jan14 l2_ process safety regulations

8/13/2019 Jan14 L2_ Process Safety Regulations

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Process Safety-RelatedRegulations and Standard


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After completing this topic, students should be able to:

! Brief understanding of safety regulations:! Malaysia Department of Occupational Safety and Health:

! OSH Act (Occupational Safety and Health Act 1994)! Control of Industrial Major Accident Hazards 1996 CIMAH 1996

! International:! US OSHA - Process Safety Management (PSM)! UK HSE - CIMAH, COMAH

! Relate the standards and regulationsrequirementswith the application of process safety fundamental toprevent losses

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! Many lives are lost annually due tooccupational accidents

! Economic losses to families, society andthe nation

! Employers loss of trained/skilledemployees

! High compensation


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! Hazardous substances kill 438,000workers annually.

! 10% of all skin cancers are attributable toworkplace exposure to hazardoussubstances.

! 20% of all adult asthma is be attributableto workplace exposure to hazardoussubstances.

Source : ILO

Statistic


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Source: SOCSO, 2009

Occupational Death in Malaysia


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Source : SOCSO,2009

Accident Rate


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Source : SOCSO,2009

Frequency of Reported

Accident 2002-2008


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1974 - Caprolactam Plant Explosion,Flixborough, UK

Poorly engineered temporary plant modifications

Vapour cloud of cyclohexane

" Control building collapsed, killing 28 operators" Outcomes

Led to Advisory Committee on MajorHazards

HSE champions Safety Report conceptLed ultimately to CEC Seveso Directive /

Safety Report Concept

The Rising Case for Change

HAZARD:

Vapour cloud

of cyclohexane


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! 2,500immediatefatalities;20,000+ total

! Many otheroffsite injuries

# 1984 Bhopal, India Toxic MaterialReleased

HAZARD:

Highly Toxic

Methyl Isocyanate


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1989 - Plastics Manufacture Plant,Pasadena, Texas

Fire following vapour cloud explosion

" Poor Maintenance procedures,Contractor control and Management ofchange

" 23 Fatalities132 InjuredUS$1,400 Million Damage

" OutcomesUS OSHA PSM regulationsCCPS established

The Rising Case for Change

HAZARD:

Flammableethylene/isobutane

vapors in a 10 line


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Closer to Home Bright Sparkles

(1991)


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! Control of Industrial Major Accident HazardRegulations 1996

! Safety and Health Committee Regulations 1996! Safety and Health Officer Regulations 1997! Classification, Packaging and Labelling of

Hazardous Chemicals Regulations 1997

! USECHH Regulations 2000! Safety and Health Officer Orders 1997! Prohibition of Use of Substance Order 1999! Notification Of Accidents, Dangerous

Occurrences, Occupational Poisoning andOccupational Diseases 2004 (NADOPOD)

OSHAct 1994 - Regulations


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! Effective date : 01-02-1996! Key points of the regulations:! These regulations are applicable to:! All industrial activities except(Reg. 2):

! A nuclear installation! An installation under armed forces! A vehicle or vessel transporting hazardous substances to

and from the site of industrial activities! An industrial activity involved or likely to be involved with a

quantity of hazardous substance(s) which is/are equal orless than 10% of the threshold quantity of the hazardous

substance(s)! Under these regulations, the Manufacturer shall be obliged to

(Reg. 5):! Complywith the requirements of these regulations! Take immediate action to rectify the situation which may

affect the safety of persons or the environment


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Control of Industrial MajorAccident Hazards Regulations

(CIMAH) 1996


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(CIMAH) 1996


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(CIMAH) 1996


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! The Manufacturer is also responsiblefor identifying anyindustrial activity and submitting to the Director-General theNotification forms within 3 months after commencement ofthese regulations for existing installation or installation underconstruction, and within 1 month before construction of newinstallation (Reg. 7.1).

! Upon notification, it is at the Director-Generals discretion todeterminewhether the installation submitted is a majorhazard installation or not (Reg. 7.2).

