process safety management - esafetyline s...process safety management (psm) •on july 17, 1990,...
TRANSCRIPT
Process Safety Management
Joe Grills, C.I.H, C.S.P., P.E. Perdue Pharma
Objectives
• Provide Historical Perspective on
Process Safety Management
(PSM)
• Overview of the PSM Standard
and Elements
• Contrast with Risk Management
Plan (RMP)
• Review Major Practices o
Process Hazards Analysis (PHA)
• Present List of External
References
Major Disasters
• December, 1984 Bhopal, India, incident resulting in more than 2,000 deaths (Design Reviews, - scrubber system not operating- Emergency Procedures, etc.)
• October, 1989 Phillips Petroleum Company, Pasadena, TX, incident resulting in 23 deaths and 132 injuries (Process Safety Reviews – locked valve not installed properly)
• July, 1976 Sevaso, Italy 600 people evacuated(TCDD Release)
• June, 1974 Flixboro, UK Incident (Management of Change)
Clean Air Act Amendments of 1990
• This standard was required under
the Clean Air Act Amendments of
1990
• Because of this, OSHA had to
promulgate the standard
• Required EPA to establish RMP
standard
• Also established Chemical Safety
Board
• Authorized by the Clean Air Act
Amendments of 1990 and became
operational in January 1998.
• "The principal role of the new chemical
safety board is to investigate accidents to
determine the conditions and circumstances
which led up to the event and to identify the
cause or causes so that similar events
might be prevented.“
• Congress gave the CSB a unique statutory
mission and provided in law that no other
agency or executive branch official may
direct the activities of the Board
• Congress directed that the CSB's
investigative function be completely
independent of the rulemaking, inspection,
and enforcement authorities of the EPA and
OSHA
Chemical Safety Board
Risk Management Plan (RMP)
• Mandated by CAAA, Section
112 (r), 40 CFR Part 68
• Promulgated - May 24, 1996
• Published Federal Register -
June 20, 1996
• More than 100,000 (1992)
facilities affected
• Designed to help reduce risk
of accidental release of
hazardous substances
• 3 years to implement
Hazard Assessment
• Offsite Consequence
• Population estimate
• Public receptors
• Environmental
receptors
EPA’s Visions for Accidental Release Prevention
• Emphasize community right-
to-know
• Let information drive action
• Focus the program at the
local level
• EPA support
• Coordinate communications
at local level
Process Safety Management (PSM)
• On July 17, 1990, OSHA published in the Federal Register a proposed standard, - ”Process Safety Management of Highly Hazardous Chemicals” - containing requirements for the management of hazards associated with processes using highly hazardous chemicals to help assure safe and healthful workplaces
• OSHA's 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
• The full text of the final OSHA standard was issued in the Federal Register on February 24, 1992, including the list of covered chemicals and threshold amounts
PSM applies to those companies that deal with:
• Any of more than 130 specific toxic and reactive
chemicals in listed quantities;
• Also includes flammable liquids and gases in
quantities of 10,000 pounds (4,535.9 Kg) or
more.
PSM Coverage
PSM vs. RMP Requirements
• PSM’s concern - potential hazard and protection
of employees inside a regulated area
• RMP’s concern - potential incidents that may
cause environmental and health hazards outside
facility boundaries
• OSHA issued citations to Meer Corporation for not including tanks
storing flammable materials stored at atmospheric pressure in their
PSM program because the tanks were connected to blending
vessels
• Meer appealed the citations, and when the Occupational Safety and
Health Review Commission (OSHRC) issued its final order in May
1997,
• Administrative law judge ruled that the OSHA failed to prove that
Meer's flammable material storage tanks were connected to a
process within the definition of a process in the PSM Standard.
• Ruling also extended beyond Meer by stating that the definition of a
process in the Standard was unconstitutional because it is vague and
does not give a facility the necessary information on whether it is
required to comply.
Meer Decision
OSHA Request for Information (RFI)
• OSHA announced 12/9/13 RFI seeking public
comment on potential revisions to PSM and related
standards, as well as other policy options to prevent
major chemical incidents
• RFI is in response to executive order 13650, which
seeks to improve chemical facility safety and
security, issued in the wake of the April 2013 West,
Texas, tragedy that killed 15 in an ammonium nitrate
explosion
• OSHA will use the information received in response
to RFI to determine what actions, if any, it may take
West Fertilizer Explosion and Fire
Specific Public Information Requests • Clarifying the PSM exemption for atmospheric storage tanks (Meer)
• Expanding PSM Coverage and Requirements for Reactivity Hazards;
• Updating the List of Highly Hazardous Chemicals in Appendix A of the PSM Standard
• Revising the PSM Standard to Require Additional Management-System Elements
• Amending PSM Standard to Require Evaluation of Updates to Applicable recognized and generally accepted good engineering practices (RAGAGEP)
• Clarifying the PSM Standard by Adding a Definition for RAGAGEP
• Expanding the Scope of PSM Standard to Cover the Mechanical Integrity of Any Safety-Critical Equipment
Specific Public Information Requests
(continued) • Clarifying Explicit Requirement that Employers Manage Organizational
Changes
• Revising PSM Standard to Require Coordination of Emergency Planning with
Local Emergency-Response Authorities
• Revising PSM Standard to Require Third-Party Compliance Audits
• Updating the Regulations Addressing the Storage, Handling, and
Management of Ammonium Nitrate
• Changing Enforcement Policy of the PSM Exemption for Retail Facilities
• Changing Enforcement Policy for Highly Hazardous Chemicals Listed in
Appendix A of the PSM Standard without Specific Concentrations.
