Incorporating Prevention through Design Methods into the Design and Redesign Process

Incorporating Prevention through Design Methods into the Design and Redesign Process ASSE Safety 2013 Las Vegas, Nevada June 26, 2013 Presented By: Frank M. Renshaw, PhD, CIH, CSP Bayberry EHS Consulting, LLC 1

Agenda NIOSH Plan for the National Initiative First Seek to Understand PtD Methods Design and Redesign Process Key PtD Partners Incorporate PtD into the Design/Redesign Process Setting Policy and Standards Establishing Work Processes and Procedures Applying Tools and Practices 2

Solid Caustic Open System Transfer Bayberry ES Consulting, LLC 3

Solid Caustic Open System Transfer GHS Skin Corrosion (Category 1A) Serious Eye Damage (Category 1) Acute Aquatic Toxicity (Category 3) Elimination Substitution Substitution 3 0 2 Engineering Controls Warnings Administrative Controls Personal Protective Equipment 4

Caustic Solution - Closed System Transfer Meter Elimination Pump Additive Tank Substitution Substitution Engineering Controls Warnings Caustic Solution Administrative Controls Personal Protective Equipment 5 5

National PtD Initiative Mission* To prevent or reduce occupationally related injuries, illnesses, fatalities and exposures by including prevention considerations in all designs that affect individuals in the occupational environment. *DHHS (NIOSH) Publication No. 2011-121 DEPARTMENT OF HEALTH AND HUMAN SERVICES Centers for Disease Control and Prevention National Institute for Occupational Safety and Health 6

PREVENTION THROUGH DESIGN INITIATIVE A SYSTEMATIC, STEP-BY-STEP APPROACH Step 1 Create Awareness of PtD in All Sectors, Organizations, Agencies, Schools and Universities Step 2 Obtain Commitments to Incorporate PtD into Work Processes and Safety & Health Management Systems Step 3 Monitor the Impact of PtD on Eliminating Hazards, Minimizing Risks, and Adjust the Plan as Needed 7

Agenda NIOSH Plan for the National Initiative First Seek to Understand PtD Methods Design and Redesign Process Key PtD Partners Incorporate PtD into the Design & Redesign Process Setting Policy and Standards Establishing Work Processes and Procedures Applying Tools and Practices 8

PREVENTION THROUGH DESIGN METHODS Eliminate Hazards and Control Risks at the Source or as Early as Possible in the Project Life Cycle Method Method Include Design, Redesign, Retrofit of New & Existing Facilities, Equipment, Tools, Processes, Products, and the Organization of Work Improve Worker Safety & Health By Including Prevention Methods In All Designs that Impact Workers and others on the Premises Method 10

Capital Project Delivery Process The mechanism used within an organization to manage the development and execution of capital projects from idea conception through start-up and process optimization. 12

Coatings Manufacturing Plant 13

Waste Water Treatment Unit 14

New Research & Development Center 15

Manual Open System Weigh-up 16

Vapor-Tight Closed System 17

Remotely Operated Closed System 18

Redesign of Fall Protection System Railcar Loading/Unloading Station 19

Deficient Custom-Built Lab Hood 20

Replacement Conforming Lab Hoods Compliance with: ASHRAE 110 ANSI/AIHA Z9.5 UL 1805 21

New Acquisition Plant Startup 22

Key PtD Partners Safety Services Industrial Hygiene Occupational Health Services Environmental Services Company Fire Brigade Security PtD Project Team Leader Lead Process Engineer Engineering Specialties Site/Operations Management Technical Services/Maintenance PtD Project Owner Representative PtD PtD PtD Contractor - Engineering/Construction Safety Contractor Engineering Safety Coordinator Design/Construction Notified Body/Official Organizations Public/Community Fire Brigade Insurance Suppliers 24

Incorporating PtD Methods into The Design & Redesign Process Setting Policy & Standards Policy Standards Work Processes & Procedures Tools & Practices Establishing Work Processes & Procedures Applying Tools & Practices 26

