Process Safety Management of Highly Hazardous & Explosive Chemicals

Process Safety Management of Highly Hazardous & Explosive Chemicals

Process Hazard Analysis (PHA’s) & Management of Change

Process Hazard Analysis (PHA’s) & Management of Change

Process Hazard Analysis (PHA)Process Hazard Analysis (PHA)

1910.119(e)1910.119(e)1910.119(e)1910.119(e)

Process Hazard Analysis (PHA’s)Process Hazard Analysis (PHA’s)

Arguably the Most Difficult Part of Arguably the Most Difficult Part of Performing the StandardPerforming the Standard

Performed by Your PSM TeamPerformed by Your PSM TeamTakes Significant Time & EffortTakes Significant Time & Effort

Remember…Remember…

Arguably the Most Difficult Part of Arguably the Most Difficult Part of Performing the StandardPerforming the Standard

Performed by Your PSM TeamPerformed by Your PSM TeamTakes Significant Time & EffortTakes Significant Time & Effort

Remember…Remember…

Block Diagram

P&ID

Process Equipment Numbering

You Developed a List of Equipment ElementsYou Developed a List of Equipment Elements

Choose a PHA Process MethodChoose a PHA Process Method

•Must select a process hazard analysis (PHA) method

–What-If;

–Checklist;

–What-If/Checklist;

–Hazard and Operability Study (HAZOP);

–Failure Mode and Effects Analysis (FMEA);

–Fault Tree Analysis

The PHA Must Address:The PHA Must Address:

Equipment in the processEquipment in the process Hazards of the processHazards of the process Identification of previous incidentsIdentification of previous incidents Engineering and administrative controlsEngineering and administrative controls Consequences of failureConsequences of failure Facility sittingFacility sitting Human factorsHuman factors Qualitative evaluation of S and H effectsQualitative evaluation of S and H effects Consequences of deviationConsequences of deviation Steps required to correct or avoid deviationSteps required to correct or avoid deviation

Equipment in the processEquipment in the process Hazards of the processHazards of the process Identification of previous incidentsIdentification of previous incidents Engineering and administrative controlsEngineering and administrative controls Consequences of failureConsequences of failure Facility sittingFacility sitting Human factorsHuman factors Qualitative evaluation of S and H effectsQualitative evaluation of S and H effects Consequences of deviationConsequences of deviation Steps required to correct or avoid deviationSteps required to correct or avoid deviation

Let’s Choose the “What If” MethodLet’s Choose the “What If” Method

In a In a WWhhat Ifat If hazard analysis, hazard analysis, brainstorming techniques, in the form of brainstorming techniques, in the form of WWhhat Ifat If questions are used to identify questions are used to identify possible deviations and weaknesses in possible deviations and weaknesses in design. Once identified, these concerns design. Once identified, these concerns and their potential consequences are and their potential consequences are evaluated for risk.evaluated for risk.

In a In a WWhhat Ifat If hazard analysis, hazard analysis, brainstorming techniques, in the form of brainstorming techniques, in the form of WWhhat Ifat If questions are used to identify questions are used to identify possible deviations and weaknesses in possible deviations and weaknesses in design. Once identified, these concerns design. Once identified, these concerns and their potential consequences are and their potential consequences are evaluated for risk.evaluated for risk.

PHA What if MethodPHA What if Method

PHA Risk Analysis PHA Risk Analysis

PHA Risk Analysis PHA Risk Analysis

Process Hazard AnalysisProcess Hazard Analysis

A PHA Process Must be A PHA Process Must be Performed on Each Performed on Each Element of the Covered Element of the Covered Process:Process:

A PHA From Block A PHA From Block Diagram to P&ID to Diagram to P&ID to Every Equipment Every Equipment Element to Determine Element to Determine What Might Happen if What Might Happen if an Element of the an Element of the Covered Process FailsCovered Process Fails

A PHA Process Must be A PHA Process Must be Performed on Each Performed on Each Element of the Covered Element of the Covered Process:Process:

A PHA From Block A PHA From Block Diagram to P&ID to Diagram to P&ID to Every Equipment Every Equipment Element to Determine Element to Determine What Might Happen if What Might Happen if an Element of the an Element of the Covered Process FailsCovered Process Fails

