Conducted & Prepared By: Green Circle, Inc

Conducted & Prepared By
GREEN CIRCLE, INC.

Integrated HSEQR Consulting Engineers, Scientists & Trainers (MoEF Recognized Environmental Research Laboratory)
An ISO: 9001, NABL/ISO: 17025, ISO14001, OHSAS: 18001 Certified Organization & GPCB approved Environment Auditor – Schedule II
CORPORATE OFFICE: Green Empire (Anupushpam), Beside Canara Bank, Nr. Yash Complex, Above Axis Bank, Gotri Main Road, VADODARA – 390 021,
(Gujarat), India
E-mail: info@greencircleinc.com
www.greencircleinc.com
Trainer
Mr. Pradeep Joshi
Group President & CEO
Green Group
GREEN CIRCLE INC.,
Integrated HSE Engineers, Scientists & Trainers
&
ENVERGY PROJECTS LTD.,
Turnkey Solutions in Environment & Energy
&
International Waste Research & Technology Centre
Transforming waste to opportunities
BSc(Chem),MSc(Env), Risk Engineer (Australia),MIIE, ADIS, Research Scholar (PhD Program), Lead
Auditor in ISO 14001 & OHSAS 18001, Member – Australian EHS
Auditors ,Accredited EHS Auditor in Singapore
34 + yrs of experience in the field of Environment Risk Assessment & Safety
Conducted various training programs on Behaviour Based Safety, Fire Prevention & Control, Risk
Assessment & HIRA,PSM,ZAP & HazOp Study Etc.
Executed various assignments of HazOp, HAZAN, QRA, Safety Audit, HSE Audit, Process Safety
Audit, Risk Assessment Job, Safety Analysis, EHS Manual Safety Reports & On-site Emergency Plan.
Fire Safety Audit, Hazardous Area Classification, Dow Fire & Explosion Index Calculation for more
than 50 industries including Petrochemicals, Oil & Gas, Power and Pharmaceutical companies.
Web:www.greencircleinc.com
Email: pradeep.joshi@gccipl.net / gccipl@rediffmail.com
Cell ++91 9824272844 / ++919426721681
Session Outline
You will be able to:
• Why PSM?
• What is PSM?
• Purpose of PSM
• PSM Standards & Guidelines
• PSM Elements
• Benefits of PSM
Process Accidents
What is PSM?
The proactive and systematic identification, evaluation, and
mitigation or prevention of chemical releases that could occur
as a result of failures in process, procedures, or equipment.
Good Safety = Good Business
PSM Evolution
Bhopal (’84): focused OSHA’s attention
Institute, WV(’85): shows disasters can happen here
1988-1991: concern of public & Congress

increases with each event
Feb. 24, 1992: standard in Federal Register (OSHA

29 CFR 1910.119)
Costs and Benefits of Good
Safety Performance
What we see
Direct Cost Direct Costs of Injuries
 Medical costs
 Wage indemnity
 Claims administration fees
Indirect Cost What we don’t see

The Hidden Costs of Injuries
 Damaged equipment, vehicles & goods
5X  Lost production and quality
 Process interruptions, yield losses
 Replacement labor / Overtime
 General liability costs
 Litigation
 Damage to customer relations & public image
PSM Standard & Guidelines
PSM Elements
PSM - Technology,
Facility & People
Personal & Process Safety
Developing an Organization
Natural
Instincts  Where do you want to be?
 How fast do you want to get there?
Injury
Rates
Supervision
Reactive
Errors
Failures Self
to
perform Depend Teams
ent Independent
Interdependent
• Management
Commitment
• Condition of
• Personal Knowledge,
Employment
• Fear/Discipline Commitment, and
• Rules/Procedures Standards
• Supervisor • Internalization • Help Others Conform
Control, Emphasis, • Personal Value • Others’ Keeper
• Care for Self • Networking Contributor
and Goals • Practice, Habits • Care for Others
• Value All People • Individual Recognition • Organizational Pride
• Training
What is Process Safety ?
Why PSM ?
PSM Background
1966, Aberfan, Glamorgan, South wales, collapse
of a colliery spoil tip,144 People Killed.
1976, Seveso, Italy, exposure of
2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)
2006, Abidjan, Toxic waste dump at Ivory Coast,
17 were killed, 30,000 Injured
1976, Seveso, Italy, TCDD-dioxin Release
from reactor.
1979-99, Valley of Drums, Bullitt County, Kentucky
Thousands of residents were affected before the site was cleaned by EPA
1984, Bhopal, India, Chemical Release and Fatalities.
Purpose of PSM
Requirements for preventing or minimizing the
consequences of catastrophic releases of chemicals that
are:
Toxic
• Reactive
• Flammable
• Explosive
These releases may result in toxic, fire or explosion
hazards
A number of catastrophic accidents have occurred