Incorporating PtD into Policy Pole Vault Approach Steady Climb Approach 28

XYZ Company Model EHS Policy* The XYZ Company is the world s leading manufacturer of products. Our environmental, health, and safety values are of the utmost importance to us. They are embodied in the guiding principles set forth in this policy. They reflect our respect and care for the environment, our employees, contractors, customers and communities. We are committed to incorporating these values into everything we do as we seek to improve the quality of life and the environment through our products and services. Our Guiding Principles are: We will design our businesses, processes and products with full consideration for the needs of the present global community and the impact of our design decisions on the ability of future generations to meet their needs. We will include prevention considerations in all designs and redesign of facilities, equipment, processes, work methods and products, and will incorporate safe design methods into all phases of hazard and risk mitigation. We will continuously review and improve our worldwide operations, processes, and products, with the goal of making them free of adverse environmental, health, and safety impacts for all of our stakeholders. We will meet or exceed all applicable laws, regulations, and XYZ Company standards. --------- --------- Every employee and contractor is responsible for compliance with this policy. We will audit our performance and the Board of Directors will monitor our commitments and progress. *Adapted from the former Rohm and Haas Company President/CEO/Chairman 29

OHS Management System Standard* 3.1 Management Leadership 3.1.2 OHS Policy The organization s top management shall establish a documented occupational health and safety policy as the foundation for the OHSMS. This policy shall include a commitment to: A. Protection and continual improvement of employee health and safety; B. Inclusion of prevention considerations in design and redesign of all facilities, equipment, processes, work methods and products, and incorporation of safe design methods into all phases of hazard and risk mitigation; C. Effective employee participation; D. Conformance with the organization s health and safety requirements; and E. Compliance with applicable OH&S laws/regs *Proposed Amendments to ANSI/AIHA/ASSE Z10-2012 5.1 OHSMS Operational Elements 5.1.3 Design Review and Management of Change The organization shall establish a process to identify and take appropriate steps to prevent or otherwise control hazards at the design and redesign stages and for situations requiring Management of Change to reduce potential risks to acceptable levels. The process for design and redesign and the Management of Change process shall include: A. Identification of tasks and related health and safety hazards as early as possible in the life cycle of facilities, equipment, processes, work methods and products; B. Recognition of hazards associated with human factors including human errors caused by design deficiencies; C. Review of applicable regulations, codes..; D. Application of control measures (hierarchy of controls Section 5.1.2); E. A determination of the appropriate scope F. Employee participation 30

Capital Project Delivery Process* Decision Gates Internal/External Progress-Status Gates Stage 1 Project Initiation Stage 2 Specify & Select Option Stage 3 Detail Option Stage 4 Final Design & Procurement Stage 5 Construction Stage 6 Start-up Stage 7 Project Close-out Ongoing Activities: Performance Measurements, Quality Audits, Progress Reporting, Cost and Schedule Control = Decision Gate = Progress - Status Gate *Adapted from the former Rohm and Haas Company 32

STAGE 1 Project Initiation Project mission, initial goals and objectives, scope 1.1.1 Generate & initial screen of options 1.1.2 Project execution strategy 1.1.3 Afford to spend model 1.1.4 STAGE 2 Specify & Select Option Refined goals and objectives 2.1.1 Select best option 2.1.2 Preliminary project execution plan & schedule 2.1.3 Preliminary design basis & process description, prelim. P&IDs, PFDs, control philosophy, site plan, raw material list, prelim. major/critical equipment lists 2.1.4 STAGE 3 Detail Option Finalized goals and objectives 3.1.1 Finalized project scope document (IBL/OBL), project specifications, standards 3.1.2 Project execution plan & schedule 3.1.3 Finalized design basis, process description, PFDs, P&IDs, control philosophy, site plan, list of materials, major equipment quotes/bids 3.1.4 STAGE 4 Final Design & Procurement Updated goals and objectives 4.1.1 P&IDs, mechanical, electrical, civil, structural, control system programs all complete 4.1.2 Detailed spare parts list 4.1.3 All equipment purchase orders issued 4.1.4 STAGE 5 Construction Detailed construction plan and schedule 5.1.1 Construction roles & communication plan 5.1.2 Facility mechanically complete (approved for commissioning) 5.1.3 As-built, quality assurance, spare parts, turnover documentation 5.1.4 STAGE 6 Start-up Commissioning & start-up plan and detailed schedule 6.1.1 Operating rates documented 6.1.2 Facility operating to specifications 6.1.3 Revised operating and maintenance procedures, and documentation for design changes (as-built) issued 6.1.4 Stage 7 Project Closeout Closeout Plan 7.1.1 Final acceptance documentation 7.1.2 Project critique, customer feedback, closeout report 7.1.3 Appropriate learnings & design ideas communicated 7.1.4 Relative cost of selected options 1.1.5 Prevention through Design in scope 1.1.6 Finalized economic analysis/conceptual cost estimate 2.1.5 Prevention through Design addressed 2.1.6 Authorization request (AR) submitted 3.1.5 Prevention through Design addressed 3.1.6 Cost compliance report 4.1.5 Prevention through Design addressed 4.1.6 Construction cost report 5.1.5 Prevention through Design addressed 5.1.6 Revised start-up cost estimate 6.1.5 Prevention through Design addressed 6.1.6 Project & equipment files submitted to facility 7.1.5 Prevention through Design documented 7.1.6 CPD Key Project Execution & Design Deliverables 33