! For installations identified as non-major hazards, thefollowing actions are still required to demonstrate safeoperation including appropriate documentation (Reg. 10):a) Identification of major accident hazardsb) Prevention of major accidents or minimization

of their consequences to persons andenvironment

c) Provisionof information, training and safetyequipment to workers

d) Preparationof up-to-date on-site emergency plan

CIMAH 1996


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! A written reporton industrial activities is to be prepared andsubmitted by appointed (registered) Competent Person (CP)within 12 months after existing activity is determined asMajor Hazard Installation, or within 3 monthsbeforecommencement of the new activity (Reg. 13 & 14).

!Manufacturer to immediately notify the Director-General forany changes in the quantityof hazardous substance kept atsite, or in the pipeline, or cessation of industrial activity, byresubmitting the Notification Forms (Reg. 8).

! Director-General can request for evidence to show that themanufacturer is applying risk assessmentin their industrialactivities (Reg. 10 & 11).

! Director-Generals approval is required before any furthermodificationcan be carried out, with a written reportsubmitted by CP at least 3 months in advance(reg. 15).

! Reports are required to be reviewed every 3 years, and to beresubmitted not later than a month after expiry (Reg. 16).


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! Competent Person is also responsible to maintain and keep anup-to-date emergency response plan, which must beconstantly updated; and people affected informed (Reg. 18).

! Manufacturer is responsible for informing local/port authoritywithin 3 monthsof determination (Reg. 21):! of activity capable of producing a major accident hazard! of the need for the preparation of emergency response plan

! Information to the publicshould be given voluntarily via thelocal authority and within 6 monthsof being determined as amajor hazard installation (Reg. 22).

!Nearest DOSH office should be immediately notified should amajor accident occur. Details of the accident report to includeremedial actions (Reg. 23).


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! Objective: prevent unwanted releases of hazardous chemicalsespecially into locations that could expose employees and others toserious hazards

! Makes employers responsible for providing safe and healthy workingconditions for employees

! Highlights of OSHAs enforcement rights:! Employers must admit OSHA compliance officers into their plant sites for

safety inspections with no advanced notice. A search warrant may berequired to show probable cause

! OSHAs right of inspection includes safety and health records! Criminal penalties can be invoked! OSHA officers finding conditions of imminent danger may request plant

shutdowns

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! Aim: to improve effectiveness of CIMAH! Main changes from CIMAH:

! CIMAH emphasized technical safety but management error isresponsible for 90% of major accidents

! COMAH emphasizes management errors! Changes implemented in COMAH:

! Major Accident Prevention Plan MAPP)introduced in COMAHmust include:

! aims of processing activities! principles of hazard control! description safety management systems (SMS)


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! Changes implemented in COMAH (continued):! Safety reportsemphasized:

!Must fully address potential hazards

! Must be submitted to competent authority (i.e., HSE in UK)! Management and organizational issues must be considered

! Site and installation: provisions apply to whole site as well asindividual installations (plants)

! Domino effects: effects of an incident on surrounding plantsmust be considered! Emergency plansmust be included


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The accident pyramid


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Accident and Loss Statistics

" OSHA incidence rate is based on cases per 100 workers years."A worker year is assumed to contain 2000 hours

(50 work weeks x 40 hours/week)

$ The OSHA incidence rate is based on 200,000 hours exposureto a hazard

OSHA incidence rate Number of injuries and

(based on injuries = illnesses x 200000

and illness)

Total hours worked by allemployees during period

covered.


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OSHA incidence rate Number of Lost

(based on lost = workdays x 200,000

workdays)

Total hours worked by all

employees during period

covered.

Accident and Loss Statistics


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Use your OSHA incidence rate to compareyour company's safety performance withstate and national averages and other

business in your industry.Number of reportable injuries/illnesses: 5

Total number of hours worked by all

employees: 50

!"#$%&' )

Incident Rate Per Year: 20,000


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! http://www.hse.gov.uk/comah/index.htm! http://www.osha.gov/! http://yosemite.epa.gov/oswer/

Ceppoweb.nsf/content/RMPoverview.htm! www.hse.gov.uk/research/rrpdf/rr343.pdf! http://dosh.mohr.gov.my/koperat/LAW/

Occupational Safety and Health Act 1994(Act514)/a0514.pdf

jan14 l2_ process safety regulations

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