Process Safety Training

OSHA 29 CRF 1910.119 Process Safety Management (PSM)

PSM Background
> A number of catastrophic accidents have occurred resulting in
loss of life and significant property damage.
– Union Carbide: Bhopal, India (Dec 1984)
– Chernobyl: Ukraine (April 1986)
– Piper Alpha: North Sea (July 1988)
– Phillips Chemical: Pasadena, TX (Oct 1989)
– BP: Texas City, TX (Mar 2005)
– Patridge-Raleigh: MS (June 2006)
– Deepwater Horizon: TX (April 2010)
– West Fertilizer: West, TX (April 2013)

BP’s Texas City Refinery Disaster – 10 min

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Personal Safety vs Process Safety
What is the difference?

Personal Safety Process Safety

> Focus on preventing personal > A systematic approach to manage

injuries the hazardous process to prevent
> Measured using: OSHA recordable, potential release
lost time accidents, MVA, etc > Look at entire process – material,
> Incident Probability: High equipment, systems
> Incident Severity: Low > Measured using all systems function
> Incident Probability: Low
> Incident Severity: High

Personal safety hazards vs process safety hazards video – 3 min

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Process Safety

> ‘Process Safety’ involves the prevention of leaks, equipment

malfunctions, over pressure, corrosion, metal fatigue, etc.
> Know your process – both physically and in terms of information
about the process
> Embodies training and communicating process hazards to all
affected employees and contractors
> Analyze the process to understand process (process hazards)

> Maintain the equipment

> Manage and communicate over the life of the process

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Scope and Application

> PSM regulation provides requirements for preventing or

minimizing consequences of a catastrophic release of chemicals
that are:
– Toxic
– Reactive
– Flammable or
– Explosion

> Any group of vessels which are interconnected, and

> Separate vessels which are located such that a highly

hazardous chemical could be involved in a potential release

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Scope and Application

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Exemptions to the regulation

> PSM does not apply to:

– Retail Facilities
– Oil or gas well drilling or servicing
– Normally unoccupied remote facilities*
– Hydrocarbon fuels used solely for workplace
consumption
– Any flammable liquid stored in atmospheric
tanks or transferred which are kept below
normal boiling point without benefit of chilling or
refrigeration
* Normally Unoccupied Remote Facility is a facility normally averaging a total of less than 14.5 man-hours per week – including both
employees and contractors; geographically separated from other facilities and employees such that employees at other facilities would not
be affected by an explosion, vapor cloud of toxic gas, or other consequences of an uncontrolled release at this normally unoccupied remote
facility.

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PSM Implementation

> PSM goal is protection of personnel

> PSM is not a program with definitive completion point

> PSM is a continuous management system

– Senior Management direction and support
– Mid Management commitment
– Front line implementation

> Compliance is a moving target

– Gather data, train, implement, monitor change, communication,
evaluation, procedures, take corrective action, etc

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The Elements of PSM
OSHA 29 CRF 1910.119

1) Employee Participation 8) Mechanical Integrity

2) Process Safety Information 9) Hot Work Permit
3) Process Hazard Analysis 10) Management of Change
4) Operating Procedures 11) Incident Investigation
5) Training 12) Emergency Planning and
6) Contractors Response
7) Pre-Safety Start Up Review 13) Compliance Audits
14) Trade Secrets

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 Element 1

Employee Participation
Element 1

Employee participation means: Ways to participate:

> Provide Input on process > PID review/verify

> Consult with employees on process > SDS
> Data available to employee > Operating Procedures
> Training > PSSR
> Monitor and evaluate contractors
> Work Permits
> Management of change
> Emergency planning/drills
> Process hazard analysis
> MI: preventive maintenance,
corrosion

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 Element 2

Process Safety Information (PSI)

Element 2

Hazards of the process Equipment in the process

> Safety Data Sheets (SDS) > Piping and instrument diagrams (PID)
> Hazardous effect of inadvertent mixing > Electrical Classification
> Relief Systems/OPP
> Ventilation system design
> Material of Construction
> Material and energy balance
Technology of the process
> Safety Systems (shut downs, interlocks)
> Process Flow Diagram > Plot Plan
> Process Chemistry > Design Codes and Standards
> Maximum Intended Inventory
> Safety Upper and lower operating limits
> Consequences of Deviation

