Professional Documents
Culture Documents
OSHA Process Safety Management
OSHA Process Safety Management
Process Safety Management (PSM) is a regulation promulgated by the U.S. Occupational Safety
and Health Administration (OSHA) in February 19921. This promulgation was motivated by the
Bhopal incident occurred in 1984, where 3,800 people died and several thousand suffered
permanent injured or partial disabilities because of the release of methyl isocyanate.
The objective of PSM is to prevent or minimize the frequency and consequences of catastrophic
releases of toxic, reactive, flammable, or explosive chemicals. The PSM regulation applies to
processes which involve certain specified chemicals at or above the threshold quantities or
involve flammable liquids or gases on-site in one location, in quantities of 10,000 lbs. or more,
and processes which involve the manufacture of explosives and pyrotechnics. It is important
recognize that PSM is a process that requires the help of many division of the company.
Table 1. 14 Elements of PSM and OSHA standard number Element OSHA standard
1
Mannan, M.S., J. Makris, and H.J. Overman. Process Safety and Risk Management regulations: Impact on Process
Industry. Encyclopedia of Chemical Processing and Design. Ed. R.G. Anthony, vol. 69, Supplement 1, pp 168-193,
Marcel Dekker, Inc., New York, 2002.
Emergency Planning and Response 1910.119(n)
Compliance Audits 1910.119(o)
Trade Secret 1910.119(p)
Employee Involvement
Safe operation and maintenance requires the involvement of both employers and employees.
Therefore, OSHA requires employee participation to address all the major elements of Process
Safety Management program. Employees will have the opportunity to actively participate
through voluntary direct participation, through consultation, and through methods such as
anonymous communication and employee representation.
Input from employees with the understanding of chemical processes will be continuously
solicited as source of information in the development of chemical process incident prevention
plans, the performance of Process Hazards Analysis (PHA), and the conduct of incident
investigations and audits and other activity. Employees may be expected to participate different
areas in PSM is shown in Table 2.
It is a responsibility of the group or individual leading that activity to ascertain whether the
employees have the necessary expertise to successfully carry out the work. The employer is
required to provide ready access to all information required to develop the PSM standard. Also,
the employer should ensure that information on what is being done to complete PSM is provided
to the employee. The employer must prepare a written Employee Participation Plan. This plan
should contain a clear purpose statement and statement that employees at all levels within the
plant will be directly involved with the activities related to the PSM. The next step is to explain
this employee involvement. The written employee participation statement should be posted in a
location easily accessible to employees and the employees must be kept informed on matters
regarding PSM2.
Chemicals information
o Chemical hazards
o Toxicity
o Permissible exposure limit
o Physical, thermal, reactivity and chemical stability data
o Hazardous effects of inadvertent of different materials that could foresee ably
occur
o Effect of mixing
o Material and energy balances
Technology information
o Process flow diagram or block flow diagram
o Process chemistry
o Process limitation: safe upper and lower operating conditions (pressure,
temperature, composition, flows)
o Maximum intended inventory
o Consequence of process deviation
2
Spellman, Frank R. A Guide to compliance for Process Safety Management/ Risk Management Planning. United
States Occupational Safety and Health Administration, United States Environmental Protection Agency. CRC Press:
1998.
3
Process Safety Management Report for OSHA and ISO Compliance Volume 1 No.1, June 1992.
o Material and energy balance
o Safety system: interlocks, detection, monitoring and suppression system
PHA requires updates every 5 years to assure that the PHA is consistent with the current process.
It also requires operating locations to retain the analysis, updates, or revalidations for each
process covered, as well as the documented resolution of recommendation, for the life of the
process. PHA must be performed by one or more of the following methods or any other
equivalent methods4:
What-If analysis
Checklist method
What-If or checklist
Hazard and Operability (HAZOP) Study
Failure modes and effects analysis (FMEA)
Fault-tree analysis
What-If analysis is an unstructured method for considering results of unexpected events. This
analysis method uses questions beginning with “what if” and do not take into account on how the
failures occur. The expected outcome of this analysis would be a list of potential problem areas
and suggested mitigation methods. Example of a What-If analysis is shown in Table 3.
