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Process Safety Management Process Safety Management
Of Highly Hazardous Chemicals OSHA 29 Of Highly Hazardous Chemicals OSHA 29
CFR 1910.119CFR 1910.119
PSM PSM -- DefinitionDefinition
““Not all refining hazards are caused by the same factors or involNot all refining hazards are caused by the same factors or involve ve
the same degree of potential damage. Personal or occupational the same degree of potential damage. Personal or occupational
safety hazards give rise to incidents safety hazards give rise to incidents –– such as slips, falls, and such as slips, falls, and
vehicle accidents vehicle accidents –– that primarily affect one individual worker for that primarily affect one individual worker for
each occurrence. Process safety hazards can give rise to major each occurrence. Process safety hazards can give rise to major
accidents involving release of potentially dangerous materials, accidents involving release of potentially dangerous materials, the the
release of energy (such as fires and explosions), or both.. Prorelease of energy (such as fires and explosions), or both.. Process cess
safety incidents can have catastrophic effects and can result insafety incidents can have catastrophic effects and can result in
multiple injuries and fatalities, as well as substantial economimultiple injuries and fatalities, as well as substantial economic, c,
property, and environmental damage...The Texas City tragedy in property, and environmental damage...The Texas City tragedy in
March 2005 was a process safety incidentMarch 2005 was a process safety incident””
The Report of The U.S. Refineries Independent Safety Review PaneThe Report of The U.S. Refineries Independent Safety Review Panel, l, January 2007January 2007
PSM PSM -- DefinitionDefinition
““Process safety in a refinery involves the Process safety in a refinery involves the
prevention of leaks, spills, equipment prevention of leaks, spills, equipment
malfunctions, over pressures, excessive malfunctions, over pressures, excessive
temperatures, corrosion, metal fatigue, and other temperatures, corrosion, metal fatigue, and other
similar conditionssimilar conditions”” The Report of The U.S. Refineries The Report of The U.S. Refineries
Independent Safety Review Panel, Independent Safety Review Panel, January 2007January 2007
Year Company Location Deaths Injuries
1984 Union Carbide Bhopal 2000+ ?
1989 Phillips 66 Pasadena, TX 24 132
1990 Arco Channelview, TX 17 --
1990 BSAF Cincinnati, OH 2 41
1991 IMC Sterlington, LA 8 128
Accidents That Affected The Accidents That Affected The
PSM Regulation DevelopmentPSM Regulation Development
Objective of OSHA PSMObjective of OSHA PSM
PreventPrevent catastrophiccatastrophic releases of releases of
hazardous chemicals in areas where hazardous chemicals in areas where
employees could be exposed to serious employees could be exposed to serious
harmharm
Catastrophic ReleaseCatastrophic Release
�� A major uncontrolled A major uncontrolled emissionemission, , firefire, or , or explosionexplosion, ,
involving highly hazardous chemicalsinvolving highly hazardous chemicals
�� A Substance A Substance
possessing :possessing :
–– toxic reactivetoxic reactive
–– flammable flammable
–– explosive propertiesexplosive properties
�� Specific list of Specific list of
chemicals specified by chemicals specified by
OSHAOSHA
–– Hydrogen SulfideHydrogen Sulfide
–– Ammonia Ammonia
–– Chlorine Chlorine
Highly Hazardous ChemicalHighly Hazardous Chemical
Flammable LiquidFlammable Liquid
�� Any liquid having a flash point below 100 FAny liquid having a flash point below 100 F
–– LPG (Propane, Butane, Ethane, etc)LPG (Propane, Butane, Ethane, etc)
–– NaphthaNaphtha
–– CyclohexaneCyclohexane
–– Aromatic CompoundsAromatic Compounds
(Benzene, Toluene, etc)(Benzene, Toluene, etc)
Who Must Comply?Who Must Comply?
