Post on 16-Jul-2018
Process Safety Management of Highly Hazardous & Explosive Chemicals
Process Safety Management of Highly Hazardous & Explosive Chemicals
29CFR1910.119Clearly Understanding the Standard
29CFR1910.11929CFR1910.119Clearly Understanding the StandardClearly Understanding the Standard
Information Provided under OSHA Susan Harwood Grant#SH-17811-08-60-F-13
Susan Harwood Grant…HistorySusan Harwood Grant…History
Grants are awarded to provide training and education programs for employers and employees on the recognition, avoidance, and prevention of safety and health hazards in their workplaces.
PSM Was Chosen Given the Clear Need Past DisastersCurrent Year Disasters Perceived Weakness in PSM Program
Grants are awarded to provide training and Grants are awarded to provide training and education programs for employers and education programs for employers and employees on the recognition, avoidance, employees on the recognition, avoidance, and prevention of safety and health hazards and prevention of safety and health hazards in their workplaces. in their workplaces.
PSM Was Chosen Given the Clear Need PSM Was Chosen Given the Clear Need Past DisastersPast Disasters Current Year DisastersCurrent Year Disasters Perceived Weakness in PSM ProgramPerceived Weakness in PSM Program
GTRI PSM Susan Harwood Grant ProgramGTRI PSM Susan Harwood Grant ProgramGTRI has Offered:
Nine (9) One Day Courses Around the Southeastern United States
Eight (8) One Week In-Depth Courses Around the United States
GTRI has Offered:
Nine (9) One Day Courses Around the Southeastern United States
Eight (8) One Week In-Depth Courses Around the United States
Goals of the One Day CourseGoals of the One Day Course Understand Why Process Safety Management
(PSM) Was Promulgated Understand That Even with PSM, Catastrophes
are Still Occurring Understand Who is Covered & Exemptions Understand the Team Process to Developing a
PSM Program Understand Each of the Elements of a Properly
Designed & Implemented Program and How to Begin the Process
Understand the Basics of How PSM & RMP Work Together to Protect the Workforce & Surrounding Community
Understand Why Process Safety Management Understand Why Process Safety Management (PSM) Was Promulgated(PSM) Was Promulgated
Understand That Even with PSM, Catastrophes Understand That Even with PSM, Catastrophes are Still Occurringare Still Occurring
Understand Who is Covered & ExemptionsUnderstand Who is Covered & Exemptions Understand the Team Process to Developing a Understand the Team Process to Developing a
PSM ProgramPSM Program Understand Each of the Elements of a Properly Understand Each of the Elements of a Properly
Designed & Implemented Program and How to Designed & Implemented Program and How to Begin the ProcessBegin the Process
Understand the Basics of How PSM & RMP Understand the Basics of How PSM & RMP Work Together to Protect the Workforce & Work Together to Protect the Workforce & Surrounding CommunitySurrounding Community
Summary of the One Week CourseSummary of the One Week Course
This is an In-Depth Study of the Requirements of the Standard
Students will Actually Learn through a Real Life Case Study How to Design Each Element of the Process Safety Management Standard Requirements
Students will Also Review the Basics of EPA Risk Management Plan (RMP)
This is an InThis is an In--Depth Study of the Depth Study of the Requirements of the Standard Requirements of the Standard
Students will Actually Learn through a Real Students will Actually Learn through a Real Life Case Study How to Design Each Element Life Case Study How to Design Each Element of the Process Safety Management Standard of the Process Safety Management Standard RequirementsRequirements
Students will Also Review the Basics of EPA Students will Also Review the Basics of EPA Risk Management Plan (RMP)Risk Management Plan (RMP)
Rules of the CourseRules of the Course
This is an Open Discussion Course
Relax and Learn Ask Questions Participate in Discussions Share Experiences Share Best Practices Enjoy Yourself
This is an Open Discussion CourseThis is an Open Discussion Course
Relax and LearnRelax and Learn Ask Questions Ask Questions Participate in DiscussionsParticipate in Discussions Share ExperiencesShare Experiences Share Best PracticesShare Best Practices Enjoy YourselfEnjoy Yourself
Why Did OSHA Develop PSM?Why Did OSHA Develop PSM?
