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    736studyguide 736studyguide Document Transcript

    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc.Introduction toProcess SafetyManagement
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 2 of 51OSHAcademy Course 736 Study GuideIntroduction to Process Safety ManagementCopyright © 2013 Geigle Safety Group, Inc.No portion of this text may be reprinted for other than personal use. Any commercial use ofthis document is strictly forbidden.Contact OSHAcademy to arrange for use as a training document.This study guide is designed to be reviewed off-line as a tool for preparation to successfullycomplete OSHAcademy Course 736.Read each module, answer the quiz questions, and submit the quiz questions online throughthe course webpage. You can print the post-quiz response screen which will contain the correctanswers to the questions.The final exam will consist of questions developed from the course content and module quizzes.We hope you enjoy the course and if you have any questions, feel free to email or call:OSHAcademy1915 NW Amberglen Parkway, Suite 400Beaverton, Oregon 97006www.oshatrain.orginstructor@oshatrain.org+1.888.668.9079
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 3 of 51ContentsCourse Introduction........................................................................................................................ 6The purpose for Process Safety Management (PSM)................................................................. 6Module 1: Why We Have Process Safety Management................................................................. 7The Problem................................................................................................................................ 7A Disastrous Record.................................................................................................................... 7OSHA Proposes the PSM Standard ............................................................................................. 8The Clean Air Act Amendments and the PSM Standard............................................................. 9CAAA Requirements for the PSM Standard................................................................................ 9What are the benefits of an effective PSM program?.............................................................. 11Module 1 Quiz........................................................................................................................... 12Module 2: How the PSM Standard Applies................................................................................... 14Application................................................................................................................................ 14What does PSM target?............................................................................................................ 14What does the employer need to develop?............................................................................. 14What is the impact of the PSM? ............................................................................................... 14What can employers do to reduce risk?................................................................................... 15Who is not covered by the PSM Standard?.............................................................................. 15Module 2 Quiz........................................................................................................................... 17Module 3: Process Safety Information ......................................................................................... 18Developing the written PSM Plan............................................................................................. 18Hazards of the Chemicals Used in the Process......................................................................... 18Technology of the Process........................................................................................................ 19Block Flow Diagrams................................................................................................................. 20Process Flow Diagrams ............................................................................................................. 21Equipment in the Process ......................................................................................................... 23Module 3 Quiz........................................................................................................................... 25Module 4: Process Hazard Analysis (PHA).................................................................................... 27
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 4 of 51What is Process Hazard Analysis?............................................................................................. 27Questions to consider when deciding the methods used in PHA’s.......................................... 27Limitations of PHA Methods..................................................................................................... 27Prioritizing PHA’s....................................................................................................................... 28Methods for Conducting the PHA............................................................................................. 28The PHA..................................................................................................................................... 29Employer Response to PHA Team Findings.............................................................................. 30Review and Revalidation........................................................................................................... 31Module 4 Quiz........................................................................................................................... 32Module 5: Operating Procedures ................................................................................................. 34What are Operating Procedures?............................................................................................. 34What must operating procedures describe?............................................................................ 34Elements of the Operating Procedures .................................................................................... 35Module 5 Quiz........................................................................................................................... 37Module 6: Employee Participation ............................................................................................... 38Employers duty to involve employees...................................................................................... 38Initial Training ........................................................................................................................... 38Refresher Training..................................................................................................................... 39Training Documentation........................................................................................................... 39Module 6 Quiz........................................................................................................................... 40Module 7: Contractors.................................................................................................................. 42Application................................................................................................................................ 42Employer Responsibilities......................................................................................................... 42Contract Employer Responsibilities.......................................................................................... 43Pre-Startup Safety Review ........................................................................................................ 43Module 7 Quiz........................................................................................................................... 44Module 8: Mechanical Integrity and Hot Work Permit ................................................................ 46Mechanical Integrity................................................................................................................. 46Training ..................................................................................................................................... 46
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 5 of 51Inspection.................................................................................................................................. 46Correcting Deficiencies ............................................................................................................. 47New Construction and Equipment............................................................................................ 47Hot Work Permit....................................................................................................................... 47Final words of PSM wisdom! .................................................................................................... 48Module 8 Quiz........................................................................................................................... 49Optional Exercise .......................................................................................................................... 51
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 6 of 51Course IntroductionThe purpose for Process Safety Management (PSM)The major purpose of process safety management (PSM) of highly hazardous chemicals is toprevent unwanted releases of hazardous chemicals, especially into locations that could exposeemployees and others to serious hazards. OSHAsimply states a hazardous chemical is any chemicalwhich is a physical hazard or a health hazard.An effective process safety management programrequires a systematic approach to evaluating thewhole chemical process. Using this approach, theprocess design, process technology, process changes, operational and maintenance activitiesand procedures, non-routine activities and procedures, emergency preparedness plans andprocedures, training programs, and other elements that affect the process are all considered inthe evaluation.This course is intended to introduce you to the basic requirements in the PSM standard, theneed for process safety, and the tools used to implement process safety management systems.It covers the 14 elements required by the standard and some of the tools used to addressprocess safety requirements, identify hazards, and manage risks. This course does not itselfalter or determine compliance responsibilities, which are set forth in OSHA standardsthemselves and the Occupational Safety and Health Act.Special thanks go out to the U.S. Dept. of Labor, OSHA, for the content and images within thiscourse.
