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Management Systems,
Process Safety Management,
and RMP
Jeffrey J. Wanko, PE, CSP
Directorate of Enforcement Programs
Office of Chemical Process Safety
• Management Systems
• Process Safety Management History
• Process Safety Management Elements
• Ammonia Distribution
• PSM-RMP Comparison
• PSM Future
• How to Get Help
Safety Management System
Strengths
• Management systems (such as PSM and
Injury and Illness Prevention Programs)
work because they provide for:1. System design
2. System execution
3. System evaluation
4. System correction
5. (repeat)
Also called Plan-Do-Check-Act
Safety Management System Core
Elements
• Six core elements:
– Management leadership
– Worker participation
– Hazard identification and assessment
– Hazard prevention and control
– Education and training
– Program evaluation and improvement
History of Process Safety
Management
• PSM became effective in 1992
• Stakeholders consensus regarding the
performance-based model
• A single prescriptive regulation could not
cover all facilities
History of Process Safety
Management
• PSM sets a management framework for
preventing catastrophic releases of highly
hazardous chemicals or minimizing
consequences
• PSM incorporates the philosophy and
strengths of safety management systems
Process Safety Management
Elements• Employee participation
• Process safety
information
• Process hazard
analysis
• Operating procedures
• Training
• Contractor safety
• Pre-start up safety
review
• Mechanical integrity
• Hot work permit
• Management of change
• Incident investigation
• Emergency response
• Compliance audits
Benefits of the Process Safety
Management System Framework
• Flexible
• Comprehensive
• Adaptive
• Creative
The PSM Elements
• Employee Participation*– Workers are most likely exposed to the hazards of the
process
– Workers are most knowledgeable in how the process
operates daily
– Written plan of action to involve employees in the
program
– Consult with employees on the conduct of the
process hazards analysis (PHA)
– Communicate PHA findings to employees
The PSM Elements
• Process Safety Information (PSI)
– Information about the process, process,
design, equipment design, etc.
– The information necessary to conduct a PHA
and to operate the process over time
– Process chemicals
– Process technology
– Process equipment
The PSM Elements
• Process Hazards Analysis (PHA)– Systematic evaluation of the hazards of a process
– What could go wrong (how often and how badly)
– Evaluation of the administrative and engineering
systems that keep the process safe (not limited to
those items dedicated to safety)
– Group effort - process operator involvement not
required but encouraged
The PSM Elements
• Operating Procedures (OP)– Clear instructions on how to operate the process
– All phases of operation
– Written
– Reviewed annually to ensure they reflect current and
actual operating practice
– Includes safe work practices (lockout, confined space
entry, personnel entry, etc)
The PSM Elements
• Training
– Initial training to ensure process operators
can safely operate all phases of the process
in accordance with the operating procedures
– Refresher training as necessary but no less
than every three years
The PSM Elements
• Contractors*– Contractors who work on the process or could affect
the process
– Employer (host) responsibilities
• Evaluate
• Recordkeeping
• Communication
– Employer (contractor) responsibilities
• Communication
• Instruction in safety procedures
The PSM Elements
• Pre-Startup Safety Review (PSSR)*
– Required for new facilities or facilities having
gone through a significant change (change to
PSI)
– Ensure that everything is complete prior to
introduction of the highly hazardous chemical
• PSI update
• PHA
• OPs
• Training, etc…
The PSM Elements
• Mechanical Integrity (MI)– Maintaining the integrity of process equipment
• Vessel
• Piping/Hoses
• Pump
• Valves
• Safety systems
• Controls
– Written procedures
– Training for personnel performance maintenance
activities
The PSM Elements
• Hot Work*
– Administrative control of welding, cutting,
brazing and other spark-producing activities
– Permit
The PSM Elements
• Management of Change (MOC)*
– Changes to chemicals, process, equipment,
procedures, etc.
• Other than in-kind changes
– Establish a written program
– Inform employees affected by the change
The PSM Elements
• Incident Investigation
– Investigate incidents that resulted in or could
have resulted in a catastrophic release of
highly hazardous chemical(s)
– No later than 48 hours after the incident
– Prepare a report
The PSM Elements
• Emergency Planning and Response
– Establish a program for response during
emergencies
– One of the following:
• Emergency action plan (1910.38)
• Emergency response plan (1910.120)
The PSM Elements
• Compliance Audits
– Every three years conduct an audit of
compliance with the standard
– Prepare a report of findings
22
How Do the Elements Interact? –
An Example
• I store 100,000 pounds of anhydrous
ammonia for filling nurse tanks
• My raw materials are
– Anhydrous ammonia delivered in OTR tanker
23
What Do I Need to Do This
Safely?