Bhopal, India (1984) 2,000 deaths
Isocyanate release Pasadena, TX (1989)
23 deaths, 132 injuries Petroleum explosion
Cincinnati, OH (1990) 2 deaths
Explosion Sterlington, LA (1991)
8 deaths, 128 injuries Chemical 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
In 1991, OSHA and EPA respectively, Released the Standards, PSM & RMP that Applies to Those Companies that are Affected by 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.
Why Did OSHA Develop PSM?Why Did OSHA Develop PSM?
Process Safety Management is a regulation, promulgated by OSHA, intended to prevent an incident like the 1984 Bhopal Disaster
And…to Prevent Release of: Toxic, Reactive, Flammable, or Explosive chemicals
Process Safety Process Safety ManagementManagement is a is a regulation, promulgated regulation, promulgated by by OSHA, intended to OSHA, intended to prevent an incident like prevent an incident like the 1984 the 1984 Bhopal DisasterBhopal Disaster
AndAnd……to Prevent Release to Prevent Release of:of: Toxic, Toxic, Reactive, Reactive, Flammable, or Flammable, or Explosive chemicalsExplosive chemicals
Why Did OSHA Develop PSM?Why Did OSHA Develop PSM?
Not Only PSM, But RMPNot Only PSM, But RMP
A great many industrial facilities must comply with OSHA's Process Safety Management (PSM) regulations as well as the quite similar EPA Risk Management Program (RMP) regulations (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 quite similar well as the quite similar EPA Risk Management EPA Risk Management Program (RMP) Program (RMP) regulations (Title 40 regulations (Title 40 CFR Part 68). CFR Part 68).
PSM vs. RMP - What’s the Difference?PSM vs. RMP - What’s the Difference?
RMP-Like Sara Title III Protects the
Community Protects the General
Public Around the Facility
Protects Adjacent Facilities Such as Schools & Hospitals
RMPRMP--Like Sara Title IIILike 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 HAZCOM Protects the
Workforce Protects Contractors Protects Visitors to
the Facility Basically Protects the
Workplace
PSM PSM -- Like HAZCOMLike 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
The Standard Was Promulgated in 1991 - Is it Working?The Standard Was Promulgated in 1991 - Is it Working?
BP Products Texas City - March 2005 15 Workers Killed 170 Injured Major Property
Damage $21 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 $21 Million in Fines$21 Million in Fines
The Standard Was Promulgated in 1991 - Is it Working?The Standard Was Promulgated in 1991 - Is it Working?
What Facilities are CoveredWhat Facilities are Covered
Those Who Use Chemicals in Appendix A: A List of highly hazardous chemicals, toxics and reactive (Mandatory). Contains a listing of toxic and reactive highly hazardous chemicals which present a potential for a catastrophic event at or above the threshold quantity
Examples
Chemical Threshold Quantity (TQ) Anhydrous Ammonia: 10,000 lbs Chlorine: 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 for highly hazardous chemicals which present a potential for a catastrophic event at or above the threshold quantitya catastrophic event at or above the threshold quantity
ExamplesExamples
Chemical Chemical Threshold Quantity (TQ)Threshold Quantity (TQ) Anhydrous Ammonia:Anhydrous Ammonia: 10,000 lbs10,000 lbs Chlorine:Chlorine: 1,500 lbs1,500 lbs
A process which involves a flammable liquid or gas (as defined in 1910.1200(c) of this part) on-site in one location, in a quantity of 10,000 pounds (4535.9 kg) or 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) onpart) on--site in one 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
What Facilities are CoveredWhat Facilities are Covered
Important Interpretation: 2007 - 06/11/2007 - OSHA defines "on-site in one location" for Process Safety Management of Highly Hazardous Chemicals standard
OSHA interprets "on-site in one location" to mean that the standard applies when a threshold quantity of a highly hazardous chemical (HHC) exists within an area under the control of an employer or group of affiliated employers. It also applies to any group of vessels that are interconnected, or in separate vessels that are close enough in proximity that the HHC could be involved in a potential catastrophic release.
