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Preparing Your
Process Safety Management Program
for an OSHA Inspection
by Capaccio Environmental Engineering, Inc.
As a result of the extensive
investigations into the Bhopal India incident in 1984
and the Philips and ARCO explosions in 1989 and 1990,
the Occupational Safety and Health Administration (OSHA)
developed and implemented the Process Safety Management
(PSM) standard for existing facilities in 1992. In
recent years, however, incident investigations conducted
by the Chemical Safety Board (CSB) have shown that PSM
programs have been left idle, forgotten, or no longer
considered important or even understood by employers
after years of employee turnover. This lack of
understanding on the requirements for implementing and
maintaining a dynamic and effective PSM may have
contributed to recent explosions at refineries, chemical
plants, and other PSM regulated facilities.
In July of 2009, OSHA
launched a national emphasis program on the PSM standard
for Highly Hazardous Chemicals (HHC), 29 CFR 1910.119.
The CSB recommended OSHA develop this program after an
explosion at the BP America Refinery in Texas City, TX,
killed 15 people on March 23, 2005. Another incident in
which PSM compliance was lacking was the Danversport, MA
explosion on November 22, 2006, which destroyed an
entire neighborhood. With the emphasis program underway,
OSHA has started to inspect companies covered by the PSM
standard and PSM citations are on the rise.
OSHA did not design the PSM
standard to allow affected employers to summarize their
requirements in a written document and then place it on
a shelf and forget about it. On the contrary, OSHA
requires employers to implement an ever changing program
with associated documentation, which will continually
improve process and employee safety. PSM programs
require regular maintenance of key elements in order to
maintain compliance, and more importantly, to protect
workers and the facility from catastrophic explosions or
releases of toxic materials.
The 14 key elements required
by OSHA to demonstrate and maintain compliance with the
PSM standard are:
1. Employee Participation
Employers must develop a written program that details
how employees and contractors will be involved in the
planning process, including participation in the process
hazard analysis. The program must include methods of
providing access to information for all employees and
contractors, and methods of providing continued awareness
of the PSM program and its requirements.
2. Process Safety
Information
This section requires the compilation of written
process safety information for each HHC covered by the
standard. This information must include the hazards
involved with all processes, technologies, and equipment
used in a covered process. Process safety information
must be updated whenever there is a process or equipment
change and the compiled information must be maintained for
the life of the process.
Items that must be included in the process safety
information are:
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Physical characteristics of
chemicals: toxic, reactive, corrosive, explosive
limits
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Assessments of chemical reactions
from mixing of chemicals under a variety of
conditions: temperature, pressure, flow rates
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Equipment and process descriptions
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Block flow or simplified process
flow diagrams
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Process chemistries
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Maximum intended inventories of
regulated materials
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Design codes and standards employed
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Safe upper and lower limits for
temperature, pressure, flow rates, or compositions
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An evaluation of consequences of
deviation
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Material and energy balances for
processes built after 1999
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Materials of construction, and
operational limits of equipment
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Piping and instrument diagrams
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Electrical classifications
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Pressure relief design and design
basis
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Ventilation system designs
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3. Process Hazard Analysis
(PHA)
With all available process safety information in
place, employers are required to conduct a PHA on each
unit of the process to identify the causes and
consequences of hazards and necessary controls to be
implemented prior to the start of the process. Employers
must choose an appropriate method of PHA (Hazard
Operability Study, What-If Checklist, Fault-Tree Analysis
or other method) and develop a team and conduct the PHA
for each unit of the process. PHA must include a review
of past incidents. Follow up and close-out of necessary
actions which result from the PHA must be documented.
The PHA may need to be updated during the startup of new
equipment or during a major process change. The PHA must
be revalidated at least every five years, and maintained
for the life of the process.
