PSM for General Industry 111711


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PSM for General Industry 111711

  1. 1. The Webinar will begin shortly…The audio portion of the webinar will be throughyour computer speakers. While you are waiting forthe Webinar to begin at 10:00am, you mayexperience prolonged silence until it starts. © August Mack Environmental, Inc.
  2. 2. Process Safety Management for General Industry David Rice© August Mack Environmental, Inc.
  3. 3. PSM History• Bhopal, India (1994) – 2,000 deaths from isocynate release• Pasadena, TX (1989) – 23 deaths, 132 injuries from petroleum explosion• Cincinnati, OH (1990) – 2 deaths from explosion• Sterlington, LA (1991) – 8 deaths, 128 injuries from a chemical release © August Mack Environmental, Inc.
  4. 4. PSM Development• Promulgated by OSHA with the intent to prevent a Bhopal-like incident from happening.• Developed to prevent the release of a: – Toxic, – Reactive, – Flammable, or – Explosive chemical © August Mack Environmental, Inc.
  5. 5. PSM vs. RMP• PSM – Protects the workforce – Protects contractors – Protects visitors• RMP – Protects the community – Protects the general public – Protects adjacent facilities © August Mack Environmental, Inc.
  6. 6. PSM Standard• 29 CFR 1910.119 – Contains requirements for the management of hazards associated with processes using highly hazardous chemicals. – Contains requirements for preventing or minimizing the consequences of a catastrophic release of toxic, reactive, flammable, or explosive chemicals. © August Mack Environmental, Inc.
  7. 7. PSM Standard• 25 states, Puerto Rico, and the U.S. Virgin Islands have OSHA-approved State Plans and have adopted their own standards and enforcement policies. © August Mack Environmental, Inc.
  8. 8. Covered Facilities• Facilities who use chemicals listed in 29 CFR 1910.119 Appendix A (136 chemicals) and are above the threshold quantity.• Examples: – Anhydrous Ammonia – 10,000 lbs – Chlorine – 1,500 lbs © August Mack Environmental, Inc.
  9. 9. Covered Facilities• A process which involves a flammable liquid or gas on-site in one location, in a quantity of 10,000 lbs or greater. – OHSA interprets “on-site in one location” to mean that the standard applies when a threshold quantity of a HHC exists within an area under the control of an employer or group of employers. – Also applies to any group of vessels that are interconnected, or in separate vessels that are close enough in proximity that the HHC. © August Mack Environmental, Inc.
  10. 10. “On-site in one location” – OHSA interprets to mean that the standard applies when a threshold quantity of a HHC exists within an area under the control of an employer or group of employers. – Also applies to any group of vessels that are interconnected, or in separate vessels that are close enough in proximity that the HHC could be involved in a potential catastrophic release. © August Mack Environmental, Inc.
  11. 11. “On-site in one location” © August Mack Environmental, Inc.
  12. 12. Covered Industries• Industrial organics and inorganics• Paints• Pharmaceuticals• Adhesives• Sealants and fibers• Petrochemical facilities• Paper mills © August Mack Environmental, Inc.
  13. 13. Exclusions• A TQ of flammable liquids is stored in atmospheric tanks or transferred without the chilling or refrigeration.• Hydrocarbon fuels used solely for workplace consumption (propane for heaters; gas for vehicles). – Provided fuels are not a part of a process containing an additional HHC. © August Mack Environmental, Inc.
  14. 14. Applicable, Now What?• Create a PSM Team (legal requirement): – Engineers – Operators – EHS personnel – Maintenance – Management – Consultants © August Mack Environmental, Inc.
  15. 15. Applicable, Now What?• Create a Plan: – Responsibilities – Duties – Reporting – Document control – Progress reports – Tracking changes © August Mack Environmental, Inc.
  16. 16. 14 Elements of PSM• Process Safety Information • Mechanical Integrity (MI) (PSI) • Hot Work• Process Hazard Analysis (PHA) • Management of Change (MOC)• Operating Procedures • Incident Investigation• Employee Participation • Emergency Planning• Training • Compliance Audits• Contractors • Trade Secrets• Pre-startup Safety Review (PSSR) © August Mack Environmental, Inc.
  17. 17. Process Safety Information• Complete a compilation of written PSI, prior to conducting any PHA.• Helps to identify and understand the hazards posed by the process.• Includes: – Information on hazards associated with the process, – Information on technology of the process, and – Information on the equipment in the process. © August Mack Environmental, Inc.
  18. 18. Process Hazard Analysis• Thorough, orderly, systematic approach for identifying, evaluating, and controlling the hazards of the process.• Must conduct an initial PHA on all processes.• Must be appropriate to the complexity of the process.• Updated and revalidated, based on completion date, at least every 5 years. © August Mack Environmental, Inc.
  19. 19. Operating Procedures• Must develop and implement written operating procedures, consistent with the PSI.• Provides clear instructions for safely conducting activities involved in the covered process.• Includes: – Steps for each operating phase, – Operating limits, and – Safety and health considerations• Must be certified at least annually. © August Mack Environmental, Inc.
