Process Safety Management of Highly Hazardous & Explosive Chemicals

1. Process Safety Management of Highly Hazardous & Explosive Chemicals Operating Procedures, Safety Procedures & Training

2. Now that the PHA’s Are Competed or Underway… • Operating Procedures & Safety Programs Must Be Developed • PHA Information Can Be Used

3. Operating Procedures 1910.119(f)

4. Operating Procedures & Safety Programs Must Consider: • Initial start-up • Normal operations • Temporary operations • Emergency shutdown • Emergency operations • Normal shutdown • Start-up following turnaround • Consequences of deviation • Steps required to correct or avoid deviation

5. Operating Procedures or Standard Operating Procedures (SOP’s) • Where Did This Methodology Come From? • Answer: The Military • Definition: A standard operating procedure is a set of instructions having the force of a directive, covering those features of operations that lend themselves to a definite or standardized procedure without loss of effectiveness. Standard Operating Policies and Procedures can be effective catalysts to drive performance improvement and improving organizational results. Every good quality system is based on its standard operating procedures (SOPs).

6. Operating Procedures • Develop and implement written operating procedures* consistent with the process safety information and addresses at least the following elements: • Initial start-up, normal and temporary operations • Normal and emergency shut-down procedures • Operating limits and consequences of deviation • Hazards presented by the process *Readily accessible to employees

7. Operating Procedures • The operating procedures addressing operating parameters will contain operating instructions about: • pressure limits • temperature ranges • flow rates…and • what to do when an upset condition occurs • what alarms and instruments are pertinent if an upset condition occurs, and other subjects.

8. Operating Procedures - Start Up…We Must • Describe normal SOP's  • Describe start-up SOP's • Describe Shut-down SOP’s

9. Operating Procedures - Start Up…We Must • Include Sections such as: • Objectives • Purpose • Concerns • Procedures • Department • Operator • Equipment Involved • Location • Related Documents Let’s Look at An Example…

10. Process Safety Management Procedure - Revision HPR-1 Revision Date: 1-9-2009 by: SWD

12. Operating Procedures • Must be Developed for Each Equipment Operation in the Covered Process • Refer to Block Diagrams • Refer to P&ID • Must Cover Normal Operating Conditions, Normal Operating Parameters, i.e.. Pressure/Flow/Current/ etc. • Must Follow Procedures & Recommendations in PHA’s • Must Follow Form

13. Operating Procedures • For Shut-down Procedures…Remember: • Most operations must be shut down in a specific order! • Failure to follow these shut down procedures could results in a catastrophic release or system failure

14. Ammonia Plant Explosion Caused by Improper Shut-down of Engine Room

15. Operating Procedures • Operating Limits • Operating Limits Must be Understood • Pressures • Flows • Electrical Potential • Tolerances

16. Operating Procedures - Hazards of the Process • Operating Procedures Must Identify the Hazards of the Process in All Phases: • Start Up • Normal Operating Conditions • Temporary Operating Condition • Emergency Shut-down

17. Now That We’ve Completed the Operating Procedures We Must Develop Safety Work Practices, Programs & Procedures for Covered Processes

18. Safe Work Practices 1910.119(f)(1)

19. Safe Work Practices • Develop and implement safe work practices* to provide for the control of hazards during operations such as: • Lockout/tagout; • Confined space entry; • Line Opening process equipment or piping; and • Control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel *These safe work practices apply to contractor employees as well

20. Safe Work Practices • Safe Work Practices, Programs & Procedures must: • Be specific to the Covered Process • Follow Procedures & Recommendations in the PHA’s • Follow Procedures in the Operating Procedures • Must be Able to be Tracked • Follow Form

22. Safe Work Practices • Lockout Tagout - One of the Most Important Procedures in PSM • Must be Written Carefully & Follow all Procedures (PHA’s, Operating Procedures) • Must be Followed to the Letter!

24. Safe Work Practices • Lockout/Tagout in PSM • Why not Use Digital Imaging in Your Procedures to Identify Critical Lockout /Tagout Positions

25. Safe Work Practices • Line Opening Permits • Identify Procedures for Opening any Process Line in a Covered Process • Must Include Hazards of the Line Opening • PPE Required

26. Safe Work PracticesLine & Equipment Opening • A Hazard Review Must Completed for All Line/Equipment Hazards Including: • HAZARDOUS MATERIALS IN SYSTEM • POTENTIAL PHYSICAL HAZARDS • BARRICADING AS REQUIRED • FIRST AID IF EXPOSED • LOCATION OF SAFETY EQUIPMENT • PPE REQUIRED FOR LINE OPENING