…Continue the PHA…Continue the PHA

Continue the PHA Process UNTIL…

…Continue the PHA…Continue the PHA

All Events

…Continue the PHA…Continue the PHA

All Deviations

…Continue the PHA…Continue the PHA

All Causes

…Continue the PHA…Continue the PHA

All Consequences

…Continue the PHA…Continue the PHA

All Safeguards

…Continue the PHA…Continue the PHA

All Risk Levels

…Continue the PHA…Continue the PHA

All Recommendations

…Continue the PHA…Continue the PHA

Are Completed for

1. Every Element of…

2. Every P&ID of…

3. Every Block Diagram Section…

4. Of the Entire Covered Process

5. Is Complete

…Continue the PHA…Continue the PHA

This Process Might Entail Thousands of Covered Process Elements

…and Take Years to Complete

Establish a Project Tracking Method for all PHA Activities

What Do We Do With the PHA’s Developed?What Do We Do With the PHA’s Developed? Using the Risk Using the Risk

Column, Begin:Column, Begin: Reviewing Defense Reviewing Defense

DesignsDesigns Warning/Alarms to Warning/Alarms to

Warn of DeviationsWarn of Deviations Relief SystemsRelief Systems Ventilations SystemsVentilations Systems

Using the Risk Using the Risk Column, Begin:Column, Begin: Reviewing Defense Reviewing Defense

DesignsDesigns Warning/Alarms to Warning/Alarms to

Warn of DeviationsWarn of Deviations Relief SystemsRelief Systems Ventilations SystemsVentilations Systems

What Do We Do With the PHA’s Developed?What Do We Do With the PHA’s Developed?

With Those Analysis With Those Analysis Complete: Complete:

Begin Begin Implementation of Implementation of Engineering Engineering Controls to Minimize Controls to Minimize Potential of Potential of ReleasesReleases

With Those Analysis With Those Analysis Complete: Complete:

Begin Begin Implementation of Implementation of Engineering Engineering Controls to Minimize Controls to Minimize Potential of Potential of ReleasesReleases

Management of ChangeManagement of Change

1910.119(I)1910.119(I)1910.119(I)1910.119(I)

What if Our PHA’s Reveal the Need to Change Something In

our System to Minimize the Potential for Release…

What if Our PHA’s Reveal the Need to Change Something In

our System to Minimize the Potential for Release…

We Must Use Management of Change We Must Use Management of Change (MOC)(MOC)

We Must Use Management of Change We Must Use Management of Change (MOC)(MOC)

Management of Change - Why?Management of Change - Why?

Many of the Many of the catastrophic accidents catastrophic accidents over the past few over the past few decades can be decades can be traced, in large part, to traced, in large part, to a management of a management of change system that change system that was not in place or was not in place or was not functional was not functional (e.g., Flixborough, (e.g., Flixborough, Bhopal).Bhopal).

Many of the Many of the catastrophic accidents catastrophic accidents over the past few over the past few decades can be decades can be traced, in large part, to traced, in large part, to a management of a management of change system that change system that was not in place or was not in place or was not functional was not functional (e.g., Flixborough, (e.g., Flixborough, Bhopal).Bhopal).

Management of Change (MOC)…We MustManagement of Change (MOC)…We Must Explain the purpose of MOCExplain the purpose of MOC Set the provisions to be considered for Set the provisions to be considered for

temporary changetemporary change Define and give example of change in Define and give example of change in

equipment that requires MOCequipment that requires MOC Define and give examples of changes in Define and give examples of changes in

procedures when needprocedures when need Define and give examples of change in Define and give examples of change in

process technologyprocess technology

Explain the purpose of MOCExplain the purpose of MOC Set the provisions to be considered for Set the provisions to be considered for

temporary changetemporary change Define and give example of change in Define and give example of change in

equipment that requires MOCequipment that requires MOC Define and give examples of changes in Define and give examples of changes in

procedures when needprocedures when need Define and give examples of change in Define and give examples of change in

process technologyprocess technology

Management of Change (MOC)…We MustManagement of Change (MOC)…We Must

Define and give example of a major changeDefine and give example of a major change Define and give example of a minor changeDefine and give example of a minor change Define and give examples of "replacement Define and give examples of "replacement

