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 Grant…History
 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

And…to 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 - What’s 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

Remember…You Can’t 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? …Let’s Begin
 In the Next Session,
we will Begin to
Explore Each
Element of the
Standard and What
is Required to
Comply