1day intro
TRANSCRIPT
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Process Safety Managementof Highly Hazardous &Explosive Chemicals
Process Safety Managementof Highly Hazardous &Explosive Chemicals
29CFR1910.119
Clearly Understanding the Standard
29CFR1910.11929CFR1910.119
Clearly Understanding the StandardClearly Understanding the StandardInformation Provided under OSHA Susan Harwood Grant#SH-17811-08-60-F-13
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Susan Harwood GrantHistorySusan Harwood GrantHistory
Grants are awarded to provide training andeducation programs for employers andemployees 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
Grants are awarded to provide training andGrants are awarded to provide training andeducation programs for employers andeducation programs for employers andemployees on the recognition, avoidance,employees on the recognition, avoidance,and prevention of safety and health hazardsand prevention of safety and health hazards
in their workplaces.in their workplaces.
PSM Was Chosen Given the Clear NeedPSM Was Chosen Given the Clear Need
Past DisastersPast Disasters Current Year DisastersCurrent Year Disasters
Perceived Weakness in PSM ProgramPerceived Weakness in PSM Program
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GTRI PSM Susan HarwoodGrant ProgramGTRI PSM Susan HarwoodGrant Program
GTRI has Offered:
Nine (9) One Day Courses Around theSoutheastern United States
Eight (8) One Week In-Depth CoursesAround 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
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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 aPSM Program
Understand Each of the Elements of a ProperlyDesigned & Implemented Program and How toBegin the Process
Understand the Basics of How PSM & RMPWork Together to Protect the Workforce &
Surrounding Community
Understand Why Process Safety ManagementUnderstand Why Process Safety Management(PSM) Was Promulgated(PSM) Was Promulgated
Understand That Even with PSM, CatastrophesUnderstand That Even with PSM, Catastrophesare Still Occurringare Still Occurring
Understand Who is Covered & ExemptionsUnderstand Who is Covered & Exemptions
Understand the Team Process to Developing aUnderstand the Team Process to Developing aPSM ProgramPSM Program
Understand Each of the Elements of a ProperlyUnderstand Each of the Elements of a ProperlyDesigned & Implemented Program and How toDesigned & Implemented Program and How to
Begin the ProcessBegin the Process Understand the Basics of How PSM & RMPUnderstand the Basics of How PSM & RMP
Work Together to Protect the Workforce &Work Together to Protect the Workforce &
Surrounding CommunitySurrounding Community
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Summary of the One Week CourseSummary of the One Week Course
This is an In-Depth Study of theRequirements of the Standard Students will Actually Learn through a Real
Life Case Study How to Design Each Element
of the Process Safety Management StandardRequirements
Students will Also Review the Basics of EPARisk Management Plan (RMP)
This is an InThis is an In--Depth Study of theDepth Study of theRequirements of the StandardRequirements of the Standard
Students will Actually Learn through a RealStudents will Actually Learn through a RealLife Case Study How to Design Each ElementLife Case Study How to Design Each Element
of the Process Safety Management Standardof the Process Safety Management StandardRequirementsRequirements
Students will Also Review the Basics of EPAStudents will Also Review the Basics of EPARisk Management Plan (RMP)Risk Management Plan (RMP)
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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 QuestionsAsk Questions Participate in DiscussionsParticipate in Discussions
Share ExperiencesShare Experiences
Share Best PracticesShare Best Practices
Enjoy YourselfEnjoy Yourself
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Why Did OSHA Develop PSM?Why Did OSHA Develop PSM?
