Process Safety Management

of Highly Hazardous &

Explosive Chemicals

Contractor Pre-Qualification, Emergency

Preparedness, Incident Investigation, Audits
& EPA Risk Management Plans (RMP)
Now That We’ve Developed
 Process Safety Information
 Process Material
Process Material Toxicity
Toxicity Information
Information
 Process Hazard Analysis (PHA’s)
 Mechanical Integrity
Mechanical Integrity Certificates
Certificates
 Management of
Management of Change
Change
 Inspection/Testing/Maintenance
 Operating Procedures
Operating Procedures
 Safe Work Procedures
 Training Programs
Training Programs
 Training for
Training for Contractors
Contractors
Now…
Contractor Management

1910.119(h)
PSM Contractors
 The employer, when selecting a
contractor, shall obtain and
evaluate information regarding
the contract employer's safety
performance and programs.
 The employer shall inform
contract employers of the
known potential fire, explosion,
or toxic release hazards related
to the contractor's work and the
process
Contractor Pre-Qualification &
Authorization
 The Standard Requires You to:
 Explain contractor qualification requirements
 List what is required for contractor pre-bid
awareness - pre-qualification
 List what is required for contractor post-bid
awareness - training & orientation
Specify contractor
 Specify contractor responsibilities
responsibilities
Describe contractor
 Describe contractor 300
300 Log
Log Requirements
Requirements
Evaluate Contractor
 Evaluate Contractor Performance
Performance
 List documentation requirements for contractors to
complete
complete
 Explain the use of a work authorization system
Contractor Pre-Qualification &
Authorization
 Typical Pre-Qualification Elements:
 Years Experience in Work Process
 Experience Modification Rate (EMR)
 OSHA Total Recordable Incident Rate and
Lost Work day Case Rate Information
 Safety Programs
 Training Documentation
Emergency Preparedness

1910.119(f)(1)(I)(D)
Emergency Preparedness
 Our Written
Our Written Plan
Plan Must:
Must:

 Define an
Define an emergency
emergency action
action plan
plan
 Define an
Define an emergency
emergency response
response plan
plan
 Describe aa Minimum
Describe Minimum emergency
emergency response
response plan
plan
 Describe procedures for handling small releases
 List the three levels of emergency response
 List procedures for emergency evacuation
 List requirements of alarm systems
 List training requirements
Emergency Preparedness
 The Standard Requires You to:
 Develop a Early Warning Method for Releases
(Sensors/Alarms)
(Sensors/Alarms)
Train on
 Train on the
the Meaning
Meaning of
of the
the Alarms
Alarms (May
(May be
be Multiple
Multiple
Alarms)
 Develop Emergency Evacuation Written Plans,
Evacuation Maps
Evacuation Maps &
& Assembly
Assembly Points
Points based
based on
on
Release Characteristics
Release Characteristics
Determine Emergency
 Determine Emergency PPE
PPE Requirements
Requirements
Train Employees
 Train Employees && Contractors
Contractors inin the
the Emergency
Emergency
Evacuation Plans
 Drill The Emergency Evacuation Plan At Last Once
Per Year
Per Year
Emergency Preparedness
 Warning Systems
must:
 Clearly Notify
Employees of
Employees of the
the
Hazardous Release
Hazardous Release
Employees &
 Employees &
Contractors must
Contractors must be
be
Trained in
Trained in the
the
Meaning of
Meaning of the
the
Alarm(s)
Alarm(s)
Emergency Preparedness
Evacuation Maps
Emergency Preparedness
Assembly Points

Alternate Assembly
Points Depending
on Prevailing
Weather Affecting
Release

Alternate
Assembly
Point
Emergency Preparedness
Emergency PPE
 Hazardous
Chemicals May
Require Emergency
PPE to be Worn
 FRP
 Escape Respirators
 Eye Protection i.e..
Refinery Goggles
Refinery Goggles
Emergency Preparedness
Drills
 At Least Annual
Emergency
Preparedness Drills
 This is not Just an
Emergency
Evacuation…
 but Could Include
HAZWOPR
Response
 Must Document
Results
Incident Investigation

1910.119(m)
Incident Investigation Program
Must Include the Following
 Describe the
Describe the purpose
purpose ofof incident
incident investigation
investigation
 List the
List the circumstances
circumstances or or occurrences,
occurrences, which
which require
require
formal incident
formal incident investigation
investigation
 List the
List the major
major investigation
investigation procedures
procedures that
that should
should bebe
followed
followed
 Explain the
Explain the list
list the
the responsibilities
responsibilities of
of the
the incident
incident
investigation team
investigation team
 Explain the
Explain the contents
contents of of an
an "Incident
"Incident Summary"
Summary" formform
 Explain the
Explain the contents
contents of of an
an "Incident
"Incident Description"
Description" form
form
 Explain the contents of an "Approvals, Follow-up and
Review" form
Review" form
 Explain the contents of a "Close-out" form
 Explain Corrective
Explain Corrective Actions
Actions Taken
Taken
Incidents Can Be Minor or Major -
Both Require Investigation
Incident Investigation
Documentation Must Include
 Date of incident
 Date investigation began
 Description of the incident
 Factors contributing to the incident
 Recommendations resulting from
the investigation
Incident Investigation