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 Element 3

Process Hazard Analysis (PHA)

Element 3

Purpose of a PHA: Required PHA team:

> Purpose: PHA is in-depth review of > Engineering: Company Engineer II

the process to identify it’s current or higher
level or risk to evaluate potential > Operations: Company Operations
hazards and implement controls Technician III or higher
within the process
> Process: Company employee
> Goal: Recommendations for hazard expertise in process
mitigation
> Facilitator: knowledgeable of
> Methods: HazOP, What-If, FMEA, methodology
Fault Tree, Checklist
> Additional Members:
– I&E
– Maintenance
– Equipment Supplier
– Operational Safety

West Texas Explosion – 2 min

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Process Hazard Analysis (PHA) cont

> Engineer and administrative controls applicable to the hazards

such as detection of early warning of releases
> Human Factors

> Facility Siting Study

> The identification of any previous incident which had a likely

potential for catastrophic consequences in the workplace.
> Documentation and timely resolution of PHA recommendations

> PHA must be updated and revalidated at least every 5 years and
file for the life of the process

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Process Hazard Analysis (PHA) Cont
Project engineer or coordinator is responsible for coordinating
preparation up-to-date PSI required to conduct PHA:

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Operating Procedures
Element 4

> Develop and implement written operating procedures consistent

with process safety information for:
– Initial start-up and normal start-up
– Normal operations, emergency operations, and transition between
– Normal and emergency shut-down
– Temporary operations
– Operating limits and consequences of deviation
– Hazards presented by the process
– Include safe work practices
• LOTO, confined space, control over entrance to facility, etc

CSB Deadly Practices Video – 15 min.

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Operator Procedures Cont

> Must be current and accurate

> Annual review

– Establish a document control system to manage and track changes

> Must be readily accessible to employees

> Verify competency

– Observe, test, or both: see training

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 Element 5

Training
Element 5
> Emphasis on the specific safety and health hazards of the process

> Emphasis on procedures including:

– Operating
– Preventative Maintenance
– Emergency Shut-down
– Safe work practices applicable to employee’s job task

> Refresher training at least every three years and provide input on the type and
frequency of supplemental training

> Prepare a record which contains:

– The identity of the employee
– The date of training
– The means used to verify that employee understood the training (written, verbal, and
observation)

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Contractors
Element 6

> Applies to contractors performing maintenance or repair,

turnaround, major renovation, or specialty work on or adjacent to
a covered process
> Inform contract employees of known hazards related to work

> Obtain and evaluate information regarding safety performance

Does not apply to contractors providing incidental services which do not influence process safety, such as janitorial work, food
and drink services.

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Pre-Safety Start Up Review (PSSR)
Element 7

> Immediately prior to introduction of high hazardous chemicals, a

review must be performed for a new and modified facilities that
require a chance in the PSM information confirming:
– Construction and equipment is in accordance with design
specifications
– Safety, Operating, Maintenance, and Emergency procedures are in
place and are adequate
– No unintended hazards are introduced
– Affected employees are trained

> All PHA recommendations are resolved prior to PSSR

> Modified facilities must meet MOC requirements.

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 Element 8

Mechanical Integrity (MI)

Element 8

> Establish and implement written procedures to maintain the on-

going integrity of process equipment
– Critical Equipment List
– Inspection and tests must be performed within
• Recognized and Generally Accepted Good Engineering Practices
• Manufacturers’ recommendations
• Prior operating experience
– Fit for service

> Train employee overview to ensure safely perform tasks

> Correct deficiencies if equipment is outside acceptable limits to

assure safe operation

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Hot Work Permit
Element 9

> Must issue a hot work permit for hot work operations
conducted on or near a covered process
> Permit must document:
– Fire prevention requirements have been
implemented before starting the hot work;
– The date(s) authorized for hot work; and,
– Object identity on which hot work is to be
performed.
> Permit must be kept on file until at least the completion
of the hot work