Bhopal, India (1984) 2,000 deaths
Isocyanate release Pasadena, TX (1989)
23 deaths, 132 injuriesPetroleum explosion Cincinnati, OH (1990)
2 deathsExplosion
Sterlington, LA (1991) 8 deaths, 128 injuries
Chemical release
Bhopal, India (1984)Bhopal, India (1984) 2,000 deaths2,000 deaths
Isocyanate releaseIsocyanate release Pasadena, TX (1989)Pasadena, TX (1989)
23 deaths, 132 injuries23 deaths, 132 injuriesPetroleum explosionPetroleum explosion Cincinnati, OH (1990)Cincinnati, OH (1990)
2 deaths2 deathsExplosionExplosion
Sterlington, LA (1991)Sterlington, LA (1991) 8 deaths, 128 injuries8 deaths, 128 injuries
Chemical releaseChemical release
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In 1991, OSHA andEPA respectively,Released theStandards, PSM &RMP that Applies to
Those Companiesthat are Affected by
The Standards.
In 1991, OSHA andIn 1991, OSHA andEPA respectively,EPA respectively,Released theReleased theStandards, PSM &Standards, PSM &
RMP that Applies toRMP that Applies toThose CompaniesThose Companiesthat are Affected bythat are Affected by
The Standards.The Standards.
Why Did OSHA Develop PSM?Why Did OSHA Develop PSM?
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Process Safety
Management is aregulation, promulgatedby OSHA, intended toprevent an incident likethe 1984 Bhopal Disaster
Andto Prevent Releaseof:Toxic, Reactive, Flammable, or Explosive chemicals
Process SafetyProcess Safety
ManagementManagement is ais aregulation, promulgatedregulation, promulgatedbyby OSHA, intended toOSHA, intended toprevent an incident likeprevent an incident likethe 1984the 1984 Bhopal DisasterBhopal Disaster
AndAndto Prevent Releaseto Prevent Releaseof:of:Toxic,Toxic, Reactive,Reactive, Flammable, orFlammable, or Explosive chemicalsExplosive chemicals
Why Did OSHA Develop PSM?Why Did OSHA Develop PSM?
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Not Only PSM, But RMPNot Only PSM, But RMP
A great many industrialfacilities must complywith OSHA's ProcessSafety Management
(PSM) regulations aswell as the quite similarEPA Risk ManagementProgram (RMP)regulations (Title 40CFR Part 68).
A great many industrialA great many industrialfacilities must complyfacilities must complywith OSHA's Processwith OSHA's ProcessSafety ManagementSafety Management
(PSM) regulations as(PSM) regulations aswell as the quite similarwell as the quite similarEPA Risk ManagementEPA Risk ManagementProgram (RMP)Program (RMP)regulations (Title 40regulations (Title 40CFR Part 68).CFR Part 68).
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PSM vs. RMP - Whats theDifference?PSM vs. RMP - Whats theDifference?
RMP-Like Sara Title III Protects the
Community Protects the General
Public Around theFacility Protects Adjacent
Facilities Such asSchools & Hospitals
RMPRMP--Like Sara Title IIILike Sara Title III Protects theProtects the
CommunityCommunity
Protects the GeneralProtects the General
Public Around thePublic Around theFacilityFacility
Protects AdjacentProtects AdjacentFacilities Such asFacilities Such asSchools & HospitalsSchools & Hospitals
PSM - Like HAZCOM Protects the
Workforce
Protects Contractors
Protects Visitors tothe Facility
Basically Protects theWorkplace
PSMPSM -- Like HAZCOMLike HAZCOM Protects theProtects the
WorkforceWorkforce
Protects ContractorsProtects Contractors
Protects Visitors toProtects Visitors tothe Facilitythe Facility
Basically Protects theBasically Protects theWorkplaceWorkplace
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The Standard Was Promulgatedin 1991 - Is it Working?The Standard Was Promulgatedin 1991 - Is it Working?
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BP Products TexasCity - March 2005 15 Workers Killed
170 Injured
Major PropertyDamage
$21 Million in Fines
BP Products TexasBP Products TexasCityCity -- March 2005March 2005 15 Workers Killed15 Workers Killed
170 Injured170 Injured
Major PropertyMajor PropertyDamageDamage
$21 Million in Fines$21 Million in Fines
The Standard Was Promulgatedin 1991 - Is it Working?The Standard Was Promulgatedin 1991 - Is it Working?
