What is OSHAs Process Safety Management Program 29

OSHA Process Safety Management Topics: 1. What is PSM? 2. Which industries must comply?

What is PSM? Process Safety Management is program implemented by OSHA, which became effective

Which industries must comply? What industries are required to comply? The standard mainly applies

Why did OSHA set up the PSM standard? Unintended, accidental releases of highly hazardous

Why did OSHA set up the PSM standard? (cont. ) • July 1990 –

Happening in Conjunction OSHA proposed the PSM standard on July 17, 1990, meaning it

Happening in Conjunction Four months later, the Clean Air Act Amendments (CAAA) became law

What are the 14 Elements of PSM? Employee Participation Process Safety Information Process Hazard

Employer Requirements: Employee Participation All employees involved with chemical processes covered under OSHA 29

Employer Requirements: Process Safety Information

Employer Requirements: Process Hazard Analysis The PHA is a thorough, orderly, systematic approach for

Employer Requirements Process Hazard Analysis One or more of the following methods may be

Employer Requirements: Operating Procedures Employers must develop and implement written operating procedures, consistent with

Employer Requirements: Operating Procedures cont. Operating limits: üConsequences of deviation üSteps required to correct

Employer Requirements: Hot Work Permits A permit must be issued for hot work operations

Employer Requirements: Management of Change Employers must implement and maintain procedures on managing changes

Employer Requirements: Management of Change cont. Employees involved in operating the process and maintenance

Employer Requirements: Pre-Startup Safety Review The employer is required to perform a pre-startup safety

Employer Requirements: Mechanical Integrity The employer must establish and implement written procedures to maintain

Employer Requirements: Mechanical Integrity Inspection & testing must occur on all process equipment, using

Employer Requirements: Emergency Planning If an incident does occur, it is essential that emergency

Employer Requirements: Incident Investigations PSM requires the investigation of each incident that resulted in,

Employer Requirements: Contractors Employer responsibilities: - obtain & evaluate safety performance and programs of

Employer Requirements: Contractors Contractor employers’ responsibilities: • Ensure that contract employees are trained in

Employer Requirements: Training Each employee involved in operating a process must be trained in

Employer Requirements: Compliance Audits Employers must certify that they have evaluated compliance with the

Employer Requirements: Trade Secrets Employers must make available all information necessary to comply with

Mechanical Integrity Key element to Mechanical Integrity inspections/testing is Preventative Maintenance (PM) On a

Mechanical Integrity Storage tanks, blend vessels, piping, etc. ØCorrosion under insulation ØWall thinning ØWall

Mechanical Integrity Non-Destructive Testing Techniques (there are MANY, here a few) ØUltrasonic thickness testing

Closing Comments OSHA requires employers to follow the Process Safety Management Standard, 29 CFR

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What is OSHA’s Process Safety Management Program? 29 CFR 1910. 119 Trilby Cressman, CSP | February 24, 2020 Deer Park Community Advisory Council

OSHA Process Safety Management Topics: 1. What is PSM? 2. Which industries must comply? 3. Why did OSHA implement PSM? 4. What are the 14 elements of PSM? 5. A Little More Detail on Mechanical Integrity 6. Closing Comments 7. Questions?

What is PSM? Process Safety Management is program implemented by OSHA, which became effective on February 24, 1992… HAPPY 28 th BIRTHDAY, PSM! In order to understand the intent of PSM, you need to understand what OSHA means by “PROCESS”: “Process means any activity involving a highly hazardous chemical including using, storing, manufacturing, handling, or moving such chemicals at the site, or any combination of these activities. For purposes of this definition, any group of vessels that are interconnected, and separate vessels located in a way that could involve a highly hazardous chemical in a potential release, are considered a single process. ” PSM is a detailed program, which provides a uniform set of rules for specific industries to safely manage the use, storage, handling, etc. of highly hazardous chemicals.

Which industries must comply? What industries are required to comply? The standard mainly applies to manufacturing industries, in particular- chemicals - transportation equipment - fabricated metal products - natural gas liquids - farm product warehousing, - electric, gas, and sanitary services - pyrotechnics & explosives There are special provisions for the protection of contract workers working inside a “covered process” as well.

