_Process_Safety_Management

Process Safety Management -

Fast Tips for the Little Guy

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Eng Essam Osman GiG Risk Mnagement

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What Is Process Safety Management

Process Safety Management is the application of management principles and systems to the identification, understanding, and control of process hazards to protect employees, facility assets and the environment.

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What Is Process Safety Management 14 Elements

Application Employee

Participation Process Safety

Information Process Hazard

Analysis Operating Procedures Employee Training Contractors

Pre-Start up Safety Review

Mechanical Integrity Hot Work (Non-routine

Work Authorizations) Management of

Change Incident Investigation Emergency Planning

and Response Compliance Audits

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(a) Application Appendix A of 29 CFR 1910.119 contains a

listing of toxic and reactive highly hazardous chemicals which present a potential for a catastrophic event at or above the threshold quantities listed.

To adequately address this section, identify what brings you into coverage by the standard, specifying which processes at the facility are covered and why.

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Application cont.Consider what you can do to get out of the

situation Reduce inventories of highly hazardous

chemicals Receive smaller shipments Enhance inventory control Break up storage locations within the plant to

reduce the amounts on hand to below the threshold quantity (TQ)

Substitute listed with non-listed

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May 25, 2004 Conyers GA

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(c) Employee Participation Employees are required to be an active part

of the process and your written programs need to document what roles employees play, their involvement in the development of the programs, and continuing participation in the process.

An OSHA inspector (CSHO) will attempt to verify participation by interviewing employees at random.

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(c) Employee Participation cont.

Consultation / participation with training and supervision to determine the frequency and content of initial and refresher training.

Consultation / participation to develop and review operating and maintenance procedures.

Consultation / participation in incident investigations regarding the covered process.

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(d) Process Safety Information Material Safety Data

Sheets (MSDS) Piping and

instrumentation diagrams (PINDs)

Block flow diagrams

Material and energy balance calculations

Relevant consensus standards

Materials of construction

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(d) Process Safety Information cont. Available to all affected employees [requirement of

1910.119 (c) Employee Participation]

Available for Process Hazard Analysis and revalidations [requirement of 1910.119 (e) Process Hazard Analysis]

So auditors and CSHOs can find everything!

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(e) Process Hazard Analysis

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1910.119 (e) Process Hazard AnalysisOSHA has suggested formatsDon’t start until all information is

gatheredUse a software tool to guide, record,

manage process

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“Catastrophic release means a major uncontrolled emission, fire, or explosion involving one or more highly hazardous chemicals, that presents serious danger to employees in the workplace.” 1910.119(b)

(e) Process Hazard Analysis

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http://www.csb.gov/completed_investigations/info.cfm?ID=47

http://www.csb.gov/completed_investigations/info.cfm?ID=47

(f) Operating Procedures Standard Operating ProceduresDo in tandem with Job Hazard Analysis

(JHAs)Mesh with training programPartner with Quality Team (ISO 9001)

to create training matrix and managed documents

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(g) Employee Training The employer shall prepare a record:

Identity of employee. Date of training. Means to verify that employee

understood training At a minimum, refresher training shall be

provided at least every three years and more often if necessary to each employee involved in operating a process.

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(h) Contractors Absolute Requirements

Employer Documentation: Contract employee injury and illness logs

related to work in covered process areas. Contract Employer Documentation:

Records showing employees received training in and understands safe work practices related to the process on or near where they will be working so they perform their jobs safely.

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(i) Pre-Start up Safety Review Check, double check, and review any

changes, modifications, additions made in a PSM covered area – before you flip the switch.

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(j) Mechanical Integrity The employer shall develop and maintain a master

list of all equipment specifically covered by the standard, and equipment that is important to safety of the process. Pressure vessels and storage tanks. Piping systems including valves and other piping

components. Relief and vent systems and devices. Emergency shutdown systems. Controls (including monitoring devices and sensors,

alarms, and interlocks).

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(j) Mechanical Integrity cont.

Pumps. Rotating equipment. Heat exchange equipment. Electrical generation and distribution

equipment. Un-interruptable power supplies. Emergency power supply equipment. Fire protection equipment.

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(k) Hot Work (a.k.a. Non-routine

Work Authorizations) Welding, cutting, braising – make sure

only trained personnel perform these functions

Have trained fire watchers (align with fire extinguisher / fire response training)

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(l) Management of Change Create formalized system to review all

changes to process areas including: Raw material changes / substitutions Personnel changes Process parameters Facility changes (HVAC / roof / fire

protection / ……..)

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(l) Management of Change cont. PSI Mechanical Integrity PINDs Hot Work Contractor Safety Employee Training PSSR Operating Procedures

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(m) Incident Investigation

InvestigateIncidents

&Near-Misses

Begin within48-hours

Teamwith ProcessKnowledge

Report withConclusions &

Recommendatons

Follow-upSystem for

Recommendations

ReatainReports 5-years

IncidentInvestigation

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(n) Emergency Planning and Response Call in all resources and make plan

comprehensive: Information Technology (IT) Disaster

Recovery Plan Business Continuity Plan (session #554 @ 4:30)

Security Communications / Public Relations Employee Assistance

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(o) Compliance Audits Ask for the audit protocol ahead of timeHave a system in place to identify the

location of all PSM documentation Identify what's in or out of audit scopeAsk for money to correct audit items

before the audit is conductedPrepare management for report

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Resources OSHA web site (www.OSHA.gov):

CPL 2-2.45 – Process Safety Management of Highly Hazardous Chemicals – Compliance Guidelines and Enforcement Procedures – 78 pages of gold!

Appendix C to §1910.119 Compliance Guidelines and Recommendations for Process Safety Management (Nonmandatory)

OSHA training institute Safety and Health – Chemical Process Industry –

course #330A. PSM ‘boot camp’ – five days of fun and a three ring binder!

AIChE / CCPs35


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Please Visit!

Booth # 1312

Booth # 1310

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http://www.achmm.org/

Documents

_Process_Safety_Management