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  • 2. 2Process Safety ManagementRequired by the Environmental Protection Agencys(EPA) Clean Air Act Amendments (CAAA),Section 304Promulgated - February 24, 19925 year implementationProactive identification, evaluation, and mitigation orprevention of chemical releases that could occur as aresult of failures in processes, procedures, orequipment130 highly hazardous chemicals (HHC’s)
  • 3. 3Process Safety Management(continued)10,000 lb. or more of flammable materials that areused at or above their boiling pointsPyrotechnics and explosives manufacturersMore than 28,000 facilities affectedExemptions: fuels used for workplace consumption Comfort heating Gasoline for vehicles
  • 4. 4Risk Management PlanMandated by CAAA, Section 112 (r), 40 CFRPart 68Promulgated - May 24, 1996Published Federal Register - June 20, 1996More than 100,000 facilities affectedDesigned to help reduce risk of accidental release ofhazardous substances3 years to implement
  • 5. 5Risk Management Plan(continued)Affects owners of a stationary source with regulatedsubstances above a threshold quantity (TQ): 77 acutely toxic 63 flammable Department of Transportation (DOT) classified explosivesubstances
  • 6. 6EPA’s Visions for AccidentalRelease PreventionEmphasize community right-to-knowLet information drive actionFocus the program at the local level EPA supportCoordinate communications at local level
  • 7. 7Key Features of RMPPrevention program 7-elements “mini-PSM” program 14 elements OSHA-PSM program expanded to addressoffsite effectsEmergency response programRisk management planElectronic submission to state and LEPC Available to publicRegulatory audits
  • 8. 8Key Features(continued)3 Program levelsManagement systemOffsite consequence analysis Worst-case scenario Alternative release scenario5-year accident history
  • 9. 9Key Features(continued)Summarizes key elements of the RMP program Tells a story Hazards at the site Accident history Potential offsite consequences Prevention steps Response program
  • 10. 10Exemptions to ThresholdQuantityArticlesLaboratoriesUses: Structural components Janitorial maintenance Foods, drugs, cosmetics, or other personal items Present in process water or non-contact cooling water Compressed air or as part of combustion
  • 11. 11EPA’s Regulatory ApproachPerformance-based approach Similar to OSHA’s PSMBuild on existing programs and standardsScale the requirements to fit the riskCoordinate with OSHA and DOT
  • 12. 12Requirements of 112 (r)Established a general duty clause to: Identify hazards that may result from releases Design and maintain a safe facility Minimize the consequences or releases
  • 13. 13Requirements of 112(r)(continued)Required EPA to promulgate a list of substances andset thresholdsRequired EPA to develop a risk managementprogram (RMP) ruleRegister with EPAConduct a hazard assessmentDevelop a prevention programDevelop an emergency response program
  • 14. 14Requirements of 112 (r)(continued)Provide a summary (RMP) to EPA States Locals Public
  • 15. 15Basic PrinciplesBuild on EPCRAEmphasize community right-to-knowFocus the program at the local level Where the risk is found
  • 16. 16Basic Principles(continued)Accommodate small business concerns Provide model RMPs» Ammonia» Warehouses with chemicals» Batch processors» Refineries/gas plants Provide reference tables for offsite consequences analysis
  • 17. 17Manufacturing Industries AffectedChemical manufacturers Industrial Organics & Inorganics Paints Pharmaceuticals Adhesives, Sealants Fibers
  • 18. 18Manufacturing Industries Affected(continued)Petrochemical Products Refineries Industrial Gases Plastics and Resins Synthetic Rubber
  • 19. 19Non-Manufacturing Affected(continued)Non-Manufacturing Facilities affected Utilities» Electric and Gas Public Sources» Drinking Water and Waste Water Treatment Agriculture» Fertilizers, Pesticides
  • 20. 20Other ManufacturingElectronicsSemiconductorsPaperFabricated metalsIndustrial machineryFurnitureTextiles
  • 21. 21Other IndustriesFood and Cold StoragePropane RetailWarehousingWholesalersFederal sources Military and Energy Installations
  • 22. 22PSM vs. RMP RequirementsPSM’s concern - potential hazard and protection ofemployees inside a regulated areaRMP’s concern - potential incidents that may causeenvironmental and health hazards outside facilityboundariesEditorial changes to PSM to make text consistentwith the CAAAs language
