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TRANSCRIPT
Implementation Strategies for
PSM ● RMP ● CalARP
Regulatory Updates
Steven T. Maher, PE CSP
Risk Management Professionals
U.S. (877) 532-0806 ♦ www.RMPCorp.com
Key Topics
• Addressing Key Elements of
Regulatory Expansion/
Modernization Efforts (with
implementation tips)
• General Implementation
Strategies &
Resources
• Questions?
Addressing Key Elements of
CalARP, CalPSM-R, & RMP
Regulatory
Expansion/Modernization Efforts
(with Implementation Tips)
Types of Changes
Facility/Program
Applicability
ScheduleElements
PSM Elements
PSM
EP
PSI
PHA
OP
TRN
CON
PSSRMI
HWP
MOC
II
EP&R
CA
• Employee Participation
• Process Safety Information
• Process Hazard Analysis
• Operating Procedures
• Training
• Contractors
• Pre-Startup Safety Review
• Mechanical Integrity
• Hot Work Permit
• Management of Change
• Incident Investigation
• Emergency Planning &
Response
• Compliance Audits (CA-IIPP)
Impact Categories
• Following table follows 5189.1 Draft Regulation Table of Contents
• Three Main Categories
* indicates minimal changes to regulation or minimal effort needed for compliance
** indicates moderate changes to regulation or moderate effort needed for compliance
*** indicates new element or significant effort needed for compliance
CalPSM-R Elements
PSM-R
PSMPPSI
PHA
OP
TRN
CON
PSSR
MI
DMRIST/
HCA/STAA
HW
MOC
II-RCA
EP&R
EP
PSCA
HF
MOOC
CA
• Process Safety Information
• Process Hazard Analysis
• Operating Procedures
• Training
• Contractors
• Pre-Startup Safety Review
• Mechanical Integrity
• Damage Mechanism Review
• Hierarchy of Hazard Control
Analysis (IST/HCA/STAA)
• Hot Work
• Management of Change
• Incident Investigation - RCA
• Emergency Planning & Response
• Employee Participation
• Process Safety Culture Assessment
• Human Factors
• Management of Organizational
Change
• Compliance Audits
• PSM Program
Current Cal/OSHA, CalARP, & RMP Initiatives
Program ElementCalPSM-R
(Draft)
CalARP
(P4-Draft)
EPA-RMP
(P2/3-Draft)
Process Safety Information (PSI) * 5189.1(d) 2762.1 68.65
Process Hazard Analysis (PHA) *
Safeguard Protection Analysis (SPA) ** (CA-Only)5189.1(e)
2762.2
2762.2.168.50/67
Operating Procedures (OP) ** 5189.1(f) 2762.3 68.69
Training (TRN) * 5189.1(g) 2762.4 68.71
Contractors (CON) * 5189.1(h) 2762.12 68.87
Pre-Startup Safety Review (PSSR) * 5189.1(i) 2762.7 68.77
Mechanical Integrity (MI) *
Damage Mechanism Review (DMR) *** (CA-Only)
5189.(j)
5189.1(k)2762.5 68.73
IST / HCA / STAA *** 5189.1(l) 2762.13 68.67
Hot Work (HW) * 5189.1(m) 2762.11 68.85
Management of Change (MOC) ** 5189.1(n) 2762.6 68.75
Incident Inv. – Root Cause Analysis (II-RCA) ** 5189.1(o) 2762.9 68.81
Emergency Planning and Response (EP&R) *** 5189.1(p) 2765.2/3 68.95/96
Employee Participation (EP) * 5189.1(q) 2762.10 68.83
Process Safety Culture Assessment (PSCA) *** 5189.1(r) 2762.14 ---
Human Factors (HF) *** 5189.1(s) 2762.15 ---
Management of Organizational Change (MOOC) *** 5189.1(t) 2762.6 ---
Compliance Audits (CA) ** (Fed Rqmt. for 3rd Party) 5189.1(u) 2762.8 68.58/59/79/80
Process Safety Management Program (PSMP) ** 5189.1(v,w) 2762.16 ---
PHA-Related & MI-Related
Elements
PHA MI
SPA
DMRIST/HCA/STAA
Process Hazard Analysis (PHA)(CalPSM-R §5189.1(e), CalARP §2762.2)
• 2762.05(b) – “All portions of the petroleum refinery
are covered except” laboratories and low-hazard
utilities.
• PHA must address:
– DMRs and their recommendations
– HCAs and their recommendations
– External events
– Incident investigation findings
• The Iterative HCA Method must be applied “for all
PHA recommendations that result from a scenario
that identifies the potential for a major incident.”