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ApplicationApplication
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 ofhighly hazardous chemicals, toxics and reactive(Mandatory). Contains a listing of toxic and reactivehighly hazardous chemicals which present a potential fora 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 ofThose Who Use Chemicals in Appendix A: A List ofhighly hazardous chemicals, toxics and reactivehighly hazardous chemicals, toxics and reactive(Mandatory). Contains a listing of toxic and reactive(Mandatory). Contains a listing of toxic and reactivehighly hazardous chemicals which present a potential forhighly hazardous chemicals which present a potential fora catastrophic event at or above the threshold quantitya catastrophic event at or above the threshold quantity
ExamplesExamples
ChemicalChemical Threshold Quantity (TQ)Threshold Quantity (TQ)
Anhydrous Ammonia:Anhydrous Ammonia: 10,000 lbs10,000 lbs Chlorine:Chlorine: 1,500 lbs1,500 lbs
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A process whichinvolves aflammable liquid orgas (as defined in
1910.1200(c) of thispart) on-site in onelocation, in a
quantity of 10,000pounds (4535.9 kg)or more
A process whichA process whichinvolves ainvolves aflammable liquid orflammable liquid orgas (as defined ingas (as defined in
1910.1200(c) of this1910.1200(c) of thispart) onpart) on--site in onesite in onelocation, in alocation, in a
quantity of 10,000quantity of 10,000pounds (4535.9 kg)pounds (4535.9 kg)or moreor more
What Facilities are CoveredWhat Facilities are Covered
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Important Interpretation: 2007 - 06/11/2007 - OSHA
defines "on-site in one location" for Process SafetyManagement of Highly Hazardous Chemicalsstandard
OSHA interprets "on-site in one location" to mean thatthe standard applies when a threshold quantity of ahighly hazardous chemical (HHC) exists within anarea under the control of an employer or group ofaffiliated employers. It also applies to any group ofvessels that are interconnected, or in separatevessels that are close enough in proximity that theHHC could be involved in a potential catastrophicrelease.
Important Interpretation:Important Interpretation: 20072007 -- 06/11/200706/11/2007 -- OSHAOSHA
defines "ondefines "on--site in one location" for Process Safetysite in one location" for Process SafetyManagement of Highly Hazardous ChemicalsManagement of Highly Hazardous Chemicalsstandardstandard
OSHA interprets "onOSHA interprets "on--site in one location" to mean thatsite in one location" to mean thatthe standard applies when a threshold quantity of athe standard applies when a threshold quantity of ahighly hazardous chemical (HHC) exists within anhighly hazardous chemical (HHC) exists within anarea under the control of an employer or group ofarea under the control of an employer or group ofaffiliated employers. It also applies to any groupaffiliated employers. It also applies to any group ofofvessels that are interconnected, or in separatevessels that are interconnected, or in separatevessels that are close enough in proximity that thevessels that are close enough in proximity that theHHC could be involved in a potential catastrophicHHC could be involved in a potential catastrophicrelease.release.