in kind”in kind” Describe and list the procedures required Describe and list the procedures required

for initiating and completing a MOCfor initiating and completing a MOC

Define and give example of a major changeDefine and give example of a major change Define and give example of a minor changeDefine and give example of a minor change Define and give examples of "replacement Define and give examples of "replacement

in kind”in kind” Describe and list the procedures required Describe and list the procedures required

for initiating and completing a MOCfor initiating and completing a MOC

Any Changes in Any Changes in Defense Designs, or Defense Designs, or System Engineering will System Engineering will Require Require Management of Management of ChangeChange P&IDP&ID Equipment ListsEquipment Lists Inspection/Testing/Inspection/Testing/ Maintenance ProceduresMaintenance Procedures PHA’sPHA’s

Any Changes in Any Changes in Defense Designs, or Defense Designs, or System Engineering will System Engineering will Require Require Management of Management of ChangeChange P&IDP&ID Equipment ListsEquipment Lists Inspection/Testing/Inspection/Testing/ Maintenance ProceduresMaintenance Procedures PHA’sPHA’s

What Do We Do With the PHA’s Developed?What Do We Do With the PHA’s Developed?

Management of Change (MOC)Management of Change (MOC)

MOC procedure should ensure that MOC procedure should ensure that equipment and procedures are returned to equipment and procedures are returned to their original conditions at the end of a their original conditions at the end of a temporary changetemporary change

MOC forms/clearance sheets are acceptable MOC forms/clearance sheets are acceptable control methods of tracking changescontrol methods of tracking changes

More complex changes require a more More complex changes require a more "formal hazard evaluation" than simple "formal hazard evaluation" than simple changes (PHA not specifically mentioned).changes (PHA not specifically mentioned).

MOC procedure should ensure that MOC procedure should ensure that equipment and procedures are returned to equipment and procedures are returned to their original conditions at the end of a their original conditions at the end of a temporary changetemporary change

MOC forms/clearance sheets are acceptable MOC forms/clearance sheets are acceptable control methods of tracking changescontrol methods of tracking changes

More complex changes require a more More complex changes require a more "formal hazard evaluation" than simple "formal hazard evaluation" than simple changes (PHA not specifically mentioned).changes (PHA not specifically mentioned).

Management of Change (MOC) - Pre-Modification IssuesManagement of Change (MOC) - Pre-Modification Issues

Check codes, standards, internal engineering Check codes, standards, internal engineering specificationsspecifications

Complete design reviewComplete design review Perform reactivity testing for new substancesPerform reactivity testing for new substances Add materials to TSCA/SARA inventoriesAdd materials to TSCA/SARA inventories Complete safety and health impact reviewComplete safety and health impact review Comply with safety and loss prevention Comply with safety and loss prevention

requirementsrequirements

Check codes, standards, internal engineering Check codes, standards, internal engineering specificationsspecifications

Complete design reviewComplete design review Perform reactivity testing for new substancesPerform reactivity testing for new substances Add materials to TSCA/SARA inventoriesAdd materials to TSCA/SARA inventories Complete safety and health impact reviewComplete safety and health impact review Comply with safety and loss prevention Comply with safety and loss prevention

requirementsrequirements

Management of Change (MOC) - Pre-Modification IssuesManagement of Change (MOC) - Pre-Modification Issues

Complete maintenance review/revise spare Complete maintenance review/revise spare parts listparts list

Evaluate change against vent, relief, and flare Evaluate change against vent, relief, and flare capabilitycapability

Complete industrial hygiene reviewComplete industrial hygiene review Review change against existing Review change against existing

environmental permitsenvironmental permits Obtain required approvalsObtain required approvals

Complete maintenance review/revise spare Complete maintenance review/revise spare parts listparts list

Evaluate change against vent, relief, and flare Evaluate change against vent, relief, and flare capabilitycapability

Complete industrial hygiene reviewComplete industrial hygiene review Review change against existing Review change against existing

environmental permitsenvironmental permits Obtain required approvalsObtain required approvals

Management of Change (MOC) - Post-Modification IssuesManagement of Change (MOC) - Post-Modification Issues

Completed Process Safety Systems Review Completed Process Safety Systems Review (PSSR)(PSSR)

