Management Systems,

Process Safety Management,

and RMP

Jeffrey J. Wanko, PE, CSP

Directorate of Enforcement Programs

Office of Chemical Process Safety

• Management Systems

• Process Safety Management History

• Process Safety Management Elements

• Ammonia Distribution

• PSM-RMP Comparison

• PSM Future

• How to Get Help

Safety Management System

Strengths

• Management systems (such as PSM and

Injury and Illness Prevention Programs)

work because they provide for:1. System design

2. System execution

3. System evaluation

4. System correction

5. (repeat)

Also called Plan-Do-Check-Act

Safety Management System Core

Elements

• Six core elements:

– Management leadership

– Worker participation

– Hazard identification and assessment

– Hazard prevention and control

– Education and training

– Program evaluation and improvement

History of Process Safety

Management

• PSM became effective in 1992

• Stakeholders consensus regarding the

performance-based model

• A single prescriptive regulation could not

cover all facilities

History of Process Safety

Management

• PSM sets a management framework for

preventing catastrophic releases of highly

hazardous chemicals or minimizing

consequences

• PSM incorporates the philosophy and

strengths of safety management systems

Process Safety Management

Elements• Employee participation

• Process safety

information

• Process hazard

analysis

• Operating procedures

• Training

• Contractor safety

• Pre-start up safety

review

• Mechanical integrity

• Hot work permit

• Management of change

• Incident investigation

• Emergency response

• Compliance audits

Benefits of the Process Safety

Management System Framework

• Flexible

• Comprehensive

• Adaptive

• Creative

The PSM Elements

• Employee Participation*– Workers are most likely exposed to the hazards of the

process

– Workers are most knowledgeable in how the process

operates daily

– Written plan of action to involve employees in the

program

– Consult with employees on the conduct of the

process hazards analysis (PHA)

– Communicate PHA findings to employees

The PSM Elements

• Process Safety Information (PSI)

– Information about the process, process,

design, equipment design, etc.

– The information necessary to conduct a PHA

and to operate the process over time

– Process chemicals

– Process technology

– Process equipment

The PSM Elements

• Process Hazards Analysis (PHA)– Systematic evaluation of the hazards of a process

– What could go wrong (how often and how badly)

– Evaluation of the administrative and engineering

systems that keep the process safe (not limited to

those items dedicated to safety)

– Group effort - process operator involvement not

required but encouraged

The PSM Elements

• Operating Procedures (OP)– Clear instructions on how to operate the process

– All phases of operation

– Written

– Reviewed annually to ensure they reflect current and

actual operating practice

– Includes safe work practices (lockout, confined space

entry, personnel entry, etc)

The PSM Elements

• Training

– Initial training to ensure process operators

can safely operate all phases of the process

in accordance with the operating procedures

– Refresher training as necessary but no less

than every three years

The PSM Elements

• Contractors*– Contractors who work on the process or could affect

the process

– Employer (host) responsibilities

• Evaluate

• Recordkeeping

• Communication

– Employer (contractor) responsibilities

• Communication

• Instruction in safety procedures

The PSM Elements

• Pre-Startup Safety Review (PSSR)*

– Required for new facilities or facilities having

gone through a significant change (change to

PSI)

– Ensure that everything is complete prior to

introduction of the highly hazardous chemical

• PSI update

• PHA

• OPs

• Training, etc…

The PSM Elements

• Mechanical Integrity (MI)– Maintaining the integrity of process equipment

• Vessel

• Piping/Hoses

• Pump

• Valves

• Safety systems

• Controls

– Written procedures

– Training for personnel performance maintenance

activities

The PSM Elements

• Hot Work*

– Administrative control of welding, cutting,

brazing and other spark-producing activities

– Permit

The PSM Elements

• Management of Change (MOC)*

– Changes to chemicals, process, equipment,

procedures, etc.

• Other than in-kind changes

– Establish a written program

– Inform employees affected by the change

The PSM Elements

• Incident Investigation

– Investigate incidents that resulted in or could

have resulted in a catastrophic release of

highly hazardous chemical(s)

– No later than 48 hours after the incident

– Prepare a report

The PSM Elements

• Emergency Planning and Response

– Establish a program for response during

emergencies

– One of the following:

• Emergency action plan (1910.38)

• Emergency response plan (1910.120)

The PSM Elements

• Compliance Audits

– Every three years conduct an audit of

compliance with the standard

– Prepare a report of findings

22

How Do the Elements Interact? –

An Example

• I store 100,000 pounds of anhydrous

ammonia for filling nurse tanks

• My raw materials are

– Anhydrous ammonia delivered in OTR tanker

23

What Do I Need to Do This

Safely?

