1day Intro

7/30/2019 1day Intro

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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.



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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



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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



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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.



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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



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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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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


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

Documents

1day Intro