Process Safety Management of Highly Hazardous & Explosive Chemicals

29CFR1910.11929CFR1910.119Clearly Understanding the StandardClearly Understanding the Standard

Information Provided under OSHA Susan Harwood Grant #SH-17811-SH-8

Susan Harwood Grant…History

Grants are awarded to provide training and Grants are awarded to provide training and education programs for employers and education programs for employers and employees on the recognition, avoidance, employees on the recognition, avoidance, and prevention of safety and health hazards and prevention of safety and health hazards in their workplaces. in their workplaces.

PSM Was Chosen Given the Clear Need PSM Was Chosen Given the Clear Need Past DisastersPast Disasters Current Year DisastersCurrent Year Disasters Perceived Weakness in PSM ProgramPerceived Weakness in PSM Program

GTRI PSM Susan Harwood Grant Program

GTRI is Offering:GTRI is Offering:

Six (6) One Day Courses Around the Six (6) One Day Courses Around the Southeastern United StatesSoutheastern United States

Four (4) One Week In-Depth Courses Four (4) One Week In-Depth Courses Around the United StatesAround the United States

Goals of the One Day Course Understand Why Process Safety Management (PSM) Understand Why Process Safety Management (PSM)

Was PromulgatedWas Promulgated Understand That Even with PSM, Catastrophes are Still Understand That Even with PSM, Catastrophes are Still

OccurringOccurring Understand Who is Covered & ExemptionsUnderstand Who is Covered & Exemptions Understand the Team Process to Developing a PSM Understand the Team Process to Developing a PSM

ProgramProgram Understand Each of the Elements of a Properly Designed Understand Each of the Elements of a Properly Designed

& Implemented Program and How to Begin the Process& Implemented Program and How to Begin the Process Understand the Basics of How PSM & RMP Work Understand the Basics of How PSM & RMP Work

Together to Protect the Workforce & Surrounding Together to Protect the Workforce & Surrounding CommunityCommunity

Summary of the One Week Course

This is an In-Depth Study of the This is an In-Depth Study of the Requirements of the Standard Requirements of the Standard

Students will Actually Learn through a Real Students will Actually Learn through a Real Life Case Study How to Design Each Element Life Case Study How to Design Each Element of the Process Safety Management Standard of the Process Safety Management Standard RequirementsRequirements

Students will Also Review the Basics of EPA Students will Also Review the Basics of EPA Risk Management Plan (RMP)Risk Management Plan (RMP)

Rules of the Course

This is an Open Discussion CourseThis is an Open Discussion Course

Relax and LearnRelax and Learn Ask Questions Ask Questions Participate in DiscussionsParticipate in Discussions Share ExperiencesShare Experiences Share Best PracticesShare Best Practices Enjoy YourselfEnjoy Yourself

Why Did OSHA Develop PSM?

Bhopal, India (1984)Bhopal, India (1984) 2,000 deaths 2,000 deaths

Isocyanate releaseIsocyanate release Pasadena, TX (1989)Pasadena, TX (1989)

23 deaths, 132 injuries 23 deaths, 132 injuries Petroleum explosionPetroleum explosion

Cincinnati, OH (1990)Cincinnati, OH (1990) 2 deaths 2 deaths

ExplosionExplosion Sterlington, LA (1991) Sterlington, LA (1991)

8 deaths, 128 injuries 8 deaths, 128 injuries Chemical releaseChemical release

In 1991, OSHA and In 1991, OSHA and EPA respectively, EPA respectively, Released the Released the Standards, PSM & Standards, PSM & RMP that Applies to RMP that Applies to Those Companies Those Companies that are Affected by that are Affected by The Standards.The Standards.

Why Did OSHA Develop PSM?

Process Safety Process Safety ManagementManagement is a is a regulation, promulgated regulation, promulgated by OSHA, intended to by OSHA, intended to prevent an incident like prevent an incident like the 1984 Bhopal Disasterthe 1984 Bhopal Disaster

And…to Prevent Release And…to Prevent Release of:of: Toxic, Toxic, Reactive, Reactive, Flammable, or Flammable, or Explosive chemicalsExplosive chemicals

Why Did OSHA Develop PSM?

