process safety management process safety management.ppt

1
PROCESS SAFETY
MANAGEMENT
VS
RISK MANAGEMENT
An Overview
Tracy Estes, CSP
James E. Roughton, MS, CSP, CRSP, CHMM

2
Process Safety Management
 Required by the Environmental Protection Agency's (EPA)
Clean Air Act Amendments (CAAA),
Section 304
 Promulgated - February 24, 1992
 5 year implementation
 Proactive identification, evaluation, and mitigation or
prevention of chemical releases that could occur as a result
of failures in processes, procedures, or equipment
 130 highly hazardous chemicals (HHC’s)

3
Process Safety Management
(continued)
 10,000 lb. or more of flammable materials that are
used at or above their boiling points
 Pyrotechnics and explosives manufacturers
 More than 28,000 facilities affected
 Exemptions:
 fuels used for workplace consumption
 Comfort heating
 Gasoline for vehicles

4
Risk Management Plan
 Mandated by CAAA, Section 112 (r), 40 CFR
Part 68
 Promulgated - May 24, 1996
 Published Federal Register - June 20, 1996
 More than 100,000 facilities affected
 Designed to help reduce risk of accidental release of
hazardous substances
 3 years to implement

5
Risk Management Plan
(continued)
 Affects owners of a stationary source with regulated
substances above a threshold quantity (TQ):
 77 acutely toxic
 63 flammable
 Department of Transportation (DOT) classified explosive
substances

6
EPA’s Visions for Accidental
Release Prevention
 Emphasize community right-to-know
 Let information drive action
 Focus the program at the local level
 EPA support
 Coordinate communications at local level

7
Key Features of RMP
 Prevention program
 7-elements “mini-PSM” program
 14 elements OSHA-PSM program expanded to address offsite effects
 Emergency response program
 Risk management plan
 Electronic submission to state and LEPC
 Available to public
 Regulatory audits

8
Key Features
(continued)
 3 Program levels
 Management system
 Offsite consequence analysis
 Worst-case scenario
 Alternative release scenario
 5-year accident history

9
Key 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
Exemptions to Threshold
Quantity
 Articles
 Laboratories
 Uses:
 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
EPA’s Regulatory Approach
 Performance-based approach
 Similar to OSHA’s PSM
 Build on existing programs and standards
 Scale the requirements to fit the risk
 Coordinate with OSHA and DOT

12
Requirements 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
Requirements of 112(r)
(continued)
 Required EPA to promulgate a list of substances and set
thresholds
 Required EPA to develop a risk management program
(RMP) rule
 Register with EPA
 Conduct a hazard assessment
 Develop a prevention program
 Develop an emergency response program

14
Requirements of 112 (r)
(continued)
 Provide a summary (RMP) to
 EPA
 States
 Locals
 Public

15
Basic Principles
 Build on EPCRA
 Emphasize community right-to-know
 Focus the program at the local level
 Where the risk is found

16
Basic 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
Manufacturing Industries Affected
 Chemical manufacturers
 Industrial Organics & Inorganics
 Paints
 Pharmaceuticals
 Adhesives,
 Sealants
 Fibers

18
Manufacturing Industries Affected
(continued)
 Petrochemical Products
 Refineries
 Industrial Gases
 Plastics and Resins
 Synthetic Rubber

19
Non-Manufacturing Affected
(continued)
 Non-Manufacturing Facilities affected
 Utilities
» Electric and Gas
 Public Sources
» Drinking Water and Waste Water Treatment
 Agriculture
» Fertilizers, Pesticides

20
Other Manufacturing
 Electronics
 Semiconductors
 Paper
 Fabricated metals
 Industrial machinery
 Furniture
 Textiles

21
Other Industries
 Food and Cold Storage
 Propane Retail
 Warehousing
 Wholesalers
 Federal sources
 Military and Energy Installations

22
PSM vs. RMP Requirements
 PSM’s concern - potential hazard and protection of
employees inside a regulated area
 RMP’s concern - potential incidents that may cause
environmental and health hazards outside facility
boundaries
 Editorial changes to PSM to make text consistent
with the CAAA's language

23
Hazard Assessment
 Offsite consequence data
 Population estimate
 Public receptors
 Environmental receptors
 Every 5 years
 Within 6 months of a change that increases or
decreased distance by a factor of 2 or more

24
Overview Worst-Case Scenario
(WCS)
 Greatest quantity from vessel or piping
 May include administrative controls
 Toxic gases
 Quantity released in 10 minutes
 Toxic liquids
 Instantaneous spill to ground; volatilization; passive
mitigation
 Toxic gases liquefied by refrigeration

25
Worst-Case Scenario
(continued)
 All flammable substances
 Quantity for vapor cloud explosion
 One worst case for each process
 One worse case representing all toxic substances
 Additional worst case(s) different public receptors
 Other considerations
 Smaller quantities at higher temperature or pressure
 Source boundary proximity

