Elements of Process Safety Management

1. Elements of Process Safety Management A Review of the 14 Elements

2. Elements Concerned with Evaluation of Progress Towards Goals Process Hazards Analysis Pre-startup Safety Review Management of Change Incident Investigation Compliance Audits Trade Secrets Elements Concerned with Achieving Safety Goals Employee Participation Process Safety Information Operating Procedures Training Contractors Mechanical Integrity Hot Work Emergency Planning A Way of Looking at the 14 Elements of PSM

3. Employee Participation • Purpose • One of the Most Essential Elements for a Successful Program • People at Working Level Know Most about Operations • Serves as a Sanity Check re: Common Sense Problems • Couples with All Other Elements and Ensures Successful Implementation • What is Required, Employers Must • Have a Written Plan to Ensure Employee Participation • Involve Employees in Conduct and Implementation of PHAs & Other Elements of PSM • Provide Access to PHAs and all other Information Required to Be Developed by PSM Rule

4. Process Safety Information • Purpose - Ensure Personnel Have Access to Information Needed Work Safely and Efficiently • What is Required • HHC Hazard Information – MSDS + other Data Needed to Comply • Info on Technology (PFDs, Process Chemistry, Max Inventory, Safe Upper and Lower Limits, Evaluation of Consequences of Deviations) • Info on Equipment (Materials, P&IDs, Electrical Class, Relief System Design and, Design Codes and Standards, Material and Energy Balances, Safety Systems, e.g. Interlocks, etc.) • Documentation Equipment Complies with RAGAGEP • For Equipment Designed in Accordance with Codes and Standards no Longer in Use, Must Document Is Designed, Maintained, Inspected, Tested, and Operating in Safe Manner

5. Process Hazards Analysis • Purpose • Identify Hazards and Provide a Preliminary Estimate as to Seriousness • Correct Problems (Design Changes or Modifications, Adding Safety Features, Improving Procedures and Training) • What is Required • Process Hazard Analysis be Done Using – What If, Checklist, What-If/Checklist, HAZOP, FMEA, Fault Tree Analysis, etc. • PHA will Address – • Hazards & Identification of Previous Potentially Catastrophic Incidents • Engr. and Admin. Controls Applicable, Consequences fo Failure of Engr. and Admin. Controls • Facility Siting, Human Factors • Qualitative Evaluation Of Potential Safety and Health Effects if Controls Fail • Team – Engr. and Process Operations, One Member Specific to Process Evaluated, One Member Knowledgeable in PHA Process • Employer Must • Establish System to Address Findings • Update and Revalidate Every Five Years

6. Operating Procedures • Purpose is to Assure Safe and Reliable Operations • What is Required – Employer Must: • Address Safe Actions During Initial Startup, Normal Operations, Temporary Operations, Emergency Shutdown, Emergency Operations, Normal Shutdown, Startup Following Turnaround or Emergency Shutdown • Identify Operating Limits – Consequences of Deviation and Corrective Action • Identify Safety and Health Considerations (properties and hazards and precautions to prevent or correct problems) • Identify Safety Systems and Functions • Safe Work Practices Must be Addressed (e.g. lockout/tag-out, confined space entry, etc. • Procedures Shall be Reviewed as Required to Accurately Reflect Current Operations. Employer Must Certify to this Annually

7. Training • Purpose is to Assure Personnel Can Accomplish Duties Safely • What is Required • Initial Training with Emphasis on Safety and Health Hazards, Emergency Operations Including Shutdown, Safe Work Practices • Refresher Training at Least Every Three Years • Training Shall be Documented

8. Contractors • Purpose is to Ensure Contract Employees Observe Same Safety Rules and Standards as Permanent Employees • What is Required • Applies to Contractors Performing Maintenance, Repair, T/A, Renovation or Specialty Work In or Around a Covered Process • Employer Shall: • When Selecting, Evaluate Contractors Safety Performance and Programs • Inform Contract Employees of Known Hazards Related to Work to be Done • Explain Applicable Emergency Action Plan Provisions • Expain Application of Safe Work Practices to Control Contractor • Evaluate Performance • Maintain a Log of Injuries and Illness • Contract Employer Shall • Assure Employees Trained • Assure Employees Instructed in Known Hazards and Emergency Plan • Document Employees Receive and Understand Training • Assure Employees Follow Safety Rules of Plant • Advise Employees of any Unique Hazards Presented by Contractors Work