Why did OSHA set up the PSM standard? Unintended, accidental releases of highly hazardous chemicals pose a strong threat for catastrophic disasters • December 1982 – Bhopal, India – Union Carbide pesticide plant had a gas leak, which made its way in and around small towns bordering the plant. >500, 000 people were exposed to Methyl Isocyanate, resulting in >2, 000 deaths • October 1989 – Pasadena, TX - Phillips Petroleum Company polyethylene plant had a series of 6 explosions due to the accidental release of extremely flammable process gases. 23 workers died and 314 were injured. • July 1990 –Channelview, TX - ARCO Chemical had an explosion that killed 17 workers and flattened an area of the plant the size of a city block.

Why did OSHA set up the PSM standard? (cont. ) • July 1990 – Cincinnati, OH – BASF plant experienced 2 explosions, resulting in a fire that took several hours to extinguish before rescue personnel could get inside. The explosions were due to an over-pressurization of a reactor being cleaned with a flammable solvent. 2 workers died and >70 were injured. • May 1991 – Sterlington, LA – IMC Fertilizer plant experienced an explosion in the nitroparaffin unit, which killed 8 people and injured 120. • Records of hazardous chemical releases have been kept for years before these incidents, but these are the “high-profile” incidents which OSHA sites for developing the PSM standard.

Happening in Conjunction OSHA proposed the PSM standard on July 17, 1990, meaning it was entered into the Federal Register. The proposed standard emphasized the management of hazards associated with highly hazardous chemicals and established a comprehensive management program that integrated technologies, procedures, and management practices. Meanwhile, the EPA was establishing an amendment to the Clean Air Act (CAA), working with the Secretary of Labor and under the OSH Act of 1970, requiring promulgation of a chemical process safety standard to prevent accidental releases of chemicals that could pose a threat to employees.

Happening in Conjunction Four months later, the Clean Air Act Amendments (CAAA) became law – November 15, 1990 The CAAA required that the standard include a list of highly hazardous chemicals which includes toxic, flammable, highly reactive, and explosive substances. The CAAA also specified minimum elements that the OSHA standard must require employers to do…these elements became the Process Safety Management standard, 29 CFR 1910. 119. The CAAA established the EPA Risk Management Program (RMP) that requires risk management plans of certain facilities. PSM focused primarily on workers and RMP on the community. February 24, 1992 - 29 CFR 1910. 119 was officially adopted and the requirements were mandated.

What are the 14 Elements of PSM? Employee Participation Process Safety Information Process Hazard Analysis Operating Procedures Hot Work Permits Management of Change Pre-Startup Safety Reviews Mechanical Integrity Emergency Planning Incident Investigation Contractors Training Compliance Audits Trade Secrets

Employer Requirements: Employee Participation All employees involved with chemical processes covered under OSHA 29 CFR 1910. 119 must be involved with the PSM Program. Employee participation means: Ø Provide input on process Ø Consult with employees on process Ø Data available to employee Ø Training Ways to Participate: P&ID review/verify Operating Procedures Monitor and evaluate contractors Management of change Process hazard analysis SDS PSSR Work Permits Emergency planning/drills MI: preventive maintenance, corrosion

Employer Requirements: Process Safety Information

Employer Requirements: Process Hazard Analysis The PHA is a thorough, orderly, systematic approach for identifying, evaluating, and controlling the hazards of processes involving highly hazardous chemicals. PHAs must include: v. The hazards of the process v. The review of previous incidents that had a potential for catastrophic consequences v. Engineering and administrative controls applicable to the hazards and their interrelationships, such as appropriate application of detection methodologies to provide early warning of releases. Acceptable detection methods might include process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors v. Consequences of failure of engineering and administrative controls v. Facility siting v. Human factors v. A qualitative evaluation of a range of the possible safety and health effects on employees in the workplace if there is a failure of controls.

Employer Requirements Process Hazard Analysis One or more of the following methods may be used, as appropriate, to determine and evaluate the hazards of the process being analyzed. ØWhat-If / Checklists ØHazardous and Operability Review (HAZOP) ØFailure Mode and Effects Analysis (FMEA) ØFault Tree Analysis (FTA) ØLine by Line Hazards Analysis ØAny appropriate equivalent method PHAs must be revalidated every 5 years.