Important Interpretation: Important Interpretation: 2007 2007 -- 06/11/2007 06/11/2007 -- OSHA OSHA defines "ondefines "on--site in one location" for Process Safety site in one location" for Process Safety Management of Highly Hazardous Chemicals Management of Highly Hazardous Chemicals standardstandard
OSHA interprets "onOSHA interprets "on--site in one location" to mean that site in one location" to mean that the standard applies when a threshold quantity of a the standard applies when a threshold quantity of a highly hazardous chemical (HHC) exists within an highly hazardous chemical (HHC) exists within an area under the control of an employer or group of area under the control of an employer or group of affiliated employers. It also applies to any groupaffiliated employers. It also applies to any group of of vessels that are interconnected, or in separate vessels that are interconnected, or in separate vessels that are close enough in proximity that the vessels that are close enough in proximity that the HHC could be involved in a potential catastrophic HHC could be involved in a potential catastrophic release.release.
What Facilities are CoveredWhat Facilities are Covered
Affect of the “Meer” Decision:
MEER ruling and the MEER Memorandum addressed in the Secretary's letter, OSHA's enforcement policy that the Agency would not cite employers for violations of 1910.119 where stored flammable liquids in atmospheric tanks were connected to a process, unless the process outside of the amount in storage contained more than 10,000 pounds of the substance
Affect of the Affect of the ““MeerMeer”” Decision:Decision:
MEER MEER ruling and theruling and the MEERMEER Memorandum addressed in the Memorandum addressed in the Secretary's letter, Secretary's letter, OSHA's OSHA's enforcement policy that the Agency enforcement policy that the Agency would not cite employers forwould not cite employers for violations of 1910.119 where stored violations of 1910.119 where stored flammable liquids in atmospheric tanks were connected to a flammable liquids in atmospheric tanks were connected to a process, unless the process outside ofprocess, unless the process outside of the amount in storage the amount in storage contained more than 10,000 pounds of the substancecontained more than 10,000 pounds of the substance
What Facilities are CoveredWhat Facilities are Covered
What Types of Industries?What Types of Industries?
Industries that Process Chemicals Such As: Industrial Organics & Inorganics Paints Pharmaceuticals Adhesives Sealants and Fibers Petrochemical facilities Paper Mills Food Processing with Anhydrous Ammonia over
the 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
There are ExclusionsThere are Exclusions
An employer is exempt from the requirements of PSM when:
A threshold quantity of flammable liquids is stored in atmospheric tanks or transferred without the benefit of chilling or refrigeration
Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling), If such fuels are not a part of a process containing
another highly hazardous chemical covered by this standard
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
Retail facilities;
Oil or gas well drilling or
servicing operations; or,
Normally unoccupied
remote 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
DefinitionsDefinitions
Atmospheric tank means a storage tank which has been designed to operate at pressures from atmospheric through 0.5 p.s.i.g. (pounds per square inch gauge, 3.45 Kpa).
Boiling point means the boiling point of a liquid at a pressure of 14.7 pounds per square inch absolute (p.s.i.a.) (760 mm.).
Catastrophic release means a major uncontrolled emission, fire, or explosion, involving one or more highly hazardous chemicals, that presents serious danger to employees in the workplace.
Atmospheric tank means a storage tank which has been designed to operate at pressures from atmospheric through 0.5 p.s.i.g. (pounds per square inch gauge, 3.45 Kpa).
Boiling point means the boiling point of a liquid at a pressure of 14.7 pounds per square inch absolute (p.s.i.a.) (760 mm.).
Catastrophic release means a major uncontrolled emission, fire, or explosion, involving one or more highly hazardous chemicals, that presents serious danger to employees in the workplace.
DefinitionsDefinitions Facility means the buildings, containers or equipment
which contain a process. Highly hazardous chemical means a substance
possessing toxic, reactive, flammable, or explosive properties and specified by paragraph (a)(1) of this section.
Hot work means work involving electric or gas welding, cutting, brazing, or similar flame or spark-producing operations.
Normally unoccupied remote facility means a facility which is operated, maintained or serviced by employees who visit the facility only periodically to check its operation and to perform necessary operating or maintenance tasks. No employees are permanently stationed at the facility.
Facility means the buildings, containers or equipment Facility means the buildings, containers or equipment which contain a process. which contain a process.
