Process Safety Management

of Highly Hazardous &

Explosive Chemicals

29CFR1910.119
Clearly Understanding the Standard
Information Provided under OSHA Susan Harwood Grant
#SH-17811-SH-8

Susan Harwood GrantHistory

Grants are awarded to provide training and

education programs for employers and

employees on the recognition, avoidance,
and prevention of safety and health hazards
in their workplaces.

PSM Was Chosen Given the Clear Need

Past Disasters
Current Year Disasters
Perceived Weakness in PSM Program

GTRI PSM Susan Harwood

Grant Program
GTRI is Offering:
Six (6) One Day Courses Around the

Southeastern United States

Four (4) One Week In-Depth Courses
Around the United States

Goals of the One Day Course

Understand

Why Process Safety Management (PSM)

Was Promulgated
Understand That Even with PSM, Catastrophes are Still
Occurring
Understand Who is Covered & Exemptions
Understand the Team Process to Developing a PSM
Program
Understand Each of the Elements of a Properly Designed
& Implemented Program and How to Begin the Process
Understand the Basics of How PSM & RMP Work
Together to Protect the Workforce & Surrounding
Community

Summary of the One Week Course

This is an In-Depth Study of the

Requirements of the Standard

Students will Actually Learn through a Real
Life Case Study How to Design Each Element
of the Process Safety Management Standard
Requirements
Students will Also Review the Basics of EPA
Risk Management Plan (RMP)

Rules of the Course

This is an Open Discussion Course
Relax and Learn
Ask Questions
Participate in Discussions
Share Experiences
Share Best Practices
Enjoy Yourself

Why Did OSHA Develop PSM?

Bhopal, India (1984)

2,000 deaths
Isocyanate release
Pasadena, TX (1989)
23 deaths, 132 injuries
Petroleum explosion
Cincinnati, OH (1990)
2 deaths
Explosion
Sterlington, LA (1991)
8 deaths, 128 injuries
Chemical release

Why Did OSHA Develop PSM?

In 1991, OSHA and
EPA respectively,
Released the
Standards, PSM &
RMP that Applies to
Those Companies
that are Affected by
The Standards.

Why Did OSHA Develop PSM?

Process Safety
Management is a
regulation, promulgated
by OSHA, intended to
prevent an incident like
the 1984 Bhopal Disaster
Andto Prevent Release
of:
Toxic,
Reactive,
Flammable, or
Explosive chemicals

Not Only PSM, But RMP

A great many industrial
facilities must comply
with OSHA's Process
Safety Management
(PSM) regulations as
well as the quite similar
EPA Risk Management
Program (RMP)
regulations (Title 40
CFR Part 68).

PSM vs. RMP - Whats the

Difference?
PSM - Like HAZCOM RMP-Like Sara Title III

Protects the
Workforce
Protects Contractors
Protects Visitors to
the Facility
Basically Protects the
Workplace

Protects the
Community
Protects the General
Public Around the
Facility
Protects Adjacent
Facilities Such as
Schools & Hospitals

The Standard Was Promulgated

in 1991 - Is it Working?

The Standard Was Promulgated

in 1991 - Is it Working?
BP Products Texas

City - January 2005

15 Workers Killed
170 Injured
Major Property
Damage
$21 Million in Fines

Application
1910.119(a)

What Facilities are Covered

Those Who Use Chemicals in Appendix A: A List of

highly hazardous chemicals, toxics and reactive
(Mandatory). Contains a listing of toxic and reactive
highly hazardous chemicals which present a potential
for a catastrophic event at or above the threshold
quantity

Examples

Chemical
Threshold Quantity (TQ)
Anhydrous Ammonia - 10,000 lbs
Chlorine 1,000 lbs

What Facilities are Covered

A process which

involves a
flammable liquid or
gas (as defined in
1910.1200(c) of this
part) on-site in one
location, in a
quantity of 10,000
pounds (4535.9 kg)
or more

What Facilities are Covered

Important Interpretation: 2007 - 06/11/2007 - OSHA

defines "on-site in one location" for Process Safety
Management of Highly Hazardous Chemicals standard

OSHA interprets "on-site in one location" to mean that the

standard applies when a threshold quantity of a highly
hazardous chemical (HHC) exists within an area under
the control of an employer or group of affiliated
employers. It also applies to any group of vessels that
are interconnected, or in separate vessels that are close
enough in proximity that the HHC could be involved in a
potential catastrophic release.

