process safety management vs risk management
DESCRIPTION
PROCESS SAFETY MANAGEMENT VS RISK MANAGEMENT. An Overview Tracy Estes, CSP James E. Roughton, MS, CSP, CRSP, CHMM. Process Safety Management. Required by the Environmental Protection Agency's (EPA) Clean Air Act Amendments (CAAA), Section 304 Promulgated - February 24, 1992 - PowerPoint PPT PresentationTRANSCRIPT
1
PROCESS SAFETY
MANAGEMENT
VS
RISK MANAGEMENT
An Overview
Tracy Estes, CSP
James E. Roughton, MS, CSP, CRSP, CHMM
2
Process Safety Management
Required by the Environmental Protection Agency's (EPA) Clean Air Act Amendments (CAAA), Section 304
Promulgated - February 24, 1992
5 year implementation
Proactive identification, evaluation, and mitigation or prevention of chemical releases that could occur as a result of failures in processes, procedures, or equipment
130 highly hazardous chemicals (HHC’s)
3
Process Safety Management (continued)
10,000 lb. or more of flammable materials that are used at or above their boiling points
Pyrotechnics and explosives manufacturers
More than 28,000 facilities affected
Exemptions: fuels used for workplace consumption Comfort heating Gasoline for vehicles
4
Risk Management Plan
Mandated by CAAA, Section 112 (r), 40 CFR Part 68
Promulgated - May 24, 1996
Published Federal Register - June 20, 1996
More than 100,000 facilities affected
Designed to help reduce risk of accidental release of hazardous substances
3 years to implement
5
Risk Management Plan
(continued)
Affects owners of a stationary source with regulated substances above a threshold quantity (TQ): 77 acutely toxic 63 flammable Department of Transportation (DOT) classified explosive
substances
6
EPA’s Visions for Accidental
Release Prevention Emphasize community right-to-know
Let information drive action
Focus the program at the local level EPA support
Coordinate communications at local level
7
Key Features of RMP
Prevention program 7-elements “mini-PSM” program 14 elements OSHA-PSM program expanded to address offsite
effects
Emergency response program
Risk management plan
Electronic submission to state and LEPC Available to public
Regulatory audits
8
Key Features
(continued)
3 Program levels
Management system
Offsite consequence analysis Worst-case scenario Alternative release scenario
5-year accident history
9
Key Features
(continued)
Summarizes key elements of the RMP program Tells a story Hazards at the site Accident history Potential offsite consequences Prevention steps Response program
10
Exemptions to Threshold
Quantity Articles
Laboratories
Uses: Structural components Janitorial maintenance Foods, drugs, cosmetics, or other personal items Present in process water or non-contact cooling water Compressed air or as part of combustion
11
EPA’s Regulatory Approach
Performance-based approach Similar to OSHA’s PSM
Build on existing programs and standards
Scale the requirements to fit the risk
Coordinate with OSHA and DOT
12
Requirements of 112 (r)
Established a general duty clause to: Identify hazards that may result from releases Design and maintain a safe facility Minimize the consequences or releases
13
Requirements of 112(r)
(continued)
Required EPA to promulgate a list of substances and set thresholds
Required EPA to develop a risk management program (RMP) rule
Register with EPA
Conduct a hazard assessment
Develop a prevention program
Develop an emergency response program
14
Requirements of 112 (r)
(continued)
Provide a summary (RMP) to EPA States Locals Public
15
Basic Principles
Build on EPCRA
Emphasize community right-to-know
Focus the program at the local level Where the risk is found
16
Basic Principles
(continued)
Accommodate small business concerns Provide model RMPs
» Ammonia
» Warehouses with chemicals
» Batch processors
» Refineries/gas plants Provide reference tables for offsite consequences analysis
17
Manufacturing Industries Affected
Chemical manufacturers Industrial Organics & Inorganics Paints Pharmaceuticals Adhesives, Sealants Fibers
18
Manufacturing Industries Affected
(continued) Petrochemical Products Refineries Industrial Gases Plastics and Resins Synthetic Rubber
19
