Understanding Process Safety Management - 29 1910.119

1. Understanding Process Safety Management - 29 1910.119 Elizabeth Morales, MS VPP Recertification Manager Region VII 816-283-0545 ext.254

2. Purpose: Prevent Catastrophic Releases of Highly Hazardous Chemicals

3. Update FAT/CAT investigations • DuPont Phosgene Release at Belle, WV- A release of highly toxic phosgene resulted in one death. (Operator) Cause: Sudden rupture of a braided steel hose connected to a one-ton capacity phosgene tank releasing phosgene into the air. (January 23,2010) • Tesoro Refinery in Anacortes, WA- An explosion and fire in a Naphta hydrotreater unit in the refinery led to the fatal injury of six employees. (April 10,2010)

4. Purpose of the PSM Standard is…. • To prevent or minimizing the consequences of catastrophic releases of chemicals such as: • Highly toxics • Reactive • Flammables • Explosives

5. History of the PSM standard • Proposed rule was published – July 17,1990 • Final Rule was published- February 24, 1992.

6. Final Rule Provisions Application Definitions Employee Participation Process Safety Information Process Hazard Analysis Operating Procedures Training Contractors 9. Pre-start up Safety Review 10. Mechanical Integrity 11. Hot Work Permit 12. Management of Change (MOC) 13. Incident Investigations 14. Emergency Planning 15.Compliance Audits 16.Trade Secrets

7. What’s New with PSM? • Refinery National Emphasis Program (NEP) • Pilot Process Safety Management “Chemical NEP”

8. OSHA Inspection Directives • CPL-2-2.45A-CH1 – Process Safety Management of Highly Hazardous Chemicals- Compliance Guidelines and Enforcement Procedures • CPL-03-00-004- Petroleum Refinery – National Emphasis Program (NEP)

9. Refineries- National Emphasis Program

10. Refineries- NEP • 1,000 hours/inspection • Full statutory 6 months for inspection • Human Resources intensive (OSHA & Companies) • Average Penalties/inspection~ $110,000

11. Refinery NEP -Update • Last update August 18,2009 • Change: To extend timeframe for completion of NEP inspections • Region VI until end of Fiscal Year 2011.

12. Refinery NEP Most Frequently Cited PSM Elements

13. OSHA Compliance Inspection Time Frame • PSM on-site inspections~ 6 weeks up to 6 months • Time depends on many factors such as… * Size * Number of deficiencies * Violation Classifications

14. PSM Covered Chemical Facilities National Emphasis Program-09-06(CPL 02) ---- CHEMICAL NEP PSM Covered Chemical Facilities National Emphasis Program-09-06-(CPL-02) CHEMICAL NEP

15. Chemical NEP • VPP sites are NOT subject to programmed inspections. • Applies to OSHA-wide for unprogrammed PSM related inspections: * Accidents * Complaints * Referrals * Catastrophes

16. Chemical National Emphasis Program • Effective July 27,2009 • Different approach for inspecting PSM covered chemical facilities • NOT Comprehensive • Less resource intensive (OSHA & Employers)

17. Chemical NEP- Pilot Program • 1 year PILOT program for planned inspections in 3 OSHA REGIONS: • Region 1- CT, MA, ME, NH, RI • Region VII- Nebraska, Kansas and Missouri • Region X- Idaho • Voluntary for State Plans

18. Most Frequent Chemical NEP Violations

19. NEW!!!VPP –PSM requirements- New Applicants and existing sites. • New VPP-PSM applicants are required to include with their VPP application + Supplement A. • Existing VPP-PSM sites- Also are required to submit by February 15- Submit annual report + Supplement B • During onsite VPP-PSM evaluation – Supplement A & Supplement C will be use to evaluate your PSM program.

20. Supplement A • Evaluate your PSM program. • Identify areas of excellence • **Identify areas for significant improvements • Best practices

21. Section I. Management of Change

22. Section II. Relief Design

23. Section III. Vessels- Mechanical Integrity

24. Section IV: Piping- Mechanical Integrity

25. Section V. Operating Procedures

26. Section VI. Process Hazard Analysis, Incident investigations & audit findings- recommendations • PHA • Incident Investigations • MOC’s • Compliance Audits ***All corrective actions must be completed in timely manner and documented.

27. Section VII: PHA -Facility Sitting/ Human Factors • Sitting of all occupied structures- PHA • Enough time for operators to escape during an upset condition • Identify human errors and consequences of these errors.

28. Section VIII: Operator Training • Procedures • Fully qualified to perform shutdown and emergency procedures safely • Fully trained to make difficult safe decisions in timely manner.

29. Section IX: Safe Work Procedures • Motorized equipment to enter operating units or close to piping systems. • Opening process equipment, vessel entry, control of entrance to a facility or covered process. • Employees and contractors must follow the work practice procedures.

30. Section X. Incident Investigations • Document all the incidents and near-miss incidents. • Provide a detail list (1 year information)

31. Section IX: Blowdown Drums and Vent Stacks • Documentation of the original designs if the site has blowdowns should be maintained. • Document blowdowns are discharging to a safe location. • Inspection, calibration, testing, maintenance & control documents. • Operators must be trained.

32. VPP- PSM Recertification- What to expect? OSHA 300 logs (three years)- Reviewed Team Leader- Review of your PSM program Walkthrough the facility including covered process Review of Supplement B (annual evaluation) Supplement A Supplement C known as the Dynamic list of questions provided by the National Office)

33. GENERAL INFORMATION- Supplements B, A and C • On February 15 – Every VPP –PSM site must include: Annual report + Supplement B Questionnaire. • NEW VPP-PSM SITES-required to include with their VPP Application only Supplement A. • EXISTING VPP-PSM sites-during on site visit Supplement A and C will be used.

34. Do not forget -PSM and other interface standards • LOTO Program • Confined Space • Emergency Procedures • Respiratory Protection • Consensus Standards such as API, NFPA, and others…

35. VPP-PSM Best Practices in Region VII • LOTO Procedures- Specific Procedures with photos. • Labeling system – big and legible tags • Mechanical Integrity Program • Contractor Safety Program • Operator training

36. VPP - PSM Star sites • Actually, in Region VII, we only have 10 VPP-STAR sites. • Kansas - 3 sites • Missouri - 4 sites • Nebraska - 3 sites

37. Successful PSM evaluations- TIPS!! Promote continuous leadership development. Employee participation Document all significant changes in writing. Managers & Operators are properly trained. PSM Coordinator/ group Solid Mechanical Integrity Program. Avoid procrastination!!

38. References • www. CBS.gov • www.osha.gov • American Petroleum Institute • National Fire Protection Association • www. National Geographic

39. Special Thanks to…. PSM sites & SGE’s • Cargill, Blair NE • Oxychem, Kansas • Cargill, California,MO • Butterball, Carthage, MO • Omaha Steaks, Omaha,NE • Kraftfoods,Kirksville,MO • All SGE’s

40. Disclamer • This information has been developed by an OSHA Compliance Assistance Specialist and is intended to assist employers, workers, and others as they strive to improve workplace health and safety. While we attempt to thoroughly address specific topics [or hazards], it is not possible to include discussion of everything necessary to ensure a healthy and safe working environment in a presentation of this nature. Please visit our webpage www.osha.gov Thanks….

41. End • Questions????