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 7 of 51Module 1: Why We Have Process Safety ManagementThe ProblemUnexpected releases of toxic, reactive, or flammable liquids and gases in processes involvinghighly hazardous chemicals have been reported for many years. Incidents continue to occur invarious industries that use highly hazardous chemicals which may be toxic, reactive, flammable,or explosive, or may exhibit a combination of theseproperties. Regardless of the industry that uses thesehighly hazardous chemicals, there is a potential for anaccidental release any time they are not properlycontrolled. This, in turn, creates the possibility ofdisaster.Recent major disasters include the 1984 Bhopal, India,incident resulting in more than 2,800 deaths; theOctober 1989 Phillips Petroleum Company, Pasadena,TX, incident resulting in 23 deaths and 132 injuries; the July1990 BASF, Cincinnati, OH, incident resulting in 2 deaths, andthe May 1991 IMC, Sterlington, LA, incident resulting in 8deaths and 128 injuries.A Disastrous RecordSeveral major disasters involving highly hazardous chemicalsdrew international attention to the potential for majorcatastrophes; the public record in the U.S. is replete with information concerning many otherless notable releases of highly hazardous chemicals. Hazardous chemical releases continue topose a significant threat to employees and provideimpetus, internationally and nationally, forauthorities to develop or consider developinglegislation and regulations to eliminate or minimizethe potential for such events.
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 8 of 51Methyl Isocyanate Tank Rupture and ReleaseBhopal, India – Dec. 2-3, 1984On the night of December 2-3, 1984, a suddenrelease of about 30 metric tons of methylisocyanate (MIC) occurred at the Union Carbidepesticide plant at Bhopal, India. The accident wasa result of poor safety management practices,poor early warning systems, and the lack ofcommunity preparedness. The accident led to thedeath of over 2,800 people (other estimates putthe immediate death toll as high as 8000) living inthe vicinity and caused respiratory damage and eye damage to over 20,000 others. At least200,000 people fled Bhopal during the week after the accident. Estimates of the damage varywidely between $350 million to as high as $3 billion.Phillips 66 Houston Chemical Complex Pasadena, Texas – Oct. 23, 1989On October 23, 1989, at approximately 1:00 p.m., an explosion and fire ripped through thePhillips 66 Company Houston Chemical Complex in Pasadena, Texas. Twenty-three workerswere killed and more than 130 were injured. Property damage was nearly three-quarters of abillion dollars. The accident resulted from a release of extremely flammable process gases thatoccurred during regular maintenance operations on one of the plants polyethylene reactors.The evidence showed that more than 85,000 pounds of highly flammable gases were releasedthrough an open valve. A vapor cloud formed and traveled rapidly through the polyethyleneplant. Within 90 to 120 seconds, the vapor cloud came into contact with an ignition source andexploded with the force of 2.4 tons of TNT.OSHA Proposes the PSM StandardOn July 17, 1990, the U.S. Dept. of Labor, OSHA published in the Federal Register a proposedstandard, - ”Process Safety Management of Highly Hazardous Chemicals” (PSM) - containingrequirements for the management of hazards associated with processes using highly hazardouschemicals to help assure safe and healthful workplaces.OSHAs PSM standard emphasizes the management of hazards associated with highlyhazardous chemicals and established a comprehensive management program that integratedtechnologies, procedures, and management practices.
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 9 of 51The Clean Air Act Amendments and the PSM StandardApproximately four months after the publication of OSHAs proposed PSM standard, the CleanAir Act Amendments (CAAA) were enacted into law. Section 304 of the CAAA requires that theSecretary of Labor, in coordination with the Administrator of the Environmental ProtectionAgency (EPA), promulgate a PSM standard to prevent accidental releases of chemicals thatcould pose a threat to employees.CAAA Requirements for the PSM StandardThe CAAA requires that the standard include a list of highly hazardous chemicals which includestoxic, flammable, highly reactive, and explosive substances. These requirements have becomewidely known as the “14 PSM Program Elements.”The CAAA also specified 14 minimum elements that the OSHA standard must require employersto do, as follows:1. develop and maintain written safety information identifying workplace chemical andprocess hazards, equipment used in the processes, and technology used in the processes;2. perform a workplace hazard assessment, including, as appropriate, identification ofpotential sources of accidental releases, identification of any previous release within thefacility that had a potential for catastrophic consequences in the workplace, estimation ofworkplace effects of a range of releases, and estimation of the health and safety effectsof such a range on employees;3. consult with employees and their representatives on thedevelopment and conduct of hazard assessments and thedevelopment of chemical accident prevention plans andprovide access to these and other records required underthe standard;4. establish a system to respond to the workplace hazardassessment findings, which shall address prevention,mitigation, and emergency responses;5. review periodically the workplace hazard assessment andresponse system;
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 10 of 516. develop and implement written operating procedures for the chemical processes,including procedures for each operating phase, operating limitations, and safety andhealth considerations;7. provide written safety and operating information for employees and employee training inoperating procedures, by emphasizing hazards and safe practices that must be developedand made available;8. ensure contractors and contract employees are provided with appropriate informationand training;9. train and educate employees and contractors in emergency response procedures in amanner as comprehensive and effective as that required by the regulation promulgatedpursuant to section 126(d) of the Superfund Amendments and Reauthorization Act;10. establish a quality assurance program to ensure that initial process-related equipment,maintenance materials, and spare parts are fabricated and installed consistent withdesign specifications;11. establish maintenance systems for critical process-related equipment, including writtenprocedures, employee training, appropriate inspections, and testing of such equipment toensure ongoing mechanical integrity;12. conduct pre-startup safety reviews of all newly installedor modified equipment;13. establish and implement written procedures managingchange to process chemicals, technology, equipment andfacilities; and14. investigate every incident that results in or could haveresulted in a major accident in the workplace, with any findings to be reviewed byoperating personnel and modifications made, if appropriate.