Not Only PSM, But RMP

A great many industrial A great many industrial facilities must comply facilities must comply with OSHA's Process with OSHA's Process Safety Management Safety Management (PSM) regulations as (PSM) regulations as well as the quite similar well as the quite similar EPA Risk Management EPA Risk Management Program (RMP) Program (RMP) regulations (Title 40 regulations (Title 40 CFR Part 68). CFR Part 68).

PSM vs. RMP - What’s the Difference?

RMP-Like Sara Title IIIRMP-Like Sara Title III Protects the Protects the

CommunityCommunity Protects the General Protects the General

Public Around the Public Around the FacilityFacility

Protects Adjacent Protects Adjacent Facilities Such as Facilities Such as Schools & HospitalsSchools & Hospitals

PSM - Like HAZCOMPSM - Like HAZCOM Protects the Protects the

WorkforceWorkforce Protects ContractorsProtects Contractors Protects Visitors to Protects Visitors to

the Facilitythe Facility Basically Protects the Basically Protects the

Workplace Workplace

The Standard Was Promulgated in 1991 - Is it Working?

BP Products Texas BP Products Texas City - City - January 2005January 2005 15 Workers Killed15 Workers Killed 170 Injured170 Injured Major Property Major Property

DamageDamage $21 Million in Fines$21 Million in Fines

The Standard Was Promulgated in 1991 - Is it Working?

Application

1910.119(a)1910.119(a)

What Facilities are Covered

Those Who Use Chemicals in Appendix A: A List of Those Who Use Chemicals in Appendix A: A List of highly hazardous chemicals, toxics and reactive highly hazardous chemicals, toxics and reactive (Mandatory). Contains a listing of toxic and reactive (Mandatory). Contains a listing of toxic and reactive highly hazardous chemicals which present a potential highly hazardous chemicals which present a potential for a catastrophic event at or above the threshold for a catastrophic event at or above the threshold quantityquantity

ExamplesExamples

Chemical Threshold Quantity (TQ)Chemical Threshold Quantity (TQ) Anhydrous Ammonia - 10,000 lbsAnhydrous Ammonia - 10,000 lbs Chlorine - 1,000 lbsChlorine - 1,000 lbs

A process which A process which involves a involves a flammable liquid or flammable liquid or gas (as defined in gas (as defined in 1910.1200(c) of this 1910.1200(c) of this part) on-site in one part) on-site in one location, in a location, in a quantity of 10,000 quantity of 10,000 pounds (4535.9 kg) pounds (4535.9 kg) or moreor more

What Facilities are Covered

Important Interpretation: 2007 - 06/11/2007 - OSHA Important Interpretation: 2007 - 06/11/2007 - OSHA defines "on-site in one location" for Process Safety defines "on-site in one location" for Process Safety Management of Highly Hazardous Chemicals standardManagement of Highly Hazardous Chemicals standard

OSHA interprets "on-site in one location" to mean that the OSHA interprets "on-site in one location" to mean that the standard applies when a threshold quantity of a highly standard applies when a threshold quantity of a highly hazardous chemical (HHC) exists within an area under hazardous chemical (HHC) exists within an area under the control of an employer or group of affiliated the control of an employer or group of affiliated employers. It also applies to any group of vessels that employers. It also applies to any group of vessels that are interconnected, or in separate vessels that are are interconnected, or in separate vessels that are close enough in proximity that the HHC could be close enough in proximity that the HHC could be involved in a potential catastrophic release.involved in a potential catastrophic release.

What Facilities are Covered

What Types of Industries?

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 over Food Processing with Anhydrous Ammonia over

the TQthe TQ

Exclusions

1910.119(a)(1)(ii)(A)1910.119(a)(1)(ii)(A)

There are Exclusions

An employer is exempt from the requirements of PSM An employer is exempt from the requirements of PSM when:when:

A threshold quantity of flammable liquids is stored in A threshold quantity of flammable liquids is stored in atmospheric tanks or transferred without the benefit of atmospheric tanks or transferred without the benefit of chilling or refrigeration chilling or refrigeration

Hydrocarbon fuels used solely for workplace Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling), heating, gasoline for vehicle refueling), If such fuels are not a part of a process containing If such fuels are not a part of a process containing

another highly hazardous chemical covered by this another highly hazardous chemical covered by this standardstandard

