Process Safety Management 2008 Update & Review. As if there were safety in stupidity alone. Thoreau

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Jonas Lynch
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1 Process Safety Management 2008 Update & Review As if there were safety in stupidity alone. Thoreau

2 PSM A look back to the 90 s OSHA s PSM Standard became effective in Greatest concern in Meat Industry was/is Anhydrous Ammonia. Lots of requirements, compliance was phased-in thru May, That was 11 years ago.. Let s review where PSM came from. Then we ll check our ongoing compliance.

3 Hazard Management: The World as It Was Before PSM Good people doing good things

4 The Rising Case for Change 1984 Bhopal, India Toxic Material Released 2,500 immediate fatalities; 20,000+ total Many other offsite injuries HAZARD: Highly Toxic Methyl Isocyanate

5 The Rising Case for Change 1984 Mexico City, Mexico Explosion 300 fatalities (mostly offsite) $20M damages HAZARD: Flammable LPG in tank

6 The Rising Case for Change 1988 Norco, LA Explosion 7 onsite fatalities, 42 injured $400M+ damages HAZARD: Flammable hydrocarbon vapors

7 The Rising Case for Change 1989 Pasadena, TX Explosion and Fire 23 fatalities, 130 injured; damage $800M+ HAZARD: Flammable ethylene/isobutane vapors in a 10 line

8 Enter Processrocess Safetyafety Management Integral part of OSHA Occupational Safety and Health Standards since 1992 Known formally as: Process Safety Management of Highly Hazardous Chemicals (29 CFR ) PSM applies to most industrial processes containing threshold levels of hazardous materials;. Anhydrous Ammonia > 10,000 lbs.

9 In a Few Words, What is PSM? The proactive and systematic identification, evaluation, and mitigation or prevention of chemical releases that could occur as a result of failures in process, procedures, or equipment.

10 What s s Covered by PSM? Process Safety Information Employee Involvement Process Hazard Analysis Operating Procedures Training Contractors Pre-Startup Safety Review Mechanical Integrity Hot Work Management of Change Incident Investigation Emergency Planning and Response Compliance Audits Trade Secrets

11 Ammonia Refrigeration Anhydrous ammonia is widely used as refrigerant in many industrial facilities including the meat, poultry, and fish processing industry. Ammonia is a colorless gas with a strong, irritating smell. It is hygroscopic. Ammonia leaks can be very dangerous. These leaks can endanger all workers; therefore, it is critical to implement a structured safety approach to controlling ammonia applications. Accidental releases of ammonia from refrigeration facilities have resulted in both injuries and deaths to meat industry employees.

12 Ammonia Refrigeration Process Safety Management (PSM) Model Process Hazard Analysis (PHA) Mechanical Integrity Process Safety Information (PSI) Operating Procedures and Safe Work Practices Trade Secrets Process Technology Safety Management Management of Change (MOC) Pre-Startup Safety Review (PSSR) Hot Work Permit Personnel Employee Participation Personnel Training and Performance Incident Investigation Compliance Audits Emergency Planning and Response Contractor Training and Performance

13 Employee Participation Emphasis on Operator Involvement Employee Responsibility Matrix Standardized PSM Awareness Training and Documentation Employees to write (or assist) with Operating Procedures

14 Process Safety Information Equipment Documentation Format P&ID drawings and Simplified Block/Flow Diagrams System Inventory Tools Pressure Relief Valve Sizing Tools Pressure Relief Valve Vent Piping Tools Ventilation System Calculation Tool

15 Process Hazard Analysis What If /Checklist Standard Method for Ammonia systems PHA Before Engineering First Session 30% Second Session 90% Additional Session(s) Before Start-Up PHA must be reviewed/updated whenever system changes occur Revalidate every 5 years

16 Operating Procedures Standard Operating Procedures Template is OSHA Compliant Good place for employee involvement by your engine room personnel. System Procedures as well as Equipment Procedures are needed. Line Break Procedure(s) (similar to safety process of Hot Work permits

17 Training Standardized Curriculum Design For: All Employees Ammonia Refrigeration Primary Operator Ammonia Refrigeration Support Operator Maintenance Ammonia Refrigeration Authorized Production Ammonia Refrigeration Authorized Site Facility Management Site PSM Coordinator

18 Contractors Standardized Criteria for Ammonia Refrigeration Contractor Qualifications Checklist Safety Record and Experience EMR < 1.0 is Green; = Yellow Gatekeeper at each site Qualify your contractors

19 Pre-Startup Safety Review Standardized Pre-Start Safety Review Form - Checklist Plant Engineering Manager Sign Off

20 Mechanical Integrity Documented Maintenance Procedures PM s / Work Orders Equipment List Safety Critical Equipment List Use electrical Functional Location or Equipment Type PM Frequencies Non-Destructive Testing

21 Hot Work (Control) Must use Hot Work Permits for all hot work occurring on a covered process. May be used in concert with a Line breaking permit.

22 Management of Change Standardized MOC Form Standardized MOC Procedure Standardized Definitions Replacement-in-Kind (RIK) Temporary Change Safety Design Review Checklist Engineering Review Management Authorization

23 Emergency Planning and Response Specific plans as part of EAP for release of a PSM controlled substance Plan for handling small releases May also be covered by , HAZWOPER Standard

24 Incident Investigation Standardized Incident Investigation Forms Teams Established in Advance Initiate within 24 hours Involve Operators, Maintenance, Managers Identify Root Cause Retained for 5 years

25 PSM Compliance Audit Standardized Audit Protocol Audit Teams for each area Scoring System (e.g. Green, Yellow, Red items for revision) Continuous Improvement Formal audit report to be completed and maintained on file (most recent two audits must be kept on file).

26 Now where are we at today? Again, it s been 11 years since 1997 s final phase-in. Are our systems still fully compliant? Let s look at some specific requirements and consider our PSM programs in this context.

27 Required ongoing actions (i.e. to stay in compliance). Are P&ID drawings and block flow diagrams current for all changes since 1997? Has PHA been updated and validated at least once every 5 years since original completion? Should be on (at least) 3 rd version by now. Is PHA updated and validated with every system change other than RIK? Are operating procedures current for existing system?

28 Required ongoing actions (i.e. to stay in compliance). Cont. Has Refresher Training been provided at least once every 3 years? Is it documented? Are Management of Change forms maintained and document appropriate changes in other areas? Have compliance audits for the PSM process been completed every 3 years? Two most recent audits must be retained.

29 What s s next? Check for compliance with various update requirements. If all/part are missing, develop a plan to get in compliance. Perform an update PHA on current system Do a compliance audit on PSM items. Complete Refresher Training Etc. Implement compliance actions ASAP

30 What s s next? (Cont.) Institute a control system where all of these items are scheduled automatically for future review/update. When OSHA checks your PSM compliance they should see a program that is truly ongoing, with scheduled elements to maintain currency.

31 Questions? Is your PSM system up to date (as of April 2008)? Are your various reviews complete and available should OSHA inspect your process/system? If not, you need to identify shortcomings and fix it ASAP.

Process Safety Management of Highly Hazardous & Explosive Chemicals 29 CFR

Process Safety Management of Highly Hazardous & Explosive Chemicals 29 CFR 1910.119 Why Did OSHA Develop PSM? Bhopal, India (1984) 2,000 deaths Isocyanate release Pasadena, TX (1989) 23 deaths, 132 injuries