PSM Covered Chemical Facilities National Emphasis Program

2. PSM Covered Chemical Facilities National Emphasis Program I said we would and we would didI said we would and we would did

3. PROCESS SAFETY MANAGEMENT Purpose Prevention or minimization of the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals

4. PSM NATIONAL EMPHASIS PROGRAM PSM Refinery NEP OSHA initiated the Refinery NEP in 2007 to address catastrophic releases of highly hazardous chemicals at refineries (SIC 2911) Region VI has conducted 17 refinery NEP inspections Region VI will conduct an additional 15 refinery NEP inspections over the next two years. The large number of fatal or catastrophic incidents in the petroleum refining industry dictated the need for a national emphasis program. Included 52 employee deaths and 250 employee injuries, 98 of these injuries required hospitalization. OSHA promulgated the PSM standard in 1992 in response to a number of catastrophic incidents that occurred worldwide (see Process Safety Management of Highly Hazardous Chemicals; 29 CFR 1910.119). These incidents spurred broad recognition that handling highly hazardous chemicals could lead to incidents that may occur relatively infrequently, but, due to their catastrophic nature, often result in multiple injuries and fatalities. The large number of fatal or catastrophic incidents in the petroleum refining industry dictated the need for a national emphasis program. Included 52 employee deaths and 250 employee injuries, 98 of these injuries required hospitalization. OSHA promulgated the PSM standard in 1992 in response to a number of catastrophic incidents that occurred worldwide (see Process Safety Management of Highly Hazardous Chemicals; 29 CFR 1910.119). These incidents spurred broad recognition that handling highly hazardous chemicals could lead to incidents that may occur relatively infrequently, but, due to their catastrophic nature, often result in multiple injuries and fatalities.

5. Pilot Chemical NEP Pilot National Emphasis Program (NEP) to reduce or eliminate the workplace hazards associated with the catastrophic release of highly hazardous chemicals. Programmed inspections will take place in Regions I, VII and X. Unprogrammed inspections OSHA-wide. Pilot program will be effective for one year. This NEP outlines a new approach for inspecting PSM covered facilities. This approach allows for a greater number of inspections by better allocation of OSHA�s resources. This NEP will be effective for one year. The NEP will apply to unprogrammed inspections related to employer PSM-covered processes OSHA-wide. Programmed inspections under this NEP will take place in Regions I, VII and X. After one year, this pilot NEP will be evaluated and considered for renewal and expansion to other regions. To keep consultant in business I have asked Area Offices to evaluate IH programsThis NEP outlines a new approach for inspecting PSM covered facilities. This approach allows for a greater number of inspections by better allocation of OSHA�s resources. This NEP will be effective for one year. The NEP will apply to unprogrammed inspections related to employer PSM-covered processes OSHA-wide. Programmed inspections under this NEP will take place in Regions I, VII and X. After one year, this pilot NEP will be evaluated and considered for renewal and expansion to other regions. To keep consultant in business I have asked Area Offices to evaluate IH programs

6. PSM STANDARD (1910.119) Application A process which involves a chemical at or above the specified threshold quantities listed in Appendix A (136) A process which involves a flammable liquid or gas (defined in 1910.1200(c)) on site in one location, in a quantity of 10,000 pounds (4535.9 kg) or more (with some exceptions).

7. PSM STANDARD Process Safety Information (PSI) Process Hazard Analysis (PHA) Operating Procedures Pre-startup Safety Review Mechanical integrity The compilation of written process safety information used by the employer/employees to identify and understand the hazards posed by those processes involving HHCs. PSI shall include information pertaining to the hazards of the process, the technology and equipment in the process. The PHA hazard analysis (hazard evaluation) shall identify, evaluate, and control the hazards involved in the process. The compilation of written process safety information used by the employer/employees to identify and understand the hazards posed by those processes involving HHCs. PSI shall include information pertaining to the hazards of the process, the technology and equipment in the process. The PHA hazard analysis (hazard evaluation) shall identify, evaluate, and control the hazards involved in the process.

8. PSM STANDARD Contractor Evaluation/Performance Management of change Incident investigation Emergency planning and response Compliance Audits Contractors: Safety performance evaluation Inform the contractor of the potential hazards The emergency action plan Entrance and exit of contract employees Contractor illness and injury log Pre-start-up Review Construction and equipment is in accordance with design specifications Safe operating procedures, emergency procedures are in place and adequate Mechanical Integrity Pressure vessels and some storage tanks, piping system, relief/vent system, emergency shutdown system, controls, pumps Training Inspection and testing Equipment deficiencies Quality assurance Management of change -except for in-kind changes Incident investigation -The employer shall investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemical in the workplace. Compliance Audits -certification every three yearsContractors: Safety performance evaluation Inform the contractor of the potential hazards The emergency action plan Entrance and exit of contract employees Contractor illness and injury log Pre-start-up Review Construction and equipment is in accordance with design specifications Safe operating procedures, emergency procedures are in place and adequate Mechanical Integrity Pressure vessels and some storage tanks, piping system, relief/vent system, emergency shutdown system, controls, pumps Training Inspection and testing Equipment deficiencies Quality assurance Management of change -except for in-kind changes Incident investigation -The employer shall investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemical in the workplace. Compliance Audits -certification every three years

9. NEP Targeting Sources OSHA will use four sources for targeting U.S. EPA Chemical Accident Prevention Provisions, RMP 3 Explosives manufacturing NAICS codes OSHA�s IMIS database OSHA Area Office knowledge of local facilities.