OSHA List of Highly HazardousChemicals, Toxics and Reactive
Any flammable liquid or gas on sitein one location, in quantities of 10,000 lbs or more
14 ELEMENTSEmployee
Participation
Operating
Procedures
Process
Safety
Information
Process
Hazard
Analysis
TrainingMechanical
Integrity
Management
of Change
Pre-startup
Safety
Review
Contractor
Program
Safe Work
Practices
Incident
Investigation
Emergency
Planning
Compliance
Audits
Trade
Secrets
PSM Elements PSM Elements ---- Building Blocks for Reducing RiskBuilding Blocks for Reducing Risk
Element 1Element 1
Employee ParticipationEmployee Participation
Pre-Startup Safety Review
Mechanical Integrity
Management Of Change
Employee ParticipationCompliance Audits
Procedures
Training
Incident Investigation
Hot Work Permits
Contractor Plan
Process Hazard AnalysesEmergency Planning
Trade Secrets
Process Safety Information
Element 2Element 2
ProcessProcess SafetySafety InformationInformation
Process Technology
Chemical HazardsInformation
Process Equipment
Design Codes
Chemical Hazards InformationChemical Hazards Information
�� Information typically found on MSDSInformation typically found on MSDS
–– HazcomHazcom InformationInformation
–– Exposure GuidelinesExposure Guidelines
–– Physical DataPhysical Data
–– Chemical StabilityChemical Stability
�� CorrosivityCorrosivity DataData
�� Chemical IncompatibilityChemical Incompatibility
�� Hazardous Effects of Inadvertent MixingHazardous Effects of Inadvertent Mixing
�� Thermal and Chemical StabilityThermal and Chemical Stability
Process Technology InformationProcess Technology Information
�� Block Flow Or Process Flow DiagramsBlock Flow Or Process Flow Diagrams
�� Process ChemistryProcess Chemistry
�� Maximum Intended InventoryMaximum Intended Inventory
�� Safe Upper and Lower Limits for Process Safe Upper and Lower Limits for Process
ParametersParameters
�� Consequences of DeviationConsequences of Deviation
Process Equipment InformationProcess Equipment Information
�� Materials of ConstructionMaterials of Construction
�� Piping and Instrumentation Diagrams (P&ID)Piping and Instrumentation Diagrams (P&ID)
�� Electrical ClassificationElectrical Classification
�� Relief System DesignRelief System Design
�� Ventilation system designVentilation system design
�� Design Codes and StandardsDesign Codes and Standards
�� Material and Energy Balances Material and Energy Balances (Processes built after 1992)(Processes built after 1992)
�� Safety Systems Safety Systems
�� Design CodesDesign Codes
Element 3Element 3
ProcessProcess Hazard Analysis (PHA)Hazard Analysis (PHA)
Identify And Control Process Hazards
PHA PrioritizationPHA Prioritization
�� Extent of the Process HazardsExtent of the Process Hazards
�� Number of Potential Affected EmployeesNumber of Potential Affected Employees
�� Age of the Process Age of the Process
�� Operating History of the ProcessOperating History of the Process
PHA RequirementsPHA Requirements
�� Hazards of the processHazards of the process
�� Identify previous incidentsIdentify previous incidents
�� Engineering and administrative controls Engineering and administrative controls
(Safeguards)(Safeguards)
�� Failure of safeguardsFailure of safeguards
�� Facility Facility SitingSiting
�� Human FactorsHuman Factors
�� Evaluation of safety and health impactsEvaluation of safety and health impacts
PHA TeamPHA Team
�� One person One person
knowledgeable in the knowledgeable in the
process process ---- OperatorOperator
�� One person One person
knowledgeable in the knowledgeable in the
analysis methodanalysis method
�� Other members as Other members as
necessarynecessary
–– EngineeringEngineering
–– MaintenanceMaintenance
–– SupervisorsSupervisors
–– OperationsOperations
PHA ReportPHA Report
�� Document recommendations to reduce Document recommendations to reduce
hazardshazards
�� PHA results must be reviewed with PHA results must be reviewed with
employeesemployees
�� Must be filed for life of the processMust be filed for life of the process
�� Reviewed every 5 yearsReviewed every 5 years
Element 4Element 4
Operating ProceduresOperating Procedures
Objective
Develop, implement, and maintain clearly
written detailed procedures for safely