4
Idem as 1
Checklist analysis aims to identify common hazards and ensure compliance with standard
procedures. The expected result of this analysis method is the identification of existing and
lurking common hazards and means to compliance with standard procedures.
What-If/Checklist analysis method combines the creative and brainstorming features of the
What-If with the systematic features of Checklist method.
Failure modes and effects analysis (FMEA) is a systematic tabulation of plant equipment, failure
modes (cause of the equipment failure) and the effect of the failures. FMEA only identifies single
mode failure and because of that is not useful for identifying combination of failures. This
method also does not examine operator errors. Example of FMEA is shown in Figure 1.
Fault tree analysis is a deductive technique that focuses on one incident and then constructs a
logic diagram of all conceivable event sequences that could lead to that particular incident. As
other logic diagrams, FTA uses basic components such as shown in Figure 2. These basic
components need to occur accordingly in order for the top event to occur. From the logic
diagram, identification of pathways, both mechanical and human error to the final top event can
be structurally analyzed. The rupture of hot water tank is given as an example of FTA and shown
in Figure 3.
Figure 3. Example of fault tree analysis of the rupture of hot water tank.
Hazard and Operability (HAZOP) method is a rigorous method that identifies, analyzes and
controls hazards and operability problems of a process. A HAZOP study is delivered through a
systematic team approach to identify hazards and inefficiencies in a system. HAZOP employs
scenario development and brainstorming analysis method to determine the consequences of
deviations from the intended operation. A team of HAZOP review comprises of multidisciplinary
personnel from different section of the plant.
This method traces flow of materials through the system operation. To ease the tracing process,
the system operation is divided into nodes or sections. Figure 4 shows an example of node or
section from a batch reactor system used for polymerization. Different guide words that
characterize deviation of normal operation condition are used to direct the scenario development
on each node. Variety of HAZOP guide words and the process parameter subject to these guide
words for deviation are shown in Table 4 and Table 5 respectively.
Table 6. HAZOP study applied to the feed line (Intent: Feed reactants into the reactor)
Guide
Parameter Deviation Causes Consequence Recommendation
Word
5
Center for Chemical Process Safety. Guidelines for Hazard Evaluation Procedures. American
Institute of Chemical Engineers: New York, 1992.
Flow No No Flow V-1 to V-5 closed. Over-pressurization of Flow indicators after
V-6 closed. the lines with potential valves.
fracture.
Implement semi-batch
process.
Less Less Flow Leak in the pipes. Incomplete reactions. Flow indicators with
Accumulation of alarms for low flow.
reactants.
V-1, V-2, V-3, V-4, Potential hazard for the Level indicator in the
V-5 or V-6 partially product. reactor.
closed.
Temperature Higher Higher Summer season. Boiling of reactant Temperature indicators
Temperature causing overpressure in and alarms in storage
the lines. tanks and lines. Set
High temperature temperatures before
when loading. boiling points.
Lower Lower Winter season. No hazard. Temperature indicators
Temperature in storage tanks and
lines.
The result of PHA is used to determine proper safety measures that need to be added to the
process or values of process variables might be changed if they are set too high or too low. Other
advantage of PHA result is that it can be used to define critical equipment that requires
preventive maintenance, inspection, and testing programs, and also help the plant develops a
focused emergency response programs that suits the plant needs and conditions. There are
several publications that provide detail guidance on completing PHA such as Guidelines for
Hazard Evaluation Procedures by CCPS.
Operating procedures
Operating procedure that addresses the safe operation of the plant must be documented and
available to personnel that require it. Besides normal operation steps, operating procedures for
upset conditions, temporary operations, start-up, and shutdown should also be properly
documented and make readily available. These operating procedures have to be clearly written
instruction and consistent with the process safety information6.
The procedures have to take into account general and special hazards of the chemical involved in
the process, hazards of exceeding operational limits, appropriate response to upset conditions,
safety and health information, and emergency operations. Up to date and reliability of the
operating procedures must be performed frequently. This element of PSM also serves as a critical
element in training of personnel7.
