PROCESS SAFETY MANAGEMENT VS RISK MANAGEMENT

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