Retail facilities;Retail facilities;

Oil or gas well drilling or Oil or gas well drilling or

servicing operations; or,servicing operations; or,

Normally unoccupied Normally unoccupied

remote facilitiesremote facilities

There are Exclusions

Definitions

1910.119(b)1910.119(b)

Definitions

Atmospheric tank means a storage tank which Atmospheric tank means a storage tank which has been designed to operate at pressures has been designed to operate at pressures from atmospheric through 0.5 p.s.i.g. (pounds from atmospheric through 0.5 p.s.i.g. (pounds per square inch gauge, 3.45 Kpa). per square inch gauge, 3.45 Kpa).

Boiling point means the boiling point of a liquid Boiling point means the boiling point of a liquid at a pressure of 14.7 pounds per square inch at a pressure of 14.7 pounds per square inch absolute (p.s.i.a.) (760 mm.).absolute (p.s.i.a.) (760 mm.).

Catastrophic release means a major Catastrophic release means a major uncontrolled emission, fire, or explosion, uncontrolled emission, fire, or explosion, involving one or more highly hazardous involving one or more highly hazardous chemicals, that presents serious danger to chemicals, that presents serious danger to employees in the workplace.employees in the workplace.

Definitions Facility means the buildings, containers or equipment which Facility means the buildings, containers or equipment which

contain a process. contain a process. Highly hazardous chemical means a substance possessing Highly hazardous chemical means a substance possessing

toxic, reactive, flammable, or explosive properties and toxic, reactive, flammable, or explosive properties and specified by paragraph (a)(1) of this section. specified by paragraph (a)(1) of this section.

Hot work means work involving electric or gas welding, Hot work means work involving electric or gas welding, cutting, brazing, or similar flame or spark-producing cutting, brazing, or similar flame or spark-producing operations. operations.

Normally unoccupied remote facility means a facility which Normally unoccupied remote facility means a facility which is operated, maintained or serviced by employees who visit is operated, maintained or serviced by employees who visit the facility only periodically to check its operation and to the facility only periodically to check its operation and to perform necessary operating or maintenance tasks. No perform necessary operating or maintenance tasks. No employees are permanently stationed at the facility.employees are permanently stationed at the facility.

Definitions Process means any activity involving a highly Process means any activity involving a highly

hazardous chemical including any use, storage, hazardous chemical including any use, storage, manufacturing, handling, or the on-site movement of manufacturing, handling, or the on-site movement of such chemicals, or combination of these activities. such chemicals, or combination of these activities. For purposes of this definition, any group of vessels For purposes of this definition, any group of vessels which are interconnected and separate vessels which which are interconnected and separate vessels which are located such that a highly hazardous chemical are located such that a highly hazardous chemical could be involved in a potential release shall be could be involved in a potential release shall be considered a single process.considered a single process.

Replacement in kind" means a replacement which Replacement 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 of pattern, process, device, information or compilation of information that is used in an employer's businessinformation that is used in an employer's business

Employee Participation

1910.119(c)1910.119(c)

Now that we are required to comply, then what? First… Form a Team in Form a Team in

Your Company, i.e..Your Company, i.e.. Process EngineersProcess Engineers OperatorsOperators SafetySafety MaintenanceMaintenance ManagementManagement ConsultantsConsultants

Remember…You Can’t Do it Alone!

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 to comply, then what? Second…

Review Scope of Project:Review Scope of Project: Process Safety Information Process Safety Information  Equipment in the ProcessEquipment in the Process Process Hazard AnalysisProcess Hazard Analysis Operating ProceduresOperating Procedures Employee TrainingEmployee Training Training ContractorsTraining Contractors Pre-Startup Safety ReviewPre-Startup Safety Review Mechanical Integrity of Equipment  Mechanical Integrity of Equipment  Management of ChangeManagement of Change Incident InvestigationIncident Investigation Emergency PreparednessEmergency Preparedness Compliance Audits   Compliance Audits    Trade SecretsTrade Secrets

Now that we are required to comply, then what? Third…

In the Next Session, In the Next Session, we will Begin to we will Begin to Explore Each Explore Each Element of the Element of the Standard and What Standard and What is Required to is Required to ComplyComply

Now that we are required to comply, then what? …Let’s Begin