Non-Manufacturing Affected
(continued)
Non-Manufacturing Facilities affected Utilities
» Electric and Gas Public Sources
» Drinking Water and Waste Water Treatment Agriculture
» Fertilizers, Pesticides
20
Other Manufacturing
Electronics
Semiconductors
Paper
Fabricated metals
Industrial machinery
Furniture
Textiles
21
Other Industries
Food and Cold Storage
Propane Retail
Warehousing
Wholesalers
Federal sources Military and Energy Installations
22
PSM vs. RMP Requirements
PSM’s concern - potential hazard and protection of employees inside a regulated area
RMP’s concern - potential incidents that may cause environmental and health hazards outside facility boundaries
Editorial changes to PSM to make text consistent with the CAAA's language
23
Hazard Assessment
Offsite consequence data Population estimate Public receptors Environmental receptors
Every 5 years
Within 6 months of a change that increases or decreased distance by a factor of 2 or more
24
Overview Worst-Case Scenario
(WCS) Greatest quantity from vessel or piping
May include administrative controls
Toxic gases Quantity released in 10 minutes
Toxic liquids Instantaneous spill to ground; volatilization; passive
mitigation
Toxic gases liquefied by refrigeration
25
Worst-Case Scenario
(continued)
All flammable substances Quantity for vapor cloud explosion
One worst case for each process
One worse case representing all toxic substances
Additional worst case(s) different public receptors
Other considerations Smaller quantities at higher temperature or pressure Source boundary proximity
26
Alternative Release Scenario
(ARS) More likely than a worst case scenario
Much reach endpoint offsite
One scenario representative of all flammables
27
ARS Selection
Accident history events
Process hazard analysis events
Worse case with mitigation
Example scenarios: Piping or hose failures Seal failures Vessel overfilling or venting
28
List of Substances and
Thresholds Focuses on lethal effects resulting from acute
exposures
Includes mandated substances
29
Mandated Substances
Ammonia
Anhydrous Ammonia
Anhydrous Hydrogen Chloride
Anhydrous Sulfur Dioxide
Bromine
Chlorine
Ethylene Oxide
Hydrogen Cyanide
Hydrogen Fluoride
Hydrogen Sulfide
Methyl Chloride
Methyl Isocyanate
Phosgene
Sulfur Trioxide
Toluene Diisocyanate
Vinyl Chloride
30
Toxic Substances
Extremely hazardous substances under SARA
Gases and highly volatile liquids
Vapor pressure > 10 mmHg
Thresholds ranging from 500-2,000 lbs.
Thresholds based on toxicity and volatility
31
Flammable Substances
NFPA 4 Most dangerous
Flammable gases and volatile flammable liquids that could create vapor cloud explosions
Thresholds set at 10,000 lbs.
32
Threshold Quantity Determination
Total quantity of a regulated substances contained in a process at any one time
Process included interconnected vessels or separate vessels that could be involved in a release (OSHA PSM definition)
33
Offsite Consequence Analysis
Toxic endpoint
Flammable endpoints
Use appropriate models or guidance
Within circle, identify Public receptors and population Environmental receptors
34
Registration and Submittal
Submit a comprehensive RMP to: EPA State Emergency Response Commission (SERC) Local Emergency Planning Committee (LEPC) The Chemical Safety and Hazard Investigation Board
35
Registration and Submittal
(Continued)
Name, mailing address, telephone of stationary source
CAS number of all regulated substances greater than TQ
SIC code
Dun and Bradstreet number
Certification signed by owner or operator
36
Auditing the Program
Conduct audits of the management system
37
Program Eligibility Criteria
Three Programs
38
Program 1 - No impact
Register
Conduct worst-case hazard assessments
Certify no off-site consequences for worst-case scenario
Ensure inclusion in LEPC plan
Submit RMP document above
39
Program 3 - Full RMP
One comprehensive prevention program that: Protects workers The public The environment
Hazard review information Hazards Controls Mitigation Changes
40
Program 3
(continued)
Register
Conduct worst-case and other hazard assessments
Implement comprehensive prevention steps (OSHA PSM plus...)