Training
Training serves as a way of communicating knowledge of the process, communicating skills in
performing operating and emergency procedures, communicating hazards related to the process
and many other aspects of process operation and maintenance to plants personnel. An effective
and properly scheduled training are very important because they determine the end result of the
training. Industry codes and government regulations recommend, and, in some cases, require
6
Lee’s Loss Prevention in The Process Industries Vol.1, Vol.2 and Vol.3 Hazard Identification, Assessment and
Control 3rd Edition, Elsevier, 2004.
7
http://www.saic.com/environment/psm/elements.html
specific trainings for plants workers. Consequently, PSM programs need to identify and
document training requirements covering all levels of management and employees, including
contractor personnel, who manage, operate, maintain, and support the process units8.
Contractors
Contractors who are considered under the PSM program are those who are involved in the
installation or maintenance of equipment and systems at a facility that has one of the following
processes:
Employer is responsible to obtain and evaluate information regarding the contract employer's
safety performance, and inform contract employers of the known potential fire, explosion, or
toxic release hazards related to the contractor's work.
To confirm that the construction and equipment of a process are in accordance with
design specifications.
To assure that adequate safety, operating, maintenance and emergency procedures are
in place.
To assure process operator training has been completed. Also, especially for new
facilities.
To assure that the PHA must be performed and recommendations resolved and
implemented before start up. Modified facilities must meet management of change
requirement.
8
Center for Chemical Process Safety. Guidelines for Process Safety Documentation. American
Institute of Chemical Engineers.
9
Idem as 3
Mechanical Integrity
Mechanical Integrity (MI) is committed to provide the benefits of the most up-to-date inspection
technologies to support chemical plants operating efficiently and in an environmentally safe
condition, and provide the benefits to the petrochemical industries. The objective of MI is to
ensure equipment does not fail in a way that causes a release of chemicals. Equipment means
hardware that helps contain the chemicals in the process. MI covers the proper design,
fabrication, construction/installation and operation of equipment throughout the entire process
life cycle.
The ASME Code, or Section VIII of the ASME (American Society of Mechanical
Engineers)
The API Standard 620 or the American Petroleum Institute Code provides rules for
lower pressure vessels not covered by the ASME Code.
The permit requires date authorized for hot work, equipment involved in the work, a system to
maintain and document certification, identification of openings where sparks may drop, the types
and number of fire extinguishers, identification of fire watches, an inspection before the work,
authorization signatures, identification of flammable materials in the area, verification that the
surrounding area is not explosive, verification that combustible materials are isolated properly,
identification and closure of open vessels or ducts, and verification that the welded walls are not
flammable. Figure 5 shows an example of the form that is required to complete before a hot
work is performed.
10
Idem as 1
Figure 5. Example of Hot Work Permit form.
Management of change
PSM requires employee to develop and implement documented procedures to manage changes in
the process chemistry, process equipment and operating procedures through Management of
Change (MOC). MOC is a tool that can be effectively used to ensure the continued integrity of
the other PSM elements. However, MOC also requires other elements (e.g. process knowledge
and mechanical integrity) be in place and functioning; otherwise MOC will not be effective. For
example, process hazard analysis (PHA) can be used to assess the safety of the current design
and operating procedures; this establishes a baseline against which the significance of future
changes can be assessed.
The proper consideration of direct and indirect hazard potential before the change is
implemented;
That procedures are modified and retraining, where relevant, occurs before the
modification is put into service;
Enhanced emphasis on the preparation and retention of records of each change; and
The ability to audit the changes.
At plants with a strong PSM program, MOC can be expected to play a key role in maximizing
the value of the PSM program. Older plants may present a greater challenge in implementing
MOC since documentation of parts of their PSM program information may be out of date, or
missing. As a result, it may be difficult to readily determine whether a change is safe to
implement. In such situations, for a MOC program to be effective, priority attention should be
given to updating documentation that supports the plant PSM program. Effective, up-to-date
documentation is important to enable the facility to be operated safely and profitably.