• Process Safety Information

– Properties of the anhydrous ammonia

• Conditions under which is a gas or liquid

• Is it corrosive?

– To what?

• How does ammonia act at different pressures and

temperatures

• Toxicity

• Molecular weight

• Flammability/combustibility

• Other hazards?

24

What Do I Need to Do This

Safely?

• Process Safety Information

– The process and equipment

• How much do I need?

– Raw materials (inventory)

– Energy

– Safe upper and lower limits (temp, pressure)

• What should the equipment be made of to reduce

problems?– To what standards is the equipment designed and

constructed?

– Vessel construction

– Piping and hose construction

25

Looking for Possible Problems

• Systematically review the process and

analyze for hazards (PHA)• Analyze the potential ways in which problems

could arise– Overpressure

– Vehicular impact

– Design requirements (CGA K61.1 and G2.1)

– Overfilling

– Drive away

• May have to find answers to questions which arise

• Human factors

• Facility siting

26

What About Designing, Building,

and Operating?• Is my process designed correctly?

– K61.1 or G2.1

• Is my process built correctly?– Proper materials for valves, pipes, vessels, etc.– Control systems designed and installed correctly?– Do my relief valves relieve to safe locations?

• How do you show that the process is built correctly and in compliance with codes and standards

• Procedures– Operating– Startup– Shutdown & Emergency shutdown

27

What About Designing, Building,

and Operating?

• Are operators, maintenance, contractors properly

trained?– Unloading and loading operations

– Daily inspections (vessel, hose, piping)

• How do I know if my equipment is lasting as long as it

should?– Testing

– Frequency of tests

– Trained people to do testing

• How do I handle contractors working on or around my

workplace?– Can they adversely affect the process?

28

Will Things Always Stay the

Same?

• What if I make changes in materials,

pressures, equipment, procedures, etc?– How will the changes affect other items

• Procedures

• Training

• PSI

• Testing

• Emergency procedures

• etc.

– Was the change significant? (PSSR)• New hose material

• New pump seal material

• New vessel

29

Preventing Fires & Dealing with

Releases

• Do I have a program to ensure safe hot

work?

• How do I handle releases of ammonia?– Planning – is response necessary?

• If I do have a release or some incident,

what then?– Investigations

– Improvements

– What about if I “almost” have a release?

30

Regular Program Review

• How do I make sure that year after year

my programs are working?– Who should do the audits?

– What should be audited?

– How is an audit conducted?

– What happens if the auditors find problems?

31

PSI

Physical

& More

Running it

Dealing

with

Change

What could go

Wrong?

PHA Maintaining

it

RMP 2 and PSM Comparison

• RMP 2

– Eight program

elements:

• Safety Information

• Hazard Review

• Operating procedures

• Training

• Maintenance

• Incident Investigation

• Compliance audit

• Emergency response

• PSM

– Eight RMP 2 elements

plus

• Employee Participation

• Management of

Change

• Prestart-up safety

review

• Contractor safety

• Hot work program

RMP 2 and PSM Comparison

• RMP 2

– Safety information

• Safety data sheet

• Safe upper and lower

limits

• Equipment

specifications

• Codes and standards

used for design

• PSM

– Process Safety

Information

• Chemicals

• Technology

• Equipment

RMP 2 and PSM Comparison

• RMP 2

– Hazard review

• Identify hazards

• No required

methodology

• Can be completed by

an individual

• PSM

– Process Hazards

Analysis

• More in-depth study

• Requires personnel

involved in the process

• Requires human factors

analysis

• Requires facility siting

analysis

• Evaluate failure of

controls

RMP 2 and PSM Comparison

• RMP 2

– Maintenance

• Perform maintenance

• No other requirement

• PSM

– Mechanical Integrity• Six classes of equipment

including safety-critical

• Written procedures

• Procedures, inspections,

and testing must:

– Follow manufacturers

instructions

– Recognized and

generally accepted

good engineering

practice

RMP 2 and PSM Comparison

• RMP 2

– Emergency Response

• Coordinate with

responders

• PSM

– Emergency Response

• Must follow:

– 1910.38 – emergency

action plans or

– 1910.120 -

HAZWOPER

PSM Future

• Executive Order 13650 (8/1/13)

• OSHA PSM Request-for-Information

(12/9/13)

– Addresses many gaps identified since

promulgation

– Addresses modernizations necessary to align

with EPA and current industry practice

How to Get Assistance

• OSHA Compliance Assistance Program

– OSHA On-Site Consultation

– See the Web site for information on the office

closest to you

– 1-800-321-6742

• Jeffrey Wanko

– jwanko@dol.gov

– 202-693-2137