operating and maintaining a process during
all operating modes
Operating ProceduresOperating Procedures
Modes of OperationModes of Operation
�� Initial StartupInitial Startup
�� Normal OperationNormal Operation
�� Temporary OperationsTemporary Operations
�� Emergency ShutEmergency Shut--DownDown
�� Normal ShutNormal Shut--DownDown
�� StartStart--up following a turn around or after up following a turn around or after emergency shutemergency shut--downdown
Operating Procedures Operating Procedures ---- ContentContent
�� Operating LimitsOperating Limits
–– Consequences of Consequences of
deviationdeviation
–– Steps to correct or Steps to correct or
avoid deviations avoid deviations ----
Trouble ShootingTrouble Shooting
�� Safety and Health MeasuresSafety and Health Measures
–– Precautions to prevent over Precautions to prevent over
exposureexposure
–– Action to take if exposure Action to take if exposure
occursoccurs
–– HazardsHazards
�� Safety SystemsSafety Systems
Operating ProceduresOperating Procedures
�� Safe Work PracticesSafe Work Practices
–– Lockout / Lockout / tagouttagout
–– Confined space entryConfined space entry
–– Opening process equipmentOpening process equipment
–– Control over entrance into facilityControl over entrance into facility
�� Annual CertificationAnnual Certification
–– Current and accurateCurrent and accurate
Element 5Element 5
TrainingTraining
�� Initial TrainingInitial Training
Conducted for each current employee and Conducted for each current employee and
each new employee before working in a each new employee before working in a
newly assigned processnewly assigned process
–– Process OverviewProcess Overview
–– Operating ProceduresOperating Procedures
–– Specific Safety and Health HazardsSpecific Safety and Health Hazards
–– Safe Work PracticesSafe Work Practices
TrainingTraining
�� Refresher TrainingRefresher Training
–– Assures operators understand and follow Assures operators understand and follow
current operating procedurescurrent operating procedures
–– Every 3 years Every 3 years ---- More often if necessaryMore often if necessary
Training DocumentationTraining Documentation
��Verify each employee has received trainingVerify each employee has received training
��Verify each employee has understood trainingVerify each employee has understood training
Written Tests Verbal Tests
Observations
Element 6Element 6
Contractor PlanContractor Plan
Purpose
Define responsibilities of facility employers and
contract employers to ensure safe operation
Contractor PlanContractor Plan -- FHR ResponsibilitiesFHR Responsibilities
�� Evaluate safety performance and programs Evaluate safety performance and programs
�� Inform contract employers of hazardsInform contract employers of hazards
�� Train contract employers on emergency action planTrain contract employers on emergency action plan
�� Control the entrance, presence and exit of Control the entrance, presence and exit of
contractors in covered process areascontractors in covered process areas
�� Periodically evaluate contract employers in meeting Periodically evaluate contract employers in meeting
their obligationstheir obligations
�� Maintain an injury and illness logMaintain an injury and illness log
Contractor PlanContractor Plan -- FHR ResponsibilitiesFHR Responsibilities
�� Train employees on how to safely perform their jobTrain employees on how to safely perform their job
�� Instruct employees in the hazardsInstruct employees in the hazards
�� Train employees in emergency action planTrain employees in emergency action plan
�� Document that each employee has received and Document that each employee has received and understood the trainingunderstood the training
�� Assure that employees follow FHR safety rules Assure that employees follow FHR safety rules including safe work practicesincluding safe work practices
�� Advise FHR of unique hazards associated with their Advise FHR of unique hazards associated with their workwork
Element 7Element 7
PrePre--Startup Safety Review (PSSR)Startup Safety Review (PSSR)
Emergency Procedures
Operating Procedures
Process Hazard Analysis
Design Specifications
Training
Safety Procedures
Don’t Start That Machine !