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 11 of 51What are the benefits of an effective PSM program?Effective PSM helps ensure the proper development of plant systems and procedures toprevent unwanted releases which may ignite and cause toxic impacts, local fires, or explosionsin plants and installations.PSM can also improve:• the operability, productivity, stability, and quality of the outputs of hazardouschemical processes; and• the design and specification of safeguards against undesirable events.Effective PSM results in reduced exposure to lawsuits, OSHA penalties, public liability claims,and hikes in workers compensation insurance premiums.Other intangible benefits include an improved corporate image – the community sees thecompany as a responsible corporate citizen.
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 12 of 51Module 1 QuizUse this quiz to self-check your understanding of the module content. You can also go onlineand take this quiz within the module. The online quiz provides the correct answer oncesubmitted.1. Which of the following is true about the purpose of process safety management (PSM)of highly hazardous chemicals?a. to understand the nature of processesb. to keep hazardous chemicals out of processesc. to prevent unwanted releases of hazardous chemicalsd. to limit the amount of hazardous chemicals in processes2. Clean Air Act Amendments (CAAA) specified which of the minimum PSM elementsthat OSHA must require employers to do?a. Develop and maintain written safety informationb. Perform a workplace hazard assessmentc. Train and educate employees and contractorsd. all of the above3. Under the PSM Program, employers are to train and educate employees andcontractors in which of the following topics?a. emergency response proceduresb. filing complaints with OSHAc. notifying employees of unsafe actsd. what to expect from an OSHA inspection4. Establish a quality assurance program to ensure which of the following are fabricatedand installed consistent with design specifications?a. initial process-related equipmentb. maintenance materialsc. spare partsd. all of the above
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 13 of 515. A workplace hazard assessment is performed to do all of the following, EXCEPT:a. identification of potential sources of accidental releasesb. evaluation of processes that may cause faulty readingsc. identification of any previous released. estimation of workplace effects of a range of releases
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 14 of 51Module 2: How the PSM Standard AppliesApplicationThe various lines of defense incorporated into the designand operation of the PSM process should be evaluated andstrengthened to make sure they are effective at each level.Process safety management is the proactive identification,evaluation and mitigation or prevention of chemicalreleases that could occur as a result of failures inprocesses, procedures, or equipment.What does PSM target?The process safety management standard targets highly hazardous chemicals that have thepotential to cause a catastrophic incident. The purpose of the standard as a whole is to aidemployers in their efforts to prevent or mitigate episodic chemical releases that could lead to acatastrophe in the workplace and possibly in the surrounding community. It’s important to notethat the PSM standard is a performance-based rule; it does not specifically prescribe how eachelement is to be implemented. That’s left up to the employer.What does the employer need to develop?To control these types of hazards, employers need to develop the necessary expertise,experience, judgment, and initiative within their work force to properly implement andmaintain an effective process safety management program as envisioned in the OSHA PSMstandard.As you learned earlier, the OSHA PSM standard is required bythe Clean Air Act Amendments (CAAA) and the EnvironmentalProtection Agencys Risk Management Plan (RMP).Employers who merge the two sets of requirements into theirPSM program will better assure full compliance with CAAAand the RPM as well as enhance their relationship with thelocal community.What is the impact of the PSM?OSHA believes that the PSM requirements has a definite positive effect on the safety ofemployees and offers other potential benefits to employers, such as increased productivity.
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 15 of 51What can employers do to reduce risk?Employers, including small employers, may establish moreefficient inventory control by reducing, to below the establishedthreshold, the quantities of highly hazardous chemicals onsite.This reduction can be accomplished by ordering smallershipments and maintaining the minimum inventory necessaryfor efficient and safe operation.When reduced inventory is not feasible, the employer mightconsider dispersing inventory to several locations onsite.Dispersing storage into locations so that a release in onelocation will not cause a release in another location is also apractical way to reduce the risk or potential for catastrophicincidents.Who is not covered by the PSM Standard?The PSM standard does not apply to:• retail facilities;• oil or gas well drilling orservicing operations;• normally unoccupied remotefacilities;• hydrocarbon fuels used solelyfor workplace consumption as afuel (e.g. propane used forcomfort heating, gasoline forvehicle refueling), if such fuelsare not a part of a process containing another highly hazardous chemical covered bythis standard; and• flammable liquid stored in atmospheric tanks or transferred which are kept belowtheir normal boiling point without benefit of chilling or refrigerating and are notconnected to a process.
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 16 of 51BP American Refinery Explosion – Texas City, Texas (March 23, 2005)At approximately 1:20 p.m. on March 23, 2005, a series of explosions occurred at the BP TexasCity refinery during the restarting of a hydrocarbon isomerization unit. Fifteen workers werekilled and 180 others were injured. Many of the victims were in or around work trailers locatednear an atmospheric vent stack. The explosions occurred when a distillation tower flooded withhydrocarbons and was over pressurized, causing a geyser-like release from the vent stack.
