Process Safety Management of Highly Hazardous

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Process Safety Management of Highly Hazardous
Explosive Chemicals

• 29CFR1910.119
• Clearly Understanding the Standard

Information Provided under OSHA Susan Harwood
Grant SH-17811-SH-8
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Susan Harwood GrantHistory

• 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 Disasters
• Current Year Disasters
• Perceived Weakness in PSM Program

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GTRI PSM Susan Harwood Grant Program

• GTRI is Offering
• Six (6) One Day Courses Around the Southeastern
  United States
• Four (4) One Week In-Depth Courses Around the
  United States

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Goals 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

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Summary 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)

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Rules of the Course

• This is an Open Discussion Course
• Relax and Learn
• Ask Questions
• Participate in Discussions
• Share Experiences
• Share Best Practices
• Enjoy Yourself

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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

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Why Did OSHA Develop PSM?

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

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Why Did OSHA Develop PSM?

• Process Safety Management is a regulation,
  promulgated by OSHA, intended to prevent an
  incident like the 1984 Bhopal Disaster
• Andto Prevent Release of
• Toxic,
• Reactive,
• Flammable, or
• Explosive chemicals

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Not 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).

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PSM vs. RMP - Whats the Difference?

• RMP-Like Sara Title III
• Protects the Community
• Protects the General Public Around the Facility
• Protects Adjacent Facilities Such as Schools
  Hospitals

• PSM - Like HAZCOM
• Protects the Workforce
• Protects Contractors
• Protects Visitors to the Facility
• Basically Protects the Workplace

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

• BP Products Texas City - January 2005
• 15 Workers Killed
• 170 Injured
• Major Property Damage
• 21 Million in Fines

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Application

• 1910.119(a)

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What 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 - 1,000 lbs

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What Facilities are Covered

• 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

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What 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.

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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

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Exclusions

• 1910.119(a)(1)(ii)(A)

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There 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

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There are Exclusions

• Retail facilities
• Oil or gas well drilling or servicing operations
  or,
• Normally unoccupied remote facilities

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Definitions

• 1910.119(b)

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Definitions

• 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.

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Definitions

• 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.

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Definitions

• 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

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Employee Participation

• 1910.119(c)

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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

RememberYou Cant Do it Alone!
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Now that we are required to comply, then what?
Second

• Form a Plan, Determine
• Responsibilities
• Duties
• Reporting
• Document Control
• Progress Reports
• Tracking Changes

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

• Review Scope of Project
• Process Safety Information 
• Equipment in the Process
• Process Hazard Analysis
• Operating Procedures
• Employee Training
• Training Contractors
• Pre-Startup Safety Review
• Mechanical Integrity of Equipment 
• Management of Change
• Incident Investigation
• Emergency Preparedness
• Compliance Audits   
• Trade Secrets

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

• In the Next Session, we will Begin to Explore
  Each Element of the Standard and What is Required
  to Comply