resulting in loss of life and great property damage.
PSM Benefits
• The major aim of PSM is to develop plant systems and
procedures to prevent unwanted releases , which may ignite and
cause toxic impacts, local fires, or explosions in plants -
effecting nearby communities.
• PSM also address issues related to the Operability ,
Productivity, Stability, and Quality output of processes,
leading to the specification of safeguards against undesirable
events.
• Proper safety management results in reduced exposure to
lawsuits, penalties, public liability claims, and hikes in
insurance premiums.
• Other intangible benefits include retention of corporate image.
Learning from Accidents ?
H2S Exposure & Fatality at RSPL
19
Incident – H2S Exposure
•On 2nd May 2018 Tanker was filled with Spent ML containing
Sodium Thiosuphate
•Afterwards, coloured liquid was added in it
•At around 7:15 PM tanker was parked outside RSPL
•Sample was taken around 9 PM and Clearance was given to
the quick sample check by Lab department around 11:30 PM
•Tanker was taken to unloading area at 4 AM on 3rd May.
•Transfer of material from one tanker to another was done
declaring another tanker empty and ready to be transferred the
material in it.
• 3 people were dead with the exposure of H2S in the process20
3 Critical Questions ?
PSM Program Goals
Targets protecting workers, on-site personnel.
OSHA list of Highly Hazardous Chemicals focused on
immediate, on-site hazards.
Seeks implementation across chemical processing industry of
key findings from incident investigations.
Requires maintaining documents and records as long as the
life of the process.
Is a “performance-based” standard, identifies minimum
program expectations.
Comparison
Occupational Health and Safety Process Safety
• Workplace rules • Collective commitment

• Worker training • Addresses events over
• Supervision which the individual
• Individual behaviors worker has little or no
• Safety equipment control
• Focus on individual well • Focus on systems
being • Broader impact – events
that could affect groups
of workers or general
public
Risk Based PSM
Framework
Commit to Process Safety Understand Hazards and Risk
 Process Safety Culture
 Process Safety Information
 Compliance with Standards
 Hazard Identification and Risk
 Process Safety Competency
Analysis
 Workforce Involvement
 Stakeholder Outreach
Manage Risk
Learn from Experience  Operating Procedures
 Incident Investigation  Safe Work Practices
 Measurement and Metrics  Asset Integrity and Reliability
 Auditing  Contractor Management
 Management Review and  Training and Performance
Continuous Improvement Assurance
 Management of Change
 Operational Readiness
 Conduct of Operations
www.greencircleinc.com  Emergency Management
The Future of BBS - Integrate
BBS into Mainstream SMS
Extend BBS process to cover entire accident causation chain –
i.e. CEO to workgroups
Process Culture &
Behavior Based Safety
Process Improvement
Action Plan
Employee ownership
Data collection
Observation Training
Pre-Task/JSA Training
Behavior Awareness Training
Observations/Feedback
JSA
Be-Safe Program Be-
Element 1 :
Employee Participation
It requires :
The involvement of employees from all levels of the
organization.
A written plan of action for implementing employee
consultation on the development of all elements of
process hazard management.
Provide access to all the information required to be
developed under the PSM.
•OSHA requires employers to consult with employees and
employee representatives regarding the development of
process hazard analyses and other elements of process
management. They must also provide employees and
their representatives with access to process hazard
analyses as well as all relevant information.
Classic Case Study:
On the night of December 2-3, 1984, Union
Carbide pesticide plant at Bhopal, India.
Death of over 2,800 people, caused
respiratory damage and eye damage
to over 20,000 others.
Element 2 : Process Safety
Information
PSI is a Complete and accurate written information concerning
process chemicals & process technology
process equipments & Process Flow Diagrams (PFDs)
Piping & Instrumentation Diagrams (P&IDs),
Operating and storage conditions
Material of Construction
Design Codes and Standards
Classic Case Study:

On 25th December,1998, Longford Esso Gas Explosion
2 Died and 8 Injured.
Inadequate training of operators and supervisors lack of knowledge of
process information.
PSI
PSI- Materials : Raw materials, chemicals , catalysts, products,
etc
PSI- Processes : Block flow or process flow diagram, Process
chemistry, Maximum intended inventory, Safe upper/lower limits
for such items as temperatures, pressures, flows or compositions
& Consequences of deviations, e.g. runaway reaction potential
PSI-Equipments : Materials of construction, P&IDs, Electrical
Classification, Relief system design & design basis, Ventilation
system design, Design codes and standards, Material & energy
balances & Safety systems
Prior to conducting any process hazard analysis, employers are
required by OSHA to develop a compilation of written PSM safety
topics. This will help the employer and employees to understand
the potential hazards of working with highly hazardous
chemicals.
Information regarding the highly hazardous chemicals in a process
consist of the following:
• Permissible exposure limits
• Toxicity
• Reactivity data
• Corrosivity data
• Physical data
• Thermal and chemical stability data
• Hazardous effects of inadvertent mixing of different materials
Information regarding the technology of a process include the
following:
• Process chemistry
• Maximum intended inventory
• A block flow or simplified process flow diagram
• Safe upper and lower limits for items such as flows, pressures,
temperatures or compositions
• An evaluation of the consequences of deviations, particularly
those affecting employees’ health and safety
Element 3 : Process
Hazard Analysis (PHA)
using one of the following methods:
• What-If
• Checklist
• What-If/Checklist
• Hazard and Operability Study (HAZOP)
• Failure Mode and Effects Analysis (FMEA)
• Fault Tree Analysis & QRA
• Appropriate equivalent methodology
Classic Case Study for PHA
On October 23, 1989, Phillips 66 Company Houston Chemical
Complex in Pasadena, Texas.
23 workers were killed and more than 130 were injured.
Lack of process Hazard Analysis; inadequate standard
operating procedures (SOPs)
Process Hazard Analysis
• Organized and systematic effort to identify and analyze the
significance of potential hazards associated with the
processing or handling of highly hazardous chemicals
• Causes/consequences of fires & explosions

• Releases of toxic or flammable chemicals
• Major spills of hazardous chemicals
• Methodology depends on the process & its characteristics
PHA Focuses On
• Equipment
• Instrumentation
• Utilities
• Human Actions
• External Factors
• What If?
• Checklist
• What If?/Checklist
• Hazard & Operability Study (HAZOP)
• Failure Mode & Effects Analysis (FMEA)
• Fault Tree Analysis (FTA)
PHA Must Address
• Hazards of the process
• Engineering & administrative controls
• Consequences of failure of controls
• Facility siting
• Human factors
• Evaluate potential effects to on-site personnel
from failure of controls
• Identification of previous incidents
Element 4 :
Operating Procedures
Operating Procedures:
Operating procedures include not only the steps for normal
operations, but for
upset conditions,
temporary operations,
start-up, and shutdown
basic hazards of exceeding operational limits,
safety and health information, and emergency operations.
Case Study for Operating Procedure
On 29th Oct 2009 at POL Depot, Jaipur.
12 Dead, Over 200 injured.
Accident was due to the non-observance
of normal safe procedure.
Element 5 : Training
It includes:
•Initial Training
•Refresher Training
•Training Documentation
OSHA mandates training for employees responsible for

operating covered processes. The training should
emphasize safety and health hazards, emergency
operations and best work practices. Initial OSHA PSM
training must be completed prior to starting the
assignment. Refresher training should be completed at
least once every three years.
Classic Case Study:
On January 7, 1998, Sierra Chemical
Company Mustang, Nevada
Four Dead and Six Injured.
Worker training was conducted
primarily in an ineffective, informal
manner that over-relied on use of on-
the-job training.
Poor management and worker training
led to a lack of knowledge of the
hazards involved in manufacturing
explosives.
Element 6 :
Contractor Plan
Contract employers are responsible for confirming that their
employees received training, are aware of potential
process hazards, understand emergency action plans, are
familiar with facility safety rules, and know to advise
employers of any hazards. This includes contract
employees on or near covered processes involved in
maintenance, repair, turnaround, renovation, or specialty
work.
•Must established a screening process when hiring and use
contractors
•A site injury and illness log for contractors must be
maintained.
•Evaluate safety performance and programs.
•Inform contract employers of hazards.
•Train contract employers on emergency
action plan.
Case Study for Contractor:

On November 16th 2008, a Storage Tank
9208 collapsed due to vacuum
generated in the tank.
Collapse was caused as Contractor worker
covered the vacuum relief device by
plastic while painting the tank.
Element 7 : Pre-Startup
Safety Review (PSSR)
PSSR includes the following:
Emergency Procedures
Operating Procedures
Design Specifications
Training
Safety Procedures
Classic Case Study:
November 25, 1998, Equilon Puget Sound Refinery in
Anacortes an explosion and fire erupted in the coking plant.
Six refinery workers were Killed.
Proper PSSR procedure should have been followed before
restarting the coking unit to avoid the accident.
Element 8 : Mechanical Integrity
A strong mechanical integrity program and proper
operations form the first line of defense against
accidental releases from process equipment.
Covered Equipment:
Pumps & Piping Systems
Relief Vent System, Controls,
Vessels & Tanks
Emergency Shutdown Systems
•Furnaces / Heaters
•Controls
Element 8 : Mechanical Integrity
Classic Case Study:
on 24th July 1984, Union Oil Company refinery in
Romeoville
Fourteen people were killed and Twenty Three injured.
Vapors escaped from a hairline crack at high-pressure
and finding the ignition source , explosion occurred.
Element 9 :
Quality Assurance
Assure new or modified equipment is suitable
Assure that equipment is correctly installed or
modified
Assure that maintenance materials, spare parts,
and equipment are suitable
Element 10 : Work Permit
• Procedure for Hot Work Permit
• The employer must issue a hot work permit for hot work
operations conducted on or near a covered process.
• The permit must be kept on file until completion of the hot
work operations.
Classic Case Study:
Metal can ignite and burn. The amount
of metal in packed beds is a significant fuel source.
Fire occurred in a 250 foot tall, 26 - 29 foot
diameter column.
If hot work is required, a thorough safety
and fire protection review should be
performed.
Element 11 :
Management Of Change
Prevent changes in the process from introducing
unacceptable hazards to workers.
Change of process technology
Change of facility
Organizational change
Variance procedures
Permanent changes
Temporary changes
Classic Case Study:

On June 1,1974 the Nypro Co. site at Flixborough,
England was severely damaged by a large explosion.
28 workers were killed and a further 36 suffered injuries.
Element 12 : Incident
Investigation
To investigate any incident that either did, or could have
resulted in release of PSM covered Chemical.
Incident investigation must be started within
48 hours after the incident.
Look for the root causes.
Prepare Incident Investigation Documents.
Element 12 : Incident
Investigation
Classic Case Study:
On April 22,1992, PEMEX Explosion in Guadalajara
252 people were killed and nearly 500 injured.
Due to gasoline pipe corrosion a hole created
and permitted, gasoline to leak into the ground
and into the main sewer pipe and because of
this explosion took place.
Element 13 :
Emergency Planning & Response
It includes:
Emergency Preparedness
Emergency Preparedness Evacuation Maps
Emergency Preparedness Assembly Points
Emergency Preparedness Emergency PPE
Emergency Preparedness Drills
Classic Case Study:

On, Saturday, April 26, 1986 The Chernobyl Nuclear Power
Plant,
Explosion lead to death of over 500,000 workers.
Element 14 :
Compliance Audits
Purpose:
The purpose of the Audits is to determine the practices and
procedure developed under the provision of the PSM Standard
are being followed and are effective.
“Certify” compliance every three years
• procedures are adequate
• are being followed
Conducted by at least one person
familiar with process.
Report of findings.
Document response to findings.
Retain last two audit reports.
What We Need ?
Questionnaire-Documents related to PSM 14
Elements
Maintenance Department
Safety Department
Production Department
HR Department
QA & QC Department
Stores
PSM Documentation
• GAP Audit Report
• PSM Manual
• Contractor’s Manual
• PSM Implementation
• Key Performance Indicator
• PSM Internal Audit Checklist
• PSM Review Audit
PSM Summary
Facilities with a process using a highly hazardous

chemical in an amount exceeding the thresh hold
quantity must develop, document and implement:
• Written hazard information, process analysis,
operating procedures, emergency procedures and
employee/contractor training.
• Maintenance procedures, inspections, incident
evaluations
• Re-evaluation of PSM information, procedures,
compliance audits of processes and related
equipment, and refresher training every three
years.
• PHA must be updated & revalidated every 3 years.
GREEN CIRCLE, INC.,
Integrated HSEQR Consulting Engineers, Scientists & Trainers
ISO 9001,14001 & OHSAS 18001 Certified Organization
(Ministry of Environment & Forests, India Approved Environmental
Laboratory

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Conducted & Prepared By: Green Circle, Inc

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Conducted & Prepared By

GREEN CIRCLE, INC.

Good Safety = Good Business

Institute, WV(’85): shows disasters can happen here

1988-1991: concern of public & Congress

Feb. 24, 1992: standard in Federal Register (OSHA

Indirect Cost What we don’t see

A number of catastrophic accidents have occurred

• Workplace rules • Collective commitment

Classic Case Study:

• Causes/consequences of fires & explosions

OSHA mandates training for employees responsible for

Case Study for Contractor:

Classic Case Study:

Classic Case Study:

• Key Performance Indicator

• PSM Internal Audit Checklist

• PSM Review Audit

Facilities with a process using a highly hazardous

Integrated HSEQR Consulting Engineers, Scientists & Trainers

ISO 9001,14001 & OHSAS 18001 Certified Organization

(Ministry of Environment & Forests, India Approved Environmental

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