PHA Requirements(continued)
• Recommendation closure process & timing clarified:
– Not requiring a process shutdown – within 30 months
– Requiring a process shutdown – next scheduled
turnaround
– Potential for death/serious physical harm – immediately
• PHAs must be retained for the life of the process.
– Includes recommendations and their documented
resolutions
• All new (i.e., not previously required) PHAs must be
completed within 3 years of CalARP/CalPSM-R
promulgation.
Safeguard Protection Analysis (SPA)(CalPSM-R §5189.1(e), CalARP §2762.2.1)
• Objectives:
– Assess the effectiveness of existing and combined safeguards for
each failure scenario identified in the PHA
– Assure that safeguards are independent of the initiating event and
each other
• Evaluate:
– Passive, Active, or Procedural Safeguards
– Using LOPA or “equally effective method”
• Risk reductions achieved by existing safeguards and
safeguards recommended in a PHA must be
documented.
• Conduct SPA and complete report within 6 months of
finalizing a PHA.
• The SPA report can be standalone or part of PHA.
• SPA reports must be retained for the life of the process.
SPA Implementation Tips
• Challenges– “Blending Issues” is Human Nature
– Common-Mode Failures Between Causes & Safeguards
– Over-crediting Operator Response Reliability
• Practical Implementation Guidance– Identify Root Transmitters for Causes & Safeguards
– Facilitator to Frequently Train the Team on Risk-Ranking
– Facilitator to Frequently Challenge the Team on Safeguard Effectiveness, Availability, & Reliability
– Partition Safeguards as IPLs
– Typically Group Alarms as a Single Safeguard
– Apply Risk-Graph & LOPA to Provide Additional Insights
– Apply Risk-Graph & LOPA for High Consequence/Risk Scenarios to Validate that a SIF is Not Needed
SPA Implementation Tips
• More Tips – Operator Response to Alarms –Reliability & Timing– Present to Hear the Alarm
– Alarm Prioritization & Diagnosis
– Permission for Corrective Action
– Initiating the Corrective Action
– Time for the Corrective Action to Mitigate the Event
• Actions Prior to CalARP & CalPSM-RPromulgation– SPA is effectively addressed by implementation of
best PHA practices.
– Implement best PHA practices.
Mechanical Integrity (MI)(CalPSM-R §5189.1(j), CalARP §2762.5)
• No discontinuities with current industry best practices
• Minimal substantive changes
• Clear instructions for safely conducting maintenance activities to be included in Mechanical Integrity Procedures
• Additional specificity on required documentation
• Clarification of records retention
• Additional specificity on availability of Mechanical Integrity Procedures and inspection documents
• Additional cross-referencing to Process Safety Information
• Addition of references to RAGAGEP
• For CalARP, DMR is located in 2762.5(f)
• Damage Mechanisms – mechanical, chemical,
physical or other process that results in equipment or
material degradation
• Damage Mechanism Review (DMR) Timing:
– Prior to any PHA and prior to changes affecting
chemistry, metallurgy, or operating limits
– Initial to take place at the earliest of the following:
• Initial DMR within 5 years (50% within 3 years of
CalARP/CalPSM-R promulgation)
• Revalidated every 5 years or prior to a major change
• Reviewed as part of an incident investigation
Damage Mechanism Review (DMR)(CalPSM-R §5189.1(k), CalARP §2762.5(f))
• At minimum, evaluate the following:
– Mechanical Loading Failure – Ductile fracture, brittle
fracture, buckling, mechanical fatigue
– Erosion – Abrasive wear, adhesive wear, fretting
– Corrosion – Uniform corrosion, localized corrosion,
pitting
– Thermal-Related Failure – Creep, thermal fatigue,
transformation
– Cracking – Stress-corrosion cracking
– Embrittlement – High Temperature
Hydrogen Attack (HTHA)
• DMR reports must be retained
for the life of the process.
DMR Requirements(continued)
DMR Implementation Spectrum
Enhanced
Contemporary
Best
Practices
Prioritized
DMR
Approach
iPHA
Less Effort Increased Effort, with Increased Insights
MI-Centered
Risk-Based
Assessment
DMR Implementation Tips
• Challenges– Ensure Regulatory Requirements are Met
– Effective Use of Facility Resources
– Minimizing Overlap with Other SMS Program Elements
– Maximizing Use of Efforts Completed for Other SMS Elements
DMR Implementation Tips
• Suggested Approaches– Maintain your current SMS HAZOP/MI activities.
– Initiate high-value DMR activities in the form of a Prioritized DMR.
