Training Session Purpose • Goals/Objectives • Learn to ‘talk-the-talk’ • Learn why PSM and RMP exist • Learn a bit about ammonia • Learn the PSM ‘schedule’ • Understand the consequences of failure to follow • Learn to better understand your existing program • Understand requirement changes and trends in PSM and where EPA and OSHA focus now • Learn those areas that may change when your system changes
What are PSM and RMP? • Process Safety Management (PSM) • Occupational Safety & Health Administration (OSHA) • OSHA 29 CFR 1910.110 (Process Safety Management of Highly Hazardous Chemicals) • “inside” the plant (loosely speaking) • Risk Management Program (RMP) • Environmental Protection Agency (EPA) • EPA 40 CFR Part 68 (Accidental Release Prevention Requirements: Risk Management Programs Under Clean Air Act Section 112(r)(7) • “outside” the plant (loosely speaking) • Lingo • Are PSM/RMP Interchangeable? - No! • Department of Homeland Security • Site security plans • PLUS the General Duty Clause!!!
What is the General Duty Clause All About? - 1 • General Duty Clause(s) • EPA “Purpose and General Duty – “It shall be the objective of the regulations and programs authorized under this subsection to prevent the accidental release and to minimize the consequences of any such release of any substance listed pursuant to paragraph (3) or any other extremely hazardous substance. The owners and operators of stationary sources producing, processing, handling or storing such substances have a general duty, in the same manner and to the same extent as section 654, title 29 of the United States Code, to identify hazards which may result from such releases using appropriate hazard assessment techniques, to design and maintain a safe facility taking such steps as are necessary to prevent releases, and to minimize the consequences of accidental releases which do occur.” (Section 112(r)(1) of the Clean Air Act) • OSHA Act of 1970: “The owner shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.” (29 USC 654 )
What is the General Duty Clause All About? - 2 • General Duty Clause • You can be in violation if: • A known hazard exists • This hazard poses a threat to employees lives or personal safety • If the hazard is recognized and addressed by the industry • Employees are regularly exposed to that hazard • Very open ended • Basically, if the industry recommends it, you must do it!!!
The Unofficial Phases of PSM Implementation • Phase 1: Installation of Kryptonite! • PSM Programs Initially Created in accordance with OSHA/EPA • OSHA/EPA Knowledge Is Limited • Phase 2 – The Era of the Kryptonite! • Programs sit on the Shelf • OSHA/EPA Knowledge of NH3 PSM Begins to Grow • Phase 3 – Our Kryptonite Needs Fixed???!!! • Programs sit on the Shelf • OSHA/EPA Personnel Have Extensive Knowledge of NH3 PSM • The fines are coming!
Why PSM and RMP? - 1 • December 2, 1984 - Bhopal, India • 100,800 lbs of methyl isocyanate (MIC) gas released from underground storage tanks • Union Carbide India Limited (UCIL) • Potential employee sabotage • Nocturnal temperature inversion • Substandard living/housing conditions • By the following morning, over 2,000 dead and 300,000 were injured by morning • 1,500 people died in subsequent months • Emergency services were completely overwhelmed • Emergency Services/Police provided complicating instructions • Residents were unaware that the simple act of covering their faces with wet cloths and lying indoors on the floor provided effective protection against the gas
Why PSM and RMP? - 2 • December, 1984 – Institute, West Virginia • Union Carbide • Cyanide • 135 Hospitalized • No temperature inversion • America’s wake-up call!
Our Industry • Various Industry Organizations • International Institute of Ammonia Refrigeration (IIAR) • American National Standards Institute (ANSI) • American Society of Heating, Refrigerating, and Air Conditioning Engineers (ASHRAE) • American Society of Mechanical Engineers (ASME) • Refrigerating Engineers and Technicians Association (RETA) • Other organizations indirectly will affect as well
N H 3 H O 2 1 3 0 ALK The “What’s” About Ammonia • Basic Facts about ammonia • Ammonia is considered “highly hazardous” by OSHA • Ammonia is stable and naturally occurring • Ammonia is a strong alkali • Lighter than air (when not saturated with water • Ammonia has an “affinity” for water • Human body is approximately 65% water • Readily damages all body tissues • Target easily accessible/exposed water sources on body (eyes, ears, mouth, etc.) • Personal protective equipment (PPE) is required • Incompatible with copper (and copper alloys) and galvanized steel • Incompatible with certain kinds of rubber • Considered Non Flammable for Shipping • Upper and Lower Flammability Limits: 15-28% Concentration • Auto Ignition Temperature: 1,200+ °F
If It Does This to a Buck… • Dollar Shrinking – It Isn’t Inflation Either • If it can do this to a dollar, imagine what it will do to your unprotected eyes (which has MORE water than the bill)!!!