Develop emergency response plan
Submit RMP
41
Program 3
(continued)
Process is subject to OSHA's PSM
Processes in specific SIC codes Pulp Mills (2611) Chlor-Alkali (2812) Industrial Inorganic (2819) Plastics and Resins (2821) Cyclic Crudes (2865) Industrial Organics (2869) Nitrogen Fertilizers (2873) Agricultural Chemicals (2879) Petroleum Refineries (2911)
42
Program 2 - Streamlined
Prevention Program The process is not eligible for Program 1 or 3
43
Program 2
(continued)
Statutory requirements Training Maintenance Safety Precautions Monitoring
44
Program 2
(continued)
Types of sources: Less complex; fewer changes Ideal model program and plans
Capture good management practices from PSM but less documentation
Take advantages of other rules and standards
Take advantages of equipment manufacturer or vendor information
45
Program 2
(continued)
Process information (SIC, chemicals)
List rules, standards, design codes
Hazard review information Hazards Controls Mitigation Changes
46
Program 2
(continued)
Register
Conduct worst-case and other hazard assessments
Implement seven elements of prevention program
Develop emergency response plan
Submit RMP
47
Comparison of Program
Requirements
Hazard Assessment
Program 1 Program 2 Program 3
Worst-case analysis Worst-case analysis Worst-case analysis
Alternative releases Alternative releases
5-year accident history 5-year accident history 5-year accident history
48
Comparison
(continued)
Management Program Document
Program 1 Program 2 Program 3
Management System Management System
49
Comparison
(continued)
Prevention Program
Program 1 Program 2 Program 3
Certify no additional Safety Information Process Safety Information
steps Required Hazard Review Process Hazard Review
Operating Procedures Operating Procedures
Training Training
Maintenance Mechanical Integrity
Incident Investigation Incident Investigation
50
Comparison
(continued)
Prevention Program (continued)
Program 1 Program 2 Program 3
Compliance Audit Compliance Audit
Management of Change
Pre-Startup Review
Contractors
Employee Participation
Hot Work Permits
51
Comparison
(continued)
Emergency Response Program
Program 1 Program 2 Program 3
Coordinate with Local Develop Plan Develop PlanResponders and Program and Program
52
Comparison
(continued)
Risk Management Plan Content
Program 1 Program 2 Program 3
Executive Summary Executive Summary Executive Summary
Registration Registration Registration
Worst-Case Data Worst-Case Data Worst-Case Data
5-Year Accident History Alternative Release Data Alternative Release Data
Certification. 5-Year Accident History 5-Year Accident History
53
Comparison
(continued)
Risk Management Plan Content (continued)
Program 1 Program 2 Program 3
Prevention Program Data Prevention Program Data
Emergency Response Data Emergency Response Data
Certification Certification
54
OSHA PSM Requirements EPA Program 3 Requirements
An evaluation of the consequences An evaluation of the consequences
of deviations, including those of deviations
affecting the safety and health
of employees
The identification of any previous The identification of any previous
incident which had a likely potential incident which had a likely potential
for catastrophic consequences in for catastrophic consequences
the workplace
Editorial Changes
(continued)
55
Editorial Changes
(continued)
OSHA PSM Requirements EPA Program 3 Requirements
A qualitative evaluation of a range A qualitative evaluation of a range
of possible safety and health effects of possible safety and health
of failure of controls on employees effects of failure of controls
in the workplace
The employer shall investigate each The owner or operator shall
incident which resulted in, or could investigate each incident which
reasonably have resulted in a catastrophic resulted in, or could reasonably
release of a highly hazardous chemical have resulted in a catastrophic
in the workplace release of a regulated substance
56
Language Comparison
OSHA’s - PSM EPA’s - RMP
Employer Owner or Operator
Highly Hazardous Chemicals Regulated Substances
Facility Stationary Source
Standard Rule
Workplace Impact Off-Site Consequences
57
Compliance Procedures
Develop an inventory of substances used, stored, manufactured, processed, handled or moved, or any combination of the listed activities
Compare the inventory with the TQ, as required
58
Management System
Develop a management system to oversee the implementation of the RMP elements
Identify single person or position who has overall responsibility for: Development Implementation Integration of the RMP