– Apply quantitative risk techniques (e.g., API RP 581) selectively.
– Address high priority improvements and potential vulnerabilities.
– Initiate transition of SMS HAZOP/MI Program to maintain progress towards long-term DMR objectives.
– A Prioritized DMR is a minor increment to current PHA & MI efforts, is easily expanded, and is expected to satisfy DMR objectives.
– Suggested actions Prior to CalARP &CalPSM-R Promulgation
• Migrate towards Prioritized DMR.
• Evaluate need for more detailed analysis.
HCA(CalPSM-R §5189.1(l), CalARP §2762.13)
• Hierarchy of Hazard Control Analysis (HCA) – ranking of
prevention and control measures prioritized as follows:
– 1st Order Inherent Safety (e.g., safer chemicals) – prevents
incident
– 2nd Order Inherent Safety (e.g., inventory reduction, lower
temperature) – reduces severity/likelihood of incident
– Independent Protection Layer (IPL) – Safeguards (passive, active,
or procedural)
• Conduct the HCA for:
– All existing processes (50% within 3 years and all within 5 years of
CalARP/CalPSM-R promulgation), with a 5-year revalidation
– PHA recommendations addressing a “major incident potential”
– Major changes (as part of MOC)
– Major incidents
– New processes (including making the HCA available to the public)
– At the request of UPA
HCA Requirements(continued)
• Objective – “To reduce each risk to the greatest extent feasible”, Owner/Operator shall identify and evaluate all relevant inherent safety measures, e.g.:
• Control techniques or management systems that have been achieved in practice for petroleum refining or related industrial sectors
• Control techniques or management systems that have been required or recommended for petroleum refining and related industrial sectors
• Approach – Iterative HCA Method defined in 5189.1(z)
• Outcome – Employer shall “select and recommend” 1st & 2nd Order Inherent Safety Measures, unless documented as infeasible and the proposed alternatives are justified.
• Requirement for HCA to be a standalone analysis
• Report to be completed within 90 days of HCA completion
HCA Implementation Tips
• Effective Implementation– Briefing During PHA Synchronization Training
– List of ISD Considerations in the PHA Quick Reference:
• Minimize
• Substitute
• Moderate
• Simplify – More Robust
• Simplify – Human Factors
• Simplify – Facility Siting
– Document Inherently Safer SystemsReview as Separate Node
– Checklist for ISS Review onwww.CSB.gov and fromCCPS Guidebook
HCA Implementation Tips
• Timing– As Early As Possible During the Design Phase –
Minimize Capital Costs
– As Early As Possible During Plant Operation –Minimize Costs by Addressing Needs during Unit Turnarounds
• Actions Prior to CalARP & CalPSM-R Promulgation– Apply ISS checklists during PHA.
– Ensure that technological advances are discussed/considered during PHA.
– Ensure that use of different metallurgyis considered during Prioritized DMR.
HCA Implementation References
• Textbooks– CCPS Guidelines for Risk Based Process Safety
– Inherently Safer Chemical Processes: A Life Cycle Approach
– Process Plants: A Handbook for Inherently Safer Design
– CCPS Guidelines for Engineering Design for Process Safety
• Regulatory Guidance/Requirements– Contra Costa County HSD
– NJ Toxic Catastrophe Prevention Act (TCPA)
• Checklists– Available Within Textbooks & Regulatory Guidance
Documents
Incident Investigation (CalPSM-R §5189.1(o), CalARP §2762.9)
• Incident Investigation – Root Cause Analysis – Implement an effective Root Cause Analysis (RCA)
• Team must include a person with RCA expertise and oversight
– Team must investigate underlying management system causes (including organizational and safety culture)
– Review results of HCA and DMR as part of II
– Conduct DMR, PHA, HCA, and SPA (demonstrate if an analysis is not applicable)
– Developing recommendations – conduct DMR, PHA, HCA, and SPA. Recommendations have same implementation requirements as PHA.
