psm-compliance.ppt

29CFR1910.11929CFR1910.119Simple Keys to ComplianceSimple Keys to Compliance

29CFR1910.11929CFR1910.119Simple Keys to ComplianceSimple Keys to Compliance

Process Safety Management of Highly Hazardous & Explosive Chemicals

Process Safety Management of Highly Hazardous & Explosive Chemicals

ObjectivesObjectives

Define what is PSM and who is covered Define what is PSM and who is covered by the standardby the standard

List the elements of the PSM standardList the elements of the PSM standardLocate additional resourcesLocate additional resources

Define what is PSM and who is covered Define what is PSM and who is covered by the standardby the standard

List the elements of the PSM standardList the elements of the PSM standardLocate additional resourcesLocate additional resources

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What Is Process Safety Management?What Is Process Safety Management?

PSM:PSM: Addresses the management of Highly Addresses the management of Highly

Hazardous Chemicals (HHC)Hazardous Chemicals (HHC)

Integrates Integrates TechnologyTechnologyOperating ProceduresOperating ProceduresStandard management protocolsStandard management protocols

PSM:PSM: Addresses the management of Highly Addresses the management of Highly

Hazardous Chemicals (HHC)Hazardous Chemicals (HHC)

Integrates Integrates TechnologyTechnologyOperating ProceduresOperating ProceduresStandard management protocolsStandard management protocols

3

Why Did OSHA Develop PSM?Why Did OSHA Develop PSM?

Past DisastersPast DisastersCurrent DisastersCurrent DisastersPerceived Weakness in PSM Perceived Weakness in PSM

ProgramProgram

Past DisastersPast DisastersCurrent DisastersCurrent DisastersPerceived Weakness in PSM Perceived Weakness in PSM

ProgramProgram

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Bhopal, India (1984)Bhopal, India (1984) 2,000 deaths 2,000 deaths

Isocyanate releaseIsocyanate release Pasadena, TX (1989)Pasadena, TX (1989)

23 deaths, 132 injuries 23 deaths, 132 injuries Petroleum explosionPetroleum explosion

Cincinnati, OH (1990)Cincinnati, OH (1990) 2 deaths 2 deaths

ExplosionExplosion Sterlington, LA (1991) Sterlington, LA (1991)

8 deaths, 128 injuries 8 deaths, 128 injuries Chemical releaseChemical release

Bhopal, India (1984)Bhopal, India (1984) 2,000 deaths 2,000 deaths

Isocyanate releaseIsocyanate release Pasadena, TX (1989)Pasadena, TX (1989)

23 deaths, 132 injuries 23 deaths, 132 injuries Petroleum explosionPetroleum explosion

Cincinnati, OH (1990)Cincinnati, OH (1990) 2 deaths 2 deaths

ExplosionExplosion Sterlington, LA (1991) Sterlington, LA (1991)

8 deaths, 128 injuries 8 deaths, 128 injuries Chemical releaseChemical release

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In 1991, OSHA and In 1991, OSHA and EPA respectively, EPA respectively, Released the Released the Standards, PSM & Standards, PSM & RMP that Applies to RMP that Applies to Those Companies Those Companies that are Affected by that are Affected by The Standards.The Standards.

In 1991, OSHA and In 1991, OSHA and EPA respectively, EPA respectively, Released the Released the Standards, PSM & Standards, PSM & RMP that Applies to RMP that Applies to Those Companies Those Companies that are Affected by that are Affected by The Standards.The Standards.


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Process Safety Process Safety ManagementManagement is a is a regulation, promulgated regulation, promulgated by OSHA, intended to by OSHA, intended to prevent an incident like prevent an incident like the 1984 Bhopal Disasterthe 1984 Bhopal Disaster

And…to Prevent Release And…to Prevent Release of:of: Toxic, Toxic, Reactive, Reactive, Flammable, or Flammable, or Explosive chemicalsExplosive chemicals

Process Safety Process Safety ManagementManagement is a is a regulation, promulgated regulation, promulgated by OSHA, intended to by OSHA, intended to prevent an incident like prevent an incident like the 1984 Bhopal Disasterthe 1984 Bhopal Disaster

And…to Prevent Release And…to Prevent Release of:of: Toxic, Toxic, Reactive, Reactive, Flammable, or Flammable, or Explosive chemicalsExplosive chemicals


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Not Only PSM, But RMPNot Only PSM, But RMP

A great many industrial A great many industrial facilities must comply facilities must comply with OSHA's Process with OSHA's Process Safety Management Safety Management (PSM) regulations as (PSM) regulations as well as the CAA 112(r) well as the CAA 112(r) EPA Risk EPA Risk Management Program Management Program (RMP) regulations (RMP) regulations (Title 40 CFR Part 68). (Title 40 CFR Part 68).

A great many industrial A great many industrial facilities must comply facilities must comply with OSHA's Process with OSHA's Process Safety Management Safety Management (PSM) regulations as (PSM) regulations as well as the CAA 112(r) well as the CAA 112(r) EPA Risk EPA Risk Management Program Management Program (RMP) regulations (RMP) regulations (Title 40 CFR Part 68). (Title 40 CFR Part 68).

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PSM vs. RMP - What’s the Difference?PSM vs. RMP - What’s the Difference?

RMP-Like Sara Title IIIRMP-Like Sara Title III Protects the Protects the

CommunityCommunity Protects the General Protects the General

Public Around the Public Around the FacilityFacility

Protects Adjacent Protects Adjacent Facilities Such as Facilities Such as Schools & HospitalsSchools & Hospitals

RMP-Like Sara Title IIIRMP-Like Sara Title III Protects the Protects the

CommunityCommunity Protects the General Protects the General

Public Around the Public Around the FacilityFacility

Protects Adjacent Protects Adjacent Facilities Such as Facilities Such as Schools & HospitalsSchools & Hospitals

PSM - Like HAZCOMPSM - Like HAZCOM Protects the Protects the

WorkforceWorkforce Protects ContractorsProtects Contractors Protects Visitors to Protects Visitors to

the Facilitythe Facility Basically Protects the Basically Protects the

Workplace Workplace

PSM - Like HAZCOMPSM - Like HAZCOM Protects the Protects the

WorkforceWorkforce Protects ContractorsProtects Contractors Protects Visitors to Protects Visitors to

the Facilitythe Facility Basically Protects the Basically Protects the

Workplace Workplace

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The Standard Was Promulgated in 1991 - Is it Working?The Standard Was Promulgated in 1991 - Is it Working?

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BP Products Texas BP Products Texas City - City - March 2005March 2005 15 Workers Killed15 Workers Killed 170 Injured170 Injured Major Property Major Property

DamageDamage $50.6 Million in Fines$50.6 Million in Fines

BP Products Texas BP Products Texas City - City - March 2005March 2005 15 Workers Killed15 Workers Killed 170 Injured170 Injured Major Property Major Property

DamageDamage $50.6 Million in Fines$50.6 Million in Fines

The Standard Was Promulgated in 1991 - Is it Working?The Standard Was Promulgated in 1991 - Is it Working?