59
Elements of the Program
60
Process Safety Information
Block flow or process flow diagrams
Maximum intended inventory
Establish safe limits of the operating parameters
61
Process Safety Information
(continued)
Evaluate consequences in deviations of process conditions
Equipment information
Verify equipment design with regulatory requirements/standard
62
Process Hazard Analysis
Document hazard analysis: Nature of the hazard Cause of the hazard Consequences of the hazard Actions to be considered to further protect personnel
Document follow-up steps based on recommendations
63
Process Hazard Analysis
(continued)
Document previous incidents with the potential to cause catastrophic conditions
Document hazards associated with human factors and facility siting
64
Operating Procedures
Develop clear operating procedures addressing steps for each process regarding Safe operating limits of processes Equipment
Provide precautionary instructions to prevent exposure to hazards
65
Operating Procedures
(continued)
Develop operating procedures for safety systems
Conduct annual review of operating procedures
Develop procedures for lockout/tagout, confined space entry, etc.
66
Employee Training
Document training for personnel in the process, operating procedures, and safe work practices applicable to the job tasks
Maintain records of training indicating the means used to verify that the employee understood the training
67
Maintenance (Mechanical Integrity)
Provide written procedures to maintain the structural integrity of process equipment
Document training for employees involved in maintenance of the process equipment
Verify inspections and testing of equipment and deficiencies are corrected
Document that spare parts are suitable for the appropriate application
68
Incident Investigation(Accident Investigation)
Incident reporting: The date of the incident Date of the investigation Description of the incident Factors contributing to the incident, and recommendations
that resulted
Verify that the recommendations in the incident report were promptly addressed and resolved
Identify root causes as well as initiating events
69
Compliance Audits
Evaluate compliance with program every three years
Conduct with at least one person knowledgeable in process
Develop report of findings Determine/develop a response to each finding, document that deficiencies have been corrected
Retain two most recent audit reports
70
Management of Change
Provide written procedures to manage change to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process
Verify that employees in operations and maintenance are trained accordingly
Provide evidence that changes are documented
71
Pre-Startup Review
Document that construction and equipment is in accordance with design specifications
Review documentation showing that safety, operating, maintenance, and emergency procedures are in place and adequate
Document that a PHA was performed, and recommendations were resolved and implemented
72
Pre-Startup Review
(continued)
Verify that modified facilities meet requirements in Management of Change procedures
Verify that employee training is completed
73
Contractors
Must established a screening process when hiring and use contractors
A site injury and illness log for contractors must be maintained
The contractor must ensure that each contract employee is trained in the work practices necessary to safely perform his/her job
74
Employee Participation
Must develop a written plan of action regarding the implementation of employee participation.
Required to train and educate employees and to inform all affected employees of the findings from any incident investigations.
75
Employee Participation
(continued)
Must consult with employees and employee representatives: Development of PHA and other elements Hazard assessments The development of chemical accident prevention
Must provide access to these records.
76
Permit Systems
A work authorization notice or permit system should be developed To describe the steps the maintenance supervisor, contractor
representative or other person need to follow in order to obtain the necessary clearance to get the job done.
These procedures need to address such issues as Lockout/tagout procedures Line breaking procedures Confined space entry procedures Hot work permits
77
Permit Systems
(continued)
Procedures must provide clear steps to follow once the job is completed to provide closure for those that need to know the job is completed and equipment can be returned to normal operations.