– Timelines: • Assemble Team within 48 hours
• Initial Report within 90 days
• Final Report within 6 months
Process Safety Culture Assessment (PSCA)
(CalPSM-R §5189.1(r), CalARP §2762.14)
• PSCA Program should address:– Encouragement for reporting safety concerns
– Rewards do not deter reporting safety concerns
– Ensure safety is not compromised by production
– Process Safety Leadership at all levels
– Human Factors Program to be included for all PSM elements
• Written PSCA Program should include:– Methods used to assess PSC
– Conclusions from the PSCA
– Rationale of the conclusions
– Recommendations and action plan from PSCA
– Report to be completed within 90 days of PSCA end • Signed off by refinery manager
Management of Organizational Change (CalPSM-R §5189.1(t), CalARP §2762.6(i))
• Include MOOC assessment to address:– Experience levels of employees before and after the proposed
change
– Describe the change, team make-up, team rationale, and actions required to make the change
• Ensure job functions are up-to-date and accurate for all affected positions
• Document the following:– Results of analysis
– Team make up
– What factors were considered
– Decision to implement the change or not
– Basis for decision
– Necessary actions required to move forward with the change
• Shall include Human Factors analysis
• Employees potentially affected by change shall be given information prior to implementation
Human Factors(CalPSM-R §5189.1(s), CalARP §2762.15)
• Develop, implement & maintain written program
• Program should evaluate: – Staffing levels
– Complexity of and length of time needed to complete tasks
– Level of training and expertise of employees
– Human-machine interface and human-system interface
– Physical challenges of the work environment
– Employee fatigue and shiftwork/overtime
– Communications
– Understandability and clarity of SOPs and Maintenance Procedures
• Analysis of human factor controls on process equipment in incident investigation, PHAs, MOOCs, SPA, or HCAs (e.g., error proof mechanisms, automatic alerts, automatic system shutdowns for critical operational errors)
Human Factors(continued)
• Assess human factors in new SOPs and maintenance procedures
• Assess human factors in existing SOPs and maintenance procedures– Revise procedures accordingly
– 50% assessment complete within 2 years (following effective date of regulation)
– 100% assessment complete within 3 years (following effective date of regulation)
• Provide training to operations and maintenance personnel
• Ensure employee/representation in the development, implementation, and maintenance of the Human Factors Program
New Regulatory Updates
• From OSHA
– Interpretation Letters (June-July 2015):
• RAGAGEP Enforcement
– Guidance on how to document RAGAGEP
• Retail Exemption
– If the facility does not fall under SIC 44 or 45, it is
not eligible for the exemption
– Enforcement begins mid-July 2016 (12 months)
• Covered Concentration
– Uses EPA’s 1% policy, rather than “commercial
grade”
• Other Enforcement/Interpretation Letters are
reported to follow
New Regulatory Updates
• From California:
– SB-612:
• UPA General Duty Clause
• New mapping requirements
• Other changes to UPA Programs for UST/AST,
SPCC, hazardous waste
• http://leginfo.legislature.ca.gov/faces/billNavClien
t.xhtml?bill_id=201520160SB612
General Implementation
Strategies & Resources
Key Modernization Activities(Onshore Facilities)
www.RMPCorp.com/SMS_Regulatory_Updates/
EPA
IRTF
CCC & CoR
CalOES/CalEPA
CSB
OSHACal/OSHA
CalOES: California Office of Emergency Services; Cal/OSHA: California Occupational Safety & Health
Administration; CSB: Chemical Safety Board; EPA: United States Environmental Protection Agency; IRTF:
Interagency Refinery Task Force; OSHA: U.S. Occupational Safety & Health Administration; CalEPA:
California Environmental Protection Agency; CCC: Contra Costa County; CoR: City of Richmond
Status and What to Expect
• Chemical Safety Board (CSB)– April 2013, October 2014, January 2015 – All 3
Investigation Reports Published
– Investigation Completed, Recommendations Tracked
• U.S. EPA– 14Mar16 – “Proposed Rule Making” for RMP Updates
Published
– 13May16 – Deadline for Comments
– Final Regulation Promulgation – Estimated Summer 2017
• Federal OSHA– RFI Comments to be Processed
– Draft Regulations to be Generated
– Timeline – “Years, not Months”
– “Small Business Regulatory Flexibility Review Act”
Status and What to Expect
• Contra Costa County & City of Richmond
– June 2014 – Issued ISO 450-8 (“Risk Management”) & Analogous CoR ISO
– Current Initiative to Increase Involvement of Community Oversight Group in Process Safety Culture Assessments
• California Interagency Refinery Task Force (IRTF)
– Agency Meetings Continue
– Additional Reports Not Planned
• Cal/OSHA CalPSM-R
– 24Sep15 Updated Draft §5189.1 Issued
– Final Regulation Promulgation – Estimated Spring 2017
– Initially, 2 Separate PSM Regulations in California
– Initially, No Planned Synchronization w/Federal PSM/RMP
Status and What to Expect
• CalEPA & CalOES CalARP
– 01Jan15 – Promulgation of Minor Update to CalARP
– 24Sep15 Draft of Additional Update to Align with Draft
§5189.1
– Final Regulation Promulgation – Estimated Spring 2017
– Single CalARP Regulation with Additional
Requirements (Program 4) for
“High Hazard Facilities” (NAICS 32411)
– Initially, Harmonization with §5189.1,
but No Synchronization
w/Federal PSM/RMP
Overlap of Key Current CA SMS
Programs (Onshore Facilities)
PSM CalARP/RMP
EPHA
PSIPHA
OP
TRN
MI
MOC
PSSRII
EPR
HWPCON
M
i
n
i
m
a
l
CA
Overlap of Post-2016 CA SMS Programs
(Onshore Petroleum Refineries)
Fed-RMP – Post 2016 CalPSM-R (5189.1)
CalARP
EPPSI
PHA --- SPA
OPTRN
MI --- DMR
MOC --- MOOC
PSCAII-RCA
EPR
HWCON
HACA-3
IST/HCA/STAA
Schedule &
Other “Minor”
Differences
HF
PSMP
PSSR
Schedule &
Other “Minor”
DifferencesCA-1
EPR
EPR
What Should I be Doing Now?