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 17 of 51Module 2 QuizUse this quiz to self-check your understanding of the module content. You can also go onlineand take this quiz within the module. The online quiz provides the correct answer oncesubmitted.1. Process safety management is the ________ identification, evaluation and mitigationor prevention of chemical releases that could occur as a result of failures in processes,procedures, or equipment.a. proactiveb. reactivec. systematicd. random2. According to the text, the process safety management standard targets highlyhazardous chemicals that have the potential to cause a _________ incident.a. dangerousb. catastrophicc. horrendousd. fatal3. The OSHA PSM standard is required by which of the following?a. Clean Air Act Amendments (CAAA)b. Environmental Protection Agency Management Plan (RMP)c. 1970 Occupational Safety and Health Act (OSHA)d. Both A & B4. Employers may establish more efficient inventory control by reducing the quantitiesof highly hazardous chemicals to below which of the following?a. minimum HAZCOM levelsb. maximum HAZCOM levelsc. established thresholdd. detectable threshold5. The PSM standard does not apply to the following:a. Retail facilitiesb. Oil or gas well drilling or servicing operationsc. Normally unoccupied remote facilitiesd. All of the above
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 18 of 51Module 3: Process Safety InformationDeveloping the written PSM PlanEmployers must compile written process safety information before conducting any processhazard analysis required by the standard. The written process safety information will help theemployer and the employees involved in operating the process to identify and understand thehazards posed by those processes that involve highly hazardous chemicals.To develop an effective PSM program and Process Hazard Analysis (PHA), it is important todevelop and maintain complete and accurate written information on each of the following:1. process chemicals,2. process technology, and3. process equipmentThis information will be used by:• the team performing the process hazardanalysis;• those developing the training programs and the operating procedures;• contractors whose employees will be working with the process;• those conducting the pre-startup reviews;• local emergency preparedness planners and insurance and enforcement officials.Hazards of the Chemicals Used in the ProcessThe information about the chemicals, including process intermediates, needs to becomprehensive and accurate. Information on the hazards of the highly hazardous chemicals inthe process shall consist of at least the following:• Toxicity• Permissible exposure limits• Physical data• Reactivity data
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 19 of 51• Corrosivity data• Thermal and chemical stability data• The hazardous effects of inadvertent mixing of different materialsCurrent safety data sheets (SDS) can be used to help gather information about hazardouschemicals, but it must be supplemented with process chemistry information, including runawayreaction and over-pressure hazards, if applicable.Technology of the ProcessProcess technology information is a part of the process safety information package and shouldinclude employer-established criteria for:• maximum inventory levels for process chemicals;• limits beyond which would be considered upset conditions; and• a qualitative estimate of the consequences or results of deviation that could occur ifoperating beyond the established process limits.Information on the technology of the process must include at least the following:• A block flow diagram or simplified process flow diagram,• Process chemistry,• Maximum intended inventory,• Safe upper and lower limits for such items as temperatures, pressures, flows orcompositions, and• An evaluation of the consequences of deviations, including those affecting the safetyand health of employees.Where the original technical information no longer exists, information may be developed inconjunction with the process hazard analysis in sufficient detail to support the analysis.Note: Safety Data Sheets (SDSs) meeting the requirements of the Hazard CommunicationStandard (20 CFR 1910.1200) may be used to comply with this requirement to the extent theycontain the required information.
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 20 of 51Block Flow DiagramsA block flow diagram can be used to show the major process equipment and interconnectingprocess flow lines and flow rates, stream composition, temperatures, and pressures whennecessary for clarity. The block flow diagram is a simplified diagram. See the sample block flowdiagram below:
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 21 of 51Process Flow DiagramsProcess flow diagrams are more complex and show all main flow streams including valves toenhance the understanding of the process as well as pressures and temperatures on all feed
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 22 of 51and product lines within all major vessels and in and out of headers and heat exchangers, andpoints of pressure and temperature control.Also, information on construction materials, pump capacities and pressure heads, compressorhorsepower, and vessel design pressures and temperatures are shown when necessary forclarity.In addition, process flow diagrams usually show major components of control loops along withkey utilities.
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 23 of 51Equipment in the ProcessPiping and instrument diagrams (P&IDs) may be used to describe the relationships betweenequipment and instrumentation as well as other relevant information that will enhance clarity.Computer software programs that create P&IDs or other diagrams useful to the informationpackage may be used to help meet this requirement.Information on the equipment in the process must include the following:• materials of construction;
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 24 of 51• piping and instrument diagrams (P&IDs);• electrical classification;• relief system design and design basis;• ventilation system design;• design codes and standards employed;• material and energy balances for processes built after May 26, 1992; and• safety systems (e.g., interlocks, detection, or suppression systems).The employer must document that equipment complies with recognized and generallyaccepted good engineering practices.For existing equipment designed and constructed in accordance with codes, standards, orpractices that are no longer in general use, the employer must determine and document thatthe equipment is designed, maintained, inspected, tested, and operated in a safe manner.Compiling and maintaining this information is important to:• To provide the basis for identifying and understanding the hazards of a process• To develop the process hazard analysis• Comply with other provisions of PSM such as management of change and incidentinvestigations.For existing equipment designed and constructed many years ago the employer must:• document which codes and standards were used• certify that the design and construction along with the testing, inspection, andoperation are still suitable for the intended use.Where the process technology requires a design that departs from the applicable codes andstandards, the employer must document that the design and construction are suitable for theintended purpose.