Hidden Hot Work Hazards – 11 min

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Management of Change (MOC)
Element 10

> Replacement in Kind

> Implement written procedures to manage changes to process

chemicals, technology, equipment, procedures, and facilities that
affect a covered process
– Emergency MOC
– Temporary MOC
– By-passing safety device greater than 24 hours

CSB MOC Bulletin

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Management of Change (MOC) cont

> Prior to startup, train and provide information to employees and

contractors involved in operating or maintaining a process and
whose job tasks will be affected by a change

> Update PSM information and conduct a pre-startup safety

review (PSSR) if a change affects previously documented
PSM information, operating procedures, or practices

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Incident Investigation
Element 11

> Each incident that resulted in, or could

reasonably have resulted in, a catastrophic
release of a highly hazardous chemical in the
workplace must be investigated
> The investigation must be initiated no later
than 48 hours following the incident
> An incident investigation team that consists of
persons knowledgeable in the incident
process must be established and the team
must thoroughly investigate and analyze the
incident

Deepwater Horizon – 11 min

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Incident Investigation (cont)

> A report must be prepared at the conclusion of the investigation:

> The report must contain at a minimum the following: date

of incident, date investigation began, description of the
incident, factors that contributed to the incident and
recommendations resulting from the investigation.
> A system must be developed to promptly address, resolve and
document the incident report findings, recommendations and
corrective actions.
> The incident report must be made available to affective
employees, contractors and retained for at least 5 years

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Emergency Planning and Response
Element 12

> Emergency Action Plan must be developed to ensure the safe

evacuation of employees
> Plan must address the means and methods necessary to protect
employees responding to an uncontrolled release of a process
chemical
> 29 CFR 1910.38 (Emergency Action Plan)

> 29 CFR 1910.120 (a), (p), (q) (Hazardous waste operations and
emergency response)

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Compliance Audits
Element 13

> The adequacy of procedures and practices must be evaluated

and certified at least every three years
> The compliance audit must be conducted by at least one person
knowledgeable in the process
> A report of audit findings must be developed

> Appropriate response and any corrective action for each audit
findings must be documented
> The two most recent compliance audit reports must be retained

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Trade Secrets
Element 14

> Trade secret information must be made available to persons

responsible for:
– Compiling the process safety information;
– Developing process hazard analysis, operating procedures and emergency
planning and response; and
– Conducting incident investigations and compliance audits.

> Confidentiality agreements are permitted

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OSHA

> 2009: National Emphasis Program on Petroleum Refinery

> 2011: National Emphasis Program Chemical Facilities

> 2013: President Obama Executive Order Improving Chemical

Facility Safety and Security (results of the NEP, incidents)
> 2013/2014: OSHA request for Information/Comment Process
Safety Management Enforcement/Policy update
> 2014: Chemical Safety Board (CSB) comments to potential
revisions
> Present: No changes made (anticipate summer 2016 due to EPA
Rule Changes)

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Proposed Enforcement Changes
> Clarifying exemption to atmospheric > Emergency Planning with local
storage tanks response authorities
> Oil and Gas Well Drilling and > Compliance Audit to third party
Servicing > Add dismantling and disposal of
> Oil and Gas Production Facilities explosives, blasting agents,
> Expanding Coverage pyrotechnics
> Updating list Highly Hazardous > Updating 1910.106 and 1910.107 on
Chemicals Appendix applicable consensus
(Flammable/Combustible materials)
> Require additional management
system elements
> Applicable RAGAGEP > RMP: PHA, Emergency
Preparedness, Public Availability of
> Safety Critical Equipment information, data submitted on RMP
> MOC

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 Reference: https://www.osha.gov/chemicalexecutiveorder/psm_terminology.html
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Training/References/Questions

> CCPS – Center Chemical Process Safety

> Mary Kay O’Connor: Process Safety Center (Texas AM

Engineering)
> OSHA – Occupational Safety Health Administration

> ABS Consulting

> Prima Tech

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