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ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the Technology of the

ProcessProcess Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance



The Elements of the PSM StandardThe Elements of the PSM Standard

Process Hazard Process Hazard AnalysisAnalysis

Management of ChangeManagement of Change Operating ProceduresOperating Procedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &

ResponseResponse Incident InvestigationIncident Investigation Compliance AuditsCompliance Audits Trade SecretsTrade Secrets




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ProcessProcess Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing


ProcessProcess Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing








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Process Hazard AnalysisProcess Hazard Analysis Management of Management of

ChangeChange Operating ProceduresOperating Procedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &





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The Elements of the PSM StandardThe Elements of the PSM Standard Process Hazard AnalysisProcess Hazard Analysis

Management of ChangeManagement of Change Operating Operating

ProceduresProcedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &


Process Hazard AnalysisProcess Hazard Analysis Management of ChangeManagement of Change Operating Operating

ProceduresProcedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &


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ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee Employee

ParticipationParticipation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the ProcessTechnology of the Process Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance

ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee Employee

ParticipationParticipation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the ProcessTechnology of the Process Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance




Process Hazard AnalysisProcess Hazard Analysis Management of ChangeManagement of Change Operating ProceduresOperating Procedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &


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ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the ProcessTechnology of the Process Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance



Management of ChangeManagement of Change Operating ProceduresOperating Procedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor Contractor

ManagementManagement Emergency Planning & Emergency Planning &


Process Hazard AnalysisProcess Hazard Analysis Management of ChangeManagement of Change Operating ProceduresOperating Procedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor Contractor

ManagementManagement Emergency Planning & Emergency Planning &


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Management of ChangeManagement of Change Operating ProceduresOperating Procedures Pre-Start up Safety Pre-Start up Safety

ReviewReview Hot Work PermitHot Work Permit Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & Emergency Planning &

ResponseResponse

Process Hazard AnalysisProcess Hazard Analysis Management of ChangeManagement of Change Operating ProceduresOperating Procedures Pre-Start up Safety Pre-Start up Safety


ResponseResponse

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ResponseResponse



ResponseResponse

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ReviewReview Hot Work PermitHot Work Permit Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning Emergency Planning

& Response& Response


ReviewReview Hot Work PermitHot Work Permit Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning Emergency Planning

& Response& Response

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ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the ProcessTechnology of the Process Equipment in the Equipment in the

ProcessProcess Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance

ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the ProcessTechnology of the Process Equipment in the Equipment in the





ResponseResponse



ResponseResponse

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ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the ProceTechnology of the Processss Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance

ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the ProceTechnology of the Processss Equipment in the ProcessEquipment in the Process Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance




ResponseResponse



ResponseResponse

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ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the ProceTechnology of the Processss Equipment in the Equipment in the


ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the ProceTechnology of the Processss Equipment in the Equipment in the





ResponseResponse



ResponseResponse

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The Elements of the PSM Standard

The Elements of the PSM Standard

Let’s Explore Some of the Elements…Let’s Explore Some of the Elements…Let’s Explore Some of the Elements…Let’s Explore Some of the Elements…

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ApplicationApplication

1910.119(a)1910.119(a)1910.119(a)1910.119(a)

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What Facilities are CoveredWhat Facilities are Covered

Those Who Use Chemicals in Appendix A: A List of Those Who Use Chemicals in Appendix A: A List of highly hazardous chemicals, toxics and reactive highly hazardous chemicals, toxics and reactive (Mandatory). Contains a listing of toxic and reactive (Mandatory). Contains a listing of toxic and reactive highly hazardous chemicals which present a potential highly hazardous chemicals which present a potential for a catastrophic event at or above the threshold for a catastrophic event at or above the threshold quantityquantity

ExamplesExamples

Chemical Chemical Threshold Quantity (TQ) Threshold Quantity (TQ) Anhydrous Ammonia 10,000 lbsAnhydrous Ammonia 10,000 lbs Chlorine 1,500 lbsChlorine 1,500 lbs

Those Who Use Chemicals in Appendix A: A List of Those Who Use Chemicals in Appendix A: A List of highly hazardous chemicals, toxics and reactive highly hazardous chemicals, toxics and reactive (Mandatory). Contains a listing of toxic and reactive (Mandatory). Contains a listing of toxic and reactive highly hazardous chemicals which present a potential highly hazardous chemicals which present a potential for a catastrophic event at or above the threshold for a catastrophic event at or above the threshold quantityquantity

ExamplesExamples

Chemical Chemical Threshold Quantity (TQ) Threshold Quantity (TQ) Anhydrous Ammonia 10,000 lbsAnhydrous Ammonia 10,000 lbs Chlorine 1,500 lbsChlorine 1,500 lbs

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A process which A process which involves a involves a flammable liquid or flammable liquid or gas (as defined in gas (as defined in 1910.1200(c) of this 1910.1200(c) of this part) on-site in one part) on-site in one location, in a location, in a quantity of 10,000 quantity of 10,000 pounds (4535.9 kg) pounds (4535.9 kg) or moreor more

A process which A process which involves a involves a flammable liquid or flammable liquid or gas (as defined in gas (as defined in 1910.1200(c) of this 1910.1200(c) of this part) on-site in one part) on-site in one location, in a location, in a quantity of 10,000 quantity of 10,000 pounds (4535.9 kg) pounds (4535.9 kg) or moreor more


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Important Interpretation: 2007 - 06/11/2007 - OSHA Important Interpretation: 2007 - 06/11/2007 - OSHA defines "on-site in one location" for Process Safety defines "on-site in one location" for Process Safety Management of Highly Hazardous Chemicals standardManagement of Highly Hazardous Chemicals standard

OSHA interprets "on-site in one location" to mean that the OSHA interprets "on-site in one location" to mean that the standard applies when a threshold quantity of a highly standard applies when a threshold quantity of a highly hazardous chemical (HHC) exists within an area under hazardous chemical (HHC) exists within an area under the control of an employer or group of affiliated the control of an employer or group of affiliated employers. It also applies to any group of vessels that employers. It also applies to any group of vessels that are interconnected, or in separate vessels that are are interconnected, or in separate vessels that are close enough in proximity that the HHC could be close enough in proximity that the HHC could be involved in a potential catastrophic release.involved in a potential catastrophic release.

Important Interpretation: 2007 - 06/11/2007 - OSHA Important Interpretation: 2007 - 06/11/2007 - OSHA defines "on-site in one location" for Process Safety defines "on-site in one location" for Process Safety Management of Highly Hazardous Chemicals standardManagement of Highly Hazardous Chemicals standard

OSHA interprets "on-site in one location" to mean that the OSHA interprets "on-site in one location" to mean that the standard applies when a threshold quantity of a highly standard applies when a threshold quantity of a highly hazardous chemical (HHC) exists within an area under hazardous chemical (HHC) exists within an area under the control of an employer or group of affiliated the control of an employer or group of affiliated employers. It also applies to any group of vessels that employers. It also applies to any group of vessels that are interconnected, or in separate vessels that are are interconnected, or in separate vessels that are close enough in proximity that the HHC could be close enough in proximity that the HHC could be involved in a potential catastrophic release.involved in a potential catastrophic release.