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 25 of 51Module 3 QuizUse this quiz to self-check your understanding of the module content. You can also go onlineand take this quiz within the module. The online quiz provides the correct answer oncesubmitted.1. To develop an effective PSM program and Process Hazard Analysis (PHA), it isimportant to develop and maintain complete and accurate written information oneach of the following, EXCEPT:a. process equipmentb. process theoryc. process chemicalsd. process technology2. Information on the hazards of the highly hazardous chemicals in the process shallconsist of at least which of the following?a. Toxicityb. Permissible exposure limitsc. Reactivity Datad. All of the above3. Under the PSM Program, current safety data sheets (SDS) can be used to help gatherinformation about hazardous chemicals.a. Trueb. False4. A __________can be used to show the major process equipment and interconnectingprocess flow lines and flow rates, stream composition, temperatures, and pressureswhen necessary for clarity.a. piping diagramb. brain-storming sessionc. block flow diagramd. what-if flow diagram
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 26 of 515. Where the process technology requires a design that departs from the applicablecodes and standards, the employer must do which of the following?a. document suitability for the intended purposeb. state that the technology complies with CAAAc. prove the technology has been approved by OSHAd. obtain the related permits for installation
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 27 of 51Module 4: Process Hazard Analysis (PHA)What is Process Hazard Analysis?A PHA, or evaluation, is one of the most important elements of the process safety managementprogram.A PHA is an organized and systematic effort to identify and analyze the significance of potentialhazards associated with the processing or handling of highly hazardous chemicals.A PHA provides information that will assist employers and employees in making decisions forimproving safety and reducing the consequences of unwanted or unplanned releases ofhazardous chemicals.A PHA analyzes potential causes and consequences of fires, explosions, releases of toxic orflammable chemicals, and major spills of hazardous chemicals.The PHA focuses on equipment, instrumentation, utilities, human actions (routine and non-routine), and external factors that might affect the process.The employer must perform an initial process hazard analysis (hazard evaluation) on allprocesses covered by the PSM standard.Questions to consider when deciding the methods used in PHA’sThe process hazard analysis method selected must be appropriate to the complexity of theprocess and must identify, evaluate, and control the hazards involved in the process.The selection will be influenced by many factors including how much is known about theprocess.• Is it a process that has been operated for a long period of time with little or noinnovation and extensive experience has been generated with its use?• Is it a new process or one that has been changed frequently by the inclusion ofinnovation features?Also, the size and complexity of the process will influence the decision as to the appropriatePHA method to use.Limitations of PHA MethodsAll PHA methods are subject to certain limitations. For example:
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 28 of 51• The checklist method works well when the process is very stable and no changes aremade, but it is not as effective when the process has undergone extensive change.The checklist may miss the most recent changes and consequently they would notbe evaluated.• Another limitation to be considered concerns the assumptions made by the team oranalyst. The PHA is dependent on good judgment and the assumptions made duringthe study need to be documented and understood by the team and reviewer andkept for a future PHA.Prioritizing PHA’sFirst, employers must determine and document the priority order for conducting processhazard analyses. Consideration should be given first to those processes with the potential ofadversely affecting the largest number of employees. Other considerations include:• the extent of the process hazards;• the number of potentially affected employees;• the age of the process; and• the operating history of the process.Together, these factors would suggest a ranking order using either a weighting factor system ora systematic ranking method.The use of a preliminary hazard analysis will assist an employer in determining which processshould be of the highest priority for hazard analysis resulting in the greatest improvement insafety at the facility occurring first.Methods for Conducting the PHAThe employer must use one or more of the following methods, as appropriate, to determineand evaluate the hazards of the process being analyzed:• What-if,• Checklist,• What-if/checklist,• Hazard and operability study (HAZOP),
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 29 of 51• Failure mode and effects analysis (FMEA),• Fault tree analysis, or• An appropriate equivalent method.A discussion of these methods of analysis is contained in the publication, OSHA 3133, ProcessSafety Management Guidelines for Compliance. Whichever method(s) are used, the processhazard analysis must do the following:• address the hazards of the process;• identify any previous incident that had a potential for catastrophic consequences inthe workplace;• determine engineering and administrative controls applicable to the hazards andtheir interrelationships, such as appropriate application of detection methods toprovide early warning of releases (acceptable detection methods might includeprocess monitoring and control instrumentation with alarms, and detectionhardware such as hydrocarbon sensors);• identify the consequences of failure of engineering and administrative controls;• address facility siting;• address human factors; and• conduct a qualitative evaluation of a range of the possible safety and health effectson employees in the workplace if there is a failure of controls.Different methods for various parts of the process may be used. For example, a processinvolving a series of unit operations of varying sizes, complexities, and ages may use differentmethods and team members for each operation. Then the conclusions can be integrated intoone final study and evaluation.The PHA TeamOSHA believes that the process hazard analysis is best performed by a team with expertise inengineering and process operations. The team conducting the PHA needs to understand themethod that is going to be used. The PHA team should include:
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 30 of 51• at least one employee who has experience with and knowledge of the process beingevaluated; and• one member (preferably the team leader) knowledgeable in the specific analysismethods and proper implementation of methods being used in the evaluation.The other full or part-time team members need to provide the team with expertise in areassuch as:• process technology;• process design;• operating procedures and practices;• alarms;• emergency procedures;• instrumentation;• maintenance procedures, both routine and non-routine tasks, including how thetasks are authorized;• procurement of parts and supplies;• safety and health; and• any other relevant subjects.The ideal team will have an intimate knowledge of the standards, codes, specifications, andregulations applicable to the process being studied. The selected team members need to becompatible and the team leader needs to be able to manage the team and the PHA study. Theteam needs to be able to work together while benefiting from the expertise of others on theteam or outside the team to resolve issues and to forge a consensus on the findings of thestudy and recommendations.Employer Response to PHA Team FindingsIn response to the PHA Team’s findings and recommendations, the employer must establish asystem to:• address promptly the teams findings and recommendations;• ensure that the recommendations are resolved in a timely manner and that theresolutions are documented;• document what actions are to be taken;• develop a written schedule of when these actions are to be completed;• complete actions as soon as possible; and
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 31 of 51• communicate the actions to operating, maintenance, and other employees whosework assignments are in the process and who may be affected by therecommendations or actions.Review and RevalidationAt least every five years after the completion ofthe initial process hazard analysis, the processhazard analysis must be updated and revalidatedby a team meeting the standards requirements toensure that the hazard analysis is consistent withthe current process.Employers must keep on file and make available toOSHA, upon request, process hazard analyses andupdates or revalidation for each process coveredby PSM, as well as the documented resolution ofrecommendations, for the life of the process.