STAGE 1 Project Initiation OSH project plan 1.2.1 Regulatory & permit plan 1.2.2 Early identification of significant & unique OSH hazards & risks 1.2.3 Early identification of regulatory prohibition and restrictions on hazardous substances 1.2.4 Early identification of Prevention through Design opportunities 1.2.5 STAGE 2 Specify & Select Option OSH Design Review requirements defined 2.2.1 OSH Hazard Analysis & Risk Assessment requirements defined, studies initiated as needed 2.2.2 Regulatory & permitting requirements defined 2.2.3 Insurance assessmt. done, fire protection security, machinery noise & guarding, ergo. requirements finalized 2.2.4 Prevention through Design addressed 2.2.5 STAGE 3 Detail Option OSH Design Review complete, recommendations issued 3.2.1 Hazard Analysis - Risk Assessment studies complete, recommendations issued 3.2.2 Regulatory and permitting documents complete 3.2.3 Equip. & machinery noise, guarding, ergonomic specs. approved, checks and test protocols issued 3.2.4 Prevention through Design addressed 3.2.5 Stage 4 Final Design & Procurement OSH Design Review recommendations resolved and actions tracked 4.2.1 Hazard Analysis - Risk Assessment study recommendations resolved, risk targets met,actions tracked 4.2.2 Appropriate permit application & regulatory approval 4.2.3 Detailed drawings reviewed & approved 4.2.4 Prevention through Design addressed 4.2.5 STAGE 5 Construction Pre-construction safety plan 5.2.1 Construction permits 5.2.2 Construction safety program effectiveness verification 5.2.3 Regulatory permit completion and approval verification 5.2.4 Prevention through Design addressed 5.2.5 STAGE 6 Start-up Pre-start-up OSH Review completed & actions addressed 6.2.1 Completed site acceptance testing and checks of equipment, OSH devices, critical retrofits 6.2.2 Preliminary industrial hygiene exposure monitoring complete 6.2.3 All incidents investigated and impact of root causes on design/operation addressed 6.2.4 Prevention through Design addressed 6.2.5 STAGE 7 Project Closeout OSH Project Evaluation 7.2.1 Assessment of residual risk versus targets 7.2.2 Prevention through Design compliance verification 7.2.3 Feedback on OSH standards and modifications initiated as appropriate 7.2.4 Prevention through Design documented 7.2.5 CPD OSH Deliverables 34

CPD Stage 2 - Specify & Select Option Project Execution & Design Deliverables Refined goals and objectives Select best option Preliminary project execution plan and schedule Preliminary design basis & process description, prelim. P&IDs, PFDs, control philosophy, site plan, raw material list, preliminary major/critical equipment lists Finalized economic analysis and conceptual cost estimate OSH Deliverables OSH Design Review requirements defined OSH Hazard Analysis and risk assessment requirements defined, studies initiated as needed Regulatory and permitting requirements defined Insurance assessment complete, fire protection and security requirements finalized Equipment and machinery noise, machine guarding and ergonomic requirements finalized. 35