What Types of Industries?

Industries that Process Chemicals Such As:

Industrial Organics & Inorganics

Paints
Pharmaceuticals
Adhesives
Sealants and Fibers
Petrochemical facilities
Paper Mills
Food Processing with Anhydrous Ammonia over
the TQ

Exclusions
1910.119(a)(1)(ii)(A)

There are Exclusions

An employer is exempt from the requirements of PSM

when:
A threshold quantity of flammable liquids is stored in
atmospheric tanks or transferred without the benefit of
chilling or refrigeration
Hydrocarbon fuels used solely for workplace
consumption as a fuel (e.g., propane used for comfort
heating, gasoline for vehicle refueling),
If such fuels are not a part of a process containing
another highly hazardous chemical covered by this
standard

There are Exclusions

Retail facilities;

Oil or gas well drilling or

servicing operations; or,

Normally unoccupied
remote facilities

Definitions
1910.119(b)

Definitions

Atmospheric tank means a storage tank which

has been designed to operate at pressures
from atmospheric through 0.5 p.s.i.g. (pounds
per square inch gauge, 3.45 Kpa).
Boiling point means the boiling point of a liquid
at a pressure of 14.7 pounds per square inch
absolute (p.s.i.a.) (760 mm.).
Catastrophic release means a major
uncontrolled emission, fire, or explosion,
involving one or more highly hazardous
chemicals, that presents serious danger to
employees in the workplace.

Definitions

Facility means the buildings, containers or equipment

which contain a process.
Highly hazardous chemical means a substance
possessing toxic, reactive, flammable, or explosive
properties and specified by paragraph (a)(1) of this
section.
Hot work means work involving electric or gas welding,
cutting, brazing, or similar flame or spark-producing
operations.
Normally unoccupied remote facility means a facility which
is operated, maintained or serviced by employees who
visit the facility only periodically to check its operation and
to perform necessary operating or maintenance tasks. No
employees are permanently stationed at the facility.

Definitions

Process means any activity involving a highly

hazardous chemical including any use, storage,
manufacturing, handling, or the on-site movement of
such chemicals, or combination of these activities.
For purposes of this definition, any group of vessels
which are interconnected and separate vessels which
are located such that a highly hazardous chemical
could be involved in a potential release shall be
considered a single process.
Replacement in kind" means a replacement which
satisfies the design specification.
"Trade secret" means any confidential formula,
pattern, process, device, information or compilation of
information that is used in an employer's business

Employee Participation
1910.119(c)

Now that we are required to

comply, then what? First
Form a Team in Your

Company, i.e..

Process Engineers
Operators
Safety
Maintenance
Management
Consultants

RememberYou Cant Do it Alone!

Now that we are required to

comply, then what? Second
Form a Plan,

Determine:

Responsibilities
Duties
Reporting
Document Control
Progress Reports
Tracking Changes

Now that we are required to

comply, then what? Third

Review Scope of Project:

Process Safety Information

Equipment in the Process
Process Hazard Analysis
Operating Procedures
Employee Training
Training Contractors
Pre-Startup Safety Review
Mechanical Integrity of Equipment
Management of Change
Incident Investigation
Emergency Preparedness
Compliance Audits
Trade Secrets

Now that we are required to

comply, then what? Lets Begin
In the Next Session,

we will Begin to
Explore Each
Element of the
Standard and What
is Required to
Comply