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 32 of 51Module 4 QuizUse this quiz to self-check your understanding of the module content. You can also go onlineand take this quiz within the module. The online quiz provides the correct answer oncesubmitted.1. A _______ is an organized and systematic effort to identify and analyze thesignificance of potential hazards associated with the processing or handling of highlyhazardous chemicals.a. Job Hazard Analysis (JHA)b. Process Hazard Analysis (PHA)c. Change Analysis (CA)d. Potential Hazard Analysis (PHA)2. The employer must perform an initial process hazard analysis on which of thefollowing processes covered by the PSM standard?a. Hazardousb. Identifiedc. Potentiald. all of the processes3. All of the following are methods to determine and evaluate the hazards of a processbeing analyzed, EXCEPT:a. what-ifb. checklistc. what-if/checklistd. pareto chart4. At least every ____ years after the completion of the initial process hazard analysis,the process hazard analysis must be updated and revalidated.a. twob. threec. fourd. five
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 33 of 515. OSHA believes that the process hazard analysis is best performed by a team withwhich of the following areas of expertise?a. accident investigationb. engineeringc. process operationsd. Both B & C
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 34 of 51Module 5: Operating ProceduresWhat are Operating Procedures?Operating procedures provide specific instructions or details on what steps are to be taken orfollowed in carrying out the stated procedures. The specificinstructions should include the applicable safety precautions andappropriate information on safety implications.For example, the operating procedures addressing operatingparameters will contain operating instructions about pressurelimits, temperature ranges, flow rates, what to do when an upsetcondition occurs, what alarms and instruments are pertinent if anupset condition occurs, and other subjects.Another example of using operating instructions to properlyimplement operating procedures is in starting up or shutting down the process. In these cases,different parameters will be required from those of normal operation. These operatinginstructions need to clearly indicate the distinctions between startup and normal operations,such as the appropriate allowances for heating up a unit to reach the normal operatingparameters. Also, the operating instructions need to describe the proper method for increasingthe temperature of the unit until the normal operating temperatures are reached.The employer must develop and implement written operating procedures, consistent with theprocess safety information, that provide clear instructions for safely conducting activitiesinvolved in each covered process.What must operating procedures describe?PSM operating procedures describe:• tasks to be performed,• data to be recorded,• operating conditions to be maintained,• samples to be collected, and• safety and health precautions to be taken.The procedures need to be technically accurate, understandable to employees, and revisedperiodically to ensure that they reflect current operations.
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 35 of 51The process safety information package helps to ensure that the operating procedures andpractices are consistent with the known hazards of the chemicals in the process and that theoperating parameters are correct.Operating procedures should be reviewed by engineering staff and operating personnel toensure their accuracy and that they provide practical instructions on how to actually carry outjob duties safely.OSHA believes that tasks and procedures related to the process must be appropriate, clear,consistent, and most importantly, well communicated to employees.Elements of the Operating ProceduresThe procedures must address at least the following elements:Steps for each operating phase:1. initial startup;2. normal operations;3. temporary operations;4. emergency shutdown, including the conditions under which emergency shutdown isrequired, and the assignment of shut down responsibility to qualified operators toensure emergency shutdown is executed in a safe and timely manner;5. emergency operations;6. normal shutdown; and7. startup following a turnaround, or after an emergency shut down.Operating limits:• consequences of deviation, and• steps required to correct or avoid deviation.Safety and health considerations:• properties of, and hazards presented by, the chemicals used in the process;• precautions necessary to prevent exposure, including engineering controls,administrative controls, and personal protective equipment;• control measures to be taken if physical contact or airborne exposure occurs;• quality control for raw materials and control of hazardous chemical inventory levels;• any special or unique hazards; and
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 36 of 51• safety systems (e.g., interlocks, detection or suppression systems) and theirfunctions.Operating procedures must be readily accessible to employees who work in or maintain aprocess:• to make sure that a ready and up-to-date reference is available, and• to form a foundation for needed employee training.The operating procedures must be reviewed as often as necessary to ensure that they reflectcurrent operating practices, including changes in process chemicals, technology, andequipment, and facilities.The employer must certify annually that these operating procedures are current and accurateto guard against outdated or inaccurate operating procedures.The employer must develop and implement safe work practices to provide for the control ofhazards during work activities such as:• lockout/tagout;• confined space entry;• opening process equipment or piping; and• control over entrance into a facility by maintenance, contractor, laboratory, or othersupport personnel.These safe work practices must apply both to employees and to contractor employees.
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 37 of 51Module 5 QuizUse this quiz to self-check your understanding of the module content. You can also go onlineand take this quiz within the module. The online quiz provides the correct answer oncesubmitted.1. Operating procedures provide general instructions or details on what steps are to betaken or followed in carrying out the stated procedures.a. Trueb. False2. PSM operating procedures describe:a. tasks to be performedb. cautions to be takenc. operating conditions to be maintainedd. all of the above3. Which of the following does OSHA believe to be most important about the tasks andprocedures related to the process?a. they should be appropriateb. they should be clearc. they should be well communicatedd. they should be consistent4. The employer must certify every three years that these operating procedures arecurrent and accurate to guard against outdated or inaccurate operating procedures.a. Trueb. False5. Safe work practices under the PSM program must apply to which of the following?a. employeesb. contractorsc. employersd. both a and b above
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 38 of 51Module 6: Employee ParticipationEmployers duty to involve employeesEmployers must develop a written plan of action to implementand ensure employee participation required by PSM.Under PSM, employers must consult with employees and theirrepresentatives on the:• conduct and development of process hazard analysesand• development of the other elements of processmanagement.They must provide to employees and their representatives accessto process hazard analyses and to all other information required to be developed by thestandard.Initial TrainingThe implementation of an effective training program is one of the most important steps that anemployer can take to enhance employee safety.Accordingly, PSM requires that each employee presently involved in operating a process or anewly assigned process must be trained in:• an overview of the process, and• in its operating procedures.The training must include:• emphasis on the specific safety and health hazardsof the process;• emergency operations including shutdown; and• other safe work practices that apply to theemployees job tasks.Those employees already involved in operating a process on the PSM effective date do notnecessarily need to be given initial training. Instead, the employer may certify in writing thatthe employees have the required knowledge, skills, and abilities (KSA’s) to safely carry out theduties and responsibilities specified in the operating procedures.