• All California CalARP-Covered Facilities– Adherence to New 01Jan15 CalARP Requirements
• Contra Costa County & City of Richmond – 9 Facilities– Adherence to June 2014 CCC ISO 450-8 & Analogous
CoR ISO
• California Petroleum Refineries– Recommendation from a Key Regulator – Begin Applying
“High-Value/Priority” Elements of CalPSM-R & New CalARP Now – Once promulgated, “schedules will be tight,” and if substantial progress has been made addressing the spirit of the new requirements, “selective-’grandfathering’ may be allowed.” Tight schedules could result in a shortage of qualified resources.
– Some elements (e.g., IST/HCA/STAA) are significantly more cost-effective in the design-phase, or at the earliest possible opportunity.
What Should I be Doing Now?
• U.S. PSM/RMP-Covered Petroleum Processing Facilities– Awareness of CalPSM-R for Best Practices for
“High Hazard Facilities”
• All – Closely Monitor Regulatory Changes
• Potential For– Later expansion to other highly-hazardous facilities
in California
– Later expansion to non-Californiapetroleum refineries & others
– Inference to new requirementsas best practice
– General Duty Clause Correlation -SB 612 clarifies Owner/Operatorresponsibilities.
Resources for Handling Evolving
Requirements• HAZOP/LOPA Facilitation Webinar Series (Module 10) – Effective approaches to
handling CSB recommendations and PSM and CalARP changes
– DMR
– SPA
– Inherently Safer Technology/Design (i.e., IST/HCA/STAA)
• 2015 Global Congress on Process Safety – Papers
– Maher, Nour, Schultz, “Effectively Addressing New PSM/RMP Damage Mechanism
Review Requirements with an Integrated PHA (iPHA)”
• 2016 Global Congress on Process Safety – Papers
– Maher, Metulev, “PSM/RMP Modernization Programs in California New Developments &
Correlation to Evolution at the Federal Level”
• Webinars – Updates on the PSM/RMP Regulatory Modernization Programs
– 19Aug14 – 25Sep14
– 22Jan15 – 09Apr15
– 25Jun15 – 30Jul15
– 27Aug15
– 29Oct15 – Regional Seminar – Simulcast as Webinar
• Webinar – DMR and the Integrated PHA (iPHA)
Approach – 26Mar15 & 27Aug15 (w/simpifications)
• Links are provided on www.RMPCorp.com/SMS_Regulatory_Updates/
Summary & Conclusion
• Agencies have taken a fresh look at SMS Programs.
• California and Refineries have biggest changes.
• Potential For:– Expansion
– Link to General Duty Clause & Best Practices
• Initial promulgation will not be synchronized with federal requirements, but plan to harmonize CalARP & CalPSM-R.
• Potential for long-term movementtowards synchronization.
• There are “easy“ steps to take nowto infuse some of the newrequirements into yourPSM/RMP/CalARP activities.
Summary & Conclusion
• Recommendation from a Key Regulator – Begin
Applying “High-Value/Priority” Elements of CalPSM-R Now
– Once promulgated, “schedule will be tight,” and if
substantial progress has been made, selective-
”grandfathering” may be allowed.
• Tight schedules could result in a resource shortage.
• In addition, some elements (e.g., IST/HCA/STAA) are
significantly more cost-effective in the design-phase, or at
the earliest possible opportunity.
• Risk Management & Process Safety Professionals should:
– Carefully monitor modernization programs.
– Focus on charting the course for the
long-term success of your facility’s programs.
– Develop a strategy for effective
implementation.