Incident investigation
Under the incident investigation section of PSM, chemical industries are highly encouraged to
perform a complete investigation of incidents to determine their causes and to seek ways of
preventing their recurrence. The key to preventing disaster first lies in recognizing the leading
indicators. These leading indicators exist in incidents that are less than catastrophic. They can
even be seen in so-called near misses that may have no discernable impact on routine operation.
By examining lower-consequence, higher-frequency occurrences, companies may avoid those
rare incidents that cause major consequences.
The Center for Chemical Process Safety (CCPS) of the American Institute of Chemical
Engineers (AIChE) recognized the role of incident investigation and published the original
Guidelines for Investigating Chemical Process Incidents in 1992. This book helps to define and
refine the incident investigation systems to achieve positive results effectively and efficiently by
presenting a timely treatment of incident investigation represented in four stages as follows:
Incident—an unusual or unexpected occurrence, which either resulted in, or had the
potential to result in: • serious injury to personnel, • significant damage to property, •
adverse environmental impact, or • a major interruption of process operations.
3. The third step in incident investigation is to generate a report detailing facts, findings,
and recommendations. Typically, recommendations are written to reduce risk by:
4. After the investigation is completed and the findings and recommendations are issued
in the report, a system must be in place to implement those recommendations. This is
not part of the investigation itself, but rather the follow-up related to it. It is not
enough to put a technological, procedural, or administrative response into effect. The
action should be monitored periodically for effectiveness and, where appropriate,
modified to meet the intent of the original recommendation.
These four steps will result in the greatest positive effect when they are performed in an
atmosphere of openness and trust. Management must demonstrate by both word and deed that
the primary objective is not to assign blame, but to understand what happened for the sake of
preventing future incidents.
CSB and OSHA will be notified of chemical releases through the National Response Center
(NRC) and other media. In addition, both agencies will notify each other of chemical incidents
that meet one or more of the following criteria:
The standard calls for an investigation team, including at least one person knowledgeable in the
process involved, a contract employee when the incident involved contract work and others with
knowledge and experience to investigate and analyze the incident, and to develop a written
report on the incident. Reports must be retained for five years. Following link XX presents
selected OSHA and EPA incident investigation regulations.
Emergency planning and response
Emergency planning and response requires employers to develop and implement an emergency
action plan as a respond effectively to the release of hazardous chemicals. Regulation requires
companies with more than 10 employees to prepare an emergency plan and response in case of
hazardous chemical release but nevertheless, the smallest company should always be ready to
handle hazardous chemicals. The emergency action plan must include procedures for handling
small releases as well. This is done by taking into accounts several factors such as11:
Facility siting, the location of the control room to the process, and indicate clearly
identified area of refuge.
Indicate whether the plant is down-wind of a community
Community emergency action plans.
This element requires employers to develop and implement an emergency action plan according
to the requirements of 29 CFR 1910.38(a) and 29 CFR 1910.120(a), (p), and (q). Another source
of information on preparing emergency planning and response is the NFPA 471
Recommendation Practice for Responding to Hazardous Materials Incidents can be used as a
guidance to develop safe emergency plan and response to an incident.
Compliance audit
Compliance audit is a tool to help contractors identify PSM weaknesses and develop
recommendations. Each operating location that is required to utilize the PSM Performance
Baseline shall be subject to an audit of the PSM systems. The audit is a technique used to gather
sufficient facts and information to verify compliance with standards. The purpose of the audit is
to ensure that the PSM program is operating in an integrated and effective manner. The
performance baseline is based on industry standards and is designed to satisfy the regulatory
requirements.
All the contractors must conduct internal audits or self assessments for compliance with the PSM
Rule at least every 3 years to determine the degree to which plans and programs have been
implemented. There are two major objectives of audits. The first is to assess whether the
management system in place adequately addresses all elements of the PSM rule. The second
objective is to assess whether the management system has been adequately implemented for
every facility or process. Some types of audit are shown below:
11
Idem as 3
Trade secrets
The trade secrets provision of PSM requires that the employer provide all information necessary
to comply with PSM to all persons who need it. This does not preclude the employer from taking
steps necessary to safeguard the integrity of any information disclosed. It merely prohibits the
employer from using trade secrets as an excuse not to provide information to either employees or
contractors12.
12
Idem as 7