9. Pre-Startup Safety Review • Purpose is to Assure Initial Startups or Startups Following Turnarounds or Abnormal Shutdowns are Carried Out Safely • What is Required • Review for New Facilities or Modified Facilities when The Modification Requires a Change in the Process Safety Information • Must Be done Prior to Introduction of HHCs • Must Confirm • Construction and Equipment Meets Design Specifications • Safety, Operating, Maintenance, and Emergency Procedures are Adequate • For New Facilities a PHA has Been Done and Issues Resolved • For Modified Facilities, Management of Change Procedures Have Been Completed

10. Hot Work • Purpose is to Assure Workers are Not Exposed to Sources of High Energy, e.g. Explosive Substances, Toxic Chemicals, Heat, Electricity, Moving Machinery, etc. • What is Required • Employer Issue Hot Work Permit for Work on or Near Covered Process • Permit Must Document Fire Prevention and Protection in Place • Principles Apply to Energy Control Procedures or Permits to Work As Well, e.g. digging near buried cable or pipelines

11. Management of Change • Purpose • All Accidents are a Result of Uncontrolled Changes • Make Sure Changes are Properly Identified and Controlled Before Implemented • What is Required – Employers Must • Write Procedures to Manage Changes (Except for Replacement in Kind) that Address • Technical Basis for the Change • Impact of Change on Safety and Health • Modifications to Operating Procedures • Necessary Time Period for the Change • Authorization Requirements for the Change • Inform and Train Operations, Maintenance, and Contract Employees Affected by the Change Prior to Start-up • Update Applicable Process Safety Information • Update Operating Procedures or Practices

12. Incident Investigation • Purpose • Provide Feedback for Prevention of Future Problems • Incidents are Analogous to Hazards ( Potential Problem), Become Accidents When Someone is Harmed • After the Fact vs. Other Elements Aimed at Anticipation and Prevention • What is Required • Investigation of any Incident that Resulted or Could Have Resulted in Catastrophic Release of a HHC • Prompt Initiation, Within 48 Hours • Investigation Team Formed Consisting of Knowledge of Process Affected, Contractor if Involved, Others with Appropriate Knowledge • Report Prepared • Employer has a System to Promptly and Effectively Address Findings and Recommendations; and Document this Resolution • Report is Reviewed with Affected Personnel • Reports are Retained for Five Years

13. Emergency Planning and Response • Purpose is to Minimize Injuries and Damage in Event of an Incident or Accident • What is Required • Establishment and Implementation of an Emergency Action Plan • Procedures for Handling Small Releases • Training

14. Compliance Audits • Purpose is to Compare Performance Against the Written Standards and Procedures • What is Required • Employer Certify Every Three Years He Has Verified Procedures and Practices Required by The Rule are Adequate and Being Followed • Audit Team Include One Person Knowledgeable in Process and Other Knowledgeable Personnel • Audit Report Developed • Employer Respond to Findings and Document Deficiencies Have Been Resolved • Two Most Recent Audit Reports Be Retained

15. Trade Secrets – Only Non-Technical Element in the Rule • Purpose • To Insure Employees Have Access to Information Needed to Perform Job Safely, Regardless of Trade Secrets • A Trade Secret is Knowledge not Patented but Gives a Co. a Competitive Advantage • What is Required • Information (Regardless of Status) be Made Available to Persons Responsible for • Compiling Process Safety Information • Development of Process Hazard Analysis • Development of Operating Procedures • Involved in Incident Investigations, Emergency Planning and Response, and Compliance Audits • Allows Employer’s to Require Confidentiality Agreements of Employees

16. Summary • Consistent Roadmap Through the PSM Program • The Elements Make Good Business Sense to Assure Safe and Reliable Operations