Process Safety Management of Highly Hazardous Chemicals 29 CFR 1910.119 (PSM)

1. Process Safety Management of Highly Hazardous Chemicals29 CFR 1910.119 (PSM)

2. Disasters That Led to Process Safety Management • 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

3. Clean Air Act Amendments—1990 • Requires Secretary of Labor along with EPA to promulgate a PSM standard • PSM standard must include a list of highly hazardous chemicals • Highly hazardous chemicals list must include: toxics, flammables, highly reactive and explosive materials

4. Minimum Program Requirements • Written safety information • Workplace hazard assessment • Consult with employees • Establish a system to respond to findings • Periodic review of assessments and response • Written operating procedures • Safety training and operating information

5. Minimum Program Requirements (cont.) • Appropriate information and training for contractors • Train and educate employees in emergency response • Establish a quality assurance program • Establish maintenance systems • Pre-start-up safety reviews • Management of change • Incident investigation

6. Application of PSM • Companies that process highly hazardous materials • Flammable liquids and gases in quantities in excess of 10,000 pounds

7. Initial Process Hazard Analysis Deadlines • 25% complete by May 26, 1994 • 50% complete by May 26, 1995 • 75% complete by May 26, 1996 • 100% complete by May 26, 1997

8. Process Safety Information • Toxicity • Permissible Exposure Limits • Physical Data • Reactivity Data • Corrosivity Data • Thermal and Chemical Stability Data

9. Process Technology • Block flow diagram or process flow diagram • Process chemistry • Maximum intended inventory • Upper and lower limits • Consequences of deviations

10. Information on Process Equipment • Materials of construction • Piping and instrument diagrams (PIDs) • Electrical classification • Relief system design • Ventilation system design • Design codes • Material and energy balances • Safety systems

11. Items the PHA Must Address • Hazards of the process • Identification of previous incidents • Engineering and administrative controls • Consequences of failure • Facility siting • Human factors • Qualitative evaluation of S and H effects

12. Operating Phases • Initial start-up • Normal operations • Temporary operations • Emergency shutdown • Emergency operations • Normal shutdown • Start-up following turnaround

13. Operating Limits • Consequences of deviation • Steps required to correct or avoid deviation

14. Safety and Health Considerations • Properties and hazards of the chemicals • Precautions to prevent exposures • Control measures to be taken • Quality control for raw materials/control of inventory • Special or unique hazards • Safety systems and their functions

15. Management of Change • Technical basis for the proposed change • Impact of the change on safety and health • Modifications of the operating procedures • Necessary time period for the change • Authorization requirements for the change

16. Training Requirements • Initial training • Prior to work assignment • Waved for those already in a process • Refresher training • Every three years • Training documentation

17. Contractor Requirements • PSM applies to contractors in or adjacent to a process performing • Maintenance • Repair • Turnaround • Major renovation • Specialty work • Does not apply to incidental contractors • Food service • Laundry • Delivery, etc.

18. Incident Investigation Reports • Date of incident • Date investigation began • Description of the incident • Factors contributing to the incident • Recommendations resulting from the investigation

19. Quiz 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

20. Quiz (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_________________.

21. Quiz Answers 1. True. The Process Safety Management Standard was drafted as a result of the Clean Air Act Amendments of 1990. 2. True. 3. False. The initial start-up of a process is an operating phase that must be included. 4. The items that a process hazard analysis must address include hazards of the process, identification of previous accidents, engineering. and administrative controls, consequences of failure, facility citing, human factors, and qualitative evaluation of S and H effects. 5. False. PSM does apply to contractors who work on or adjacent to a process.

22. Quiz Answers (cont.) 6. The PSM Standard applies to companies that either process highly hazardous materials or use flammable liquids and gases in excess of 10,000 pounds. 7. Process safety information includes toxicity, permissible exposure limits, physical data, reactivity data, corrosivity data, and thermal and chemical stability data. 8. True. Fault Tree Analysis is one form of an approved method of performing a process hazard analysis. 9. False. All change must have a technical basis in order to be authorized. 10. Two types of training required by the PSM standard are initial and refresher.