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Process Safety Management of Highly Hazardous & Explosive Chemicals

Contractor Pre-Qualification, Emergency Preparedness, Incident Investigation, Audits & EPA Risk Management Plans (RMP)

Now That We’ve Developed
         

Process Safety Information Process Material Toxicity Information Process Hazard Analysis (PHA’s) Mechanical Integrity Certificates Management of Change Inspection/Testing/Maintenance Operating Procedures Safe Work Procedures Training Programs Training for Contractors Now…

Contractor Management
1910.119(h)

PSM Contractors


The employer, when selecting a contractor, shall obtain and evaluate information regarding the contract employer's safety performance and programs.  The employer shall inform contract employers of the known potential fire, explosion, or toxic release hazards related to the contractor's work and the process

Contractor Pre-Qualification & Authorization


The Standard Requires You to:
       

Explain contractor qualification requirements List what is required for contractor pre-bid awareness - pre-qualification List what is required for contractor post-bid awareness - training & orientation Specify contractor responsibilities Describe contractor 300 Log Requirements Evaluate Contractor Performance List documentation requirements for contractors to complete Explain the use of a work authorization system

Contractor Pre-Qualification & Authorization


Typical Pre-Qualification Elements:
 Years

Experience in Work Process  Experience Modification Rate (EMR)  OSHA Total Recordable Incident Rate and Lost Work day Case Rate Information  Safety Programs  Training Documentation

Emergency Preparedness
1910.119(f)(1)(I)(D)

Emergency Preparedness



Our Written Plan Must:

Define an emergency action plan  Define an emergency response plan  Describe a Minimum emergency response plan  Describe procedures for handling small releases  List the three levels of emergency response  List procedures for emergency evacuation  List requirements of alarm systems  List training requirements

Emergency Preparedness


The Standard Requires You to:


Develop a Early Warning Method for Releases (Sensors/Alarms)  Train on the Meaning of the Alarms (May be Multiple Alarms)  Develop Emergency Evacuation Written Plans, Evacuation Maps & Assembly Points based on Release Characteristics  Determine Emergency PPE Requirements  Train Employees & Contractors in the Emergency Evacuation Plans  Drill The Emergency Evacuation Plan At Last Once Per Year

Emergency Preparedness


Warning Systems must:




Clearly Notify Employees of the Hazardous Release Employees & Contractors must be Trained in the Meaning of the Alarm(s)

Emergency Preparedness Evacuation Maps

Emergency Preparedness Assembly Points

Alternate Assembly Points Depending on Prevailing Weather Affecting Release
Alternate Assembly Point

Emergency Preparedness Emergency PPE


Hazardous Chemicals May Require Emergency PPE to be Worn

 

FRP Escape Respirators Eye Protection i.e.. Refinery Goggles

Emergency Preparedness Drills


At Least Annual Emergency Preparedness Drills  This is not Just an Emergency Evacuation…  but Could Include HAZWOPR Response  Must Document Results

Incident Investigation
1910.119(m)

Incident Investigation Program Must Include the Following


Describe the purpose of incident investigation  List the circumstances or occurrences, which require formal incident investigation  List the major investigation procedures that should be followed  Explain the list the responsibilities of the incident investigation team  Explain the contents of an "Incident Summary" form  Explain the contents of an "Incident Description" form  Explain the contents of an "Approvals, Follow-up and Review" form  Explain the contents of a "Close-out" form  Explain Corrective Actions Taken

Incidents Can Be Minor or Major Both Require Investigation

Incident Investigation Documentation Must Include
Date of incident  Date investigation began  Description of the incident  Factors contributing to the incident  Recommendations resulting from the investigation


Incident Investigation



Will Include Written Documentation of all Required Elements

Incident Investigation

Might Even Include a Flow Chart

Compliance Audits
1910.119(o)

Compliance Audits


1910.119 states, "Employers shall certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed."

Compliance Audits
A

List of factors that may increase the frequency of compliance audits  Results of Any OSHA Compliance Audits Performed & Citations/Action Items Developed  An Explanation of audit certification  List Compliance Audit documentation

Compliance Audits


  

Employers shall certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed The compliance audit shall be conducted by at least one person knowledgeable in the process A report of the findings of the audit shall be developed Compliance Audits Must be Performed Every 3 Years

Compliance Audits


The Compliance Audit Process Typically Includes the Following:
   

Definition of the guidelines for an audit team A List the PSM elements that must be audited A List of the minimum contents of a final report of an audit An Explanation and list the Compliant Audit reports that must be retained by the facility

Compliance Audits


OSHA PSM Citations
# Initial Penalty $25,058,853 Final Penalty $18,884,463

1393

Compliance Audits

    

Typical Types of OSHA Serious Citations failure to maintain and follow normal operating procedures failure to provide refresher training to process operators failure to correct deficiencies in process equipment in a safe manner failure to provide necessary training to emergency responders and fire brigade members Failure to perform audits as required every 3 years

Compliance Audits
There are Companies that have Covered Process, but have not implemented any PSM Program.  The Regulatory Exposure is to:

 Willful

Citations  Criminal Willful Citations  Serious Citations  Major Citation Penalties

PSM Audit Example Checklist Items (Partial)





 



Management Commitment to the PSM Program Is there evidence that an effective process safety management program has been set up and that explicit expectations, objectives and goals have been set with clear-cut, desired outputs? Have resources been provided in the form of personnel assigned to provide implementation and continuation of each element? Have clear lines of responsibility been established and roles and responsibilities assigned? Is management commitment to using all available resources for enhancing process safety knowledge at all levels of the organization clearly demonstrated by actions? Does management encourage active participation in professional and trade associations for key PSM personnel to ensure the PSM system keeps pace withTest Practices?