Element 8Element 8
Mechanical IntegrityMechanical Integrity
A strong mechanical integrity program and
proper operations form the first line of
defense against accidental releases from
process equipment
Mechanical IntegrityMechanical Integrity
Covered Equipment
Tanks
Vessels
Piping
Systems
Pumps
Furnaces / heaters
ControlsRelief vent
systems
Emergency
Shutdown
Systems
Mechanical IntegrityMechanical Integrity
�� Assure new or modified equipment is suitable Assure new or modified equipment is suitable
�� Assure that equipment is correctly installed or Assure that equipment is correctly installed or
modified modified
�� Assure that maintenance materials, spare parts, Assure that maintenance materials, spare parts,
and equipment are suitableand equipment are suitable
Quality Assurance
Mechanical IntegrityMechanical Integrity
Written procedures to maintain
the on-going integrity of process
equipment:
�� Preventive maintenancePreventive maintenance
�� Equipment RepairEquipment Repair
�� Inspection and TestingInspection and Testing
Mechanical IntegrityMechanical Integrity
�� Process overviewProcess overview
�� Hazards associated with the processHazards associated with the process
�� Maintenance proceduresMaintenance procedures
Maintenance Employee Training
Element 9Element 9
Hot Work PermitHot Work Permit
Establish hot work permit system that complies with
29 CFR 1910.252 (a)
Element 10Element 10
Management Of Change (MOC)Management Of Change (MOC)
Objective
Prevent changes in the process from
introducing unacceptable hazards to workers
Management of Change ProgramManagement of Change Program
Written Procedure for managing changes to:Written Procedure for managing changes to:
Process ChemicalsProcess Chemicals
TechnologyTechnology
EquipmentEquipment
ProceduresProcedures
FacilitiesFacilitiesProcess Safety Information
Management of ChangeManagement of Change
�� Technical Basis Technical Basis ----
Why?Why?
�� Safety and Health Safety and Health
ImpactsImpacts
�� Time Period for Time Period for
ChangeChange
�� Authorization Authorization
RequirementsRequirements
Specific Items To Be Addressed For Each Change
Element 11Element 11
Incident Investigation Incident Investigation
Investigate each
incident that resulted
or could have resulted
in a catastrophic
release
Incident InvestigationIncident Investigation
�� Incident investigation must be started as soon Incident investigation must be started as soon
as possible, but no later than 48 hours after the as possible, but no later than 48 hours after the
incidentincident
�� Incident investigation teamIncident investigation team
–– At least one person knowledgeable in the process At least one person knowledgeable in the process
including contract employees where applicableincluding contract employees where applicable
Incident Investigation ReportIncident Investigation Report
�� Incident Investigation ReportIncident Investigation Report
–– Date of incidentDate of incident
–– A description of the incidentA description of the incident
–– Factors contributing to the incidentFactors contributing to the incident
–– RecommendationsRecommendations
�� Report must be reviewed with all affected employees Report must be reviewed with all affected employees
including contract employees if necessaryincluding contract employees if necessary
�� System to resolve report recommendationsSystem to resolve report recommendations
Element 12Element 12
Emergency Planning And ResponseEmergency Planning And Response
Institute an emergency response plan Institute an emergency response plan
according to 29 CFR 1910.38(a)according to 29 CFR 1910.38(a)
Plan must be reviewed Plan must be reviewed
with each employeewith each employee
Emergency Planning And Response / Emergency Planning And Response /
Emergency PlanEmergency Plan
Emergency escape Emergency escape
procedures and routesprocedures and routes
Accounting for all Accounting for all
employees after evacuationemployees after evacuation
Procedures for employees Procedures for employees
who remain to perform who remain to perform
critical plant operationscritical plant operations
Emergency Planning And Response / Emergency Planning And Response /
Emergency PlanEmergency Plan
�� Rescue and medical dutiesRescue and medical duties
�� Preferred means of reporting fires and Preferred means of reporting fires and
emergenciesemergencies
�� Emergency drills are not required, but are Emergency drills are not required, but are
recommendedrecommended
Element 13Element 13
Compliance AuditsCompliance Audits
�� Evaluate compliance with the PSM standard Evaluate compliance with the PSM standard
every 3 yearsevery 3 years
�� Audit team must include at least one person Audit team must include at least one person
knowledgeable in the processknowledgeable in the process
�� Audit report documents findingsAudit report documents findings
Compliance AuditsCompliance Audits
�� Document responses to each of the findings Document responses to each of the findings
listed in the audit reportlisted in the audit report
�� Document that all findings have been Document that all findings have been
correctedcorrected
�� Keep the two most recent compliance auditsKeep the two most recent compliance audits
Element 14Element 14
Trade SecretsTrade Secrets
�� Employer must make available all necessary Employer must make available all necessary
information available to employeesinformation available to employees
–– Process Safety InformationProcess Safety Information
–– PHAsPHAs
–– Operating ProceduresOperating Procedures
–– Incident InvestigationsIncident Investigations
–– Emergency Planning and ResponseEmergency Planning and Response
–– Compliance AuditsCompliance Audits