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Process Safety Management of Highly Hazardous & Explosive Chemicals

Process Safety Management of Highly Hazardous & Explosive Chemicals. Process Hazard Analysis (PHA’s) & Management of Change. Process Hazard Analysis (PHA). 1910.119(e). Process Hazard Analysis (PHA’s). Arguably the Most Difficult Part of Performing the Standard Performed by Your PSM Team

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Process Safety Management of Highly Hazardous & Explosive Chemicals

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  1. Process Safety Management of Highly Hazardous & Explosive Chemicals Process Hazard Analysis (PHA’s) & Management of Change

  2. Process Hazard Analysis (PHA) 1910.119(e)

  3. Process Hazard Analysis (PHA’s) • Arguably the Most Difficult Part of Performing the Standard • Performed by Your PSM Team • Takes Significant Time & Effort Remember…

  4. Block Diagram

  5. P&ID

  6. Process Equipment Numbering

  7. You Developed a List of Equipment Elements

  8. Choose a PHA Process Method • Must select a process hazard analysis (PHA) method • What-If; • Checklist; • What-If/Checklist; • Hazard and Operability Study (HAZOP); • Failure Mode and Effects Analysis (FMEA); • Fault Tree Analysis

  9. The PHA Must Address: • Equipment in the process • Hazards of the process • Identification of previous incidents • Engineering and administrative controls • Consequences of failure • Facility sitting • Human factors • Qualitative evaluation of S and H effects • Consequences of deviation • Steps required to correct or avoid deviation

  10. Let’s Choose the “What If” Method • In a What Ifhazard analysis, brainstorming techniques, in the form of What Ifquestions are used to identify possible deviations and weaknesses in design. Once identified, these concerns and their potential consequences are evaluated for risk.

  11. PHA What if Method

  12. PHA Risk Analysis

  13. PHA Risk Analysis

  14. Process Hazard Analysis • A PHA Process Must be Performed on Each Element of the Covered Process: • A PHA From Block Diagram to P&ID to Every Equipment Element to Determine What Might Happen if an Element of the Covered Process Fails

  15. …Continue the PHA Continue the PHA Process UNTIL…

  16. …Continue the PHA All Events

  17. …Continue the PHA All Deviations

  18. …Continue the PHA All Causes

  19. …Continue the PHA All Consequences

  20. …Continue the PHA All Safeguards

  21. …Continue the PHA All Risk Levels

  22. …Continue the PHA All Recommendations

  23. …Continue the PHA Are Completed for Every Element of… Every P&ID of… Every Block Diagram Section… Of the Entire Covered Process 5. Is Complete

  24. …Continue the PHA This Process Might Entail Thousands of Covered Process Elements …and Take Years to Complete

  25. Establish a Project Tracking Method for all PHA Activities

  26. What Do We Do With the PHA’s Developed? • Using the Risk Column, Begin: • Reviewing Defense Designs • Warning/Alarms to Warn of Deviations • Relief Systems • Ventilations Systems

  27. What Do We Do With the PHA’s Developed? With Those Analysis Complete: Begin Implementation of Engineering Controls to Minimize Potential of Releases

  28. Management of Change 1910.119(I)

  29. What if Our PHA’s Reveal the Need to Change Something In our System to Minimize the Potential for Release… We Must Use Management of Change (MOC)

  30. Management of Change - Why? • Many of the catastrophic accidents over the past few decades can be traced, in large part, to a management of change system that was not in place or was not functional (e.g., Flixborough, Bhopal).

  31. Management of Change (MOC)…We Must • Explain the purpose of MOC • Set the provisions to be considered for temporary change • Define and give example of change in equipment that requires MOC • Define and give examples of changes in procedures when need • Define and give examples of change in process technology

  32. Management of Change (MOC)…We Must • Define and give example of a major change • Define and give example of a minor change • Define and give examples of "replacement in kind” • Describe and list the procedures required for initiating and completing a MOC

  33. What Do We Do With the PHA’s Developed? • Any Changes in Defense Designs, or System Engineering will Require Management of Change • P&ID • Equipment Lists • Inspection/Testing/ Maintenance Procedures • PHA’s

  34. Management of Change (MOC) • MOC procedure should ensure that equipment and procedures are returned to their original conditions at the end of a temporary change • MOC forms/clearance sheets are acceptable control methods of tracking changes • More complex changes require a more "formal hazard evaluation" than simple changes (PHA not specifically mentioned).

  35. Management of Change (MOC) - Pre-Modification Issues • Check codes, standards, internal engineering specifications • Complete design review • Perform reactivity testing for new substances • Add materials to TSCA/SARA inventories • Complete safety and health impact review • Comply with safety and loss prevention requirements

  36. Management of Change (MOC) - Pre-Modification Issues • Complete maintenance review/revise spare parts list • Evaluate change against vent, relief, and flare capability • Complete industrial hygiene review • Review change against existing environmental permits • Obtain required approvals

  37. Management of Change (MOC) - Post-Modification Issues • Completed Process Safety Systems Review (PSSR) • Completed training on change for affected employees • SOPs marked-up • P&IDs, PFDs, plot plans and other affected Process Safety Information (PSI) marked-up • Training program modifications identified • Preventive maintenance program modifications identified

  38. Management of Change • Must Have a Method for Request, Tracking, Completion and Other Systems Affected.

  39. Process Hazard Analysis Summary • The Process Hazard Analysis is the Backbone of the Process Safety Management Program. • It Provides the Structure Upon Which PSM is Built • It Makes Available Pertinent Data & Safety Information to Design an Effective PSM Safety Program

  40. Management of Change Summary • We must establish and implement written procedures to manage changes except "replacements in kind" for a covered process. • If a Change in Design or Components is Required, Management of Change Must be Employed, Tracked, and Analyzed. • All PHA’s, P&ID’s & Required Procedures Must be Revised • Work-site employees and contract employers must be informed and trained on the changes prior to start-up.

  41. PSM Documentation - Technology Use • Consider the Use of Technology to: • Perform • Document • Track • Adjust • Maintain The PSM Program

  42. What’s Next? In the Next Session, we will Cover the Standard Operating Procedures and Safety Programs That Must Be Developed Based on the Results of the PHA’s

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