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Affect of the “Meer” Decision:Affect of the “Meer” Decision:

MEER ruling and theMEER ruling and the MEER Memorandum addressed in the MEER Memorandum addressed in the Secretary's letter, OSHA's enforcement policy that the Secretary's letter, OSHA's enforcement policy that the Agency would not cite employers forAgency would not cite employers for violations of 1910.119 violations of 1910.119 where stored flammable liquids in atmospheric tanks were where stored flammable liquids in atmospheric tanks were connected to a process, unless the process outside ofconnected to a process, unless the process outside of the the amount in storage contained more than 10,000 pounds of amount in storage contained more than 10,000 pounds of the substancethe substance

Affect of the “Meer” Decision:Affect of the “Meer” Decision:

MEER ruling and theMEER ruling and the MEER Memorandum addressed in the MEER Memorandum addressed in the Secretary's letter, OSHA's enforcement policy that the Secretary's letter, OSHA's enforcement policy that the Agency would not cite employers forAgency would not cite employers for violations of 1910.119 violations of 1910.119 where stored flammable liquids in atmospheric tanks were where stored flammable liquids in atmospheric tanks were connected to a process, unless the process outside ofconnected to a process, unless the process outside of the the amount in storage contained more than 10,000 pounds of amount in storage contained more than 10,000 pounds of the substancethe substance


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What Types of Industries?What Types of Industries?

Industries that Process Chemicals Such As:Industries that Process Chemicals Such As: Industrial Organics & InorganicsIndustrial Organics & Inorganics PaintsPaints PharmaceuticalsPharmaceuticals AdhesivesAdhesives Sealants and FibersSealants and Fibers Petrochemical facilitiesPetrochemical facilities Paper MillsPaper Mills Food Processing with Anhydrous Ammonia over Food Processing with Anhydrous Ammonia over

the TQthe TQ

Industries that Process Chemicals Such As:Industries that Process Chemicals Such As: Industrial Organics & InorganicsIndustrial Organics & Inorganics PaintsPaints PharmaceuticalsPharmaceuticals AdhesivesAdhesives Sealants and FibersSealants and Fibers Petrochemical facilitiesPetrochemical facilities Paper MillsPaper Mills Food Processing with Anhydrous Ammonia over Food Processing with Anhydrous Ammonia over

the TQthe TQ

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ExclusionsExclusions

1910.119(a)(1)(ii)(A)1910.119(a)(1)(ii)(A)1910.119(a)(1)(ii)(A)1910.119(a)(1)(ii)(A)

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There are ExclusionsThere are Exclusions

An employer is exempt from the requirements of PSM An employer is exempt from the requirements of PSM when:when:

A threshold quantity of flammable liquids is stored in A threshold quantity of flammable liquids is stored in atmospheric tanks or transferred without the benefit of atmospheric tanks or transferred without the benefit of chilling or refrigeration chilling or refrigeration

Hydrocarbon fuels used solely for workplace Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling), heating, gasoline for vehicle refueling), If such fuels are not a part of a process containing If such fuels are not a part of a process containing

another highly hazardous chemical covered by this another highly hazardous chemical covered by this standardstandard

An employer is exempt from the requirements of PSM An employer is exempt from the requirements of PSM when:when:

A threshold quantity of flammable liquids is stored in A threshold quantity of flammable liquids is stored in atmospheric tanks or transferred without the benefit of atmospheric tanks or transferred without the benefit of chilling or refrigeration chilling or refrigeration

Hydrocarbon fuels used solely for workplace Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling), heating, gasoline for vehicle refueling), If such fuels are not a part of a process containing If such fuels are not a part of a process containing

another highly hazardous chemical covered by this another highly hazardous chemical covered by this standardstandard

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Retail facilities;Retail facilities;

Oil or gas well drilling or Oil or gas well drilling or

servicing operations; or,servicing operations; or,

Normally unoccupied Normally unoccupied

remote facilitiesremote facilities

Retail facilities;Retail facilities;

Oil or gas well drilling or Oil or gas well drilling or

servicing operations; or,servicing operations; or,

Normally unoccupied Normally unoccupied

remote facilitiesremote facilities

There are ExclusionsThere are Exclusions

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Employee ParticipationEmployee Participation

1910.119(c)1910.119(c)1910.119(c)1910.119(c)

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Now that we are required to comply, then what? Now that we are required to comply, then what? Form a Team in Form a Team in

Your Company, i.e..Your Company, i.e.. Process EngineersProcess Engineers OperatorsOperators SafetySafety MaintenanceMaintenance ManagementManagement ConsultantsConsultants

Form a Team in Form a Team in Your Company, i.e..Your Company, i.e.. Process EngineersProcess Engineers OperatorsOperators SafetySafety MaintenanceMaintenance ManagementManagement ConsultantsConsultants

Remember…You Can’t Do it Alone!

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Form a Plan, Form a Plan, Determine:Determine: ResponsibilitiesResponsibilities DutiesDuties ReportingReporting Document ControlDocument Control Progress ReportsProgress Reports Tracking ChangesTracking Changes

Form a Plan, Form a Plan, Determine:Determine: ResponsibilitiesResponsibilities DutiesDuties ReportingReporting Document ControlDocument Control Progress ReportsProgress Reports Tracking ChangesTracking Changes

Now that we are required to comply, then what? Now that we are required to comply, then what?

Then…Begin the Process of Developing & Implementing the PSM Program

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Hazards of the ProcessHazards of the Process

1910.119(d)(1)1910.119(d)(1)1910.119(d)(1)1910.119(d)(1)

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The Requirements of the Standard - Hazard Determination

The Requirements of the Standard - Hazard Determination

Determine:Determine:

Chemicals in Your ProcessChemicals in Your ProcessProcess ChemistryProcess ChemistryQuantity of Chemicals in lbsQuantity of Chemicals in lbsCompare to Appendix A List with Compare to Appendix A List with

Threshold Quantities (TQ’s)Threshold Quantities (TQ’s)

Determine:Determine:

Chemicals in Your ProcessChemicals in Your ProcessProcess ChemistryProcess ChemistryQuantity of Chemicals in lbsQuantity of Chemicals in lbsCompare to Appendix A List with Compare to Appendix A List with

Threshold Quantities (TQ’s)Threshold Quantities (TQ’s)

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Toxicity InformationToxicity Information

1910.119(d)(1)(i)1910.119(d)(1)(i)1910.119(d)(1)(i)1910.119(d)(1)(i)

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The Requirements of the Standard - Develop Toxicity Information

The Requirements of the Standard - Develop Toxicity Information

Obtain Toxicity Obtain Toxicity Information on the Information on the Chemical(s) in the Chemical(s) in the ProcessProcess

MSDS are Typical MSDS are Typical ResourceResource

You May Need You May Need Other References, Other References, NIOSH Pocket NIOSH Pocket Guide, ACGIH TLV’sGuide, ACGIH TLV’s

Obtain Toxicity Obtain Toxicity Information on the Information on the Chemical(s) in the Chemical(s) in the ProcessProcess

MSDS are Typical MSDS are Typical ResourceResource

You May Need You May Need Other References, Other References, NIOSH Pocket NIOSH Pocket Guide, ACGIH TLV’sGuide, ACGIH TLV’s

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Technology of the ProcessTechnology of the Process

1910.119(d)(2)1910.119(d)(2)1910.119(d)(2)1910.119(d)(2)

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The Requirements of the Standard - Process Technology

The Requirements of the Standard - Process Technology

Block flow diagram Block flow diagram or process flow or process flow diagramdiagram