Highly hazardous chemical means a substance Highly hazardous chemical means a substance possessing toxic, reactive, flammable, or explosive possessing toxic, reactive, flammable, or explosive properties and specified by paragraph (a)(1) of this properties and specified by paragraph (a)(1) of this section. section.
Hot work meansHot work means work involving electric or gas work involving electric or gas welding, cutting, brazing, or similar flame or sparkwelding, cutting, brazing, or similar flame or spark--producing operations. producing operations.
Normally unoccupied remote facility means a facility Normally unoccupied remote facility means a facility which is operated, maintained or serviced by which is operated, maintained or serviced by employees who visit the facility only periodicallemployees who visit the facility only periodically to y to check its operation and to perform necessary check its operation and to perform necessary operating or maintenance tasks. No employees are operating or maintenance tasks. No employees are permanently stationed at the facility.permanently stationed at the facility.
DefinitionsDefinitions Process means any activity involving a highly
hazardous chemical including any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or combination of these activities. For purposes of this definition, any group of vessels which are interconnected and separate vessels which are located such that a highly hazardous chemical could be involved in a potential release shall be considered a single process.
“Replacement in kind" means a replacement which satisfies the design specification.
"Trade secret" means any confidential formula, pattern, process, device, information or compilation of information that is used in an employer's business
Process means any activity involving a highly Process means any activity involving a highly hazardous chemical including any use, storage, hazardous chemical including any use, storage, manufacturing, handling, or the onmanufacturing, handling, or the on--site movement of site movement of such chemicals, or combination of these activities. such chemicals, or combination of these activities. For purposes of this definition, any group of vessels For purposes of this definition, any group of vessels whichwhich are interconnected and separate vessels which are interconnected and separate vessels which are located such that a highly hazardous chemical are located such that a highly hazardous chemical could be involved in a potential release shall be could be involved in a potential release shall be considered a single process.considered a single process.
““Replacement in kind" means a replacement which Replacement in kind" means a replacement which satisfies the design specification.satisfies the design specification.
"Trade secret" means any confidential formula, "Trade secret" means any confidential formula, pattern, process, device, information or compilation of pattern, process, device, information or compilation of information that is used in an employer's businessinformation that is used in an employer's business
Now that we are required to comply, then what? First…Now that we are required to comply, then what? First… Form a Team in
Your Company, i.e.. Process Engineers Operators Safety Maintenance Management Consultants
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!
Form a Plan, Determine: Responsibilities Duties Reporting Document Control Progress Reports Tracking 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? Second…Now that we are required to comply, then what? Second…
Now that we are required to comply, then what? Third…Review Scope of the Project:
Now that we are required to comply, then what? Third…Review Scope of the Project: Application Exclusions Definitions Employee Participation Hazards of the Process Toxicity Technology of the
Process Equipment in the
Process Mechanical Integrity Inspection & Testing Quality Assurance
ApplicationApplication ExclusionsExclusions DefinitionsDefinitions Employee ParticipationEmployee Participation Hazards of the ProcessHazards of the Process ToxicityToxicity Technology of the Technology of the
ProcessProcess Equipment in the Equipment in the
ProcessProcess Mechanical IntegrityMechanical Integrity Inspection & TestingInspection & Testing Quality AssuranceQuality Assurance
Process Hazard Analysis
Management of Change Operating Procedures Safe Work Practices Training Contractor
Management Emergency Planning &
Response Incident Investigation Compliance Audits Trade Secrets
Process Hazard Process Hazard AnalysisAnalysis
Management of ChangeManagement of Change Operating ProceduresOperating Procedures Safe Work PracticesSafe Work Practices TrainingTraining Contractor Contractor
ManagementManagement Emergency Planning & Emergency Planning &
ResponseResponse Incident InvestigationIncident Investigation Compliance AuditsCompliance Audits Trade SecretsTrade Secrets
In the Next Session, we will Begin to Explore Each Element of the Standard and What is Required to Comply
In the Next Session, In the Next Session, we will Begin to we will Begin to Explore Each Explore Each Element of the Element of the Standard and What Standard and What is Required to is Required to ComplyComply
Now that we are required to comply, then what? …Let’s BeginNow that we are required to comply, then what? …Let’s Begin