PSM Audit Example Checklist Items (Partial)
  



 



Process Hazard Analysis Does the PSM program establish a process hazard analysis procedure in accordance with the PSM rule? Have personnel, who will take part in PHA痴, been provided with training in the PHA technique that will be used for their study? Does the PHA procedure establish that the hazard identification team be multi-disciplined in nature, capable of covering such issues as maintenance, operations, design, inspection & testing, safety, health and environment, etc? Does the PHA procedure require that the PHA team leader be specially trained in the technique that will be used? Does documentation of the hazard identification process include all issues, not only those resulting in findings or recommendations? Have PHA been conducted on all PSM-covered processes and if not, is there an established schedule for completing all PHA’s?

Compliance Audits
Audit Findings must be Documented  Actions must be Taken on All Exceptions  All Actions Affecting P&ID’s, PHA’s, Mechanical Integrity Certificates, Inspection/Testing/Maintenance, Operating Procedures & Training Procedures will Require Revision of All of the Above


Compliance Audits


Remember,

The Audit Process is Determine if there are any weaknesses in the system or PSM Program and to provide a report an method to take action. These actions can prevent catastrophic release, injury and death.

Trade Secrets
1910.119(p)

Trade Secrets
All Information Regarding the Process Must be Made Available to Persons Involved in the PSM Program Including Trade Secrets  Confidentiality Agreements are Allowed


Summary of PSM Elements
            

Process Safety Information Equipment ii the Process Process Hazard Analysis Operating Procedures Employee Training Training Contractors Pre-Startup Safety Review Mechanical Integrity of Equipment Management of Change Incident Investigation Emergency Preparedness Compliance Audits Trade Secrets

EPA Risk Management Plans (RMP) Basics
CAA 112(r)

One More Thing to Discuss… EPA Risk Management Plans (RMP)
Many Times Companies Who Must Comply with PSM, must also Comply with the Requirements of EPA Risk Management Plans (RMP)  The RMP Standard was to be a Mirror of the PSM Standard…Didn’t happen!  Remember…PSM Protects the Workforce, RMP Protects the Community


EPA RMP


Basic Requirements
 Executive summary  Registration  Off-site consequence analysis  Five-year accident history  Emergency response plan  Prevention program summary information  Certification

Sound Much Easier than PSM…Right?

All Public Facilities in this Release Plume Must be Identified & Surveyed

Release Plume

EPA RMP


Emergency Response Plan & Prevention Plans Must Be Developed to Prevent Accidental Release of the Covered Chemical

EPA RMP 1998 Changes Compliance Elements
Follow-up / completion of PHA recommendation  Re-validation of your PHA every 5 years  Compliance audits (required every 3 years)  Follow-up / completion of compliance audit recommendations


EPA RMP 1998 Changes Compliance Elements
Annual review and certification of operating procedures  Employee training  Updates related to system modifications, inventory changes, operational changes  Off-site consequence analysis


Process Safety Management of Highly Hazardous & Explosive Chemicals & EPA Risk Management Plans
Summary

Goals 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 a PSM Program Understand Each of the Elements of a Properly Designed & Implemented Program and How to Begin the Process Understand the Basics of How PSM & RMP Work Together to Protect the Workforce & Surrounding Community

Resources


GTRI http://www.oshainfo.gatech.edu/index.html  OSHA PSM Compliance Guidelines http://www.osha.gov/Publications/osha3133.html  OSHA PSM for Construction 1926.64 http://www.osha.gov/doc/outreachtraining/htmlfile s/psm.html

PSM One Day Review

PSM One Day Review
1. The Process Safety Management
2. 3. Standard was drafted as a requirement of the Clean Air Act. True or False The PSM program must include a list of highly hazardous chemicals. True or False The initial start-up of a process is not included as an operating phase under the PSM Standard. True or False List three items that the process hazard analysis must address. ___________, __________ and __________. PSM does not apply to contractors, regardless of the work they are doing. True or False

4.
5.

PSM One Day Review (cont.)
6. The PSM Standard applies to companies that either process
highly _____________ materials or use _____________ liquids and gases in excess of 10,000 pounds. 7. Process safety information includes: ______________, _____________ and _____________. 8. Fault tree analysis is one form of an approved method of performing a process hazard analysis. True or False 9. A technical basis is not required to change a process covered by the PSM Standard. True or False 10. Two types of training required by the PSM standard are ________________ and_________________.

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