Process chemistryProcess chemistry Maximum intended Maximum intended

inventoryinventory Upper and lower Upper and lower

limitslimits Consequences of Consequences of

deviationsdeviations

Block flow diagram Block flow diagram or process flow or process flow diagramdiagram

Process chemistryProcess chemistry Maximum intended Maximum intended

inventoryinventory Upper and lower Upper and lower

limitslimits Consequences of Consequences of

deviationsdeviations43

The Requirements of the Standard - Process Equipment


Materials of Materials of constructionconstruction

Process and instrument Process and instrument drawings (P&ID’s)drawings (P&ID’s)

Electrical classificationElectrical classification Relief system designRelief system design Ventilation system Ventilation system

designdesign Design codesDesign codes Material and energy Material and energy

balancesbalances Safety systemsSafety systems

Materials of Materials of constructionconstruction

Process and instrument Process and instrument drawings (P&ID’s)drawings (P&ID’s)

Electrical classificationElectrical classification Relief system designRelief system design Ventilation system Ventilation system

designdesign Design codesDesign codes Material and energy Material and energy

balancesbalances Safety systemsSafety systems

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Equipment in the Process Equipment in the Process

1910.119(d)(3)1910.119(d)(3)1910.119(d)(3)1910.119(d)(3)

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Now:Now: Identify Each Piece of Identify Each Piece of

Equipment in the Equipment in the Covered Process by Covered Process by P&ID, Block Diagram P&ID, Block Diagram and Number Themand Number Them

Remember - Must Remember - Must Follow Form Follow Form

Must be Able to Track Must be Able to Track Each Number Through Each Number Through the Entire Programthe Entire Program

Now:Now: Identify Each Piece of Identify Each Piece of

Equipment in the Equipment in the Covered Process by Covered Process by P&ID, Block Diagram P&ID, Block Diagram and Number Themand Number Them

Remember - Must Remember - Must Follow Form Follow Form

Must be Able to Track Must be Able to Track Each Number Through Each Number Through the Entire Programthe Entire Program

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Mechanical IntegrityMechanical Integrity

1910.119(j)1910.119(j)1910.119(j)1910.119(j)

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Mechanical Integrity CertificatesMust be Obtained for Each Element of the ProcessMust be Marked with Numbering System that Follows Form

Mechanical Integrity CertificatesMust be Obtained for Each Element of the ProcessMust be Marked with Numbering System that Follows Form



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Process Hazard Analysis (PHA)

Process Hazard Analysis (PHA)

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

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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

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

Performed by Your PSM TeamPerformed by Your PSM TeamTakes Significant Time & EffortTakes Significant Time & EffortPHA’s are Never EndingPHA’s are Never Ending

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

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

Performed by Your PSM TeamPerformed by Your PSM TeamTakes Significant Time & EffortTakes Significant Time & EffortPHA’s are Never EndingPHA’s are Never Ending

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Process Hazard AnalysisProcess Hazard Analysis

A PHA Process Must be Performed on Each Element of the Covered Process:A PHA From Block Diagram to P&ID to Every Equipment Component to Determine What Might Happen if an Element of the Covered Process Fails

A PHA Process Must be Performed on Each Element of the Covered Process:A PHA From Block Diagram to P&ID to Every Equipment Component to Determine What Might Happen if an Element of the Covered Process Fails

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There is Much More to PSMThere is Much More to PSM Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance Management of ChangeManagement of Change Operating ProceduresOperating Procedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & ResponseEmergency Planning & Response Incident InvestigationIncident Investigation Compliance AuditsCompliance Audits Trade SecretsTrade Secrets

Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance Management of ChangeManagement of Change Operating ProceduresOperating Procedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor ManagementContractor Management Emergency Planning & ResponseEmergency Planning & Response Incident InvestigationIncident Investigation Compliance AuditsCompliance Audits Trade SecretsTrade Secrets

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Management of ChangeManagement of Change

Procedures to manage changes to the Procedures to manage changes to the covered process.covered process. Exception: “replacement in kind”Exception: “replacement in kind”

Management of Change includes:Management of Change includes: Process chemicalsProcess chemicals TechnologyTechnology EquipmentEquipment Operating ProceduresOperating Procedures FacilitiesFacilities

Procedures to manage changes to the Procedures to manage changes to the covered process.covered process. Exception: “replacement in kind”Exception: “replacement in kind”

Management of Change includes:Management of Change includes: Process chemicalsProcess chemicals TechnologyTechnology EquipmentEquipment Operating ProceduresOperating Procedures FacilitiesFacilities

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Management of Change AddressesManagement of Change Addresses

1.1. Technical basis of the changeTechnical basis of the change2.2. Impact to employee safety and healthImpact to employee safety and health3.3. Modification to operating proceduresModification to operating procedures4.4. Time period for changeTime period for change5.5. Authorization of changeAuthorization of change

1.1. Technical basis of the changeTechnical basis of the change2.2. Impact to employee safety and healthImpact to employee safety and health3.3. Modification to operating proceduresModification to operating procedures4.4. Time period for changeTime period for change5.5. Authorization of changeAuthorization of change

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Operating ProceduresOperating ProceduresDevelop and implement written Develop and implement written

operating procedures that are clear operating procedures that are clear instructions for all expected phases of instructions for all expected phases of operations.operations.

AKA – Standard Operating Procedures AKA – Standard Operating Procedures (SOPs) (SOPs)

Must cover:Must cover: Operation phaseOperation phase Operational limitsOperational limits Safety & health considerationsSafety & health considerations

Develop and implement written Develop and implement written operating procedures that are clear operating procedures that are clear instructions for all expected phases of instructions for all expected phases of operations.operations.

AKA – Standard Operating Procedures AKA – Standard Operating Procedures (SOPs) (SOPs)

Must cover:Must cover: Operation phaseOperation phase Operational limitsOperational limits Safety & health considerationsSafety & health considerations

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OPs Must AddressOPs Must Address Initial start-upInitial start-upNormal operationsNormal operationsTemporary operationsTemporary operationsEmergency shutdownEmergency shutdownEmergency operationsEmergency operationsNormal shutdownNormal shutdownStart-up following turnaroundStart-up following turnaroundConsequences of deviationConsequences of deviationSteps required to correct or avoid deviationSteps required to correct or avoid deviation

Initial start-upInitial start-upNormal operationsNormal operationsTemporary operationsTemporary operationsEmergency shutdownEmergency shutdownEmergency operationsEmergency operationsNormal shutdownNormal shutdownStart-up following turnaroundStart-up following turnaroundConsequences of deviationConsequences of deviationSteps required to correct or avoid deviationSteps required to correct or avoid deviation

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SOPsSOPsMust be readily available to employeesMust be readily available to employeesMust be reviewed as needed to ensure Must be reviewed as needed to ensure

they reflect current operating practicce.they reflect current operating practicce.Must cover:Must cover:

Process chemicalsProcess chemicals Technology and equipmentTechnology and equipment FacilitiesFacilities

SOPs must be certified annually that SOPs must be certified annually that they are correct and accurate.they are correct and accurate.

Must be readily available to employeesMust be readily available to employeesMust be reviewed as needed to ensure Must be reviewed as needed to ensure

they reflect current operating practicce.they reflect current operating practicce.Must cover:Must cover:

Process chemicalsProcess chemicals Technology and equipmentTechnology and equipment FacilitiesFacilities

SOPs must be certified annually that SOPs must be certified annually that they are correct and accurate.they are correct and accurate.