CPD Stage 2 OSH Deliverables/Tools OSH Deliverables OSH design review requirements defined OSH hazard analysis and risk assessment requirements defined and studies initiated Regulatory and permitting requirements defined Insurance assessment complete, fire protection requirements finalized Equipment and machinery noise, machine guarding and ergonomic requirements finalized. OSH Tools EHS Design Review Checklist & Schedule HAZOP Study, What-if Checklist, Hazard & Control Banding Protocol, Risk Assessment Guide for Machine Tools Federal - State - Local Air, Water, Hazardous Waste, Community Noise Permit Procedures Insurance Carrier Fire Protection Site Visit and Final Report, Corporate Fire Protection Standards, ACC Responsible Care Process Safety and Security Codes Corporate Equipment Noise Standard, NASA Buy-Quiet Process Roadmap, ANSI B-11.0, NIOSH Lifting Guide 36

Project: Manager: Date: OSH Deliverables Planning Template OHS Deliverable Description 1.2.1 OSH project plan 1.2.2 Regulatory & permit plan 1.2.3 Early identification of significant & unique OSH hazards & risks 1.2.4 Early identification of Prevention through Design opportunities 2.2.1 OSH Design Review requirements defined 2.2.2 Hazard Analysis & Risk Assessment requirements defined, studies initiated 2.2.3 Regulatory & permitting requirements defined 2.2.4 Insurance assess. done, fire prot, security, mach noise, guarding, ergo finalized 3.2.1 OSH Design Review complete, recommendations issued 3.2.2 Hazard Anal.-Risk Assess. complete, recommendations issued 3.2.3 Regulatory and permitting documents complete 3.2.4 Equip. noise, guarding, ergo. specs approved, checks & test protocols issued 4.2.1 OSH Design Review recommendations resolved and actions tracked 4.2.2 PHA recommendations resolved, risk targets met, actions tracked 4.2.3 Appropriate permit application & regulatory approval 4.2.4 Detailed drawings reviewed & approved 5.2.1 Pre-Construction safety plan 5.2.2 Construction permits 5.2.3 Construction safety program effectiveness verification 5.2.4 Regulatory permit completion and approval verification 6.2.1 Pre-start-up OSH Review completed & actions addressed 6.2.2 Completed site acceptance testing of equipment & OSH devices 6.2.3 Completed checks, tests & critical retrofits 6.2.4 Preliminary Industrial hygiene exposure monitoring complete 6.2.5 All incidents investigated and impact of root causes addressed 7.2.1 OSH project evaluation 7.2.2 Assessment of residual risk versus targets 7.2.3 Prevention through Design compliance verification 7.2.4 Feedback on OSH standards & modifications initiated as appropriate Date Completed mm/dd/yy Deliverable Documented (Y/N) Actions Tracked (Y/N) Proj. Mgr. Reviewed (Y/N) 37

Management of Change Definition A system to assess and address the EHS impact of changes to a process, facilities, or organization before the changes are made. 38

Flixborough Explosion 39

Temporary electrical wire is draped across warehouse aisle in preparation for upcoming power outage. Forklift operator towing two 4,000 lb. tote bins with tow motor rated at 6,000 lbs. Co-worker warns driver just in time as tote catches wire which is now hanging lower. Driver jumps up to reposition wire on top of fence post 8 ft. high. Fence s sharp twisted ends tear open hand which requires 21 stitches. Temporary electrical wire draped across forklift aisle 8 ft. high Chain Link Fence 40

MOC Key Principles Every change must be managed. Changes must not be made without an appropriate review. The type of review should be consistent with the complexity of the change. MOC systems should be simple to use. 41

What Level Are These Changes? Exercise 1. New filtration system in the plant 2. New pump identical to the one it replaces 3. Change of valve for identical type from different manufacturer 4. Change of valve for a different type Identical Substitution Replacement in Kind Basic Change Major Change MOC Training Supervisors & Employees 42

Type of Review Management of Change Process Type of Review Level of Change Always a Formal EHS Review; May also require a Process Hazard Analysis HAZOP Study Formal EHS Review What-If/Checklist FTA, QRA, etc. Personal Review Identical Substitution Replacement In Kind Basic Change Major Facility or Process Change Level of Change 43