Ammonia and How It Affects You • Various Exposure Limits • 0-50 ppm - Detectable odor • 50-100 ppm - Mild eye, nose, and throat irritation; may develop tolerance in 1-2 weeks with no adverse effects thereafter • 140 ppm - Moderate eye irritation; no long-term tissue injury in exposures of less than 2 hours • 300 ppm - IDLH • 400 ppm - Moderate throat irritation • 700 ppm - Immediate eye irritation/injury • 1000-2500 ppm - Directly caustic to airway, spasms of the larynx and bronchospasms, severe eye and skin injury/irritation • 1700 ppm – Uncontrollable spasm of the larynx • 2500 ppm - Fatality (after half-hour exposure) • 2500-6500 ppm – permanent destruction of lung, sinus, and throat tissues. Also significant pain • 5000 ppm - Rapidly fatal exposure
Ammonia Ammonia Is Ammonia All THAT Terrible? • Keep Things in Perspective • Naturally Occurring • Commonly Used on Farms • Like Any Tool • If You Fail to Respect Ammonia, Ammonia Will Fail to Respect you
Why Ammonia Then? Why not Freon • Ammonia • Naturally occurring • Environmentally friendly • Self alarming • Inexpensive • If You Fail to Respect Ammonia, Ammonia Will Fail to Respect you • Freon and Fluorocarbons • Fire creates phosgene gas (mustard gas) • Suffocant (heavier than air) • Can’t smell it • Expensive
Who Has a Role? • EVERYONE! • Management • PSM Coordinator • Operators • Mechanics • Floor Personnel • Contractors! • Remember that these are REQUIRED by OSHA and EPA!!!
The “When’s” of PSM/RMP • Every Year • Safety Inspection Forms • Review Standard Operating Procedures (SOPS) and SIGN OFF • Review contractors performance • Every three years • Compliance Audit • Operator and Mechanic Refresher training • Every five (5) years • Submit RMP to the EPA • Process Hazard Analysis (PHA) revalidation • If you have electronic maintenance system (e.g., Maximo), this would be a good tool to use
Consequences – “OSHA/EPA Shock and Awe” - 1 • February 12, 2004 • John Morrell Company - Sioux Falls, South Dakota • People living within ¾ miles told to stay in home • 19,300 pound release from a 5” line • 77 Injuries • Full facility evacuation • High pressure liquid • $57,000 in fines • Federal investigators said that John Morrell should have done a better job of watching out for corrosion on pipes [mechanical integrity]…
Consequences – “OSHA/EPA Shock and Awe” - 2 • March 27, 1999 • Albertsons Distribution Center – Denver, Pennsylvania • NO RELEASE • Potential disgruntled employee • $170,000 • ONLY ammonia PSM related • October 10, 2010 • Tanner Industries, East Providence, Rhode Island • NO RELEASE • $149,080 • Emergency Response Plan didn’t address releases during times when facility isn’t occupied.
Consequences – “OSHA/EPA Shock and Awe” - 3 • January 22, 2000 • Wells Dairy – LeMar, Iowa • 100,000 pound release • Loss of ammonia compressor room and additional areas • $15,000 fine issued (originally $20,000) by Iowa’s OSHA • Worst enemy (fire) may have been their best friend? • As of October 2010, courts are still resolving the civil liability. Wells Dairy, the construction firm, and RVS were found to be at fault, but no financial rulings have been awarded
Consequences – “OSHA/EPA Shock and Awe” - 4 • September, 2010 • Tree Top Incorporated, Selah, Washington • 1,100 pounds of ammonia released from relief valve on July 10, 2009 • Facility incident occurred around 7pm am, but didn’t inform EPA until 1:30 pm on July 11, 2009 • $107,000 fine • September, 2010 • Pilgrim's Pride, Russellville, Alabama • Incident investigation from ammonia odors, tripping hazards, and cutting and stabbing injuries (Source: TimesDaily.com) • Improper Ventilation $5,000 fine • Inadequate emergency preparedness for ammonia release - $5,000 • Fines were issued as a result of other OSHA issues.