 Will Include Written

Documentation of all
Required Elements
Incident Investigation

Might Even Include a Flow Chart

Compliance Audits

1910.119(o)
Compliance Audits
 1910.119 states, "Employers shall certify that
they have evaluated compliance with the
provisions of this section at least every three
years to verify that the procedures and
practices developed under the standard are
adequate and are being followed."
Compliance Audits
 A List of factors that may increase the
frequency of compliance audits
 Results of Any OSHA Compliance Audits
Performed & Citations/Action Items Developed
 An Explanation of audit certification
 List Compliance Audit documentation
Compliance Audits
 Employers shall
Employers shall certify
certify that
that they
they have
have evaluated
evaluated
compliance with
compliance with the
the provisions
provisions of of this
this section
section at
at least
least
every three
every three years
years to
to verify
verify that
that the
the procedures
procedures and
and
practices developed
practices developed under
under thethe standard
standard areare adequate
adequate
and are
and are being
being followed
followed
 The compliance audit shall be conducted by at least
one person
one person knowledgeable
knowledgeable in in the
the process
process
 A report
A report of
of the
the findings
findings ofof the
the audit
audit shall
shall be
be
developed
 Compliance Audits Must be Performed Every 3 Years
Compliance Audits
 The Compliance Audit Process Typically
Includes the Following:

 Definition of the guidelines for an audit team

 A List the PSM elements that must be audited
 A List of the minimum contents of a final report of an
audit
audit
Explanation and
An Explanation
 An and list
list the
the Compliant
Compliant Audit
Audit reports
reports
that must be retained by the facility
 Compliance Audits

 OSHA PSM Citations

# Initial Penalty Final Penalty

1393 $25,058,853 $18,884,463

Compliance Audits
 Typical Types
Typical Types of
of OSHA
OSHA Serious
Serious Citations
Citations
 failure to
failure to maintain
maintain and
and follow
follow normal
normal operating
operating
procedures
procedures
 failure to
failure to provide
provide refresher
refresher training
training to
to process
process
operators
operators
 failure to correct deficiencies in process equipment in
aa safe
safe manner
manner
 failure to
failure to provide
provide necessary
necessary training
training to
to emergency
emergency
responders and fire brigade members
 Failure to perform audits as required every 3 years
Compliance Audits

 There are Companies that have

Covered Process, but have not
implemented any PSM Program.
 The Regulatory Exposure is to:
 Willful Citations
 Criminal Willful Citations
 Serious Citations
 Major Citation Penalties
PSM Audit Example Checklist
Items (Partial)
 Management Commitment to the PSM Program
 Is there evidence that an effective process safety management
program has
program has been
been set
set up
up and
and that
that explicit
explicit expectations,
expectations,
objectives and
objectives and goals
goals have
have been
been set
set with
with clear-cut,
clear-cut, desired
desired
outputs?
outputs?
 Have resources
Have resources been
been provided
provided in
in the
the form
form ofof personnel
personnel assigned
assigned
to provide implementation and continuation of each element?

 Have clear
Have clear lines
lines of
of responsibility
responsibility been
been established
established and and roles
roles and
and
responsibilities assigned?
responsibilities assigned?
 Is management
Is management commitment
commitment to to using
using all
all available
available resources
resources for
for
enhancing process
enhancing process safety
safety knowledge
knowledge atat all
all levels
levels of
of the
the
organization clearly demonstrated by actions?
 Does management encourage active participation in professional
and trade
and trade associations
associations for
for key
key PSM
PSM personnel
personnel to to ensure
ensure the
the
PSM system
PSM system keeps
keeps pace
pace withTest
withTest Practices?
Practices?
PSM Audit Example Checklist
Items (Partial)
 Process Hazard Analysis
 Does the
Does the PSM
PSM program
program establish
establish aa process
process hazard
hazard analysis
analysis
procedure in accordance with the PSM rule?
 Have personnel,
Have personnel, who
who will
will take
take part
part in
in PHA
PHA 痴 痴 ,, been
been provided
provided with
with
training in
training in the
the PHA
PHA technique
technique thatthat will
will be
be used
used for
for their
their study?
study?
 Does the
Does the PHA
PHA procedure
procedure establish
establish that
that the
the hazard
hazard identification
identification team
team
be multi-disciplined
be multi-disciplined in
in nature,
nature, capable
capable of of covering
covering such
such issues
issues as
as
maintenance, operations,
maintenance, operations, design,
design, inspection
inspection & & testing,
testing, safety,
safety, health
health
and environment, etc?
 Does the
Does the PHA
PHA procedure
procedure require
require that
that the
the PHA
PHA team
team leader
leader be
be
specially trained in the technique that will be used?
 Does documentation
Does documentation of of the
the hazard
hazard identification
identification process
process include
include all
all
issues, not only those resulting in findings or recommendations?