What Facilities are CoveredWhat Facilities are Covered
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Affect of the MeerDecision:
MEER ruling and the MEER Memorandum addressed in theSecretary's letter, OSHA's enforcement policy that the Agency
would not cite employers for violations of 1910.119 where storedflammable liquids in atmospheric tanks were connected to aprocess, unless the process outside of the amount in storagecontained more than 10,000 pounds of the substance
Affect of theAffect of the MeerMeerDecision:Decision:
MEERMEERruling and theruling and the MEERMEERMemorandum addressed in theMemorandum addressed in the
Secretary's letter,Secretary's letter, OSHA'sOSHA's enforcement policy that the Agencyenforcement policy that the Agency
would not cite employers forwould not cite employers for violations of 1910.119 where storedviolations of 1910.119 where storedflammable liquids in atmospheric tanks were connected to aflammable liquids in atmospheric tanks were connected to a
process, unless the process outside ofprocess, unless the process outside ofthe amount in storagethe 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
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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 overFood Processing with Anhydrous Ammonia overthe 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)
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There are ExclusionsThere are Exclusions
An employer is exempt from the requirements of PSMwhen: A threshold quantity of flammable liquids is stored in
atmospheric tanks or transferred without the benefit ofchilling or refrigeration
Hydrocarbon fuels used solely for workplaceconsumption as a fuel (e.g., propane used for comfortheating, gasoline for vehicle refueling), If such fuels are not a part of a process containing
another highly hazardous chemical covered by thisstandard
An employer is exempt from the requirements of PSMAn employer is exempt from the requirements of PSMwhen:when:
A threshold quantity of flammable liquids is stored inA threshold quantity of flammable liquids is stored inatmospheric tanks or transferred without the benefit ofatmospheric tanks or transferred without the benefit ofchilling or refrigerationchilling or refrigeration
Hydrocarbon fuels used solely for workplaceHydrocarbon fuels used solely for workplaceconsumption as a fuel (e.g., propane used for comfortconsumption as a fuel (e.g., propane used for comfortheating, gasoline for vehicle refueling),heating, gasoline for vehicle refueling),
If such fuels are not a part of a process containingIf such fuels are not a part of a process containing
another highly hazardous chemical covered by thisanother highly hazardous chemical covered by thisstandardstandard
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Retail facilities;
Oil or gas well drilling or
servicing operations; or, Normally unoccupied
remote facilities
Retail facilities;Retail facilities;
Oil or gas well drilling orOil or gas well drilling or
servicing operations; or,servicing operations; or,
Normally unoccupiedNormally unoccupied
remote facilitiesremote facilities
There are ExclusionsThere are Exclusions
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DefinitionsDefinitions
1910.119(b)1910.119(b)1910.119(b)
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DefinitionsDefinitions
Atmospheric tank means a storage tank which hasbeen designed to operate at pressures fromatmospheric through 0.5 p.s.i.g. (pounds per squareinch gauge, 3.45 Kpa).
Boiling point means the boiling point of a liquid at apressure 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 morehighly hazardous chemicals, that presents serious
danger to employees in the workplace.
Atmospheric tank means a storage tank which hasbeen designed to operate at pressures fromatmospheric through 0.5 p.s.i.g. (pounds per squareinch gauge, 3.45 Kpa).
Boiling point means the boiling point of a liquid at apressure 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 morehighly hazardous chemicals, that presents serious
danger to employees in the workplace.
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DefinitionsDefinitions Facility means the buildings, containers or equipment
which contain a process.
Highly hazardous chemical means a substancepossessing toxic, reactive, flammable, or explosiveproperties and specified by paragraph (a)(1) of thissection.
Hot work means work involving electric or gaswelding, cutting, brazing, or similar flame or spark-producing operations.
Normally unoccupied remote facility means a facilitywhich is operated, maintained or serviced byemployees who visit the facility only periodically tocheck its operation and to perform necessaryoperating or maintenance tasks. No employees arepermanently stationed at the facility.
Facility means the buildings, containers or equipmentFacility means the buildings, containers or equipmentwhich contain a process.which contain a process.
Highly hazardous chemical means a substanceHighly hazardous chemical means a substancepossessing toxic, reactive, flammable, or explosivepossessing toxic, reactive, flammable, or explosiveproperties and specified by paragraph (a)(1) of thisproperties and specified by paragraph (a)(1) of thissection.section.
Hot work meansHot work means work involving electric or gaswork involving electric or gaswelding, cutting, brazing, or similar flame or sparkwelding, cutting, brazing, or similar flame or spark--producing operations.producing operations.