10. SITE SELECTION Regions I, VII and X will conduct programmed (target list) NEP inspections Region VI Site Specific Targeting (SST) Plan inspections Region VI Unprogrammed Inspections Complaints, Referrals, Accidents and Catastrophes comprehensive inspection of the PSM-covered process(es) at the facility. CSHOs may, after consulting with the Area Director, expand the PSM portion of the inspection beyond this notice if they determine that PSM deficiencies may exist outside of the selected unit or dynamic list questions. Complaint or referral. If a formal complaint or referral is received relating to a PSM-covered process and it: � involves an application of the PSM standard - the AD shall evaluate the complaint or referral item(s) in the usual manner (CPL 02-00-148 � Field Operations Manual) and conduct an inspection using this notice. � does not involve an application of the PSM standard (for example, there is a complaint about PPE requirements in a PSM covered process)- the inspection or inquiry will normally be limited to the complaint and referral item(s)/subject(s) only. However, if the 11 facility has not already been inspected using this notice, a concurrent inspection using this NEP may be conducted at the AD�s discretion. b. Accidents and Catastrophes. Responses to accidents an comprehensive inspection of the PSM-covered process(es) at the facility. CSHOs may, after consulting with the Area Director, expand the PSM portion of the inspection beyond this notice if they determine that PSM deficiencies may exist outside of the selected unit or dynamic list questions. Complaint or referral. If a formal complaint or referral is received relating to a PSM-covered process and it: � involves an application of the PSM standard - the AD shall evaluate the complaint or referral item(s) in the usual manner (CPL 02-00-148 � Field Operations Manual) and conduct an inspection using this notice. � does not involve an application of the PSM standard (for example, there is a complaint about PPE requirements in a PSM covered process)- the inspection or inquiry will normally be limited to the complaint and referral item(s)/subject(s) only. However, if the 11 facility has not already been inspected using this notice, a concurrent inspection using this NEP may be conducted at the AD�s discretion. b. Accidents and Catastrophes. Responses to accidents an

11. AMMONIA and CHLORINE Use in refrigeration systems Chlorine used in disinfection systemsUse in refrigeration systems Chlorine used in disinfection systems

12. Chemical NEP Inspection Plan OSHA will select one or more units and use a dynamic list of questions to review compliance. OSHA will not publicly disclose the dynamic lists OSHA will develop dynamic lists in 5 categories: PSM General, Ammonia Refrigeration, Storage, Water and/or Wastewater Treatment, and Chemical Processing. Inspection emphasis on implementation over documentation.

13. Chemical NEP Inspection Plan OSHA to inspect host and contract employers Contractors (including subcontractors) working on or adjacent to the Selected Unit OSHA will use the applicable questions in the dynamic list to evaluate contractor compliance Includes construction contractors working on or adjacent to the Selected Unit(s)

14. Selection of Unit OSHA shall select a PSM-covered process(es) For large continuous processes, OSHA may select a portion of the covered process (the Selected Unit(s)) Selection will be based on factors such as: Risk of releasing flammables and toxic substances Operating pressures/temperatures Quantity of chemicals present Incident reports and other history Age of the process unit Employee representative input

15. Chemical NEP Outreach The OSHA Training Institute will develop chemical plant PSM information and training materials. OSHA to develop outreach programs that will support their enforcement efforts. Outreach products and activities include: letters and news releases, seminars on chemical plant process safety topics, coordination with OSHA�s cooperative program participants, including Voluntary Protection Programs, Strategic Partnership, and Alliance. OSHA will disseminate agency compliance assistance resources as well as work with Alliance Program participants to develop and disseminate additional resources to support Agency efforts.

16. NANOTECHNOLOGY Nanotechnology is the understanding, manipulation, and control of matter at dimensions of roughly 1 to 100 nanometers, Nanomaterials are materials that have been purposefully manufactured, synthesized, or manipulated to have a size with at least one dimension in the range of approximately 1 to 100 nanometers and that exhibit unique properties determined by their size.

17. NANOPARTICLE USES Nanoscale structures have the potential to revolutionize electronics, medicine, and consumer products Sunscreens and cosmetics; Longer-lasting tennis balls/light-weight, stronger tennis racquets; Stain-free clothing and mattresses; Polymer films used in displays for laptops, cell phones, digital cameras; Coatings for easier cleaning glass; Bumpers and catalytic converters on cars Protective/glare-reducing coatings for glasses and cars.

18. RESEARCH AND DEVELOPMENT NIOSH is the leading federal agency providing guidance and conducting research on the occupational safety and health implications. NIST AIHA Nanotechnology Working Group EPA, Consortiums, NCI, Colleges, International The NIST nanotechnology webpage contains information on nanotechnology activities, news, developments and accomplishments. NIST's Center for Nanoscale Science and Technology operates the Nanofab, a shared-use facility providing economical access to state-of-the-art nanotechnology-measurement tools and nanofabrication, and a research program.The NIST nanotechnology webpage contains information on nanotechnology activities, news, developments and accomplishments. NIST's Center for Nanoscale Science and Technology operates the Nanofab, a shared-use facility providing economical access to state-of-the-art nanotechnology-measurement tools and nanofabrication, and a research program.

19. OSHA General Duty Clause Section 5(a)(1) of the Occupational Safety and Health Act of 1970 (29 U.S.C. 654), often referred to as the General Duty Clause, requires employers to "furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees."

20. OSHA STANDARDS Standards that Apply 1910.132, Personal protective equipment, general requirements 1910.134, Respiratory protection 1910.1200, Hazard communication 1910.1450, Occupational exposure to hazardous chemicals in laboratories