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 39 of 51Refresher TrainingRefresher training must be provided at least every three years, or more often if necessary, toeach employee involved in operating a process to ensure that the employee understands andadheres to the current operating procedures of the process.The employer, in consultation with the employees involved in operating the process, mustdetermine the appropriate frequency of refresher training.Training DocumentationThe employer must determine whether each employee operating a process has received andunderstood the training required by PSM.A record must be kept containing the identity of the employee, the date of training, and howthe employer verified that the employee understood the training.Employees should also be able to demonstrate the necessary skills needed to safely completePSM procedures.
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 40 of 51Module 6 QuizUse this quiz to self-check your understanding of the module content. You can also go onlineand take this quiz within the module. The online quiz provides the correct answer oncesubmitted.1. According to the text, under the PSM standard, employers must consult withemployees and their representatives on which of the following?a. conduct and development of process hazard analysesb. development of accident and incident investigationsc. results of process hazard initial testingd. results of OSHA complaint inspections2. The PSM standard requires that each employee involved in operating a process or anewly assigned process must be trained in an overview of the process, and in itsoperating procedures.a. Trueb. False3. Refresher training must be provided at least every ______years, or more often ifnecessary, to each employee involved in operating a process.a. twob. threec. fourd. five4. The employer may certify in writing that experienced employees have the requiredknowledge, skills, and abilities (KSA’s) to safely carry out the duties andresponsibilities specified in the operating procedures.a. Trueb. False
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 41 of 515. Under the PSM Program, an employee training record must be kept containing whichof the following information?a. identity of the employeeb. date of trainingc. how employer verified understandingd. All of the above
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 42 of 51Module 7: ContractorsApplicationMany categories of contract labor may be presentat a jobsite. Some workers may actually operatethe facility or do only a particular aspect of a jobbecause they have specialized knowledge or skill.Others work only for short periods when there isneed for increased staff quickly, such as inturnaround operations.PSM includes special provisions for contractorsand their employees to emphasize the importanceof everyone taking care that they do nothing toendanger those working nearby who may work for another employer.PSM, therefore, applies to contractors performing maintenance or repair, turnaround, majorrenovation, or specialty work on or adjacent to a covered process.It does not apply, however, to contractors providing incidental services that do not influenceprocess safety, such as janitorial, food and drink, laundry, delivery, or other supply services.Employer ResponsibilitiesWhen selecting a contractor, the employer must obtain and evaluate information regarding thecontract employers safety performance and programs. The employer also must:• inform contract employers of the known potential fire, explosion, or toxic releasehazards related to the contractors work and the process;• explain to contract employers the applicable provisions of the emergency actionplan;• develop and implement safe work practices to control the presence, entrance, andexit of contract employers and contract employees in covered process areas;• evaluate periodically the performance of contract employers in fulfilling theirobligations; and• maintain a contract employee injury and illness log related to the contractors workin the process areas.
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 43 of 51Contract Employer ResponsibilitiesThe contract employer must:• ensure that contract employees are trained in the work practices necessary toperform their job safely;• ensure that contract employees are instructed in the known potential fire,explosion, or toxic release hazards related to their job and the process, and in theapplicable provisions of the emergency action plan;• document that each contract employee has received and understood the trainingrequired by the standard by preparing a record that contains the identity of thecontract employee, the date of training, and the means used to verify that theemployee understood the training;• ensure that each contract employee follows the safety rules of the facility includingthe required safe work practices required in the operating procedures section of thestandard; and• advise the employer of any unique hazards presented by the contract employerswork.Pre-Startup Safety ReviewIt is important that a safety review takes place before any highly hazardous chemical isintroduced into a process.PSM, therefore, requires the employer to perform a pre-startup safety review for new facilitiesand for modified facilities when the modification is significant enough to require a change inthe process safety information.Prior to the introduction of a highly hazardous chemical to a process, the pre-startup safetyreview must confirm that the following:• construction and equipment are in accordance with design specifications;• safety, operating, maintenance, and emergency procedures are in place and areadequate;• a process hazard analysis has been performed for new facilities andrecommendations have been resolved or implemented before startup, and modifiedfacilities meet the management of change requirements; and• training of each employee involved in operating a process has been completed.