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Safe Work Practices (SWPs)Safe Work Practices (SWPs)Must be developed and implemented to Must be developed and implemented to

provide for the control of hazards during provide for the control of hazards during work activities such as:work activities such as: Lock-out/Tag-outLock-out/Tag-out Confined space entryConfined space entry Opening processes, piping or equipmentOpening processes, piping or equipment

Must be developed and implemented to Must be developed and implemented to provide for the control of hazards during provide for the control of hazards during work activities such as:work activities such as: Lock-out/Tag-outLock-out/Tag-out Confined space entryConfined space entry Opening processes, piping or equipmentOpening processes, piping or equipment

58

TrainingTrainingPSM specific training is requiredPSM specific training is required

Must cover:Must cover: Safety and health hazards associated with Safety and health hazards associated with

the covered processthe covered process Safe work practicesSafe work practices

Refresher training is required every 3 Refresher training is required every 3 years or as needed to ensure years or as needed to ensure employees are complying with all PSM employees are complying with all PSM requirementsrequirements

PSM specific training is requiredPSM specific training is required

Must cover:Must cover: Safety and health hazards associated with Safety and health hazards associated with

the covered processthe covered process Safe work practicesSafe work practices

Refresher training is required every 3 Refresher training is required every 3 years or as needed to ensure years or as needed to ensure employees are complying with all PSM employees are complying with all PSM requirementsrequirements

59

ContractorsContractorsContractors involved in or around a Contractors involved in or around a

covered process must be informed of covered process must be informed of required PSM elements.required PSM elements.

Contract work includes:Contract work includes: Maintenance and repairMaintenance and repair Turn aroundTurn around Major renovationsMajor renovations Specialty knowledge or servicesSpecialty knowledge or services

Does not include support services not Does not include support services not involved with the covered process, like involved with the covered process, like laundry or vending machine supplylaundry or vending machine supply

Contractors involved in or around a Contractors involved in or around a covered process must be informed of covered process must be informed of required PSM elements.required PSM elements.

Contract work includes:Contract work includes: Maintenance and repairMaintenance and repair Turn aroundTurn around Major renovationsMajor renovations Specialty knowledge or servicesSpecialty knowledge or services

Does not include support services not Does not include support services not involved with the covered process, like involved with the covered process, like laundry or vending machine supplylaundry or vending machine supply

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Emergency Action Plans (EAP)Emergency Action Plans (EAP)Must have EAP for entire facilityMust have EAP for entire facilityEAP must have provisions for small EAP must have provisions for small

releases of HHCsreleases of HHCsDevelop a Early Warning Method for Develop a Early Warning Method for

Releases Releases Train on the Meaning of the AlarmsTrain on the Meaning of the AlarmsDevelop Emergency Evacuation Written Develop Emergency Evacuation Written

Plans, Evacuation Maps & Assembly Plans, Evacuation Maps & Assembly PointsPoints

Must have EAP for entire facilityMust have EAP for entire facilityEAP must have provisions for small EAP must have provisions for small

releases of HHCsreleases of HHCsDevelop a Early Warning Method for Develop a Early Warning Method for

Releases Releases Train on the Meaning of the AlarmsTrain on the Meaning of the AlarmsDevelop Emergency Evacuation Written Develop Emergency Evacuation Written

Plans, Evacuation Maps & Assembly Plans, Evacuation Maps & Assembly PointsPoints

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Incident InvestigationsIncident Investigations

Must be initiated ASAP, but within 48 Must be initiated ASAP, but within 48 hourshours

Team must include:Team must include: Person knowledgeable in the process Person knowledgeable in the process

involvedinvolved Includes contractor if work of the contractor Includes contractor if work of the contractor

involvedinvolved Other persons with appropriate knowledge Other persons with appropriate knowledge

of the covered processof the covered process

Must be initiated ASAP, but within 48 Must be initiated ASAP, but within 48 hourshours

Team must include:Team must include: Person knowledgeable in the process Person knowledgeable in the process

involvedinvolved Includes contractor if work of the contractor Includes contractor if work of the contractor

involvedinvolved Other persons with appropriate knowledge Other persons with appropriate knowledge

of the covered processof the covered process

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Incident Investigation ReportIncident Investigation ReportReport must be produced with the following:Report must be produced with the following:

Date of incidentDate of incident Date of start of investigationDate of start of investigation Description of incidentDescription of incident Factors contributing to incidentFactors contributing to incident RecommendationsRecommendations

System must be established to promptly address System must be established to promptly address recommendations and findings of reportrecommendations and findings of report

Resolutions and corrective action must be Resolutions and corrective action must be documenteddocumented

Report must be produced with the following:Report must be produced with the following: Date of incidentDate of incident Date of start of investigationDate of start of investigation Description of incidentDescription of incident Factors contributing to incidentFactors contributing to incident RecommendationsRecommendations

System must be established to promptly address System must be established to promptly address recommendations and findings of reportrecommendations and findings of report

Resolutions and corrective action must be Resolutions and corrective action must be documenteddocumented

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Compliance AuditCompliance AuditTo ensure that PSM is effective, employers To ensure that PSM is effective, employers

must certify every 3 years that they have must certify every 3 years that they have evaluated compliance with the standardevaluated compliance with the standard

Must be completed by at least on person Must be completed by at least on person knowledgeable in the processknowledgeable in the process

Report must be developed and documentedReport must be developed and documentedDeficiency corrections must be documentedDeficiency corrections must be documentedLast two compliance audits must be kept on Last two compliance audits must be kept on

filefile

To ensure that PSM is effective, employers To ensure that PSM is effective, employers must certify every 3 years that they have must certify every 3 years that they have evaluated compliance with the standardevaluated compliance with the standard

Must be completed by at least on person Must be completed by at least on person knowledgeable in the processknowledgeable in the process

Report must be developed and documentedReport must be developed and documentedDeficiency corrections must be documentedDeficiency corrections must be documentedLast two compliance audits must be kept on Last two compliance audits must be kept on

filefile64

Trade SecretsTrade SecretsEmployers must make all necessary Employers must make all necessary

information required to comply with information required to comply with PSM, regardless of trade secrets, PSM, regardless of trade secrets, available to persons involved in available to persons involved in developing or creating:developing or creating: Compiling process safety informationCompiling process safety information PHAsPHAs SOPsSOPs Incident investigationsIncident investigations Emergency planning and responseEmergency planning and response Compliance auditsCompliance audits

Confidentiality agreements are allowedConfidentiality agreements are allowed

Employers must make all necessary Employers must make all necessary information required to comply with information required to comply with PSM, regardless of trade secrets, PSM, regardless of trade secrets, available to persons involved in available to persons involved in developing or creating:developing or creating: Compiling process safety informationCompiling process safety information PHAsPHAs SOPsSOPs Incident investigationsIncident investigations Emergency planning and responseEmergency planning and response Compliance auditsCompliance audits

Confidentiality agreements are allowedConfidentiality agreements are allowed 65

BP Texas City Refinery Case Study in PSMBP Texas City Refinery Case Study in PSM

The third largest petroleum refinery in the The third largest petroleum refinery in the United States with a refining capacity of United States with a refining capacity of 475,000 barrels of crude per day.475,000 barrels of crude per day.