Consequences – “OSHA/EPA Shock and Awe” - 5 • October 28, 2010 • American Seafoods International, LLC, New Bedford, Massachusetts • NO INJURIES • $195,000 fine for inadequate PSM program including inadequate SOPs and lack of inspections (Mechanical Integrity Program) • Additional $84,000 fine for failure to update Process Safety Information and failure to investigate a 2001 incident • December 1, 2004 • Associated Milk Producers – New Ulm, Illinois • $88,400 fine • “…for failure to immediately notify the NRC of a 3,873-pound anhydrous ammonia release during a fire at the facility…” (approximately a 5 hour delay) and follow up wasn’t reported for 80 days • June 18, 2010 • Creekstone Farms Premium Beef, Arkansas City, Kansas • $130,00 fine • Inadequate or missing: employee participation, employee training, process hazard analysis, SOPs, emergency response program, and mechanical integrity
Consequences – “OSHA/EPA Shock and Awe” - 6 • LAST BUT NOT LEAST!!! • January 24, 2001 • Ammonia Theft • A couple of young thieves trying to steal the anhydrous ammonia from a nursing tank in a cotton field in Mississippi had an accident and the pressurized gas escaped, burning them and about 25 to 30 acres of the field. "They were extracting it from the tank, and because it was pressurized, they either couldn't cap it back off or couldn't contain it in their tank," an officer said. "The chemical began to release and got on their clothes and burned them. "They stripped off their clothes and ran to a creek where the sheriff found them buck naked and arrested them," he said. • Ammonia theft is a huge industry issue!
Consequences – “OSHA/EPA Shock and Awe” - 7 • Are these image you want your customers to remember about you?
PSM (and RMP) Elements/Programs • Employee Participation • Mechanical Integrity • Incident Investigations • Trade Secrets • Process Safety Information (PSI) • Process Hazard Analysis (PHA) • Standard Operating Procedures (SOPS) • Pre-Startup Safety Review • Management of Change • Contractor Qualification • Compliance Audit • [Operator and Mechanic] Training • Hot Work • Emergency Planning and Response
Employee Participation Program • General Program Description • Ensures employees are actively involved in the creation and maintenance of the PSM Program. • Basic Principals • To ensure employee involvement in the PSM/RMP Program • To ensure employee access to information to the PSM/RMP Program • To ensure proper program information dissemination • Specific Areas of Interest/Attention • Process Hazard Analysis (PHA) • Standard Operating Procedures (SOPs) • Consider basic ammonia awareness for all employees • DOCUMENTATION IS IMPORTANT!!!
Mechanical Integrity Program - 1 • General Program Description • Creates a structure of procedures and schedules to ensure safe operation of ammonia refrigeration equipment, piping, and systems. • Basic Principals • To properly identify all equipment in the ammonia refrigeration system • To ensure accurate operating and maintenance procedures have been created • To ensure adequate operator and mechanic training has been established • To ensure all necessary testing, inspection, and preventative maintenance is scheduled • To identify all equipment deficiencies and to take corrective actions to address those deficiencies
Mechanical Integrity Program - 2 • Specific Areas of Interest • Standard Operating Procedures • Operator Training • Maintenance Procedures • Computerized Databases (e.g., Maximo or other maintenance planning programs) • This is a MAJOR thrust of recent OSHA inspections • Do you have a Mechanical Integrity or “break it/fix it” program • Documentation, documentation, and more documentation
Incident Investigation Program • General Program Purpose • Implements procedures for investigating serious incidents and near‑misses and to prevent any recurrence of similar incidents. • Basic Principals • Define what constitutes an incident and a ‘near-miss’ • Create a structure for performing incident (and ‘near-miss’) investigations • Identify methods for addressing recommendations as the result of near incidents (and ‘near-misses’) • Establishing methods of communicating the status of the investigation team • 100 Pounds in 24 hours constitutes an ‘incident’ • Other Notes • Incident Investigations must be kept for five (5) years
Process Safety Information - 1 • General Program Purpose • To identify the hazards posed by anhydrous ammonia and the process (the refrigeration system) in which it is used including: • The specific [chemical] hazards of anhydrous ammonia • The technology used in the ammonia refrigeration system, and • The equipment used in the ammonia refrigeration system. • Basic Principals • Hazards of anhydrous ammonia including discussions of: • Toxicity information for anhydrous ammonia • Physical data of anhydrous ammonia • Reactivity of anhydrous ammonia • Corrosivity of anhydrous ammonia • Thermal and chemical mixing of anhydrous ammonia • Historical reactions to anhydrous ammonia exposure
EVAPORATORATIVE CONDENSER LIQUID RECEIVER SUCTION ACCUMULATOR MOTOR COMPRESSOR EVAPORATOR COIL Process Safety Information - 2 • Basic Principals (Continued) • Discussion of technology associated with the anhydrous ammonia refrigeration system • simplified process or block flow diagram • process chemistry • maximum intended inventory • safe lower and upper operating limits • consequences of deviation from normal operating limits • Lost or missing information/data
