Improper management of highly hazardous chemicals, including toxic, reactive or flammable liquids, can cause accidental releases and emergency responses. OSHA’s Process Safety Management of Highly Hazardous Chemicals standard (29 CFR 1910.119) regulates the management of highly hazardous chemicals. Violations can carry fines of up to $126,000. Do you have a PSM program in place?

1. Process Safety
Management
Triumvirate Environmental Presents

2. Meet Your Moderator:
James Ciccone

3. During this Webinar
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 There will be a Q&A session at the end of the
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throughout the webinar.
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4. Meet Your Presenter
Rick Foote

5. OSHA Has
Been Busy
• Since 2010 OSHA has issued more
than 69 enforcement cases
regarding PSM
• A recent fine was just issued for
$264,000
• A new National Emphasis Program
was issued in January 2017

6. Why Did OSHA
Develop PSM?
Past disasters
Current disasters
Perceived weakness and lack of
understanding of PSM program

7. Why Did OSHA
Develop PSM?
Bhopal, India (1984)
 2,000 deaths,
Isocyanate release
Pasadena, TX (1989)
 23 deaths, 132
injuries, Petroleum
explosion
Cincinnati, OH (1990)
 2 deaths,
Explosion
Sterlington, LA (1991)
 8 deaths, 128
injuries, Chemical
release

8. Why Did OSHA
Develop PSM?
In 1991, OSHA and EPA
released both the Process Safety
Management and the Risk
Management Program

9. Why Did OSHA
Develop PSM?
• PSM is a regulation that is intended to
prevent an incident like the 1984
Bhopal disaster
• And…to prevent release of:
 Toxic,
 Reactive,
 Flammable, or
 Explosive
chemicals

10. What is Required in
a Process Safety
Management
Program?

11. Elements of the Standard
• Application
• Exclusions
• Definitions
• Employee Participation
• Hazards of the Process
• Toxicity
• Technology of the Process
• Equipment in the Process
• Mechanical Integrity
• Inspection & Testing
• Quality Assurance
• Process Hazard Analysis
• Management of Change
• Operating Procedures
• Safe Work Practices
• Training
• Contractor Management
• Emergency Planning & Response
• Incident Investigation
• Compliance Audits
• Trade Secrets

12. 1910.119(a)
Application

13. What Facilities are Covered?
• Companies that use chemicals found in Appendix A
of the standard
• The Appendix contains a listing of toxic and reactive
highly hazardous chemicals which present a potential
for a catastrophic event at or above the threshold
quantity

14. Appendix A
Some example chemicals include:
• Anhydrous Ammonia – 10,000
pounds
• Chlorine – 1,500 pounds
• Hydrogen Fluoride – 1,000
pounds
• Important to check and verify
the CAS #

15. What Facilities are Covered?
• Important Interpretation: 2007 - 06/11/2007 - OSHA defines "on-site in
one location" for Process Safety Management of Highly Hazardous
Chemicals standard
• OSHA interprets "on-site in one location" to mean that the standard
applies when a threshold quantity of a highly hazardous chemical (HHC)
exists within an area under the control of an employer or group of affiliated
employers. It 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.

16. What Types of Industries?
Industries that process chemicals such as:
• Industrial organics & inorganics
• Paints
• Pharmaceuticals
• Adhesives
• Sealants and fibers
• Petrochemical facilities
• Paper mills
• Food processing with Anhydrous
Ammonia over the TQ

17. 1910.119(a)(1)(ii)(A)
Exclusions

18. What are some Exclusions?
A company is exempt from the requirements of PSM when:
• A threshold quantity of flammable liquids is stored in
atmospheric tanks or transferred without the benefit of
chilling or refrigeration
• Hydrocarbon fuels used solely for workplace consumption
as a fuel (e.g., propane used for comfort heating, gasoline
for vehicle refueling),
• If such fuels are not a part of a process containing another
highly hazardous chemical covered by this standard

19. 1910.119(c)
Employee
Participation

20. So Now You are
in PSM?
Form a committee, with members such as:
• Process engineers
• Operators
• Safety
• Maintenance
• Management
• Consultants

21. • Responsibilities of
members
• Duties of members
• Reporting
So Now You are
in PSM?
• Document control
• Progress reports
• Tracking changes
Develop a written plan that details:

22. Conduct a Hazard
Assessment
Determine:
• Chemicals in your process
• Process chemistry
• Quantity of chemicals in pounds
• Compare to Appendix A List with
Threshold Quantities (TQ’s)

23. 1910.119(d)(1)(i)
Toxicity
Information

24. Need to Collect
Toxicity Information
Standard requires the facility to determine the
toxicity of each of the regulated materials.
Some sources to help with this include:
Safety Data Sheets
NIOSH Pocket Guide
ACGIH
Other web resources

25. What Toxicity Information
Do I Need to Collect?
• Permissible Exposure
Limits
• Physical Data
• Reactivity Data
• Corrosivity Data
• Thermal and chemical
stability data
• Hazardous effects of
inadvertent mixing of
different materials that
could foreseeably occur

26. 1910.119(d)(2)
Process
Technology

27. Facility Needs
to Develop
• Block flow diagram or process
flow diagram
• Process chemistry
• Maximum intended inventory
• Upper and lower limits
• Consequences of deviations

28. 1910.119(d)(3)
Equipment in
Process

29. Facility Needs
to Review:
• Materials of
construction
• Process and instrument
drawings (P&ID’s)
• Electrical classification
• Relief system design
• Ventilation
system design
• Design codes
• Material and
energy balances
• Safety systems