• Process Safety Information
– Properties of the anhydrous ammonia
• Conditions under which is a gas or liquid
• Is it corrosive?
– To what?
• How does ammonia act at different pressures and
temperatures
• Toxicity
• Molecular weight
• Flammability/combustibility
• Other hazards?
24
What Do I Need to Do This
Safely?
• Process Safety Information
– The process and equipment
• How much do I need?
– Raw materials (inventory)
– Energy
– Safe upper and lower limits (temp, pressure)
• What should the equipment be made of to reduce
problems?– To what standards is the equipment designed and
constructed?
– Vessel construction
– Piping and hose construction
25
Looking for Possible Problems
• Systematically review the process and
analyze for hazards (PHA)• Analyze the potential ways in which problems
could arise– Overpressure
– Vehicular impact
– Design requirements (CGA K61.1 and G2.1)
– Overfilling
– Drive away
• May have to find answers to questions which arise
• Human factors
• Facility siting
26
What About Designing, Building,
and Operating?• Is my process designed correctly?
– K61.1 or G2.1
• Is my process built correctly?– Proper materials for valves, pipes, vessels, etc.– Control systems designed and installed correctly?– Do my relief valves relieve to safe locations?
• How do you show that the process is built correctly and in compliance with codes and standards
• Procedures– Operating– Startup– Shutdown & Emergency shutdown
27
What About Designing, Building,
and Operating?
• Are operators, maintenance, contractors properly
trained?– Unloading and loading operations
– Daily inspections (vessel, hose, piping)
• How do I know if my equipment is lasting as long as it
should?– Testing
– Frequency of tests
– Trained people to do testing
• How do I handle contractors working on or around my
workplace?– Can they adversely affect the process?
28
Will Things Always Stay the
Same?
• What if I make changes in materials,
pressures, equipment, procedures, etc?– How will the changes affect other items
• Procedures
• Training
• PSI
• Testing
• Emergency procedures
• etc.
– Was the change significant? (PSSR)• New hose material
• New pump seal material
• New vessel
29
Preventing Fires & Dealing with
Releases
• Do I have a program to ensure safe hot
work?
• How do I handle releases of ammonia?– Planning – is response necessary?
• If I do have a release or some incident,
what then?– Investigations
– Improvements
– What about if I “almost” have a release?
30
Regular Program Review
• How do I make sure that year after year
my programs are working?– Who should do the audits?
– What should be audited?
– How is an audit conducted?
– What happens if the auditors find problems?
RMP 2 and PSM Comparison
• RMP 2
– Eight program
elements:
• Safety Information
• Hazard Review
• Operating procedures
• Training
• Maintenance
• Incident Investigation
• Compliance audit
• Emergency response
• PSM
– Eight RMP 2 elements
plus
• Employee Participation
• Management of
Change
• Prestart-up safety
review
• Contractor safety
• Hot work program
RMP 2 and PSM Comparison
• RMP 2
– Safety information
• Safety data sheet
• Safe upper and lower
limits
• Equipment
specifications
• Codes and standards
used for design
• PSM
– Process Safety
Information
• Chemicals
• Technology
• Equipment
RMP 2 and PSM Comparison
• RMP 2
– Hazard review
• Identify hazards
• No required
methodology
• Can be completed by
an individual
• PSM
– Process Hazards
Analysis
• More in-depth study
• Requires personnel
involved in the process
• Requires human factors
analysis
• Requires facility siting
analysis
• Evaluate failure of
controls
RMP 2 and PSM Comparison
• RMP 2
– Maintenance
• Perform maintenance
• No other requirement
• PSM
– Mechanical Integrity• Six classes of equipment
including safety-critical
• Written procedures
• Procedures, inspections,
and testing must:
– Follow manufacturers
instructions
– Recognized and
generally accepted
good engineering
practice
RMP 2 and PSM Comparison
• RMP 2
– Emergency Response
• Coordinate with
responders
• PSM
– Emergency Response
• Must follow:
– 1910.38 – emergency
action plans or
– 1910.120 -
HAZWOPER
PSM Future
• Executive Order 13650 (8/1/13)
• OSHA PSM Request-for-Information
(12/9/13)
– Addresses many gaps identified since
promulgation
– Addresses modernizations necessary to align
with EPA and current industry practice
How to Get Assistance
• OSHA Compliance Assistance Program
– OSHA On-Site Consultation
– See the Web site for information on the office
closest to you
– 1-800-321-6742
• Jeffrey Wanko
– 202-693-2137