Employer Requirements: Operating Procedures Employers must develop and implement written operating procedures, consistent with the process safety information, that provide clear instructions for safely conducting activities involved in each covered process. These procedures must include: Steps for each operating phase: üInitial startup üNormal operations üTemporary operations üEmergency shutdown, including the conditions under which emergency shutdown is required, and the assignment of shut down responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner üEmergency operations üNormal shutdown üStartup following a turnaround, or after an emergency shutdown

Employer Requirements: Operating Procedures cont. Operating limits: üConsequences of deviation üSteps required to correct or avoid deviation Safety and health considerations: üProperties of, and hazards presented by, the chemicals used in the process üPrecautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment üControl measures to be taken if physical contact or airborne exposure occurs üQuality control for raw materials and control of hazardous chemical inventory levels üAny special or unique hazards üSafety systems (e. g. , interlocks, detection or suppression systems) and their functions

Employer Requirements: Hot Work Permits A permit must be issued for hot work operations conducted on or near a covered process. What is “hot work”? Hot work is any work that involves burning, welding, cutting, brazing, soldering, grinding, using fire- or sparkproducing tools, or other work that produces a source of ignition.

Employer Requirements: Management of Change Employers must implement and maintain procedures on managing changes to the process chemicals, technology, equipment, procedures and facilities. These procedures must cover both long-term and temporary changes. Process changes must be documented and kept as part of the Process Safety Information. The procedure shall ensure the following items are addressed prior to the change: • • • The technical basis for the proposed change The impact of the change on safety & health Modifications to operating procedures Necessary time period for the change Authorization for the change

Employer Requirements: Management of Change cont. Employees involved in operating the process and maintenance personnel and contract employees whose job tasks may be affected by the change, must be notified of and trained in the change. "Replacement in Kind" is not considered to be a change. For example, if you replace a pump in the process with one of the same design, this is not considered to be a process change.

Employer Requirements: Pre-Startup Safety Review The employer is required to perform a pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information. Prior to the introduction of a highly hazardous chemical to a process, the pre-startup safety review must confirm that the following: ØConstruction and equipment are in accordance with design specifications ØSafety, operating, maintenance, and emergency procedures are in place and are adequate ØA process hazard analysis has been performed for new facilities and recommendations have been resolved or implemented before startup, and modified facilities meet the management of change requirements ØTraining of each employee involved in operating a process has been completed. THIS MUST BE DOCUMENTED AND THOSE WHO WERE PART OF THE REVIEW MUST SIGN-OFF!

Employer Requirements: Mechanical Integrity The employer must establish and implement written procedures to maintain the ongoing integrity of process equipment. • Pressure vessels and storage tanks • Piping systems (including piping components such as valves) • Emergency shutdown systems • Controls (including monitoring devices and sensors, alarms, and interlocks) • Pumps Employees involved in maintaining the ongoing integrity of process equipment must be trained in an overview of the process and its hazards and trained in the procedures applicable to the employees' job tasks.

Employer Requirements: Mechanical Integrity Inspection & testing must occur on all process equipment, using “recognized and generally accepted good engineering practices” or RAGAGEP. Frequency of testing is based on manufacturers’ recommendations & good engineering practices. Inspections must be documented and include: § § § type of testing name of person who performed the testing serial numbers (or other identifiers) of the equipment tested description of the testing performed results of the testing Generally, deficiencies must be corrected before the equipment is put back in service. The employer also must ensure that maintenance materials, spare parts, and equipment are suitable for the process application for which they will be used.

Employer Requirements: Emergency Planning If an incident does occur, it is essential that emergency pre-planning and training make employees aware of, and able to execute, the proper actions. For this reason, an emergency action plan for the entire plant must be developed and implemented in accordance with the provisions of other OSHA rules (29 CFR 1910. 38(a)). In addition, the emergency action plan must include procedures for handling small releases of hazardous chemicals. These plans must be documented and reviewed periodically to ensure they are still current.

