Process Safety Management -

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Process Safety Management -

• Tips for the Little Guy

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What Is Process Safety Management

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

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What Is Process Safety Management 14 Elements

• Application
• Employee Participation
• Process Safety Information
• Process Hazard Analysis
• Operating Procedures
• Employee Training
• Contractors

• Pre-Start up Safety Review
• Mechanical Integrity
• Hot Work (Non-routine Work Authorizations)
• Management of Change
• Incident Investigation
• Emergency Planning and Response
• Compliance Audits

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1910.119 (a) Application

• Appendix A of 29 CFR 1910.119 contains a listing
  of toxic and reactive highly hazardous chemicals
  which present a potential for a catastrophic
  event at or above the threshold quantities
  listed.
• To adequately address this section, identify what
  brings you into coverage by the standard,
  specifying which processes at the facility are
  covered and why.

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1910.119 (a) Application cont.

• Consider what you can do to get out of the
  situation
• Reduce inventories of highly hazardous chemicals
• Receive smaller shipments
• Enhance inventory control
• Break up storage locations within the plant to
  reduce the amounts on hand to below the threshold
  quantity (TQ)
• Substitute listed with non-listed

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May 25, 2004 Conyers GA
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1910.119 (c) Employee Participation

• Employees are required to be an active part of
  the process and your written programs need to
  document what roles employees play, their
  involvement in the development of the programs,
  and continuing participation in the process.
• An OSHA inspector (CSHO) will attempt to verify
  participation by interviewing employees at
  random.

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1910.119 (c) Employee Participation cont.

• Consultation / participation with training and
  supervision to determine the frequency and
  content of initial and refresher training.
• Consultation / participation to develop and
  review operating and maintenance procedures.
• Consultation / participation in incident
  investigations regarding the covered process.

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1910.119 (d) Process Safety Information

• Material Safety Data Sheets (MSDS)
• Piping and instrumentation diagrams (PINDs)
• Block flow diagrams

• Material and energy balance calculations
• Relevant consensus standards
• Materials of construction

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1910.119 (d) Process Safety Information cont.

• Available to all affected employees requirement
  of 1910.119 (c) Employee Participation
• Available for Process Hazard Analysis and
  revalidations requirement of 1910.119 (e)
  Process Hazard Analysis
• So auditors and CSHOs can find everything!

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1910.119 (e) Process Hazard Analysis
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1910.119 (e) Process Hazard Analysis

• OSHA has suggested formats
• Dont start until all information is gathered
• Use a software tool to guide, record, manage
  process

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1910.119 (e) Process Hazard Analysis

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

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1910.119 (f) Operating Procedures

• Standard Operating Procedures
• Do in tandem with Job Hazard Analysis (JHAs)
• Mesh with training program
• Partner with Quality Team (ISO 9001) to create
  training matrix and managed documents

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1910.119 (g) Employee Training

• The employer shall prepare a record
• Identity of employee.
• Date of training.
• Means to verify that employee understood training
• At a minimum, refresher training shall be
  provided at least every three years and more
  often if necessary to each employee involved in
  operating a process.

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1910.119 (h) Contractors

• Absolute Requirements
• Employer Documentation
• Contract employee injury and illness logs related
  to work in covered process areas.
• Contract Employer Documentation
• Records showing employees received training in
  and understands safe work practices related to
  the process on or near where they will be working
  so they perform their jobs safely.

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1910.119 (i) Pre-Start up Safety Review

• Check, double check, and review any changes,
  modifications, additions made in a PSM covered
  area before you flip the switch.

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1910.119 (j) Mechanical Integrity

• The employer shall develop and maintain a master
  list of all equipment specifically covered by the
  standard, and equipment that is important to
  safety of the process.
• Pressure vessels and storage tanks.
• Piping systems including valves and other piping
  components.
• Relief and vent systems and devices.
• Emergency shutdown systems.
• Controls (including monitoring devices and
  sensors, alarms, and interlocks).

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1910.119 (j) Mechanical Integrity cont.

• Pumps.
• Rotating equipment.
• Heat exchange equipment.
• Electrical generation and distribution equipment.
• Un-interruptable power supplies.
• Emergency power supply equipment.
• Fire protection equipment.

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1910.119 (k) Hot Work (a.k.a. Non-routine Work
Authorizations)

• Welding, cutting, braising make sure only
  trained personnel perform these functions
• Have trained fire watchers (align with fire
  extinguisher / fire response training)

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1910.119 (l) Management of Change

• Create formalized system to review all changes to
  process areas including
• Raw material changes / substitutions
• Personnel changes
• Process parameters
• Facility changes (HVAC / roof / fire protection /
  ..)

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1910.119 (l) Management of Change cont.

• PSI
• Mechanical Integrity
• PINDs
• Hot Work
• Contractor Safety
• Employee Training
• PSSR
• Operating Procedures

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1910.119 (m) Incident Investigation
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1910.119 (n) Emergency Planning and Response

• Call in all resources and make plan
  comprehensive
• Information Technology (IT) Disaster Recovery
  Plan
• Business Continuity Plan (session 554 _at_ 430)
• Security
• Communications / Public Relations
• Employee Assistance

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1910.119 (o) Compliance Audits

• Ask for the audit protocol ahead of time
• Have a system in place to identify the location
  of all PSM documentation
• Identify what's in or out of audit scope
• Ask for money to correct audit items before the
  audit is conducted
• Prepare management for report

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Resources

• OSHA web site (www.OSHA.gov)
• CPL 2-2.45 Process Safety Management of Highly
  Hazardous Chemicals Compliance Guidelines and
  Enforcement Procedures 78 pages of gold!
• Appendix C to 1910.119 Compliance Guidelines and
  Recommendations for Process Safety Management
  (Nonmandatory)
• OSHA training institute
• Safety and Health Chemical Process Industry
  course 330A. PSM boot camp five days of fun
  and a three ring binder!
• AIChE / CCPs

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