Process Safety Management of Highly Hazardous Chemicals

Process Safety Management (PSM)

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The Front Page

• 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

HOW OFTEN DO CHEMICAL PROCESS INDUSTRY INCIDENTS OCCUR?

A lot more often than you might think…or want to know

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BASFLudwigshafen, 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 CarbideBhopal, 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 PetroleumPasadena, 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. ChemicalIndustry: 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 & Facilitiesmust 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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• Employee Participation• Process Safety

Information• Process Hazard

Analysis• Operating Procedures• Employee Training• Contractor

Involvement• Pre-Startup Safety

Review

The Elements of the PSM Standard

• 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 Spill-

2010• 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.

The Final Word

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Last but not Least…

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

Toxicity Permissible Exposure

Limits Physical Data Reactivity Data Corrosivity Data Thermal & Chemical

Stability Data Hazardous Effects of

inadvertent mixing

Toxicity Permissible Exposure

Limits Physical Data Reactivity Data Corrosivity Data Thermal & Chemical

Stability Data Hazardous Effects of

inadvertent mixing

Hazards of the Process Chemicals

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Block flow diagram or process flow diagram

Process chemistry Maximum intended

inventory Upper and lower limits Consequences of

deviations

Block flow diagram or process flow diagram

Process chemistry Maximum intended

inventory Upper and lower limits Consequences of

deviations

Process Technology Information

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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

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

Process Equipment Information

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Process & Instrumentation Diagram

• Schematic diagram of process

• Identifies all:– Equipment– Motors– Instruments– Pipelines– Valves– Equipment Sequencing– Physical Interlocks– Control Relationships

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A simple P&ID Diagram

Arguably the Most Difficult requirement of the Standard

PHA process is dynamic and subject to revision whenever changes are made

Performed by Your PSM TeamTakes Significant Time & EffortPHA’s are Never Complete

Arguably the Most Difficult requirement of the Standard

PHA process is dynamic and subject to revision whenever changes are made

Performed by Your PSM TeamTakes Significant Time & EffortPHA’s are Never Complete

Process Hazard Analysis (PHA’s)

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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

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SWPs are for:• Operators• Maintenance personnel• Contractors• Lab personnel• Other support personnel

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 35

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 37

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. Technical basis of the change2. Impact to employee safety and health3. Modification to operating procedures4. Time period for change5. 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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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 56

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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