26
Alternative Release Scenario
(ARS)
 More likely than a worst case scenario
 Much reach endpoint offsite
 One scenario representative of all flammables

27
ARS Selection
 Accident history events
 Process hazard analysis events
 Worse case with mitigation
 Example scenarios:
 Piping or hose failures
 Seal failures
 Vessel overfilling or venting

28
List of Substances and
Thresholds
 Focuses on lethal effects resulting from acute
exposures
 Includes mandated substances

29
Mandated Substances
 Ammonia
 Anhydrous Ammonia
 Anhydrous Hydrogen Chloride
 Anhydrous Sulfur Dioxide
 Bromine
 Chlorine
 Ethylene Oxide
 Hydrogen Cyanide
 Hydrogen Fluoride
 Hydrogen Sulfide
 Methyl Chloride
 Methyl Isocyanate
 Phosgene
 Sulfur Trioxide
 Toluene Diisocyanate
 Vinyl Chloride

30
Toxic Substances
 Extremely hazardous substances under SARA
 Gases and highly volatile liquids
 Vapor pressure > 10 mmHg
 Thresholds ranging from 500-2,000 lbs.
 Thresholds based on toxicity and volatility

31
Flammable Substances
 NFPA 4
 Most dangerous
 Flammable gases and volatile flammable liquids that
could create vapor cloud explosions
 Thresholds set at 10,000 lbs.

32
Threshold Quantity Determination
 Total quantity of a regulated substances contained in
a process at any one time
 Process included interconnected vessels or separate
vessels that could be involved in a release (OSHA
PSM definition)

33
Offsite Consequence Analysis
 Toxic endpoint
 Flammable endpoints
 Use appropriate models or guidance
 Within circle, identify
 Public receptors and population
 Environmental receptors

34
Registration and Submittal
 Submit a comprehensive RMP to:
 EPA
 State Emergency Response Commission (SERC)
 Local Emergency Planning Committee (LEPC)
 The Chemical Safety and Hazard Investigation Board

35
Registration and Submittal
(Continued)
 Name, mailing address, telephone of stationary
source
 CAS number of all regulated substances greater than
TQ
 SIC code
 Dun and Bradstreet number
 Certification signed by owner or operator

36
Auditing the Program
 Conduct audits of the management system

37
Program Eligibility Criteria
 Three Programs

38
Program 1 - No impact
 Register
 Conduct worst-case hazard assessments
 Certify no off-site consequences for worst-case
scenario
 Ensure inclusion in LEPC plan
 Submit RMP document above

39
Program 3 - Full RMP
 One comprehensive prevention program that:
 Protects workers
 The public
 The environment
 Hazard review information
 Hazards
 Controls
 Mitigation
 Changes

40
Program 3
(continued)
 Register
 Conduct worst-case and other hazard assessments
 Implement comprehensive prevention steps (OSHA
PSM plus...)
 Develop emergency response plan
 Submit RMP

41
Program 3
(continued)
 Process is subject to OSHA's PSM
 Processes 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
Program 2 - Streamlined
Prevention Program
 The process is not eligible for Program 1 or 3

43
Program 2
(continued)
 Statutory requirements
 Training
 Maintenance
 Safety Precautions
 Monitoring

44
Program 2
(continued)
 Types of sources:
 Less complex; fewer changes
 Ideal model program and plans
 Capture good management practices from PSM but
less documentation
 Take advantages of other rules and standards
 Take advantages of equipment manufacturer or vendor
information

45
Program 2
(continued)
 Process information (SIC, chemicals)
 List rules, standards, design codes
 Hazard review information
 Hazards
 Controls
 Mitigation
 Changes

46
Program 2
(continued)
 Register
 Conduct worst-case and other hazard assessments
 Implement seven elements of prevention program
 Develop emergency response plan
 Submit RMP

47
Comparison of Program
Requirements
Hazard Assessment
Program 1 Program 2 Program 3
Worst-case analysis Worst-case analysis Worst-case analysis
Alternative releases Alternative releases
5-year accident history 5-year accident history 5-year accident history

48
Comparison
(continued)
Management Program Document
Management System Management System

49
Comparison
(continued)
Prevention Program
Certify no additional Safety Information Process Safety Information
steps Required Hazard Review Process Hazard Review
Operating Procedures Operating Procedures
Training Training
Maintenance Mechanical Integrity
Incident Investigation Incident Investigation

50
Comparison
(continued)
Prevention Program (continued)
Compliance Audit Compliance Audit
Management of Change
Pre-Startup Review
Contractors
Employee Participation
Hot Work Permits

51
Comparison
(continued)
Emergency Response Program
Coordinate with Local Develop Plan Develop Plan
Responders and Program and Program