 Have PHA
Have PHA been
been conducted
conducted on
on all
all PSM-covered
PSM-covered processes
processes and
and ifif not,
not,
is there
is there an
an established
established schedule
schedule for
for completing
completing all
all PHA
PHA’s?
’s?
Compliance Audits
 Audit Findings must be Documented
 Actions must be Taken on All
Exceptions
 All Actions Affecting P&ID’s, PHA’s,
Mechanical Integrity Certificates,
Inspection/Testing/Maintenance,
Operating Procedures & Training
Procedures will Require Revision of
All of the Above
Compliance Audits

 Remember,

The Audit Process is Determine if there are

any weaknesses in the system or PSM
Program and to provide a report an
method to take action.
These actions can prevent catastrophic
release, injury and death.
Trade Secrets

1910.119(p)
Trade Secrets

 All Information Regarding the Process

Must be Made Available to Persons
Involved in the PSM Program Including
Trade Secrets
 Confidentiality Agreements are Allowed
Summary of PSM Elements
 Process Safety
Process Safety Information
Information
 Equipment ii the Process
Process Hazard
 Process Hazard Analysis
Analysis
 Operating Procedures
Employee Training
 Employee Training
 Training Contractors
Pre-Startup Safety
 Pre-Startup Safety Review
Review
Mechanical Integrity
 Mechanical Integrity of
of Equipment
Equipment
 Management of Change
Incident Investigation
 Incident Investigation
 Emergency Preparedness
Compliance Audits
 Compliance Audits
 Trade Secrets
EPA Risk Management Plans
(RMP) Basics
CAA 112(r)
One More Thing to Discuss…
EPA Risk Management Plans
(RMP)
 Many Times Companies Who Must
Comply with PSM, must also Comply
with the Requirements of EPA Risk
Management Plans (RMP)
 The RMP Standard was to be a Mirror
of the PSM Standard…Didn’t happen!
 Remember…PSM Protects the
Workforce, RMP Protects the
Community
EPA RMP
 Basic Requirements
 Executive summary
 Registration
 Off-site consequence analysis
 Five-year accident history
 Emergency response plan
 Prevention program summary information
 Certification

Sound Much Easier than PSM…Right?

All Public Facilities
in this Release Release
Plume Must be Plume
Identified &
Surveyed
EPA RMP

 Emergency Response Plan &

Prevention Plans Must Be Developed to
Prevent Accidental Release of the
Covered Chemical
EPA RMP 1998 Changes
Compliance Elements
 Follow-up / completion of PHA
recommendation
 Re-validation of your PHA every 5
years
 Compliance audits (required every
3 years)
 Follow-up / completion of
compliance audit
recommendations
EPA RMP 1998 Changes
Compliance Elements
 Annual review and certification of
operating procedures
 Employee training
 Updates related to system
modifications, inventory changes,
operational changes
 Off-site consequence analysis
Process Safety Management of
Highly Hazardous & Explosive
Chemicals & EPA Risk
Management Plans

Summary
Goals of the One Day Course
 Understand Why Process Safety Management (PSM)
Was Promulgated
Was Promulgated
 Understand That Even with PSM, Catastrophes are Still
Occurring
Occurring
 Understand Who
Understand Who is
is Covered
Covered && Exemptions
Exemptions
 Understand the Team Process to Developing a PSM
Program
Program
 Understand Each
Understand Each of
of the
the Elements
Elements of
of aa Properly
Properly Designed
Designed
& Implemented
& Implemented Program
Program and
and How
How to
to Begin
Begin the
the Process
Process
 Understand the
Understand the Basics
Basics of
of How
How PSM
PSM & & RMP
RMP Work
Work
Together to
Together to Protect
Protect the
the Workforce
Workforce &
& Surrounding
Surrounding
Community
Resources
 GTRI -
http://www.oshainfo.gatech.edu/index.html
 OSHA PSM Compliance Guidelines -
http://www.osha.gov/Publications/osha3133.html
 OSHA PSM for Construction 1926.64 -
http://www.osha.gov/doc/outreachtraining/htmlfile
s/psm.html
PSM One Day Review
PSM One Day Review
1. The Process Safety Management
Standard was drafted as a requirement
of the Clean Air Act. True or False
2. The PSM program must include a list
of highly hazardous chemicals. True or False
3. The initial start-up of a process is not
included as an operating phase under
the PSM Standard. True or False
4. List three items that the process hazard analysis must
address. ___________, __________ and __________.
5. PSM does not apply to contractors,
regardless of the work they are doing. True or False
PSM One Day Review (cont.)
6. The PSM Standard applies to companies that either process highly
_____________ materials or use _____________ liquids and gases
in excess of 10,000 pounds.
7. Process safety information includes:
______________, _____________ and _____________.
8. Fault tree analysis is one form of an
approved method of performing a process
hazard analysis. True or False
9. A technical basis is not required to change
a process covered by the PSM Standard. True or False
10. Two types of training required by the PSM
standard are ________________ and_________________.