30. Safe Work Practices-Hot Work A Program Must be Developed for the Covered Process That Requires: • A Hot Work Permit be Issued for ALL Hot Work Performed in the Plant by Employees or Contractors • A Permit must be Posted at the Location of the Hot Work • A Fire Watch Is Required • A Fire Extinguisher or Other Appropriate Fire Fighting Equipment Must Be Present, Fire Watch must be Trained in its use

31. Paper Mill Explosion & Fire Caused by Failure to Follow Hot Work Procedures

32. Safe Work Practices • Must be Specific for the Covered Process • May Require Additional Program other than Lockout Tagout, Line Opening & Hot Work…such as Confined Space, Electrical Safe Work Practices, Combustible Dust

33. Now That We’ve Developed Safe Work Practices We Have to Train

34. Training 1910.119(g)

35. PSM 29CFR1910.119(g) Requires (G) Training (Initial, Refresher, and Documentation) (paragraphs (g)(1), (g)(2), and (g)(3)). • Paragraph (g)(1) requires employers to train employees operating dangerous process. Paragraph (g)(2) requires that the employer provide refresher training at least every three years. Paragraph (g)(3) requires the employer to prepare a record that contains the name of employee, the date of training, and the means used to verify that the employee understood the training

36. PSM Training • PSM Training Programs Must be Developed for: • Affected Employees - Those not Directly Involved in the Process Operation • Authorized Employees - Those Directly Involved in the Process Operation • Contractors Who May Perform Work on a Covered Process • Vendors/Visitors who May Visit the Facility and May Potentially be Exposed to the Covered Process

37. PSM Training • Training Must Be Performed as Follows: • Initial training • Prior to work assignment • Waved for those already in a process • Refresher training • Every three years • All Training Must be Documented

38. PSM Training • Training Subjects Must Include at Least: • Lockout Tagout • Hot Work • Line & Equipment Opening • Confined Space (if applicable) • Emergency Response

39. Examples of Training PSM training example including the means used to verify that the employee understood the training.

40. Let’s Use Hot Work Procedures

41. Safe Work Practices Hot Work Program

42. EXAMPLES OF HOT WORK

43. Safe Work Practices Hot Work Burning, Welding, Grinding Our Program Requires • A Hot Work Permit be Issued for ALL Hot work Performed in the Plant by Employees or Contractors • Permit must be Posted at the Location of the Hot Work • Fire Watch Is Required • Fire Extinguisher Must Be Present, Fire Watch must be Trained in its use

44. Safe Work PracticesHOT WORK PERMIT MUST BE COMPLETED PRIOR TO BEGINNING WORK INVOLVIING ANY HOT WORK PERMIT SHALL BE DISPLAYED AT THE LOCATION OF THE ACTUAL HOT WORK OPERATION

46. VERIFICATION OF UNDERSTANDING WORKSHEETHOT WORK CIRCLE THE CORRECT ANSWER 1. A HOT WORK permit must be obtained prior to beginning HOT.work by welders and contractors before beginning a job. TRUE 2. A HOT WORK permit is not necessary if just burning and grinding is being done on a job. FALSE 3. Contractors are not required to obtain HOT WORK permits. FALSE 4. The employee or contractor will obtain a HOT WORK permit from his supervisor and must determine if conditions are safe and have a fire watch if necessary. TRUE

47. 5. HOT WORK is permitted in explosive atmospheres, around hazardous tanks and equipment. FALSE 6. The following protective measures can be used: damp sand on floors, protective shields, or fire resistant coverings while Hot Work is taking place. TRUE 7. 35 feet is a good safe distance for covered combustibles to be away from HOT WORK. TRUE 8. Fully charged and operable fire extinguishers and/or hose lines shall be available and ready. TRUE 9. The HOT WORK permit shall be posted at the job site, and the supervisor shall retain the permits for three (3) days. TRUE 10. The fire watch does not have to be trained in fire extinguishing and is not responsible for sounding an alarm in the event of a fire. FALSE

48. PSM Operating Procedures Summary • You Must Develop and implement written operating procedures consistent with the process safety information and addresses at least the following elements: • Initial start-up, normal and temporary operations • Normal and emergency shut-down procedures • Operating limits and consequences of deviation • Hazards presented by the process

49. PSM Safe Work PracticesSummary • Safe Work Practices, Programs & Procedures must: • Be specific to the Covered Process(s) • Follow Procedures & Recommendations in the PHA’s • Follow Procedures in the Operating Procedures • Must be Able to be Tracked • Follow Form

50. PSM Training Summary • PSM Training Programs Must be Developed for All Necessary Workers and Contractors • Verification of Understanding is Required • Training Must Be Performed as Follows: • Initial training • Prior to work assignment • Waved for those already in a process • Refresher training • Every three years • All Training Must be Documented