78
Emergency Planning and
Response Document that an emergency plan has been established and
implemented in accordance with 29 CFR 1910.38 and 1910.120, as applicable
Emergency action plan that include procedures for handling releases
Document specific actions to be taken in response to an accidental release of a regulated substance to protect humans and the environment Conduct drills Exercise to test plan
79
Emergency Response Plan -
Basic Requirements Emergency response plan
Procedures for use of emergency response equipment and for it inspection, testing, and maintenance
Training for all employees in relevant procedures
Procedures to review and update of the plan to reflect changes at the facility and ensure that employees are informed of changes
80
Elements - Legislative
Requirements Procedures for informing the public and local emergency
response agencies
Documentation of proper first-aid and emergency medical treatment necessary to treat accidental human exposures
Procedures and measures for emergency response after a release
Written plan must comply with other federal regulations
Coordinate with local LEPC
81
Planning Option - One-Plan Guidance
for Integrated Contingency Plan (ICP)
Intended to: Provide a mechanism for consolidating multiple facility
response plans Improve coordination of response activities Minimize duplication and simplify plan development and
maintenance Ensure regulatory compliance with all relevant federal
requirements
82
Communicating RMP to Public
83
Communication
Rule does not specify How communication should take place When it should take place How much risk communication
Anyone putting public at risk must show how risk is addressed/prevented and responded to
84
Regulatory Approach
Industry tells government and the public how it will address risk for preventing major accidents
Government and public can review what industry has presented
Government and community can respond to industry, communicate concerns, and make recommendation
85
Communicating the RMP
Start now
Explain the program
Tell the public what to expect with your WCS and when to expect it
Explain your WCS
Detail chemical(s) on site that can cause explosions, environmental impacts, etc.
Explain why you can’t reduce your inventory of regulated substances
86
Community Outreach
Suggestions Open house/plant tours
Local citizen groups/civic organization
High school programs
Community survey What does the community think about you?
Neighborhood meetings
Plant newsletter
Community advisory panels
87
Audience
Neighbors
Implementing agencies
LEPC
Emergency responders
City and county officials
88
Audience
(continued)
Business and community leaders
Educators
Local media
State legislators
89
Other Programs
Risk communications training
Training on handling the with media
Informing industrial neighbors
90
Summary - Developing an RMP
Implementation Plan
91
Implementation Strategy -
Technical Acquire/understand regulatory information
Determine coverage
Determine technical capabilities/needs
Prepare RMP implementation plan
92
Implementation Strategy -
Technical (continued)
Perform program level screening
Develop hazard assessment protocol
Perform hazard assessment
Compile 5-year accident history
93
Implementation Strategy -
Technical (continued)
Implement/upgrade PSM program to consider offsite effects
Review/upgrade emergency response activities and plan
Prepare and submit the RMP
94
Implementation Strategy -
Communication Determine internal risk communication
capabilities/needs
Survey community outreach status
Establish/improve community outreach
Prepare communication plan
Improve internal risk communication capabilities
Communicate the RMP to the public
95
Available Resources
Chemical Emergency Preparedness and Prevention Office (CEPPO) Internet - (http://www.epa.gov/swercepp/acc-pre.html)
96
Suggested Team Members
Health and safety Professionals Program development and review
Chemical, electrical, and mechanical engineering Process safety information and hazard analysis
development
Air Quality Specialist/Industrial Hygienist Air modeling dispersion. Identify acute health effects
97
Suggested Team Members
(continued)
Risk Assessment Specialist Population exposure and environmental effects
Communications Specialists Communicating with the public
98
Summary - Final Word
PSM and RMP outlines requirements for facilities to reduce risks associated with accidental releases
A good communications program will help reduce misinformation, distrust, and build good community relations
Reduction in inventory will result in a reduction of the risk and potential for a catastrophic incident
99
Summary - Final Word
(continued)
Audits are to be comprehensive, involving systematic assessment of all elements of the program