Hazard Analysis & Risk Assessment Tools 45

Control Effectiveness Control Effectiveness Hierarchy of Controls* Most Elimination Eliminate hazard Elimination during design or redesign Most Substitution Substitution Less hazardous materials, processes, operations or equipment Engineering Controls Design-in engineering controls to minimize risk Warnings Automatic and manual systems, signs, labels Administrative Controls Training, well designed work methods Least Personal Protective Equipment Available, effective, easy to use Least *Adapted from Schulte and Heidel, 2009 46

Applying Tools and Practices Robust In Sync with CPD Policy Standards Work Processes & Procedures Tools & Practices Applied Properly & Consistently By Competent People Working Together Straightforward & Simple as Possible 47

Robust Tools PHA Methods What-If/ Checklist Fault Tree Analysis HAZOP Study Failure Mode & Effects Analysis Release Modeling & Consequence Analysis Quantitative Risk Assessment 48

Acrylonitrile Railcar Unloading Risk Reduction Measures Importance Risk Reduction Measure 1 Tank Construction 2 Top Unloading 3 Redundant Level Indicators 4 Drains/Flanges 5 Pump Seals 6 Spill Pit 7 Operator Training/Discipline 8 Backflow Prevention 9 Unloading Protection 10 Connection Quality 49

Robust Practice - Top Unloading* Elimination Substitution Engineering Controls Warnings *Acrylonitrile Safe Storage and Handling Guide, INEOS USA LLC Admin. Controls PPE 50

Process Hazard Analysis Tools Applied in Sync with CPD* Project Initiation EHS Reviews Ongoing Process Development Early EHS Process CHA Chemistry Hazard Analysis Interaction Matrix Started Specify & Select Options RISK Indices MAPP (Worst Case Scenarios Only) Checklists EHS Agreements at this time FSHI Index Detail Option EHS Design Reviews Optimum timing for HAZOP is at end of "Detail Option" Interaction Matrix (w/intermediates, MOCs, Utilities) Final Design Construction & Procurement Startup HAZOP MAPP Generic Process HAZOP FMEA Project Execution LOPA What-If/ Checklists FTA QRA MOC Review of Design Changes PreStart-up Safety Review Operations & Maintenance MOC Reviews all changes using appropriate PHA technique PHA Renewals 3-5 year basis using appropriate PHA technique *Adapted from the former Rohm and Haas Company 51

Applied Properly & Consistently Chemical Transfer Technology Ltd. Newcastle, UK 52

Enclosed, Ventilated Drum Hood 53

Process Engineer - Key PtD Partner 54

Competent People Working Together 55

Straightforward & Simple 56

No. Safety Shower and Eyewash Stations Item Requirement applies where worker could be exposed to materials which can seriously injure the skin or eyes on contact (e.g., corrosive or severely irritating chemicals) or to toxic materials absorbable through the skin in harmful amounts. Complete (Y, N, N/A) Corp XYZ Section in standard 1 Plumbed showers and eyewash stations must be installed where this standard applies. 4.1.1 2 Clearly marked, highly visible at all hours, in a well-lit area 4.3.1 3 Clear access at all times 4.3.2 4 In remote areas, provide automatic alarm when unit is used or other effective means to summon help in emergency. 4.3.3 5 Must be able to travel from potential source of exposure to station in 10 seconds or less (CONTACT OWNER FOR INTERPRETATION). 4.3.4 6 If exposure could occur while using station, a barrier must be used to prevent contact. 4.3.4 7 Water must be fit for human consumption and meet local potability standards. 8 Provide 15 minutes of uninterrupted flow simultaneously through shower and eyewash units. 4.4.2 9 Shower head flow rate - at least 76 lpm (20 gpm) 4.4.3 12 Eye-face wash unit flow rate at least 11.4 lpm (3 gpm) 4.4.4 17 Block valves in water supply line to stations must be either locked open or have the handle removed. 4.5.1 22 Steam tracing is prohibited for stations. 4.6.4 2.1 4.4.1 57

Summary NIOSH Plan for the National Initiative First Seek to Understand PtD Methods Design and Redesign Process Key PtD Partners Incorporate PtD into the Design & Redesign Process Setting Policy and Standards Establishing Work Processes and Procedures Applying Tools and Practices 58

Including prevention considerations in all designs that affect individuals in the occupational environment. 59