52
Comparison
(continued)
Risk Management Plan Content
Executive Summary Executive Summary Executive Summary
Registration Registration Registration
Worst-Case Data Worst-Case Data Worst-Case Data
5-Year Accident History Alternative Release Data Alternative Release Data
Certification. 5-Year Accident History 5-Year Accident History

53
Comparison
(continued)
Risk Management Plan Content (continued)
Prevention Program Data Prevention Program Data
Emergency Response Data Emergency Response Data
Certification Certification

54
OSHA PSM Requirements EPA Program 3 Requirements
An evaluation of the consequences An evaluation of the consequences
of deviations, including those of deviations
affecting the safety and health
of employees
The identification of any previous The identification of any previous
incident which had a likely potential incident which had a likely potential
for catastrophic consequences in for catastrophic consequences
the workplace
Editorial Changes
(continued)

55
Editorial Changes
(continued)
OSHA PSM Requirements EPA Program 3
Requirements
A qualitative evaluation of a range A qualitative evaluation of a range
of possible safety and health effects of possible safety and health
of failure of controls on employees effects of failure of controls
in the workplace
The employer shall investigate each The owner or operator shall
incident which resulted in, or could investigate each incident which
reasonably have resulted in a catastrophic resulted in, or could reasonably
release of a highly hazardous chemical have resulted in a catastrophic
in the workplace release of a regulated substance

56
Language Comparison
OSHA’s - PSM EPA’s - RMP
Employer Owner or Operator
Highly Hazardous Chemicals Regulated Substances
Facility Stationary Source
Standard Rule
Workplace Impact Off-Site Consequences

57
Compliance Procedures
 Develop an inventory of substances used, stored,
manufactured, processed, handled or moved, or any
combination of the listed activities
 Compare the inventory with the TQ, as required

58
Management System
 Develop a management system to oversee the
implementation of the RMP elements
 Identify single person or position who has overall
responsibility for:
 Development
 Implementation
 Integration of the RMP

60
Process Safety Information
 Block flow or process flow diagrams
 Maximum intended inventory
 Establish safe limits of the operating parameters

61
Process Safety Information
(continued)
 Evaluate consequences in deviations of process
conditions
 Equipment information
 Verify equipment design with regulatory
requirements/standard

62
Process Hazard Analysis
 Document hazard analysis:
 Nature of the hazard
 Cause of the hazard
 Consequences of the hazard
 Actions to be considered to further protect personnel
 Document follow-up steps based on
recommendations

63
Process Hazard Analysis
(continued)
 Document previous incidents with the potential to
cause catastrophic conditions
 Document hazards associated with human factors
and facility siting

64
Operating Procedures
 Develop clear operating procedures addressing steps
for each process regarding
 Safe operating limits of processes
 Equipment
 Provide precautionary instructions to prevent
exposure to hazards

65
Operating Procedures
(continued)
 Develop operating procedures for safety systems
 Conduct annual review of operating procedures
 Develop procedures for lockout/tagout, confined
space entry, etc.

66
Employee Training
 Document training for personnel in the process,
operating procedures, and safe work practices
applicable to the job tasks
 Maintain records of training indicating the means
used to verify that the employee understood the
training

67
Maintenance
(Mechanical Integrity)
 Provide written procedures to maintain the structural
integrity of process equipment
 Document training for employees involved in
maintenance of the process equipment
 Verify inspections and testing of equipment and
deficiencies are corrected
 Document that spare parts are suitable for the
appropriate application

68
Incident Investigation
(Accident Investigation)
 Incident reporting:
 The date of the incident
 Date of the investigation
 Description of the incident
 Factors contributing to the incident, and recommendations that
resulted
 Verify that the recommendations in the incident report
were promptly addressed and resolved
 Identify root causes as well as initiating events

69
Compliance Audits
 Evaluate compliance with program every three years
 Conduct with at least one person knowledgeable in
process
 Develop report of findings Determine/develop a
response to each finding, document that deficiencies
have been corrected
 Retain two most recent audit reports

70
Management of Change
 Provide written procedures to manage change to
process chemicals, technology, equipment, and
procedures, and changes to facilities that affect a
covered process
 Verify that employees in operations and maintenance
are trained accordingly
 Provide evidence that changes are documented

71
Pre-Startup Review
 Document that construction and equipment is in
accordance with design specifications
 Review documentation showing that safety,
operating, maintenance, and emergency procedures
are in place and adequate
 Document that a PHA was performed, and
recommendations were resolved and implemented

72
Pre-Startup Review
(continued)
 Verify that modified facilities meet requirements in
Management of Change procedures
 Verify that employee training is completed

73
Contractors
 Must established a screening process when hiring
and use contractors
 A site injury and illness log for contractors must be
maintained
 The contractor must ensure that each contract
employee is trained in the work practices necessary
to safely perform his/her job

74
 Must develop a written plan of action regarding the
implementation of employee participation.
 Required to train and educate employees and to
inform all affected employees of the findings from
any incident investigations.