Completed training on change for affected Completed training on change for affected employeesemployees

SOPs marked-upSOPs marked-up P&IDs, PFDs, plot plans and other affected P&IDs, PFDs, plot plans and other affected

Process Safety Information (PSI) marked-upProcess Safety Information (PSI) marked-up Training program modifications identifiedTraining program modifications identified Preventive maintenance program Preventive maintenance program

modifications identifiedmodifications identified

Completed Process Safety Systems Review Completed Process Safety Systems Review (PSSR)(PSSR)

Completed training on change for affected Completed training on change for affected employeesemployees

SOPs marked-upSOPs marked-up P&IDs, PFDs, plot plans and other affected P&IDs, PFDs, plot plans and other affected

Process Safety Information (PSI) marked-upProcess Safety Information (PSI) marked-up Training program modifications identifiedTraining program modifications identified Preventive maintenance program Preventive maintenance program

modifications identifiedmodifications identified

Management of ChangeManagement of Change

Must Have a Method Must Have a Method for Request, for Request, Tracking, Tracking, Completion and Completion and Other Systems Other Systems Affected.Affected.

Must Have a Method Must Have a Method for Request, for Request, Tracking, Tracking, Completion and Completion and Other Systems Other Systems Affected.Affected.

Process Hazard Analysis SummaryProcess Hazard Analysis Summary

The Process Hazard Analysis is the The Process Hazard Analysis is the Backbone of the Process Safety Backbone of the Process Safety Management Program. Management Program.

It Provides the Structure Upon Which It Provides the Structure Upon Which PSM is Built PSM is Built

It Makes Available Pertinent Data & It Makes Available Pertinent Data & Safety Information to Design an Safety Information to Design an Effective PSM Safety ProgramEffective PSM Safety Program

The Process Hazard Analysis is the The Process Hazard Analysis is the Backbone of the Process Safety Backbone of the Process Safety Management Program. Management Program.

It Provides the Structure Upon Which It Provides the Structure Upon Which PSM is Built PSM is Built

It Makes Available Pertinent Data & It Makes Available Pertinent Data & Safety Information to Design an Safety Information to Design an Effective PSM Safety ProgramEffective PSM Safety Program

Management of Change SummaryManagement of Change Summary We must establish and implement written We must establish and implement written

procedures to manage changes except procedures to manage changes except "replacements in kind" for a covered process."replacements in kind" for a covered process.

If a Change in Design or Components is If a Change in Design or Components is Required, Management of Change Must be Required, Management of Change Must be Employed, Tracked, and Analyzed. Employed, Tracked, and Analyzed.

All PHA’s, P&ID’s & Required Procedures All PHA’s, P&ID’s & Required Procedures Must be RevisedMust be Revised

Work-site employees and contract employers Work-site employees and contract employers must be informed and trained on the changes must be informed and trained on the changes prior to start-up. prior to start-up.

We must establish and implement written We must establish and implement written procedures to manage changes except procedures to manage changes except "replacements in kind" for a covered process."replacements in kind" for a covered process.

If a Change in Design or Components is If a Change in Design or Components is Required, Management of Change Must be Required, Management of Change Must be Employed, Tracked, and Analyzed. Employed, Tracked, and Analyzed.

All PHA’s, P&ID’s & Required Procedures All PHA’s, P&ID’s & Required Procedures Must be RevisedMust be Revised

Work-site employees and contract employers Work-site employees and contract employers must be informed and trained on the changes must be informed and trained on the changes prior to start-up. prior to start-up.

PSM Documentation - Technology UsePSM Documentation - Technology Use

Consider the Use of Consider the Use of Technology to:Technology to: PerformPerform DocumentDocument TrackTrack AdjustAdjust MaintainMaintain

The PSM ProgramThe PSM Program

Consider the Use of Consider the Use of Technology to:Technology to: PerformPerform DocumentDocument TrackTrack AdjustAdjust MaintainMaintain

The PSM ProgramThe PSM Program

What’s Next?What’s Next?

In the Next Session, we will Cover the Standard Operating Procedures and Safety Programs That Must Be Developed Based on the Results of the PHA’s

In the Next Session, we will Cover the Standard Operating Procedures and Safety Programs That Must Be Developed Based on the Results of the PHA’s