  • 23. 23Hazard AssessmentOffsite consequence data Population estimate Public receptors Environmental receptorsEvery 5 yearsWithin 6 months of a change that increases ordecreased distance by a factor of 2 or more
  • 24. 24Overview Worst-Case Scenario(WCS)Greatest quantity from vessel or piping May include administrative controlsToxic gases Quantity released in 10 minutesToxic liquids Instantaneous spill to ground; volatilization; passivemitigationToxic gases liquefied by refrigeration
  • 25. 25Worst-Case Scenario(continued)All flammable substances Quantity for vapor cloud explosionOne worst case for each processOne worse case representing all toxic substancesAdditional worst case(s) different public receptorsOther considerations Smaller quantities at higher temperature or pressure Source boundary proximity
  • 26. 26Alternative Release Scenario(ARS)More likely than a worst case scenarioMuch reach endpoint offsiteOne scenario representative of all flammables
  • 27. 27ARS SelectionAccident history eventsProcess hazard analysis eventsWorse case with mitigationExample scenarios: Piping or hose failures Seal failures Vessel overfilling or venting
  • 28. 28List of Substances andThresholdsFocuses on lethal effects resulting from acuteexposuresIncludes mandated substances
  • 29. 29Mandated SubstancesAmmoniaAnhydrous AmmoniaAnhydrous Hydrogen ChlorideAnhydrous Sulfur DioxideBromineChlorineEthylene OxideHydrogen CyanideHydrogen FluorideHydrogen SulfideMethyl ChlorideMethyl IsocyanatePhosgeneSulfur TrioxideToluene DiisocyanateVinyl Chloride
  • 30. 30Toxic SubstancesExtremely hazardous substances under SARAGases and highly volatile liquidsVapor pressure > 10 mmHgThresholds ranging from 500-2,000 lbs.Thresholds based on toxicity and volatility
  • 31. 31Flammable SubstancesNFPA 4 Most dangerousFlammable gases and volatile flammable liquids thatcould create vapor cloud explosionsThresholds set at 10,000 lbs.
  • 32. 32Threshold Quantity DeterminationTotal quantity of a regulated substances contained ina process at any one timeProcess included interconnected vessels or separatevessels that could be involved in a release (OSHAPSM definition)
  • 33. 33Offsite Consequence AnalysisToxic endpointFlammable endpointsUse appropriate models or guidanceWithin circle, identify Public receptors and population Environmental receptors
  • 34. 34Registration and SubmittalSubmit a comprehensive RMP to: EPA State Emergency Response Commission (SERC) Local Emergency Planning Committee (LEPC) The Chemical Safety and Hazard Investigation Board
  • 35. 35Registration and Submittal(Continued)Name, mailing address, telephone of stationarysourceCAS number of all regulated substances greater thanTQSIC codeDun and Bradstreet numberCertification signed by owner or operator
  • 36. 36Auditing the ProgramConduct audits of the management system
  • 37. 37Program Eligibility CriteriaThree Programs
  • 38. 38Program 1 - No impactRegisterConduct worst-case hazard assessmentsCertify no off-site consequences for worst-casescenarioEnsure inclusion in LEPC planSubmit RMP document above
  • 39. 39Program 3 - Full RMPOne comprehensive prevention program that: Protects workers The public The environmentHazard review information Hazards Controls Mitigation Changes
  • 40. 40Program 3(continued)RegisterConduct worst-case and other hazard assessmentsImplement comprehensive prevention steps (OSHAPSM plus...)Develop emergency response planSubmit RMP
  • 41. 41Program 3(continued)Process is subject to OSHAs PSMProcesses in specific SIC codes Pulp Mills (2611) Chlor-Alkali (2812) Industrial Inorganic (2819) Plastics and Resins (2821) Cyclic Crudes (2865) Industrial Organics (2869) Nitrogen Fertilizers (2873) Agricultural Chemicals (2879) Petroleum Refineries (2911)
  • 42. 42Program 2 - StreamlinedPrevention ProgramThe process is not eligible for Program 1 or 3
  • 43. 43Program 2(continued)Statutory requirements Training Maintenance Safety Precautions Monitoring
  • 44. 44Program 2(continued)Types of sources: Less complex; fewer changes Ideal model program and plansCapture good management practices from PSM butless documentationTake advantages of other rules and standardsTake advantages of equipment manufacturer orvendor information
  • 45. 45Program 2(continued)Process information (SIC, chemicals)List rules, standards, design codesHazard review information Hazards Controls Mitigation Changes
  • 46. 46Program 2(continued)RegisterConduct worst-case and other hazard assessmentsImplement seven elements of prevention programDevelop emergency response planSubmit RMP
