?
• The facility must establish and implement
written procedures to maintain the ongoing
integrity of process equipment
• Train employees involved in maintaining the
on-going integrity of process equipment
• Conduct inspections and test on equipment
• Document all of the above
34. The Hardest Part
• The facility must perform an initial process hazard analysis
(hazard evaluation) on processes covered by this standard.
• The process hazard analysis shall be appropriate to the
complexity of the process and shall identify, evaluate, and control
the hazards involved in the process.
• Employers shall determine and document the priority order for
conducting process hazard analyses based on a rationale which
includes such considerations as extent of the process hazards,
number of potentially affected employees, age of the process, and
operating history of the process.
35. Facilities must determine and document the
priority order for conducting process hazard
analyses based on a rationale which
includes such considerations as:
• Extent of the process hazards
• Number of potentially affected employees
• Age of the process
• Operating history of the process
The Hardest Part
36. How Do You Do This?
The facility must use one or more
of the following:
• What-if scenarios
• Develop a checklist
• What if/checklist
• Hazard and Operability Study (HAZOP)
• Failure Mode and Effects Analysis
(FMEA)
• An appropriate equivalent methodology
38. 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
39. Management of
Change Addresses:
1. Technical basis of the change
2. Impact to employee safety
and health
3. Modification to operating
procedures
4. Time period for change
5. Authorization of change
40. Operating Procedures
• Develop and implement written
operating procedures that are clear
instructions for all expected
phases of operations
• AKA – Standard Operating
Procedures (SOPs)
• Must cover:
Operation phase
Operational limits
Safety & health considerations
41. OPs 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
42. SOPs:
• Must be readily available to employees
• Must be reviewed as needed to ensure
they reflect current operating practice
• Must cover:
Process chemicals
Technology and equipment
Facilities
• SOPs must be certified annually that
they are correct and accurate
43. 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
44. Training
• PSM specific training 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 all
PSM requirements
45. 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
46. Emergency Action
Plans (EAP)
• Must have EAP for entire facility
• EAP must have provisions for small
releases of HHCs
• Develop an early warning method for
releases
• Train on the meaning of the alarms
• Develop emergency evacuation written
plans, evacuation maps & assembly points
47. Incident
Investigations
• Must be initiated ASAP, 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
48. 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
49. Incident Investigation
Report
• System must be established to
promptly address recommendations
and findings of report
• Resolutions and corrective action
must be documented
50. 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
51. 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 one 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
54. Thank You For Attending!
Request a Free
Compliance Audit:
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Rick Foote:
rfoote@triumvirate.com
Director of Industrial Practice
Triumvirate Environmental
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