Process Safety Management of Highly Hazardous & Explosive Chemicals29CFR1910.119Clearly Understanding the StandardInformation Provided under OSHA Susan Harwood Grant #SH-17811-SH-8

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

PSM Was Chosen Given the Clear Need Past DisastersCurrent Year DisastersPerceived Weakness in PSM Program

GTRI PSM Susan Harwood Grant ProgramGTRI is Offering:

Six (6) One Day Courses Around the Southeastern United StatesFour (4) One Week In-Depth Courses Around the United States

Goals of the One Day CourseUnderstand Why Process Safety Management (PSM) Was PromulgatedUnderstand That Even with PSM, Catastrophes are Still OccurringUnderstand Who is Covered & ExemptionsUnderstand the Team Process to Developing a PSM ProgramUnderstand Each of the Elements of a Properly Designed & Implemented Program and How to Begin the ProcessUnderstand the Basics of How PSM & RMP Work Together to Protect the Workforce & Surrounding Community

Summary of the One Week CourseThis is an In-Depth Study of the Requirements of the Standard Students will Actually Learn through a Real Life Case Study How to Design Each Element of the Process Safety Management Standard RequirementsStudents will Also Review the Basics of EPA Risk Management Plan (RMP)

Rules of the CourseThis is an Open Discussion Course

Relax and LearnAsk Questions Participate in DiscussionsShare ExperiencesShare Best PracticesEnjoy Yourself

Why Did OSHA Develop PSM?Bhopal, India (1984)2,000 deaths Isocyanate releasePasadena, TX (1989)23 deaths, 132 injuries Petroleum explosionCincinnati, OH (1990)2 deaths ExplosionSterlington, LA (1991) 8 deaths, 128 injuries Chemical release

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

Why Did OSHA Develop PSM?Process Safety Management is a regulation, promulgated by OSHA, intended to prevent an incident like the 1984 Bhopal Disaster

Andto Prevent Release of:Toxic, Reactive, Flammable, or Explosive chemicals

Not Only PSM, But RMPA great many industrial facilities must comply with OSHA's Process Safety Management (PSM) regulations as well as the quite similar EPA Risk Management Program (RMP) regulations (Title 40 CFR Part 68).

PSM vs. RMP - Whats the Difference?PSM - Like HAZCOMProtects the WorkforceProtects ContractorsProtects Visitors to the FacilityBasically Protects the Workplace

RMP-Like Sara Title IIIProtects the CommunityProtects the General Public Around the FacilityProtects Adjacent Facilities Such as Schools & Hospitals

The Standard Was Promulgated in 1991 - Is it Working?

The Standard Was Promulgated in 1991 - Is it Working?BP Products Texas City - January 200515 Workers Killed170 InjuredMajor Property Damage$21 Million in Fines

Application1910.119(a)

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

Examples

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

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

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

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

What Types of Industries?Industries that Process Chemicals Such As:Industrial Organics & InorganicsPaintsPharmaceuticalsAdhesivesSealants and FibersPetrochemical facilitiesPaper MillsFood Processing with Anhydrous Ammonia over the TQ

Exclusions1910.119(a)(1)(ii)(A)

There are ExclusionsAn employer is exempt from the requirements of PSM when:A threshold quantity of flammable liquids is stored in atmospheric tanks or transferred without the benefit of chilling or refrigeration Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling), If such fuels are not a part of a process containing another highly hazardous chemical covered by this standard

There are ExclusionsRetail facilities;Oil or gas well drilling or servicing operations; or,Normally unoccupied remote facilities

Definitions1910.119(b)

DefinitionsAtmospheric tank means a storage tank which has been designed to operate at pressures from atmospheric through 0.5 p.s.i.g. (pounds per square inch gauge, 3.45 Kpa). Boiling point means the boiling point of a liquid at a pressure 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 more highly hazardous chemicals, that presents serious danger to employees in the workplace.

DefinitionsFacility means the buildings, containers or equipment which contain a process. Highly hazardous chemical means a substance possessing toxic, reactive, flammable, or explosive properties and specified by paragraph (a)(1) of this section. Hot work means work involving electric or gas welding, cutting, brazing, or similar flame or spark-producing operations. Normally unoccupied remote facility means a facility which is operated, maintained or serviced by employees who visit the facility only periodically to check its operation and to perform necessary operating or maintenance tasks. No employees are permanently stationed at the facility.

DefinitionsProcess means any activity involving a highly hazardous chemical including any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or combination of these activities. For purposes of this definition, any group of vessels which are interconnected and separate vessels which are located such that a highly hazardous chemical could be involved in a potential release shall be considered 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 of information that is used in an employer's business

Employee Participation1910.119(c)

Now that we are required to comply, then what? FirstForm a Team in Your Company, i.e..Process EngineersOperatorsSafetyMaintenanceManagementConsultants

RememberYou Cant Do it Alone!

Now that we are required to comply, then what? SecondForm a Plan, Determine:ResponsibilitiesDutiesReportingDocument ControlProgress ReportsTracking Changes

Now that we are required to comply, then what? ThirdReview Scope of Project:Process Safety InformationEquipment in the ProcessProcess Hazard AnalysisOperating ProceduresEmployee TrainingTraining ContractorsPre-Startup Safety ReviewMechanical Integrity of Equipment Management of ChangeIncident InvestigationEmergency PreparednessCompliance Audits Trade Secrets

Now that we are required to comply, then what? Lets BeginIn the Next Session, we will Begin to Explore Each Element of the Standard and What is Required to Comply