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 44 of 51Module 7 QuizUse this quiz to self-check your understanding of the module content. You can also go onlineand take this quiz within the module. The online quiz provides the correct answer oncesubmitted.1. The PSM standard applies to contractors performing maintenance or repair,turnaround, major renovation, or specialty work ______________.a. on or adjacent to a covered processb. only when union contractors are involvedc. during the PHA phase of the constructiond. prior to the start of construction2. The PSM standard does not apply to contractors providing incidental services that____________.a. are on covered processesb. do not influence process safetyc. are approved prior to the start of workd. have attended a pre-job conference3. The PSM standard generally does not apply to any of the following services, EXCEPT:a. janitorial servicesb. delivery of food, drink or laundryc. other supply servicesd. maintenance on covered processes4. According to the text, ensuring that each contract employee follows the safety rules isthe responsibility of which of the following?a. safety managerb. contract employerc. host employerd. all employees
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 45 of 515. Prior to the introduction of a highly hazardous chemical to a process, the pre-startupsafety review must confirm which of the following?a. Construction and equipment conform to specificationsb. All procedures are in place and adequatec. A PHA has been performed for new facilitiesd. All of the above
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 46 of 51Module 8: Mechanical Integrity and Hot Work PermitMechanical IntegrityOSHA believes it is important to maintain the mechanical integrity of critical process equipmentto ensure it is designed and installed correctly and operates properly.PSM mechanical integrity requirements apply to the followingequipment:• pressure vessels and storage tanks;• piping systems (including piping components suchas valves);• relief and vent systems and devices;• emergency shutdown systems;• controls (including monitoring devices and sensors,alarms, and interlocks); and• pumps.The employer must establish and implement writtenprocedures to maintain the ongoing integrity of processequipment.TrainingEmployees involved in maintaining the ongoing integrity of process equipment must be trainedin an overview of that process and its hazards and trained in the procedures applicable to theemployees job tasks.InspectionInspection and testing must be performed on process equipment,using procedures that follow recognized and generally acceptedgood engineering practices. The frequency of inspections and testsof process equipment must conform to manufacturersrecommendations and good engineering practices, or morefrequently if determined to be necessary by prior operatingexperience.Each inspection and test on process equipment must bedocumented, identifying the date of the inspection or test, the
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 47 of 51name of the person who performed the inspection or test, the serial number or other identifierof the equipment on which the inspection or test was performed, a description of theinspection or test performed, and the results of the inspection or test.Correcting DeficienciesEquipment deficiencies outside the acceptable limits defined by the process safety informationmust be corrected before further use. In some cases, it may not be necessary that deficienciesbe corrected before further use, as long as deficiencies are corrected in a safe and timelymanner, when other necessary steps are taken to ensuresafe operation.New Construction and EquipmentIn constructing new plants and equipment, the employermust ensure that equipment as it is fabricated is suitable forthe process application for which it will be used. Appropriatechecks and inspections must be performed to ensure thatequipment is installed properly and is consistent with designspecifications and the manufacturers instructions.The employer also must ensure that maintenance materials,spare parts, and equipment are suitable for the process application for which they will be used.Hot Work PermitA permit must be issued for hot work operations conducted on or near a covered process. Thepermit must:• document that the fire prevention and protection requirements in OSHA regulations(1910.252(a)) have been implemented prior to beginning the hot work operations;• it must indicate the date(s) authorized for hot work; and• identify the object on which hot work is to be performed. The permit must be kepton file until completion of the hot work.
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 48 of 51Final words of PSM wisdom!Process Safety is a team effort. Know your role and work with your fellow employees to protectyourself and others.Know the hazards associated with mixing, separating, or storing process materials, including:• Which chemicals are reactive or able to cause a runaway reaction.• Toxic, fire, or explosive hazards associated with your process chemicals.• What to do during an incident or unusual process condition.Be aware of equipment operation and maintenance requirements, including:• Signs of corrosion, leakage, or other signs of equipment problems.• Who to alert when you see a problem.Know your process:• Follow operating, safety, and emergency procedures.• Keep up-to-date with changes to procedures,equipment, and chemicals.• Provide feedback – report all incidents and near misses.
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 49 of 51Module 8 QuizUse this quiz to self-check your understanding of the module content. You can also go onlineand take this quiz within the module. The online quiz provides the correct answer oncesubmitted.1. According to the text, PSM mechanical integrity requirements apply to all of thefollowing equipment, EXCEPT:a. Pressure vessels and storage tanksb. Relief and vent systems and devicesc. Mechanical startup systemsd. Pumps2. Employees involved in maintaining the ongoing integrity of process equipment mustbe trained in an overview of that process and its hazards and trained in theprocedures applicable to the employees job tasks.a. Trueb. False3. Equipment deficiencies outside the acceptable limits defined by the process safetyinformation must be corrected or tagged with “caution” signs.a. Trueb. False4. The employer also must ensure that all of the following are suitable for the processapplication for which they will be used, EXCEPT:a. spare partsb. maintenance materialsc. recognition plansd. equipment
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 50 of 515. A permit must be issued for hot work operations conducted on or near a coveredprocess. The permit must:a. document implementation of fire preventionb. indicate the date(s) hot work is authorizedc. identify the object on which hot work is performedd. All of the above
    • OSHAcademy Course 736 Study GuideCopyright © 2000-2013 Geigle Safety Group, Inc. Page 51 of 51Optional ExerciseScenario:Art and Ray were sent to the Tank Farm to replace bearings on an isopropanol pump located onthe alcohol pad. They found the bearings “frozen” in place. When Art told his supervisor theywould have to pull the pump, he said, “Let’s see if we can’t pull those bearings in place; we’vegot too much downtime in that area already.” First they tried to loosen the bearings with abearing heater, a powerful electric heat gun, without success. Ray then called a welder whoheated the casing with her torch until the bearings came free. While the welder was there, thesupervisor had her weld brackets on an I-beam so he could install a “Warning-Flammable Area”sign.A piece of slag from the welding rolled into a nearby pile of damp wooden shims. After themechanics and the welder left the area, the wood began to smolder and then burst into flames.At the same time an operator began to charge ethanol to his unit by remote computer control.The ethanol transfer pump started to leak around its mechanical seal creating a pool of alcoholon the pad. The vapors from the pool traveled towards the fire, which then ignited them.The fire spread instantly to the pump and grew in intensity as the heat increased the size of theleak. The tank farm operator saw the fire, sounded the alarm and attacked the fire with anextinguisher. She was overcome by vapors and fell unconscious. Quick response by the in-plant emergency response team saved her life and stopped a potentially disastrous fire.Task:In your groups, choose a scribe. Discuss the incident and, based on your experience, answerthe following questions.1. What could have been done to prevent this fire? List the factsheet(s) you used to backup your answer.2. Now, think about the hot work program in your plant, are there any changes orimprovements that should be made to improve the program? Please list and explain.