  • 47. 47Comparison of ProgramRequirementsHazard AssessmentProgram 1 Program 2 Program 3Worst-case analysis Worst-case analysis Worst-case analysisAlternative releases Alternative releases5-year accident history 5-year accident history 5-year accident history
  • 48. 48Comparison(continued)Management Program DocumentProgram 1 Program 2 Program 3Management System Management System
  • 49. 49Comparison(continued)Prevention ProgramProgram 1 Program 2 Program 3Certify no additional Safety Information Process Safety Informationsteps Required Hazard Review Process Hazard ReviewOperating Procedures Operating ProceduresTraining TrainingMaintenance Mechanical IntegrityIncident Investigation Incident Investigation
  • 50. 50Comparison(continued)Prevention Program (continued)Program 1 Program 2 Program 3Compliance Audit Compliance AuditManagement of ChangePre-Startup ReviewContractorsEmployee ParticipationHot Work Permits
  • 51. 51Comparison(continued)Emergency Response ProgramProgram 1 Program 2 Program 3Coordinate with Local Develop Plan Develop PlanResponders and Program and Program
  • 52. 52Comparison(continued)Risk Management Plan ContentProgram 1 Program 2 Program 3Executive Summary Executive Summary Executive SummaryRegistration Registration RegistrationWorst-Case Data Worst-Case Data Worst-Case Data5-Year Accident History Alternative Release Data Alternative Release DataCertification. 5-Year Accident History 5-Year Accident History
  • 53. 53Comparison(continued)Risk Management Plan Content (continued)Program 1 Program 2 Program 3Prevention Program Data Prevention Program DataEmergency Response Data Emergency Response DataCertification Certification
  • 54. 54OSHA PSM Requirements EPA Program 3 RequirementsAn evaluation of the consequences An evaluation of the consequencesof deviations, including those of deviationsaffecting the safety and healthof employeesThe identification of any previous The identification of any previousincident which had a likely potential incident which had a likely potentialfor catastrophic consequences in for catastrophic consequencesthe workplaceEditorial Changes(continued)
  • 55. 55Editorial Changes(continued)OSHA PSM Requirements EPA Program 3RequirementsA qualitative evaluation of a range A qualitative evaluation of a rangeof possible safety and health effects of possible safety and healthof failure of controls on employees effects of failure of controlsin the workplaceThe employer shall investigate each The owner or operator shallincident which resulted in, or could investigate each incident whichreasonably have resulted in a catastrophic resulted in, or could reasonablyrelease of a highly hazardous chemical have resulted in a catastrophicin the workplace release of a regulated substance
  • 56. 56Language ComparisonOSHA’s - PSM EPA’s - RMPEmployer Owner or OperatorHighly Hazardous Chemicals Regulated SubstancesFacility Stationary SourceStandard RuleWorkplace Impact Off-Site Consequences
  • 57. 57Compliance ProceduresDevelop an inventory of substances used, stored,manufactured, processed, handled or moved, or anycombination of the listed activitiesCompare the inventory with the TQ, as required
  • 58. 58Management SystemDevelop a management system to oversee theimplementation of the RMP elementsIdentify single person or position who has overallresponsibility for: Development Implementation Integration of the RMP
  • 59. 59Elements of the Program
  • 60. 60Process Safety InformationBlock flow or process flow diagramsMaximum intended inventoryEstablish safe limits of the operating parameters
  • 61. 61Process Safety Information(continued)Evaluate consequences in deviations of processconditionsEquipment informationVerify equipment design with regulatoryrequirements/standard
  • 62. 62Process Hazard AnalysisDocument hazard analysis: Nature of the hazard Cause of the hazard Consequences of the hazard Actions to be considered to further protect personnelDocument follow-up steps based onrecommendations
  • 63. 63Process Hazard Analysis(continued)Document previous incidents with the potential tocause catastrophic conditionsDocument hazards associated with human factorsand facility siting
  • 64. 64Operating ProceduresDevelop clear operating procedures addressing stepsfor each process regarding Safe operating limits of processes EquipmentProvide precautionary instructions to preventexposure to hazards
  • 65. 65Operating Procedures(continued)Develop operating procedures for safety systemsConduct annual review of operating proceduresDevelop procedures for lockout/tagout, confinedspace entry, etc.