Located on a 1,200-acre facility in Texas City, Located on a 1,200-acre facility in Texas City, Texas southeast of Houston in Galveston Texas southeast of Houston in Galveston County.County.

1,200 permanent BP employees and 1,200 permanent BP employees and hundreds of additional contractors at the hundreds of additional contractors at the facilityfacility

The third largest petroleum refinery in the The third largest petroleum refinery in the United States with a refining capacity of United States with a refining capacity of 475,000 barrels of crude per day.475,000 barrels of crude per day.

Located on a 1,200-acre facility in Texas City, Located on a 1,200-acre facility in Texas City, Texas southeast of Houston in Galveston Texas southeast of Houston in Galveston County.County.

1,200 permanent BP employees and 1,200 permanent BP employees and hundreds of additional contractors at the hundreds of additional contractors at the facilityfacility

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Anatomy of a Disaster- BP Texas CityAnatomy of a Disaster- BP Texas City

Things to Think About:Things to Think About: What went wrong?What went wrong? What went right?What went right? What could/should have been done to What could/should have been done to

prevent this disaster?prevent this disaster?

Things to Think About:Things to Think About: What went wrong?What went wrong? What went right?What went right? What could/should have been done to What could/should have been done to

prevent this disaster?prevent this disaster?

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BP Texas City Refinery Case Study in PSMBP Texas City Refinery Case Study in PSM

Fact Sheet on BP 2009 Monitoring I nspection The U.S. Department of Labor's Occupational Safety and Health Administration (OSHA) has proposed $87,430,000 in propose penalties against BP Products North America, Inc. for 709 alleged failures to comply with the 2005 settlement agreement and citations, and violations of safety and health standards identified during the agency's inspection of the corporation's refinery in Texas City, TX (BPTCR). The inspection of the refinery was conducted from May through October 2009. BP Texas City Refinery (BPTCR):

The third largest petroleum refinery in the United States with a refining capacity of 475,000 barrels of crude per day.

Located on a 1,200-acre facility in Texas City, Texas southeast of Houston in Galveston County.

1,200 permanent BP employees and hundreds of additional contractors at the facility

Prior History at BPTCR:

On March 23, 2005, an explosion and fire in the I somerization Unit of the BP Texas City Refinery (BPTCR) resulted in the death of 15 contractor employees and injury of at least 170 other BP employees and contractors.

OSHA initiated safety and health inspections into the March 2005 incident and issued citations and fines totaling over $21 million, the highest penalty that OSHA had ever issued.

The Report of the BP U.S. Refineries Independent Safety Review Panel (aka Baker Report) issued in J anuary 2007 identified a number of systemic process safety issues at BP refineries in the U.S.

March 2007, U.S. Chemical Safety and Hazard Investigation Board (CSB) released its report Refinery Explosion and Fire (15 Killed, 180 Injured). CSB found, "The Texas City disaster was caused by organizational and safety deficiencies at all levels of the BP Corporation".

OSHA has conducted 17 separate inspections at the refinery in the last 4 years.

Prior to the 2005 incident, two employees of BPTCR died due to a breakdown of the company’s lockout and tagout program.

Since the 2005 incident, four more fatal incidents have occurred at the facility, involving one BPTCR employee and 3 contractors.

2005 Settlement Agreement

As a result of the March 2005 explosion and subsequent inspection, BP entered into a settlement agreement with OSHA in September 2005

BP agreed to pay $21 million in penalties

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JORDAN BARABDeputy Assistant SecretaryJORDAN BARABDeputy Assistant SecretaryAfter BP-Texas City, Have We Learned Anything?After BP-Texas City, Have We Learned Anything? Now, in spite of your efforts, we have to acknowledge that Now, in spite of your efforts, we have to acknowledge that

something is desperately wrong. The status quo isn't working. something is desperately wrong. The status quo isn't working. In the past three months alone, In the past three months alone, 58 workers have died58 workers have died in in

explosions, fires and collapses at refineries, coal mines, an explosions, fires and collapses at refineries, coal mines, an oil drilling rig, and a natural-gas-fired power plant construction oil drilling rig, and a natural-gas-fired power plant construction site.site.

OSHA is particularly concerned about the recent number of OSHA is particularly concerned about the recent number of serious incidents at refineries that have scalded, burned or serious incidents at refineries that have scalded, burned or struck down your fellow workers. We are tracking these struck down your fellow workers. We are tracking these catastrophes and looking for trends -- including problems catastrophes and looking for trends -- including problems resulting from aging facilities. Since the BP Texas City resulting from aging facilities. Since the BP Texas City explosion in 2005, OSHA has counted over explosion in 2005, OSHA has counted over 20 serious 20 serious incidents in refineriesincidents in refineries across the country. across the country.

After BP-Texas City, Have We Learned Anything?After BP-Texas City, Have We Learned Anything? Now, in spite of your efforts, we have to acknowledge that Now, in spite of your efforts, we have to acknowledge that

something is desperately wrong. The status quo isn't working. something is desperately wrong. The status quo isn't working. In the past three months alone, In the past three months alone, 58 workers have died58 workers have died in in

explosions, fires and collapses at refineries, coal mines, an explosions, fires and collapses at refineries, coal mines, an oil drilling rig, and a natural-gas-fired power plant construction oil drilling rig, and a natural-gas-fired power plant construction site.site.

OSHA is particularly concerned about the recent number of OSHA is particularly concerned about the recent number of serious incidents at refineries that have scalded, burned or serious incidents at refineries that have scalded, burned or struck down your fellow workers. We are tracking these struck down your fellow workers. We are tracking these catastrophes and looking for trends -- including problems catastrophes and looking for trends -- including problems resulting from aging facilities. Since the BP Texas City resulting from aging facilities. Since the BP Texas City explosion in 2005, OSHA has counted over explosion in 2005, OSHA has counted over 20 serious 20 serious incidents in refineriesincidents in refineries across the country. across the country.

69

There is Much More to PSMThere is Much More to PSM

Now, The OSHA PSM National Emphasis Now, The OSHA PSM National Emphasis Program for Refineries & Chemical Program for Refineries & Chemical

Facilities & Facilities & Severe Violator Severe Violator Enforcement Program (SVEP)Enforcement Program (SVEP)

Now, The OSHA PSM National Emphasis Now, The OSHA PSM National Emphasis Program for Refineries & Chemical Program for Refineries & Chemical

Facilities & Facilities & Severe Violator Severe Violator Enforcement Program (SVEP)Enforcement Program (SVEP)

70

OSHA National Emphasis Program (NEP) for Refineries & Chemical Facilities

OSHA National Emphasis Program (NEP) for Refineries & Chemical Facilities

Petroleum Petroleum Refineries NEPRefineries NEP Issued August Issued August

20092009Chemical Facilities Chemical Facilities

NEPNEP Issued July 2010Issued July 2010

Petroleum Petroleum Refineries NEPRefineries NEP Issued August Issued August

20092009Chemical Facilities Chemical Facilities

NEPNEP Issued July 2010Issued July 2010

71

Typical Standards CitedTypical Standards Cited

1910.119 1910.119 PSM – 249 violationsPSM – 249 violations 1910.147 1910.147 Lock and Tag - 20Lock and Tag - 20 1910.120 1910.120 Hazwoper - 19Hazwoper - 19 1910.1200 1910.1200 Hazcom - 12Hazcom - 12 1910.146 1910.146 Confined Space - 11Confined Space - 11 5A.001 5A.001 General Duty - 9General Duty - 9 1910.307 1910.307 Hazardous Locations - 7Hazardous Locations - 7

