Process Safety Management of Highly Hazardous & Explosive Chemicals

1. Process Safety Management of Highly Hazardous & Explosive Chemicals 29CFR1910.119 Clearly Understanding the Standard Information Provided under OSHA Susan Harwood Grant #SH-17811-SH-8

2. Susan Harwood Grant…History • Grants are awarded to provide training and education programs for employers and employees on the recognition, avoidance, and prevention of safety and health hazards in their workplaces. • PSM Was Chosen Given the Clear Need • Past Disasters • Current Year Disasters • Perceived Weakness in PSM Program

3. GTRI PSM Susan Harwood Grant Program GTRI is Offering: • Six (6) One Day Courses Around the Southeastern United States • Four (4) One Week In-Depth Courses Around the United States

4. Goals of the One Day Course • Understand Why Process Safety Management (PSM) Was Promulgated • Understand That Even with PSM, Catastrophes are Still Occurring • Understand Who is Covered & Exemptions • Understand the Team Process to Developing a PSM Program • Understand Each of the Elements of a Properly Designed & Implemented Program and How to Begin the Process • Understand the Basics of How PSM & RMP Work Together to Protect the Workforce & Surrounding Community

5. Summary of the One Week Course • This is an In-Depth Study of the Requirements of the Standard • Students will Actually Learn through a Real Life Case Study How to Design Each Element of the Process Safety Management Standard Requirements • Students will Also Review the Basics of EPA Risk Management Plan (RMP)

6. Rules of the Course • This is an Open Discussion Course • Relax and Learn • Ask Questions • Participate in Discussions • Share Experiences • Share Best Practices • Enjoy Yourself

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 respectively, Released the Standards, PSM & RMP that Applies to Those Companies that are Affected by The Standards.

9. Why Did OSHA Develop PSM? Process Safety Management is a regulation, promulgated by OSHA, intended to prevent an incident like the 1984 Bhopal Disaster And…to Prevent Release of: • Toxic, • Reactive, • Flammable, or • Explosive chemicals

10. Not Only PSM, But RMP A great many industrial facilities must comply with OSHA's Process Safety Management (PSM) regulations as well as the quite similar EPA Risk Management Program (RMP) regulations (Title 40 CFR Part 68).

11. RMP-Like Sara Title III Protects the Community Protects the General Public Around the Facility Protects Adjacent Facilities Such as Schools & Hospitals PSM - Like HAZCOM Protects the Workforce Protects Contractors Protects Visitors to the Facility Basically Protects the Workplace PSM vs. RMP - What’s the Difference?

12. The Standard Was Promulgated in 1991 - Is it Working?

13. The Standard Was Promulgated in 1991 - Is it Working? • BP Products Texas City - January 2005 • 15 Workers Killed • 170 Injured • Major Property Damage • $21 Million in Fines

14. Application 1910.119(a)

15. What Facilities are Covered • Those Who Use Chemicals in Appendix A: A List of highly hazardous chemicals, toxics and reactive (Mandatory). Contains a listing of toxic and reactive highly hazardous chemicals which present a potential for a catastrophic event at or above the threshold quantity • Examples Chemical Threshold Quantity (TQ) • Anhydrous Ammonia - 10,000 lbs • Chlorine - 1,000 lbs

16. What Facilities are Covered • A process which involves a flammable liquid or gas (as defined in 1910.1200(c) of this part) on-site in one location, in a quantity of 10,000 pounds (4535.9 kg) or more

17. 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.

18. 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

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

20. There are Exclusions • An employer 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

21. There are Exclusions • Retail facilities; • Oil or gas well drilling or servicing operations; or, • Normally unoccupied remote facilities

22. Definitions 1910.119(b)

23. Definitions • Atmospheric tank means a storage tank which has been designed to operate at pressures from atmospheric through 0.5 p.s.i.g. (pounds per square inch gauge, 3.45 Kpa). • Boiling point means the boiling point of a liquid at a pressure of 14.7 pounds per square inch absolute (p.s.i.a.) (760 mm.). • Catastrophic release means a major uncontrolled emission, fire, or explosion, involving one or more highly hazardous chemicals, that presents serious danger to employees in the workplace.

24. Definitions • Facility means the buildings, containers or equipment which contain a process. • Highly hazardous chemical means a substance possessing toxic, reactive, flammable, or explosive properties and specified by paragraph (a)(1) of this section. • Hot work means work involving electric or gas welding, cutting, brazing, or similar flame or spark-producing operations. • Normally unoccupied remote facility means a facility which is operated, maintained or serviced by employees who visit the facility only periodically to check its operation and to perform necessary operating or maintenance tasks. No employees are permanently stationed at the facility.

25. Definitions • Process means any activity involving a highly hazardous chemical including any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or combination of these activities. For purposes of this definition, 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 shall be considered a single process. • Replacement in kind" means a replacement which satisfies the design specification. • "Trade secret" means any confidential formula, pattern, process, device, information or compilation of information that is used in an employer's business

26. Employee Participation 1910.119(c)

27. Now that we are required to comply, then what? First… • Form a Team in Your Company, i.e.. • Process Engineers • Operators • Safety • Maintenance • Management • Consultants Remember…You Can’t Do it Alone!

28. Now that we are required to comply, then what? Second… • Form a Plan, Determine: • Responsibilities • Duties • Reporting • Document Control • Progress Reports • Tracking Changes

29. Now that we are required to comply, then what? Third… • Review Scope of Project: • Process Safety Information  • Equipment in the Process • Process Hazard Analysis • Operating Procedures • Employee Training • Training Contractors • Pre-Startup Safety Review • Mechanical Integrity of Equipment  • Management of Change • Incident Investigation • Emergency Preparedness • Compliance Audits    • Trade Secrets

30. Now that we are required to comply, then what? …Let’s Begin • In the Next Session, we will Begin to Explore Each Element of the Standard and What is Required to Comply