  • 66. 66Employee TrainingDocument training for personnel in the process,operating procedures, and safe work practicesapplicable to the job tasksMaintain records of training indicating the meansused to verify that the employee understood thetraining
  • 67. 67Maintenance(Mechanical Integrity)Provide written procedures to maintain the structuralintegrity of process equipmentDocument training for employees involved inmaintenance of the process equipmentVerify inspections and testing of equipment anddeficiencies are correctedDocument that spare parts are suitable for theappropriate application
  • 68. 68Incident Investigation(Accident Investigation)Incident reporting: The date of the incident Date of the investigation Description of the incident Factors contributing to the incident, and recommendationsthat resultedVerify that the recommendations in the incidentreport were promptly addressed and resolvedIdentify root causes as well as initiating events
  • 69. 69Compliance AuditsEvaluate compliance with program every three yearsConduct with at least one person knowledgeable inprocessDevelop report of findings Determine/develop aresponse to each finding, document that deficiencieshave been correctedRetain two most recent audit reports
  • 70. 70Management of ChangeProvide written procedures to manage change toprocess chemicals, technology, equipment, andprocedures, and changes to facilities that affect acovered processVerify that employees in operations and maintenanceare trained accordinglyProvide evidence that changes are documented
  • 71. 71Pre-Startup ReviewDocument that construction and equipment is inaccordance with design specificationsReview documentation showing that safety,operating, maintenance, and emergency proceduresare in place and adequateDocument that a PHA was performed, andrecommendations were resolved and implemented
  • 72. 72Pre-Startup Review(continued)Verify that modified facilities meet requirements inManagement of Change proceduresVerify that employee training is completed
  • 73. 73ContractorsMust established a screening process when hiringand use contractorsA site injury and illness log for contractors must bemaintainedThe contractor must ensure that each contractemployee is trained in the work practices necessaryto safely perform his/her job
  • 74. 74Employee ParticipationMust develop a written plan of action regarding theimplementation of employee participation.Required to train and educate employees and toinform all affected employees of the findings fromany incident investigations.
  • 75. 75Employee Participation(continued)Must consult with employees and employeerepresentatives: Development of PHA and other elements Hazard assessments The development of chemical accident preventionMust provide access to these records.
  • 76. 76Permit SystemsA work authorization notice or permit system shouldbe developed To describe the steps the maintenance supervisor,contractor representative or other person need to follow inorder to obtain the necessary clearance to get the job done.These procedures need to address such issues as Lockout/tagout procedures Line breaking procedures Confined space entry procedures Hot work permits
  • 77. 77Permit Systems(continued)Procedures must provide clear steps to follow oncethe job is completed to provide closure for those thatneed to know the job is completed and equipmentcan be returned to normal operations.