1910.119 1910.119 PSM – 249 violationsPSM – 249 violations 1910.147 1910.147 Lock and Tag - 20Lock and Tag - 20 1910.120 1910.120 Hazwoper - 19Hazwoper - 19 1910.1200 1910.1200 Hazcom - 12Hazcom - 12 1910.146 1910.146 Confined Space - 11Confined Space - 11 5A.001 5A.001 General Duty - 9General Duty - 9 1910.307 1910.307 Hazardous Locations - 7Hazardous Locations - 7

72

Most Frequent NEP PSM CitationsMost Frequent NEP PSM Citations

(f)(1) Operating procedures…………..38(f)(1) Operating procedures…………..38

(d)(3) PSI pertaining to equipment ….28(d)(3) PSI pertaining to equipment ….28

(e)(3) PHA specific criteria……………26(e)(3) PHA specific criteria……………26

(j)(4) MI Inspection & Testing ………..21(j)(4) MI Inspection & Testing ………..21

(e)(5) PHA recommendation ...………12(e)(5) PHA recommendation ...………12

(l)(1) MOC implementation …………..12(l)(1) MOC implementation …………..12

(f)(1) Operating procedures…………..38(f)(1) Operating procedures…………..38

(d)(3) PSI pertaining to equipment ….28(d)(3) PSI pertaining to equipment ….28

(e)(3) PHA specific criteria……………26(e)(3) PHA specific criteria……………26

(j)(4) MI Inspection & Testing ………..21(j)(4) MI Inspection & Testing ………..21

(e)(5) PHA recommendation ...………12(e)(5) PHA recommendation ...………12

(l)(1) MOC implementation …………..12(l)(1) MOC implementation …………..12

1910.119

73

Severe Violator Enforcement Program (SVEP)Severe Violator Enforcement Program (SVEP)

This Instruction establishes enforcement This Instruction establishes enforcement policies and procedures for OSHA's Severe policies and procedures for OSHA's Severe Violator Enforcement Program (SVEP), which Violator Enforcement Program (SVEP), which concentrates resources on inspecting concentrates resources on inspecting employers who have demonstrated employers who have demonstrated indifference to their OSH Actindifference to their OSH Act obligations by obligations by willful, repeated, or failure-to-abate violations. willful, repeated, or failure-to-abate violations. This Instruction replaces OSHA's Enhanced This Instruction replaces OSHA's Enhanced Enforcement Program (EEP).Enforcement Program (EEP).

This Instruction establishes enforcement This Instruction establishes enforcement policies and procedures for OSHA's Severe policies and procedures for OSHA's Severe Violator Enforcement Program (SVEP), which Violator Enforcement Program (SVEP), which concentrates resources on inspecting concentrates resources on inspecting employers who have demonstrated employers who have demonstrated indifference to their OSH Actindifference to their OSH Act obligations by obligations by willful, repeated, or failure-to-abate violations. willful, repeated, or failure-to-abate violations. This Instruction replaces OSHA's Enhanced This Instruction replaces OSHA's Enhanced Enforcement Program (EEP).Enforcement Program (EEP).

74

Severe Violator Enforcement Program (SVEP)Severe Violator Enforcement Program (SVEP)

References:References:

OSHA Instruction CPL 03-00-010, Petroleum OSHA Instruction CPL 03-00-010, Petroleum Refinery Process Safety Management Refinery Process Safety Management National Emphasis Program, August 18, 2009National Emphasis Program, August 18, 2009

References:References:

OSHA Instruction CPL 03-00-010, Petroleum OSHA Instruction CPL 03-00-010, Petroleum Refinery Process Safety Management Refinery Process Safety Management National Emphasis Program, August 18, 2009National Emphasis Program, August 18, 2009

75

Severe Violator Enforcement Program (SVEP)Severe Violator Enforcement Program (SVEP) Enhanced Follow-up InspectionsEnhanced Follow-up Inspections Nationwide Inspections of Related Nationwide Inspections of Related

Workplaces/WorksitesWorkplaces/Worksites Increased Company Awareness of OSHA Increased Company Awareness of OSHA

EnforcementEnforcement Enhanced Settlement ProvisionsEnhanced Settlement Provisions Federal Court Enforcement under Section 11(b) Federal Court Enforcement under Section 11(b)

of the OSH Actof the OSH Act

Bottom Line: OSHA is Serious Bottom Line: OSHA is Serious AboutAbout

Compliance and Enforcement of Compliance and Enforcement of PSMPSM

Enhanced Follow-up InspectionsEnhanced Follow-up Inspections Nationwide Inspections of Related Nationwide Inspections of Related

Workplaces/WorksitesWorkplaces/Worksites Increased Company Awareness of OSHA Increased Company Awareness of OSHA

EnforcementEnforcement Enhanced Settlement ProvisionsEnhanced Settlement Provisions Federal Court Enforcement under Section 11(b) Federal Court Enforcement under Section 11(b)

of the OSH Actof the OSH Act

Bottom Line: OSHA is Serious Bottom Line: OSHA is Serious AboutAbout

Compliance and Enforcement of Compliance and Enforcement of PSMPSM 76

EPA Risk Management Plans (RMP) Basics

EPA Risk Management Plans (RMP) Basics

CAA 112(r)CAA 112(r)CAA 112(r)CAA 112(r)

77

One More Thing to Discuss…EPA Risk Management Plans(RMP)

One More Thing to Discuss…EPA Risk Management Plans(RMP)

Many Times Companies Who Must Comply Many Times Companies Who Must Comply with PSM, must also Comply with the with PSM, must also Comply with the Requirements of EPA Risk Management Requirements of EPA Risk Management Plans (RMP)Plans (RMP)

The RMP Standard was to be a Mirror of the The RMP Standard was to be a Mirror of the PSM Standard…Didn’t happen!PSM Standard…Didn’t happen!

Remember…PSM Protects the Workforce, Remember…PSM Protects the Workforce, RMP Protects the CommunityRMP Protects the Community

Many Times Companies Who Must Comply Many Times Companies Who Must Comply with PSM, must also Comply with the with PSM, must also Comply with the Requirements of EPA Risk Management Requirements of EPA Risk Management Plans (RMP)Plans (RMP)

The RMP Standard was to be a Mirror of the The RMP Standard was to be a Mirror of the PSM Standard…Didn’t happen!PSM Standard…Didn’t happen!