75
(continued)
 Must consult with employees and employee
representatives:
 Development of PHA and other elements
 Hazard assessments
 The development of chemical accident prevention
 Must provide access to these records.

76
Permit Systems
 A work authorization notice or permit system should be
developed
 To describe the steps the maintenance supervisor, contractor
representative or other person need to follow in order 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
Permit Systems
(continued)
 Procedures must provide clear steps to follow once
the job is completed to provide closure for those that
need to know the job is completed and equipment
can be returned to normal operations.

78
Emergency Planning and
Response
 Document that an emergency plan has been established and
implemented in accordance with 29 CFR 1910.38 and
1910.120, as applicable
 Emergency action plan that include procedures for handling
releases
 Document specific actions to be taken in response to an
accidental release of a regulated substance to protect humans
and the environment
 Conduct drills
 Exercise to test plan

79
Emergency Response Plan -
Basic Requirements
 Emergency response plan
 Procedures for use of emergency response equipment
and for it inspection, testing, and maintenance
 Training for all employees in relevant procedures
 Procedures to review and update of the plan to reflect
changes at the facility and ensure that employees are
informed of changes

80
Elements - Legislative
Requirements
 Procedures for informing the public and local emergency
response agencies
 Documentation of proper first-aid and emergency medical
treatment necessary to treat accidental human exposures
 Procedures and measures for emergency response after a
release
 Written plan must comply with other federal regulations
 Coordinate with local LEPC

81
Planning Option - One-Plan Guidance
for Integrated Contingency Plan (ICP)
 Intended to:
 Provide a mechanism for consolidating multiple facility
response plans
 Improve coordination of response activities
 Minimize duplication and simplify plan development and
maintenance
 Ensure regulatory compliance with all relevant federal
requirements

82
Communicating RMP to Public

83
Communication
 Rule does not specify
 How communication should take place
 When it should take place
 How much risk communication
 Anyone putting public at risk must show how risk is
addressed/prevented and responded to

84
Regulatory Approach
 Industry tells government and the public how it will
address risk for preventing major accidents
 Government and public can review what industry has
presented
 Government and community can respond to industry,
communicate concerns, and make recommendation

85
Communicating the RMP
 Start now
 Explain the program
 Tell the public what to expect with your WCS and when to expect
it
 Explain your WCS
 Detail chemical(s) on site that can cause explosions,
environmental impacts, etc.
 Explain why you can’t reduce your inventory of regulated
substances

86
Community Outreach
Suggestions
 Open house/plant tours
 Local citizen groups/civic organization
 High school programs
 Community survey
 What does the community think about you?
 Neighborhood meetings
 Plant newsletter
 Community advisory panels

87
Audience
 Neighbors
 Implementing agencies
 LEPC
 Emergency responders
 City and county officials

88
Audience
(continued)
 Business and community leaders
 Educators
 Local media
 State legislators

89
Other Programs
 Risk communications training
 Training on handling the with media
 Informing industrial neighbors

90
Summary - Developing an RMP
Implementation Plan

91
Implementation Strategy -
Technical
 Acquire/understand regulatory information
 Determine coverage
 Determine technical capabilities/needs
 Prepare RMP implementation plan

92
Technical (continued)
 Perform program level screening
 Develop hazard assessment protocol
 Perform hazard assessment
 Compile 5-year accident history

93
Technical (continued)
 Implement/upgrade PSM program to consider offsite
effects
 Review/upgrade emergency response activities and
plan
 Prepare and submit the RMP

94
Communication
 Determine internal risk communication
capabilities/needs
 Survey community outreach status
 Establish/improve community outreach
 Prepare communication plan
 Improve internal risk communication capabilities
 Communicate the RMP to the public

95
Available Resources
 Chemical Emergency Preparedness and Prevention
Office (CEPPO)
 Internet - (http://www.epa.gov/swercepp/acc-pre.html)

96
Suggested Team Members
 Health and safety Professionals
 Program development and review
 Chemical, electrical, and mechanical engineering
 Process safety information and hazard analysis
development
 Air Quality Specialist/Industrial Hygienist
 Air modeling dispersion.
 Identify acute health effects

97
Suggested Team Members
(continued)
 Risk Assessment Specialist
 Population exposure and environmental effects
 Communications Specialists
 Communicating with the public

98
Summary - Final Word
 PSM and RMP outlines requirements for facilities to
reduce risks associated with accidental releases
 A good communications program will help reduce
misinformation, distrust, and build good community
relations
 Reduction in inventory will result in a reduction of
the risk and potential for a catastrophic incident

99
Summary - Final Word
(continued)
 Audits are to be comprehensive, involving
systematic assessment of all elements of the program

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