  • 78. 78Emergency Planning andResponseDocument that an emergency plan has beenestablished and implemented in accordance with 29CFR 1910.38 and 1910.120, as applicableEmergency action plan that include procedures forhandling releasesDocument specific actions to be taken in response toan accidental release of a regulated substance toprotect humans and the environment Conduct drills Exercise to test plan
  • 79. 79Emergency Response Plan -Basic RequirementsEmergency response planProcedures for use of emergency response equipmentand for it inspection, testing, and maintenanceTraining for all employees in relevant proceduresProcedures to review and update of the plan to reflectchanges at the facility and ensure that employees areinformed of changes
  • 80. 80Elements - LegislativeRequirementsProcedures for informing the public and localemergency response agenciesDocumentation of proper first-aid and emergencymedical treatment necessary to treat accidental humanexposuresProcedures and measures for emergency response aftera releaseWritten plan must comply with other federalregulationsCoordinate with local LEPC
  • 81. 81Planning Option - One-Plan Guidancefor Integrated Contingency Plan (ICP)Intended to: Provide a mechanism for consolidating multiple facilityresponse plans Improve coordination of response activities Minimize duplication and simplify plan development andmaintenance Ensure regulatory compliance with all relevant federalrequirements
  • 82. 82Communicating RMP to Public
  • 83. 83CommunicationRule does not specify How communication should take place When it should take place How much risk communicationAnyone putting public at risk must show how risk isaddressed/prevented and responded to
  • 84. 84Regulatory ApproachIndustry tells government and the public how it willaddress risk for preventing major accidentsGovernment and public can review what industry haspresentedGovernment and community can respond to industry,communicate concerns, and make recommendation
  • 85. 85Communicating the RMPStart nowExplain the programTell the public what to expect with your WCS andwhen to expect itExplain your WCSDetail chemical(s) on site that can cause explosions,environmental impacts, etc.Explain why you can’t reduce your inventory ofregulated substances
  • 86. 86Community OutreachSuggestionsOpen house/plant toursLocal citizen groups/civic organizationHigh school programsCommunity survey What does the community think about you?Neighborhood meetingsPlant newsletterCommunity advisory panels
  • 87. 87AudienceNeighborsImplementing agenciesLEPCEmergency respondersCity and county officials
  • 88. 88Audience(continued)Business and community leadersEducatorsLocal mediaState legislators
  • 89. 89Other ProgramsRisk communications trainingTraining on handling the with mediaInforming industrial neighbors
  • 90. 90Summary - Developing an RMPImplementation Plan
  • 91. 91Implementation Strategy -TechnicalAcquire/understand regulatory informationDetermine coverageDetermine technical capabilities/needsPrepare RMP implementation plan
  • 92. 92Implementation Strategy -Technical (continued)Perform program level screeningDevelop hazard assessment protocolPerform hazard assessmentCompile 5-year accident history
  • 93. 93Implementation Strategy -Technical (continued)Implement/upgrade PSM program to consider offsiteeffectsReview/upgrade emergency response activities andplanPrepare and submit the RMP
  • 94. 94Implementation Strategy -CommunicationDetermine internal risk communicationcapabilities/needsSurvey community outreach statusEstablish/improve community outreachPrepare communication planImprove internal risk communication capabilitiesCommunicate the RMP to the public
  • 95. 95Available ResourcesChemical Emergency Preparedness and PreventionOffice (CEPPO) Internet - (
  • 96. 96Suggested Team MembersHealth and safety Professionals Program development and reviewChemical, electrical, and mechanical engineering Process safety information and hazard analysisdevelopmentAir Quality Specialist/Industrial Hygienist Air modeling dispersion. Identify acute health effects
  • 97. 97Suggested Team Members(continued)Risk Assessment Specialist Population exposure and environmental effectsCommunications Specialists Communicating with the public
  • 98. 98Summary - Final WordPSM and RMP outlines requirements for facilities toreduce risks associated with accidental releasesA good communications program will help reducemisinformation, distrust, and build good communityrelationsReduction in inventory will result in a reduction ofthe risk and potential for a catastrophic incident
  • 99. 99Summary - Final Word(continued)Audits are to be comprehensive, involvingsystematic assessment of all elements of the program