Process Safety Information - 3 • Basic Principals (Continued) • Discussion of equipment associated with and used in the ammonia refrigeration system • materials of construction • piping and instrumentation diagrams (P&IDs) • electrical classification • relief system design and design basis • ventilation system design and design basis • design codes and standards employed • material and energy balance (system load estimate) • safety systems
Process Safety Information - 4 • Piping and Instrumentation Diagrams (P&IDs) and Block/Process Flow Diagrams – The Difference Between…
Process Safety Information - 5 • Special Considerations • Relief Valve Calculations • Modifications to ANSI/ASHRAE 15 • More strict requirements for maximum distance from valve to header (or direct atmospheric discharge, when applicable) • Header diameter requirements can be affected • These lines are grandfathered if there is no modification to that run • This is a general duty clause issue and a code/ordinance compliance issue
Process Hazard Analysis - 1 • General Program Purpose • to analyze potential hazards associated with the anhydrous ammonia refrigeration system • Basic Principals • Establish an acceptable methodology • Determine appropriate potential hazards to address • Develop an appropriate PHA Team • Identify recommendations to improve the safety of the anhydrous ammonia refrigeration system • Create a structure to track recommendations and ensure their resolutions
Process Hazard Analysis - 2 • Acceptable Methodologies • What if • Checklist • What if/checklist • Hazard and Operability Study (HAZOP) • Failure and Mode and Effects Analysis (FMEA) • Fault Tree Analysis • “Or other equivalent method” • Generally What If/Checklists are performed
Process Hazard Analysis - 3 • What should be addressed? • Known hazards • Previous incidents • Engineering and administrative controls • Consequences of control failures • Facility site issues • Human Factors • A facility walk through and inspection should be performed by the Team! • Who does it? • Someone knowledgeable in the analysis method used • Someone knowledgeable in refrigeration plant design • Someone knowledgeable in refrigeration plant operations
Process Hazard Analysis - 4 • Additional Notes • A listing of recommendations must be made • Recommendations must be reviewed in a ‘timely’ manner • The EPA and OSHA both review for completeness during audits • The PHA should be an open dialog of potential hazards seen by the each member of the team based on their own experiences • The team should NOT be exclusively from the facility • Only each unique type of equipment needs to be reviewed and not each individual piece of equipment • Since over 5 years, perspectives, experience, personnel, and the methods of performing PHAs changes, it is recommended to ‘start over” and not just review the previous PHA. • Unofficial term/concept – equipment classification
Standard Operating Procedures - 1 • General Program Purpose • To provide clear instructions for anhydrous ammonia refrigeration system operation • Basic Principals • Identify safety and health information regarding anhydrous ammonia • Identify the required operating phases • Identification of safety features associated with each type of ammonia refrigeration equipment • Identify the operating limits of each type of ammonia refrigeration equipment
Standard Operating Procedures - 2 • Operating Phases • Initial Startup • Normal Operations • Temporary Operations • Emergency Shutdown • Emergency Operations • Normal Shutdown • Startup Following a Turnaround or after an Emergency Shutdown • Applicability • Not All Are Applicable to Ammonia Refrigeration • Some Are Combined (Emergency Shutdown and Emergency Operations)
Standard Operating Procedures - 3 • Safe Work Practices • Hot Work • Confined Space Entry • Lockout/Tagout (LOTO) • Line Opening Procedure • Other notes • When the system changes, the SOPs may as well • These must be annually reviewed • The annual review MUST be documented. The EPA and OSHA will fine you during an audit if you do not show record of SOP annual review! • These should be in easy access to operators/mechanics
Operator and Mechanic Training Program - 1 • General Program Purpose • provides on and off the job training for mechanic/operators to enable them to safely operate the ammonia refrigeration system • Basic Principals • Define qualification • Identify employees requiring training • If someone is touching the system, they better have records showing they are qualified to do what they are doing. • System wide training versus task training • Identify acceptable training types • Identify documentation to be completed • Define general requirements • Identify terms of refresher training • Identify appropriate ‘grandfathering’
Operator and Mechanic Training Program - 2 • Important Notes • What is Qualification • Task related training • System related training • Refresher Training • Every three (3) years (required) • Can be open ended and subjective • Internal and external • Annual review of training is recommended (this eliminates the confusion of the three year timing) • May be required if new equipment is added • Grandfathering • If you’ve been running the system since before May 26, 1992 • Documentation is the difference!!!