Remember…PSM Protects the Workforce, Remember…PSM Protects the Workforce, RMP Protects the CommunityRMP Protects the Community

78

EPA RMPEPA RMP

Basic RequirementsBasic Requirements Executive summaryExecutive summary RegistrationRegistration Off-site consequence analysisOff-site consequence analysis Five-year accident historyFive-year accident history Emergency response planEmergency response plan Prevention program summary informationPrevention program summary information CertificationCertification

Basic RequirementsBasic Requirements Executive summaryExecutive summary RegistrationRegistration Off-site consequence analysisOff-site consequence analysis Five-year accident historyFive-year accident history Emergency response planEmergency response plan Prevention program summary informationPrevention program summary information CertificationCertification

79

All Public Facilities in this Release Plume Must be Identified & Surveyed

Release Plume

80

OSHA PSM SummaryOSHA PSM Summary

PSM is a Comprehensive, Difficult StandardPSM is a Comprehensive, Difficult Standard Although it was Promulgated in 1991, Although it was Promulgated in 1991,

Catastrophes Continue to OccurCatastrophes Continue to Occur Recognizing these Facts, OSHA has Recognizing these Facts, OSHA has

Developed a National Emphasis Program for Developed a National Emphasis Program for Refineries and Chemical ManufacturersRefineries and Chemical Manufacturers

More Emphasis Planned for all PSM SitesMore Emphasis Planned for all PSM Sites There is Much More Work to be Done…There is Much More Work to be Done… RMP Must Also be Considered for Many RMP Must Also be Considered for Many

FacilitiesFacilities

PSM is a Comprehensive, Difficult StandardPSM is a Comprehensive, Difficult Standard Although it was Promulgated in 1991, Although it was Promulgated in 1991,

Catastrophes Continue to OccurCatastrophes Continue to Occur Recognizing these Facts, OSHA has Recognizing these Facts, OSHA has

Developed a National Emphasis Program for Developed a National Emphasis Program for Refineries and Chemical ManufacturersRefineries and Chemical Manufacturers

More Emphasis Planned for all PSM SitesMore Emphasis Planned for all PSM Sites There is Much More Work to be Done…There is Much More Work to be Done… RMP Must Also be Considered for Many RMP Must Also be Considered for Many

FacilitiesFacilities

81

Tools for Additional PSM AssistanceTools for Additional PSM Assistance

PSM ChecklistPSM Checklist www.oshainfo.gatech.eduwww.oshainfo.gatech.edu

OSHA WebsiteOSHA Website www.osha.govwww.osha.gov

Chemical Safety Board WebsiteChemical Safety Board Website www.csb.govwww.csb.gov

PSM ChecklistPSM Checklist www.oshainfo.gatech.eduwww.oshainfo.gatech.edu

OSHA WebsiteOSHA Website www.osha.govwww.osha.gov

Chemical Safety Board WebsiteChemical Safety Board Website www.csb.govwww.csb.gov

82

PSM Checklist

Use this checklist to help determine employer compliance with the Process Safety Management Standard issued by the Occupational Safety and Health Administration. Please note that the checklist does not include all of the standard’s requirements and does not reflect all OSHA letters of interpretation or compliance directives in particular situations. There are 3 elements to a review of a PSM program:

1. Documentation review – examination of the documentation of the programs required by the standard. 2. Field Inspection & Verification – examination of the physical covered process; its equipment, piping,

instrumentation, procedures, and operation. 3. Interviews – discussions with employees and contractors to determine if the implemented program matches the

program outlined in the documentation. In order to gather the information needed to audit a PSM program the following questions need to be asked for each PSM program element

Who What When Where Why How

Who – Who is responsible for developing and implementing each of the program elements? What – What are the requirements and contents of each program element? When – When are the required actions for each element completed and when were they required to be

completed? Where – Where have actions been implemented or changed? Why – Why have the implementation decisions and priorities been made as recorded in the documentation? How – How is the program implemented and how is the program’s effectiveness evaluated and improved?

An essential part of verifying program implementation is to audit the flow of information and activities among the elements. When information in one element is changed or when action takes place in one element that affects other elements, an auditor/reviewer should examine a sample of the related elements to see if the appropriate changes and followup actions have taken place. The following example demonstrates the interrelationship among the elements: During a routine inspection of equipment (Mechanical Integrity), the maintenance worker discovers a valve that no longer meets the applicable code and must be changed. Because the type of valve is no longer made, a different type of valve must be selected and installed (Management of Change). The type of valve selected may mandate different steps for the operators (Operating Procedures) who will require training and verification in the new procedures (Training). The rationale for selecting the type of valve must be made available for review by employees and their representatives (Employee Participation). When the new valve is installed by the supplier (Contractors), a qualified and safe contractor must be selected to perform the work (Contractor Management). The work will involve shutting down part of the process (Pre-startup Safety Review) as well as brazing some of the lines (Safe Work Practices - Hot Work Permit). The employer must review the response plan (Emergency Planning) to ensure that procedures are adequate for the installation hazards. Although Management of Change provisions cover interim changes, after the new valve is in place the Process Safety Information will have to be updated before the (Process Hazard Analysis) is updated or revalidated, to account for potential hazards associated with the new equipment. Also, inspection and maintenance procedures and training will need to be updated (Mechanical Integrity). In summary, 12 PSM elements can be affected by changing one valve. A reviewer/inspector/auditor/compliance officer would check a representative number of these 11 elements to confirm that the required follow-up activities have been implemented for the new valve.

83

For More InformationFor More Information

www.psmtraining.comwww.psmtraining.com

www.oshainfo.gatech.eduwww.oshainfo.gatech.edu

www.pe.gatech.edu/safetywww.pe.gatech.edu/safety

www.psmtraining.comwww.psmtraining.com

www.oshainfo.gatech.eduwww.oshainfo.gatech.edu

www.pe.gatech.edu/safetywww.pe.gatech.edu/safety

84

Contact InformationContact InformationMichelle Dunham, MSPH, MSMMichelle Dunham, MSPH, MSM

[email protected]@gtri.gatech.edu 404-407-8284404-407-8284

Bob HendryBob Hendry [email protected]@gtri.gatech.edu

Art Wickman, CIHArt Wickman, CIH [email protected]@gtri.gatech.edu

Georgia Tech Occupational Safety & Health ProgramGeorgia Tech Occupational Safety & Health Program www.oshainfo.gatech.eduwww.oshainfo.gatech.edu

Michelle Dunham, MSPH, MSMMichelle Dunham, MSPH, MSM [email protected]@gtri.gatech.edu 404-407-8284404-407-8284

Bob HendryBob Hendry [email protected]@gtri.gatech.edu

Art Wickman, CIHArt Wickman, CIH [email protected]@gtri.gatech.edu

Georgia Tech Occupational Safety & Health ProgramGeorgia Tech Occupational Safety & Health Program www.oshainfo.gatech.eduwww.oshainfo.gatech.edu

85

FundingFundingFunding for:Funding for:

Process Safety Management of Highly Process Safety Management of Highly Hazardous and Explosive Chemicals: Hazardous and Explosive Chemicals: Simple Keys to ComplianceSimple Keys to Compliance

By special funding from the Occupational By special funding from the Occupational Safety and Health AdministrationSafety and Health Administration

Funding for:Funding for:

Process Safety Management of Highly Process Safety Management of Highly Hazardous and Explosive Chemicals: Hazardous and Explosive Chemicals: Simple Keys to ComplianceSimple Keys to Compliance

By special funding from the Occupational By special funding from the Occupational Safety and Health AdministrationSafety and Health Administration

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psm-compliance.ppt

Documents

testing quality

largest petroleum

process toxicity

process hazard

highly hazardous

process safety

osha develop

block diagram