Employee Involvement 29 CFR 1910.119 5189 Title 8 Are You Involved In PSM? Process Safety Management
What is PSM? • The regulations contain requirements for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable or explosive chemicals. • The establishment of process safety management regulations are intended to eliminate to a substantial degree, the risks to which employees are exposed in petroleum refineries, chemical plants and other similar facilities.
What is the purpose of PSM? • To protect our employees and the community • To protect the environment • The right way to do business • It increases employee involvement and awareness • Provides sustainable systems through on-going requirements • And it’s the Law!
1980s and early 1990s witnessed an alarming number of industrial accidents OSHA/EPA driven to prevent the unexpected releases of toxic, reactive, or flammable liquids and gases Trade unions seeking greater protection for represented employees Communities demanding protection for themselves and the environment Industry is supportive of OSHA/EPA’s movement to protect communities, employees, and surrounding environment Year Location Deaths Injuries 1984 Bhopal 2000+ 1988 PEPCON 2 350 1989 Phillips 23 350 1990 ARCO Chemical 17 1990 BASF 2 1991 IMC 8 128 1991 Union Carbide 1 History Behind PSM
14-PSM ElementsBuilding Blocks for Reducing Risks Employee Participation Process Safety Information Process Hazard Analysis Operating Procedures Training Contractor Program Pre-Startup Safety Review Mechanical Integrity Hot Work Permit Management of Change Incident Investigation Emergency Planning Compliance Audits Trade Secrets
What is PSM? Will not be covering the following PSM Elements: • Element 6: Contractors • Element 8: Mechanical Integrity • Element 12: Emergency Planning & Response • Element 13: Compliance Audits • Element 14: Trade Secrets
Element 1Employee Participation • Operating Procedures • Procedure Review • Development of procedures • Incident Investigation team members • Hazardous Energy Control (LOTO) • Maintaining LOTO Logs (documentation) • Employees participate in Hazops • Employee Participation is not limited to the items above. • A pro-active facility will involve their employees in the other PSM elements as well.
Element 2Process Safety Information • Hazards of the chemicals • Process Technology • Process Equipment • MSDS • Pressure Safety Valve Design • P&ID’s • Design Standards • Electrical Classification • Equipment Records • Safe Operating Limits • Written information is compiled and available to allow employees to understand the hazards posed by the process which shall include, but is not limited to the following:
Element 3Process Hazard Analysis (PHA or Hazop) • Hazards of the process • Previous incidents • Engineering controls for hazards • Administrative controls for hazards • Consequences of control failures • Facility siting • Human factors • Effect of failure on employees • A detailed study of each process unit to ensure the fundamental design adequately addresses the process hazards and identifies the safeguards to prevent accidental releases. • The study is conducted by a team including engineering and operations expertise and trained PHA facilitator.
Element 4Operating Procedures • Operating Limits • Consequence of deviation • Steps to correct or avoid deviations (Trouble Shooting) • Safety and Health Measures • Precautions to prevent over exposure • Action to take if exposure occurs • Hazards • Safety Systems • Lockout / tagout • Confined space entry • Opening process equip • Annual Certification • Current and accurate Objective • Develop, implement, and maintain clearly written detailed procedures for safely operating and maintaining a process during all operating modes. Required content in operating procedures:
Element 5Training Initial training • Each employee presently involved in operating or maintaining a process, and each employee before working in a newly assigned process, shall be trained in an overview of the process and in the operating procedures. • The training shall include emphasis on the specific safety and health hazards, procedures, and safe practices applicable to the employee's job tasks.
Element 5Training Refresher and supplemental training • At least every three years, and more often if necessary, refresher and supplemental training shall be provided to each maintenance or operating employee and other workers necessary to ensure safe operation of the facility.
Element 7Pre-Startup Safety Review (PSSR) • The pre-start up safety review shall confirm that prior to the introduction of acutely hazardous, flammable and explosive materials to a process: • Construction and/or equipment are in accordance with design specifications; • Safety, operating, maintenance, and emergency procedures are in place and are adequate; • For new facilities, a process hazard analysis has been performed and recommendations have been resolved or implemented before start-up; and modified facilities
Element 7Pre-Startup Safety Review (PSSR) • Training of each operating employee and maintenance worker has been completed. • The Pre-Start Up Safety Review shall involve employees with expertise in process operations and engineering.
Element 9Hot Work Permit Hot Work Permit • Shall develop and implement a written procedure for the issuance of "hot work" permits. • The permit shall certify that the applicable portions of the fire prevention and protection requirements have been implemented prior to beginning the hot work operations; • Indicate the date(s) authorized for hot work • Identify the equipment or facility on which hot work is to be done. • The permit shall be kept on file until completion of the hot work operations.
Element 10Management of Change (MOC) Management Of Change • Shall establish and implement written procedures to manage changes (except for "replacement in kind") to process chemicals, technology, and equipment, and changes to facilities. • Employees involved in the process shall be informed of, and trained in, the change in the process as early as practicable prior to its start up.
Element 11Incident Investigation Incident Investigation • Shall establish a written procedure for prompt reporting and investigating every incident which results in or could reasonably have resulted in a major accident. • Incident investigations shall be initiated no later than 48 hours following the incident. • An incident investigation team shall be established and consist of persons knowledgeable in the process involved including a contract employee if the incident involved work of the contractor, and other persons who are qualified to thoroughly investigate and analyze the incident. • Shall prepare a report and either provide a copy of the report or communicate the contents of the report to all employees and other personnel whose work assignments are within the facility, where the incident occurred at the time the incident occurred