Internet Reference for OSHA RFI
• https://www.federalregister.gov/articles/2013/12/09/2013-
29197/process-safety-management-and-prevention-of-
major-chemical-accidents
PHA Partners
ab Chemical
Development
d
e
f
g
PHA
EHS
Engineering
PHA Pro ® Software
Team Members and Attendance
• Written plan of action
regarding implementation of
the employee participation
• Consult with employees on the
conduct and development of
process hazards analyses and
on the development of the
other elements of PSM
• Provide to employees access
to process hazard analyses
and to all other information
Employee Participation
• The employer shall develop and implement
safe work practices to provide for the control
of hazards during operations such as
Lockout/tagout;
Confined space entry;
Opening process equipment or piping;
and
Control over entrance into a facility by
maintenance, contractor, laboratory, or
other support personnel.
Safe Work Practices
Thermal Hazards Assessment: Runaway Reactions
• An exothermic reaction can lead to thermal runaway,
which begins when the heat produced by the reaction
exceeds the heat removed.
• The surplus heat raises the temperature of the reaction
mass, which causes the rate of reaction to increase. This
in turn accelerates the rate of heat production.
• Thermal runaway can occur because, as the temperature
increases, the rate at which heat is removed increases
linearly but the rate at which heat is produced increases
exponentially.
Differential Scanning Calorimetry (DSC)
Accelerating Rate Calorimeter (ARC)
PHAs Per OSHA PSM Standard 29 CFR 1910.119
A PHA is required for covered process systems
Allowable PHA methods are:
–What-If;
–Checklist;
–What-If/Checklist;
–Hazard and Operability Study (HAZOP);
–Failure Mode and Effects Analysis (FMEA);
–Fault Tree Analysis; or
–An appropriate equivalent methodology
Items PHAs Must Address
• The hazards of the process
• The identification of any previous incident which had a likely
potential for catastrophic consequences
• Engineering and administrative controls applicable to the
hazards
• Consequences of failure of engineering and administrative
controls;
• Facility siting
• Human factors
• A qualitative evaluation of a range of the possible safety and
health effects of failure of controls on employees
HAZOP
• Directed Creative Brainstorming Method
• Based on experience and knowledge of PHA Team
• Use Guide Words to Control the PHA Team Discussions
• Focuses on one small part of the system at a time
• Very Widely Used in Process, Chemical, Refining and
Pharmaceutical Industries
Design Deviations
Fault Tree Analysis and Quantitative Risk
Assessment
Events in a fault tree are associated with statistical
probabilities. In this simplest case, failure probability
depends on the rate λ and the exposure time t:
P = 1 - exp(-λt)
P ≈ λt, λt < 0.1
An AND gate represents a combination of
independent events.
P (A and B) = P (A ∩ B) = P(A) P(B)
An OR gate, on the other hand, corresponds to set
union:
Mutually exclusive events:
P (A or B) ≈ P(A) + P(B), P (A ∩ B) ≈ 0
What-If Example
Drawings and Other Documentation
Materials Compatibility Matrix - NOAA
Materials Compatibility Matrix (continued)
Materials Compatibility Matrix
MOC Matrix
PPE Assessment
• Perform a pre-startup safety review for new
facilities and for modified facilities when the
modification is significant
• The pre-startup safety review shall confirm that
prior to the introduction of highly hazardous
chemicals to a process
Construction and equipment is in accordance
with design specifications
Safety, operating, maintenance, and
emergency procedures are in place and are
adequate
Pre-startup Safety Review
• Certify that site has evaluated compliance with the
provisions of PSM at least every three years
• Verify that the procedures and practices 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
• Promptly determine and document an appropriate
response to each of the findings and document that
deficiencies have been corrected
Compliance Audits
PSM Resources
• Major PSM Contractors, some have
testing capability others have expertise in
engineering design, Thermal Hazards
Assessment or PSM Management
Systems
• Printed Resources available on-line and in
libraries
Books on Process Safety
Hyperlinks for Internet References
• ioMosaic Process Safety Consultants
• http://www.iomosaic.com/
• Superchem™ Software
• http://www.ioiq.com/superchems/overview.aspx
• ABB Process Safety Management
• http://www.abb.us/service/seitp335/657a872cca71d550c12574e200356c0b.aspx
• HEL Process Safety Consultants and Testing
• http://www.helgroup.com/consultancy/
• DIERS
• http://www.iomosaic.com/diersweb/htdocs/minutes/minutes.htm
• Chemical Reactivity Worksheet
• http://response.restoration.noaa.gov/reactivityworksheet
• PHA Pro ® Software
• http://www.ihs.com/products/ehs-sustainability/operational-risk/pha-
pro.aspx