Contractor Qualification Program - 1 • General Program Purpose • evaluates contractors’ safety performance while ensuring contractors understand known hazards and can work safely • Basic Principals • Define means used to select contractors • Define the steps necessary to qualify a contactor • Identify the facility’s requirements and responsibilities to contractors working at the facility • Identify the contractors requirements and responsibilities
Contractor Qualification Program - 2 • Facility’s Responsibilities the Contractor • evaluating the contractor’s qualifications to perform the work projected • informing the contractor of known fire, explosion, and toxic release hazards (especially for non ammonia contractors) • explaining applicable OSHA regulations and how they affect the project • implementing and employing safe work practices contractor entry and exit • periodic contractor evaluation • providing facility safe work practices and emergency response plan • reviewing and evaluating the contractor’s safe work practices and training and ensuring that each contract employee has been informed and trained and understood the training • reviewing the design, engineering, and P & IDs for the project with the contractor • performing site walk through noting the hazards associated with ammonia system • maintaining a separate contractor employee injury and illness log related to the contractor’s work on the project
Contractor Qualification Program - 3 • Contractor’s Responsibilities to Their Employees • ensuring contractor employees are trained in the work practices (especially safe work practices) • instructing employees of known potential fire, explosion or toxic release hazards and the applicable provisions of emergency response plan • documenting that each employee has received and understood the instructions and training • ensuring that employees follows safety rules. • advising your company of any unique hazards presented by the contractor’s work or of any hazards found by the contractor’s work. • Additional Notes • Contractor information must be updated annually • Documentation is a MUST! • OSHA and the EPA will fine you if you do not have documentation for your contractors during audits
Management of Change Program • General Program Purpose • establishes and implements written procedures for managing changes to the technology, equipment, and procedures for the anhydrous ammonia refrigeration system. • Basic Principals • ensure all appropriate anticipated reviews are considered prior to commencing a refrigeration plant modification • Identify potential documentation changes required as the result of proposed changes • Ensure appropriate document updating is completed • Ensure design reviews are completed • Ensure safety and health considerations are addressed as the result of changes • Does NOT apply to “Replacement in Kind”… but…
Pre-Startup Safety Review Program • General Program Purpose • ensures all PSM and RMP Program related areas have been addressed prior to introducing ammonia to the refrigeration system. • Basic Principals • Ensure all PSM documentation has been modified to suit the modified facility prior to introducing ammonia into the new system/component • Ensure all necessary training has been performed regarding new equipment/processes prior to introducing ammonia into the new system/component
Compliance Audit Program • General Program Purpose • To verify that the PSM and RMP programs meets federal requirements and are implemented • Basic Principals • Establish audit frequency and timing • Define the requirements of the auditor and/or team • Identify the scope of the audit • Define requirements for addressing and tracking audit recommendations • Additional Notes • The “team” • You can have a team; however, having an individual with experience auditing programs is a must! • Don’t audit yourself! • Two most recent audits must be maintained
Trade Secret Program • General Program Purpose • Defines the rights of employees regarding access to PSM and the effects of trade secrets • Basic Principals • Regardless of potential industry secrets, the employer must inform employees working with the process about the process • Not applicable to ammonia refrigeration system except in rare circumstances
Risk Management Program - 1 • General Program Purpose • To summarize, document and communicate the elements of the Risk Management Program (RMP) to the Environmental Protection Agency (EPA) and other state and federal agencies and responders • Basic Principals • Identify the covered process • Describe the anhydrous ammonia refrigeration system in general as it relates to the facility and local community (executive summary) • Describe the Prevention Program 3 information
Risk Management Program - 2 • Basic Principals (Continued) • Management System • A listing of how the PSM/RMP will be administered, but more importantly, by whom • Risk Management PLAN vs. Risk Management PROGRAM • Risk Management PLAN is a document that is [re]submitted to the EPA at least every five (5) years or sooner if facility modifications require resubmittal • The Risk Management PROGRAM discusses how the PSM Program and Emergency programs are administered and provides details about the covered “process” • BOTH are required – Many facilities do not have a “Program”