4. Operation Procedures
PSM requires the development of written operating and
maintenance procedures. Standard operating procedures
(SOPs) apply to process technicians, and must include
current work practices, process properties, hazards,
process change of chemicals, and startup and shutdown
procedures. Maintenance procedures apply to maintenance
employees and must identify how a specific task is to be
completed. Any change in the process or equipment
requires updating of written procedures and training
before any work can be done. A reminder for a regularly
scheduled review of procedures needs to be put in place to
ensure they reflect current practices.
5. Pre-startup Safety
Review
The pre-startup safety review and process hazard
analysis work together during the startup process review.
During this review, the equipment and the construction are
carefully scrutinized. It is during this documented
process that operational and safety procedures are written
and tested and PHA items are closed out.
6. Employee Training
In order to prevent catastrophic events, employers
must provide adequate employee training. Training programs
must include and cover the following:
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Process overview and hazards of chemicals
used in the process
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Current work practices and procedures
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Training must be provided initially,
updated as necessary, and refresher training provided at
least every three years
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Contractors must train their employees on
the PSM and document the training
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Records of training, methods used to
administer the training, and methods used to evaluate
competency must be documented.
7. Contractors
Contractors fall under the same requirements of the
PSM standard as company employees. In addition, a written
contractor program is required to provide proof of
training and a review of contactor safety performance is
required at least annually.
8. Mechanical Integrity
Mechanical integrity is a term that applies to the
soundness of a plant process. Hazard analysis and
pre-start up safety review processes monitor the integrity
of the process. For example, if it is found that a piece
of equipment fails at a rate more frequently than the
maintenance schedule, the PHA would capture this and
require a change in the maintenance frequency.
Documentation of operational rounds, inspections, routine
maintenance, and testing should be recorded and
maintained.
9. Hot Work Permit
The purpose of the hot work permit is to protect
personnel from fires and explosions that could result from
hot work that is performed in the process area. Hot work
is defined as welding, cutting, or using a spark producing
device. A permit approval process must be in place that
evaluates the work and implements controls to prevent
fires or explosions prior to the start of such work.
10. Management of Change
Employers must develop a formal approval system to
evaluate process or equipment changes which would affect
the overall safety of the process. Changes may require
updates to process safety information, process hazard
analyses, operating procedures, training, and other
elements. The change approval must be documented and the
proper training set in place for each employee prior to
the change going into effect.
11. Incident Investigation
Incident investigation is a process that is triggered
when a catastrophic or a near catastrophic event occurs.
Incident investigation reports must be maintained for at
least five years. Incident investigations teams must be
assembled within 48 hours. All findings must be
addressed, and all of the action items identified during
the investigation must be corrected and documented.
12. Emergency Planning and
Response
Employers are required to develop a written emergency
planning and response document and provide training for
personnel who are required to respond. There are several
levels to be covered in the program including procedures
for employees to act upon, designated meeting points, key
contacts, and roles and responsibilities of people during
the event. The plan must also include how to deal with
emergencies that could affect the community.
13. Compliance Audit
Employers must conduct a compliance audit every 3
years to verify that the procedures, practices, and
documentation required under the PSM standard are adequate
and being followed at the facility. OSHA inspections will
often start with a review of documentation, such as a
review of the last two documented compliance audits.
Compliance audits that are conducted in-house are often
scrutinized more than those conducted by outside personnel
due to potential biases. Compliance audits must involve
persons knowledgeable in the process.
14. Trade Secrets
Many companies have specific trade secrets that need
to be kept confidential to protect them from their
competitors. This section of the standard allows companies
to protect themselves by entering into confidentiality
agreements with their employees.
Need Assistance?
The summary provides some basic
requirements for OSHA PSM facilities. CAPACCIO has
engineers and environmental, health and safety specialists
with extensive experience in assisting facilities with the
development, implementation, and maintenance of each
element required by a PSM program. For assistance with
compliance audits, assessing process safety information,
leading process hazard analysis teams, developing
operating procedures and training or other PSM elements
please contact: Geoff Gilbert at 509-970-0033 ext. 142 or
ggilbert@capaccio.com.
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