Normally unoccupied remote facility means a facilityNormally unoccupied remote facility means a facilitywhich is operated, maintained or serviced bywhich is operated, maintained or serviced byemployees who visit the facility only periodicallemployees who visit the facility only periodically toy tocheck its operation and to perform necessarycheck its operation and to perform necessaryoperating or maintenance tasks. No employees areoperating or maintenance tasks. No employees arepermanently stationed at the facility.permanently stationed at the facility.
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DefinitionsDefinitions Process means any activity involving a highly
hazardous chemical including any use, storage,
manufacturing, handling, or the on-site movement ofsuch chemicals, or combination of these activities.For purposes of this definition, any group of vesselswhich are interconnected and separate vessels which
are located such that a highly hazardous chemicalcould be involved in a potential release shall beconsidered 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 ofinformation that is used in an employer's business
Process means any activity involving a highlyProcess means any activity involving a highlyhazardous chemical including any use, storage,hazardous chemical including any use, storage,
manufacturing, handling, or the onmanufacturing, handling, or the on--site movement ofsite movement ofsuch chemicals, or combination of these activities.such chemicals, or combination of these activities.For purposes of this definition, any group of vesselsFor purposes of this definition, any group of vesselswhichwhich are interconnected and separate vessels whichare interconnected and separate vessels which
are located such that a highly hazardous chemicalare located such that a highly hazardous chemicalcould be involved in a potential release shall becould be involved in a potential release shall beconsidered a single process.considered a single process.
Replacement in kind" means a replacement whichReplacement 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 ofpattern, process, device, information or compilation ofinformation that is used in an employer's businessinformation that is used in an employer's business
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Employee ParticipationEmployee Participation
1910.119(c)1910.119(c)1910.119(c)
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Now that we are required tocomply, then what? FirstNow that we are required tocomply, then what? First
Form a Team inYour Company, i.e.. Process Engineers
Operators
Safety
Maintenance
Management
Consultants
Form a Team inForm a Team inYour Company, i.e..Your Company, i.e.. Process EngineersProcess Engineers
OperatorsOperators
SafetySafety
MaintenanceMaintenance
ManagementManagement
ConsultantsConsultants
RememberYou Cant Do it Alone!
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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 tocomply, then what? SecondNow that we are required tocomply, then what? Second
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Now that we are required to
comply, then what? ThirdReview Scope of the Project:
Now that we are required to
comply, then what? ThirdReview Scope of the Project:
Application Exclusions Definitions Employee Participation
Hazards of the Process Toxicity Technology of the
Process
Equipment in theProcess Mechanical Integrity Inspection & Testing
Quality Assurance
ApplicationApplication
ExclusionsExclusions
DefinitionsDefinitions
Employee ParticipationEmployee Participation
Hazards of the ProcessHazards of the Process ToxicityToxicity
Technology of theTechnology of theProcessProcess
Equipment in theEquipment in theProcessProcess
Mechanical IntegrityMechanical Integrity
Inspection & TestingInspection & Testing
Quality AssuranceQuality Assurance
Process HazardAnalysis
Management of Change Operating Procedures Safe Work Practices Training Contractor
Management
Emergency Planning &Response Incident Investigation Compliance Audits
Trade Secrets
Process HazardProcess HazardAnalysisAnalysis
Management of ChangeManagement of Change
Operating ProceduresOperating Procedures
Safe Work PracticesSafe Work Practices
TrainingTraining
ContractorContractorManagementManagement
Emergency Planning &Emergency Planning &ResponseResponse
Incident InvestigationIncident Investigation
Compliance AuditsCompliance Audits
Trade SecretsTrade Secrets
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In the Next Session,we will Begin toExplore EachElement of the
Standard and Whatis Required toComply
In the Next Session,In the Next Session,we will Begin towe will Begin toExplore EachExplore EachElement of theElement of the
Standard and WhatStandard and Whatis Required tois Required toComplyComply
Now that we are required tocomply, then what? Lets BeginNow that we are required tocomply, then what? Lets Begin