Employer Requirements: Incident Investigations PSM requires the investigation of each incident that resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical in the workplace. Incident Investigation must begin within 48 hours of the incident occurring. Team will consist of: - at least one person knowledgeable of the process - a contractor, if one was involved in the incident - a person with knowledge & experience in the investigation process & able to analyze the incident thoroughly The final report will consist of: • Date of incident, • Date investigation began, • Description of the incident, • Factors that contributed to the incident, and • Recommendations resulting from the investigation. These reports must be retained for at least 5 years!

Employer Requirements: Contractors Employer responsibilities: - obtain & evaluate safety performance and programs of the contract company - make the contract employer aware of known potential fire, explosion, or toxic release hazards related to the contractor's work and the process - explain the applicable parts of the emergency action plans - implement a safe work practice for accountability of contracted employees - periodically evaluate the performance of the contracted employees - maintain an injury & illness log for contracted employees

Employer Requirements: Contractors Contractor employers’ responsibilities: • Ensure that contract employees are trained in the work practices necessary to perform their job safely • Ensure that contract employees are aware of the known potential fire, explosion, or toxic release hazards related to their job and the process, and the emergency action plans • Document that each contract employee has received and understood the training required by the standard by preparing a record that contains the identity of the contract employee, the date of training, and the means used to verify that the employee understood the training • Ensure that each contract employee follows the safety rules of the facility including the required safe work practices • Advise the employer of any unique hazards presented by the contract employer's work.

Employer Requirements: Training Each employee involved in operating a process must be trained in an overview of the process and in its operating procedures. The training must include emphasis on the specific safety and health hazards of the process, emergency operations including shutdown, and other safe work practices that apply to the employee's job tasks. Training must be done “initially” and every 3 years, employees must have “refresher” training. All training must be documented with a way to verify the employee understands the hazards of the tasks as hand (i. e. tests).

Employer Requirements: Compliance Audits Employers must certify that they have evaluated compliance with the provisions of PSM at least every three years. This will verify that the procedures and practices developed under the standard are adequate and are being followed. The compliance audit must be conducted by at least one person knowledgeable in the process and a report of the findings of the audit must be developed and documented noting deficiencies that have been corrected. The two most recent compliance audit reports must be kept on file.

Employer Requirements: Trade Secrets Employers must make available all information necessary to comply with PSM to personnel responsible for: ØCompiling the Process Safety Information ØDeveloping the Process Hazard Analysis (PHA), Operating Procedures, and Emergency Response Plans ØConducting Incident Investigations & Compliance Audits *may require employees/persons granted knowledge to sign a non-disclosure agreement

Mechanical Integrity Key element to Mechanical Integrity inspections/testing is Preventative Maintenance (PM) On a set frequency, testing and/or inspection of critical equipment is performed. ØTo ensure proper functionality ØTo ensure warning systems function properly ØTo ensure safety first! • Pressure vessels and storage tanks – internal & external inspections (i. e. confined space entry to check for wall thickness, pitting, deformation of welds, junctions) • Piping systems (including piping components such as valves) – external/visual inspections to determine wall thickness of pipes. • Emergency shutdown systems – to ensure they are functioning properly • Controls (including monitoring devices and sensors, alarms, and interlocks) • Pumps – to ensure all moving parts are in good condition, no leaks present at seals, etc.

Mechanical Integrity Storage tanks, blend vessels, piping, etc. ØCorrosion under insulation ØWall thinning ØWall pitting ØHoles ØWelds verification

Mechanical Integrity Non-Destructive Testing Techniques (there are MANY, here a few) ØUltrasonic thickness testing – ultrasonic waves are passed through an object (tank wall or piping) at specific frequencies. The change in waves absorbed detects abnormalities or internal flaws in the object. ØIndustrial radiography – use X-rays or gamma rays to verify structure and integrity of an object ØAcoustic resonance testing – use sound waves to measure the integrity of an object

Closing Comments OSHA requires employers to follow the Process Safety Management Standard, 29 CFR 1910. 119 PSM was developed to protect workers from hazards associated with the use of highly-hazardous chemicals in a process. The requirements, when implemented successfully, GREATLY reduce the chances of a catastrophic event from occurring.

Questions?