  20. 20. Employee Participation• Employers are to consult with the employees and their representatives regarding the development and implementation of a PSM program.• Required to train employees and inform them of the findings of an incident investigation, required by the PSM program.• Provide access to PHA and all other information developed under the PSM program. © August Mack Environmental, Inc.
  21. 21. Training• Initial – Each employee presently involved in a covered process or newly assigned must be trained in an overview of the process and its operating procedures. – Emphasis on specific safety and health hazards. – Employers may certify in writing that employees have the required knowledge, skills, and abilities to safely carry out duties specified in operating procedures. © August Mack Environmental, Inc.
  22. 22. Training• Refresher – At least every 3 years• Documentation – Employee name, – Date of training, and – How training comprehension was verified. © August Mack Environmental, Inc.
  23. 23. Contractors• PSM applies to contractors performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process. – Does not apply to incidental services that do not influence the process safety. © August Mack Environmental, Inc.
  24. 24. Contractors• Must obtain and evaluate contractor’s safety performance and programs.• Must inform contractors of the known potential hazards associated with their work and the process.• Explain applicable EAP information.• Develop and implement safe work practices.• Periodically evaluate contractor’s safety performance.• Maintain a contractor injury and illness log. – for work in the process area © August Mack Environmental, Inc.
  25. 25. Pre-startup Safety Review• Safety review must take place before the introduction of any HHC to a process.• Must conduct a PSSR for new facilities and modified facilities where the change is significant enough to require a change in the PSI. © August Mack Environmental, Inc.
  26. 26. Pre-startup Safety Review• Includes: – Construction and equipment; – Safety, operating, maintenance, and emergency procedures; – PHA; and, – Training. © August Mack Environmental, Inc.
  27. 27. Mechanical Integrity• Must establish and implement written procedures to maintain the ongoing integrity of the process equipment.• Inspection and testing using recognized and generally accepted good engineering practices. – Frequency must conform to manufacture’s recommendations and good engineering practices. – Inspections and testing must be documented. © August Mack Environmental, Inc.
  28. 28. Mechanical Integrity• Equipment deficiencies outside the acceptable limits, as defined by the PSI, must be corrected before further use.• New facilities, must make sure that equipment is fabricated so it is suitable for the process.• Must ensure that maintenance materials, spare parts, and equipment are suitable for the process. © August Mack Environmental, Inc.
  29. 29. Hot Work• Permit must be issued for hot work conducted on or near a covered process.• Must document that the fire prevention and protection requirements have been implemented prior to beginning hot work. © August Mack Environmental, Inc.
  30. 30. Management of Change• Written procedures to manage changes to process chemicals, technology, equipment, and procedures.• Employees involved in the process must be informed of and trained in the change prior to startup of the affected process (or part thereof).• If change requires a change to PSI, the PSI must be updated. © August Mack Environmental, Inc.
  31. 31. Incident Investigations• Must conduct an investigation of each incident that resulted in, or could have reasonably resulted in, a catastrophic release of a HHC.• Must be initiated as soon as possible, but no later than 48 hours after the incident.• Investigation must be conducted by a team: – Knowledgeable in the process, and – Knowledgeable and experienced in investigating and analyzing incidents. © August Mack Environmental, Inc.
  32. 32. Incident Investigations• Must establish a system to promptly address and resolve the incident report findings and recommendations.• Resolutions and corrective actions must be documented and reviewed by all affected personnel.• Incident investigations must be retained on file for 5 years. © August Mack Environmental, Inc.
  33. 33. Emergency Planning• An Emergency Action Plan must be developed and implemented for the entire facility if you are PSM applicable.• EAP must include procedures for handling small releases of hazardous chemicals. © August Mack Environmental, Inc.
  34. 34. Compliance Audits• Employers must certify that they have evaluated PSM compliance at least every 3 years.• Must be conducted by at least one person knowledgeable in the process.• Must conclude with a report of findings documenting any deficiencies, and any corrected deficiencies.• The 2 most recent compliance audits must be kept on file. © August Mack Environmental, Inc.
  35. 35. Trade Secrets• Employers must make available all information necessary to comply with PSM, without regard to possible trade secret status, to those responsible for: – Compiling PSI; – Developing PHAs; – Developing operating procedures; and, – Performing incident investigations, emergency planning and response, and compliance audits.• Confidentiality agreements can be required. © August Mack Environmental, Inc.
  36. 36. Overview• PSM applies to 136 specific toxic and reactive chemicals.• PSM applies to flammable liquids and gases in quantities over 10,000 lbs.• There are 14 elements of a PSM program. © August Mack Environmental, Inc.
  37. 37. Overview• PSM is a monster!• It is too big to tackle on your own, you must get a team to help you.• The health and safety of your personnel is dependant on having a solid and functioning PSM program in place. © August Mack Environmental, Inc.
  38. 38. Questions? Dave Rice Project Manager Nancy WadeCorporate Health & Safety Manager © August Mack Environmental, Inc.