30. 1910.119(j)
Mechanical
Integrity

31. Applies to
the Following:
• Pressure vessels and storage tanks
• Piping systems (including piping
components such as valves)
• Relief and vent systems and devices
• Emergency shutdown systems
• Controls (including monitoring devices
and sensors, alarms, and interlocks)
• Pumps

32. What Do You
Have to Do?
• The facility must establish and implement
written procedures to maintain the ongoing
integrity of process equipment
• Train employees involved in maintaining the
on-going integrity of process equipment
• Conduct inspections and test on equipment
• Document all of the above

33. 1910.119(e)
Process Hazard
Analysis (PHA)

34. The Hardest Part
• The facility must perform an initial process hazard analysis
(hazard evaluation) on processes covered by this standard.
• The process hazard analysis shall be appropriate to the
complexity of the process and shall identify, evaluate, and control
the hazards involved in the process.
• Employers shall determine and document the priority order for
conducting process hazard analyses based on a rationale which
includes such considerations as extent of the process hazards,
number of potentially affected employees, age of the process, and
operating history of the process.

35. Facilities must determine and document the
priority order for conducting process hazard
analyses based on a rationale which
includes such considerations as:
• Extent of the process hazards
• Number of potentially affected employees
• Age of the process
• Operating history of the process
The Hardest Part

36. How Do You Do This?
The facility must use one or more
of the following:
• What-if scenarios
• Develop a checklist
• What if/checklist
• Hazard and Operability Study (HAZOP)
• Failure Mode and Effects Analysis
(FMEA)
• An appropriate equivalent methodology

37. Wait, There’s
More?
• Inspection & Testing
• Quality Assurance
• Management of
Change
• Operating Procedures
• Safe Work Practices
• Training
• Contractor Management
• Emergency Planning &
Response
• Incident Investigation
• Compliance Audits
• Trade Secrets

38. Management of Change
• Procedures to manage changes to
the covered process
 Exception: “replacement in kind”
• Management of Change includes:
 Process chemicals
 Technology
 Equipment
 Operating procedures
 Facilities

39. Management of
Change Addresses:
1. Technical basis of the change
2. Impact to employee safety
and health
3. Modification to operating
procedures
4. Time period for change
5. Authorization of change

40. Operating Procedures
• Develop and implement written
operating procedures that are clear
instructions for all expected
phases of operations
• AKA – Standard Operating
Procedures (SOPs)
• Must cover:
 Operation phase
 Operational limits
 Safety & health considerations

41. OPs Must Address:
• Initial start-up
• Normal operations
• Temporary operations
• Emergency shutdown
• Emergency operations
• Normal shutdown
• Start-up following turnaround
• Consequences of deviation
• Steps required to correct or
avoid deviation

42. SOPs:
• Must be readily available to employees
• Must be reviewed as needed to ensure
they reflect current operating practice
• Must cover:
 Process chemicals
 Technology and equipment
 Facilities
• SOPs must be certified annually that
they are correct and accurate

43. Safe Work
Practices (SWPs)
Must be developed and implemented
to provide for the control of hazards
during work activities such as:
 Lock-out/Tag-out
 Confined space entry
 Opening processes, piping or
equipment

44. Training
• PSM specific training is required
• Must cover:
 Safety and health hazards associated
with the covered process
 Safe work practices
• Refresher training is required every 3
years or as needed to ensure
employees are complying with all
PSM requirements

45. Contractors
• Contractors involved in or around a covered
process must be informed of required PSM
elements
• Contract work includes:
 Maintenance and repair
 Turn around
 Major renovations
 Specialty knowledge or services
 Does not include support services not involved
with the covered process, like laundry or
vending machine supply

46. Emergency Action
Plans (EAP)
• Must have EAP for entire facility
• EAP must have provisions for small
releases of HHCs
• Develop an early warning method for
releases
• Train on the meaning of the alarms
• Develop emergency evacuation written
plans, evacuation maps & assembly points

47. Incident
Investigations
• Must be initiated ASAP, but within
48 hours
• Team must include:
 Person knowledgeable in the process
involved
 Includes contractor if work of the contractor
involved
 Other persons with appropriate knowledge
of the covered process

48. Incident
Investigation
Report
Report must be produced with the
following:
 Date of incident
 Date of start of investigation
 Description of incident
 Factors contributing to incident
 Recommendations

49. Incident Investigation
Report
• System must be established to
promptly address recommendations
and findings of report
• Resolutions and corrective action
must be documented

50. Trade Secrets
• Employers must make all necessary information required to
comply with PSM, regardless of trade secrets, available to
persons involved in developing or creating:
 Compiling process safety information
 PHAs
 SOPs
 Incident investigations
 Emergency planning and response
 Compliance audits
• Confidentiality agreements are allowed

51. Compliance Audit
• To ensure that PSM is effective, employers must certify
every 3 years that they have evaluated compliance
with the standard
• Must be completed by at least one person
knowledgeable in the process
• Report must be developed and documented
• Deficiency corrections must be documented
• Last two compliance audits must be kept on file

52. Tools for Additional
PSM Assistance
• PSM Checklist
 www.oshainfo.gatech.edu
• OSHA Website
 www.osha.gov
• Chemical Safety Board Website
 www.csb.gov

53. QUESTIONS?

54. Thank You For Attending!
Request a Free
Compliance Audit:
http://info.triumvirate.com/osha-compliance-review-webinar
Rick Foote:
rfoote@triumvirate.com
Director of Industrial Practice
Triumvirate Environmental
Call Us!
1-888-834-9697
www.triumvirate.com