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29CFR1910.119 Simple Keys to Compliance 29CFR1910.119 Process Safety Management of Highly Hazardous & Explosive Chemicals.

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Presentation on theme: "29CFR1910.119 Simple Keys to Compliance 29CFR1910.119 Process Safety Management of Highly Hazardous & Explosive Chemicals."— Presentation transcript:

1 29CFR Simple Keys to Compliance 29CFR Process Safety Management of Highly Hazardous & Explosive Chemicals

2 Objectives Define what is PSM and who is covered by the standard Define what is PSM and who is covered by the standard List the elements of the PSM standard List the elements of the PSM standard Locate additional resources Locate additional resources Define what is PSM and who is covered by the standard Define what is PSM and who is covered by the standard List the elements of the PSM standard List the elements of the PSM standard Locate additional resources Locate additional resources 2

3 What Is Process Safety Management? PSM: PSM: Addresses the management of Highly Hazardous Chemicals (HHC) Addresses the management of Highly Hazardous Chemicals (HHC) Integrates Integrates Technology Technology Operating Procedures Operating Procedures Standard management protocols Standard management protocols PSM: PSM: Addresses the management of Highly Hazardous Chemicals (HHC) Addresses the management of Highly Hazardous Chemicals (HHC) Integrates Integrates Technology Technology Operating Procedures Operating Procedures Standard management protocols Standard management protocols 3

4 Why Did OSHA Develop PSM? Past Disasters Past Disasters Current Disasters Current Disasters Perceived Weakness in PSM Program Perceived Weakness in PSM Program Past Disasters Past Disasters Current Disasters Current Disasters Perceived Weakness in PSM Program Perceived Weakness in PSM Program 4

5 Why Did OSHA Develop PSM? Bhopal, India (1984) Bhopal, India (1984) 2,000 deaths Isocyanate release 2,000 deaths Isocyanate release Pasadena, TX (1989) Pasadena, TX (1989) 23 deaths, 132 injuries Petroleum explosion 23 deaths, 132 injuries Petroleum explosion Cincinnati, OH (1990) Cincinnati, OH (1990) 2 deaths Explosion 2 deaths Explosion Sterlington, LA (1991) Sterlington, LA (1991) 8 deaths, 128 injuries Chemical release 8 deaths, 128 injuries Chemical release Bhopal, India (1984) Bhopal, India (1984) 2,000 deaths Isocyanate release 2,000 deaths Isocyanate release Pasadena, TX (1989) Pasadena, TX (1989) 23 deaths, 132 injuries Petroleum explosion 23 deaths, 132 injuries Petroleum explosion Cincinnati, OH (1990) Cincinnati, OH (1990) 2 deaths Explosion 2 deaths Explosion Sterlington, LA (1991) Sterlington, LA (1991) 8 deaths, 128 injuries Chemical release 8 deaths, 128 injuries Chemical release 5

6 In 1991, OSHA and EPA respectively, Released the Standards, PSM & RMP that Applies to Those Companies that are Affected by The Standards. Why Did OSHA Develop PSM? 6

7 Process Safety Management is a regulation, promulgated by OSHA, intended to prevent an incident like the 1984 Bhopal Disaster And…to Prevent Release of: Toxic, Toxic, Reactive, Reactive, Flammable, or Flammable, or Explosive chemicals Explosive chemicals Process Safety Management is a regulation, promulgated by OSHA, intended to prevent an incident like the 1984 Bhopal Disaster And…to Prevent Release of: Toxic, Toxic, Reactive, Reactive, Flammable, or Flammable, or Explosive chemicals Explosive chemicals Why Did OSHA Develop PSM? 7

8 Not Only PSM, But RMP A great many industrial facilities must comply with OSHA's Process Safety Management (PSM) regulations as well as the CAA 112(r) EPA Risk Management Program (RMP) regulations (Title 40 CFR Part 68). 8

9 PSM vs. RMP - Whats the Difference? RMP-Like Sara Title III Protects the Community Protects the General Public Around the Facility Protects Adjacent Facilities Such as Schools & Hospitals PSM - Like HAZCOM PSM - Like HAZCOM Protects the Workforce Protects the Workforce Protects Contractors Protects Contractors Protects Visitors to the Facility Protects Visitors to the Facility Basically Protects the Workplace Basically Protects the Workplace PSM - Like HAZCOM PSM - Like HAZCOM Protects the Workforce Protects the Workforce Protects Contractors Protects Contractors Protects Visitors to the Facility Protects Visitors to the Facility Basically Protects the Workplace Basically Protects the Workplace 9

10 The Standard Was Promulgated in Is it Working? 10

11 BP Products Texas City - March 2005 BP Products Texas City - March Workers Killed 15 Workers Killed 170 Injured 170 Injured Major Property Damage Major Property Damage $50.6 Million in Fines $50.6 Million in Fines BP Products Texas City - March 2005 BP Products Texas City - March Workers Killed 15 Workers Killed 170 Injured 170 Injured Major Property Damage Major Property Damage $50.6 Million in Fines $50.6 Million in Fines The Standard Was Promulgated in Is it Working? 11

12 Application Application Exclusions Exclusions Definitions Definitions Employee Participation Employee Participation Hazards of the Process Hazards of the Process Toxicity Toxicity Technology of the Process Technology of the Process Equipment in the Process Equipment in the Process Mechanical Integrity Mechanical Integrity Inspection & Testing Inspection & Testing Quality Assurance Quality Assurance Application Application Exclusions Exclusions Definitions Definitions Employee Participation Employee Participation Hazards of the Process Hazards of the Process Toxicity Toxicity Technology of the Process Technology of the Process Equipment in the Process Equipment in the Process Mechanical Integrity Mechanical Integrity Inspection & Testing Inspection & Testing Quality Assurance Quality Assurance The Elements of the PSM Standard Process Hazard Analysis Process Hazard Analysis Management of Change Management of Change Operating Procedures Operating Procedures Safe Work Practices Safe Work Practices Training Training Contractor Management Contractor Management Emergency Planning & Response Emergency Planning & Response Incident Investigation Incident Investigation Compliance Audits Compliance Audits Trade Secrets Trade Secrets 12

13 Application Application Exclusions Exclusions Definitions Definitions Employee Participation Employee Participation Hazards of the Process Hazards of the Process Toxicity Toxicity Technology of the Process Technology of the Process Equipment in the Process Equipment in the Process Mechanical Integrity Mechanical Integrity Inspection & Testing Inspection & Testing Application Application Exclusions Exclusions Definitions Definitions Employee Participation Employee Participation Hazards of the Process Hazards of the Process Toxicity Toxicity Technology of the Process Technology of the Process Equipment in the Process Equipment in the Process Mechanical Integrity Mechanical Integrity Inspection & Testing Inspection & Testing The Elements of the PSM Standard Process Hazard Analysis Process Hazard Analysis Management of Change Management of Change Operating Procedures Operating Procedures Safe Work Practices Safe Work Practices Training Training Contractor Management Contractor Management Emergency Planning & Response Emergency Planning & Response Incident Investigation Incident Investigation Compliance Audits Compliance Audits Trade Secrets Trade Secrets 13

14 Application Application Exclusions Exclusions Definitions Definitions Employee Participation Employee Participation Hazards of the Process Hazards of the Process Toxicity Toxicity Technology of the Process Technology of the Process Equipment in the Process Equipment in the Process Mechanical Integrity Mechanical Integrity Inspection & Testing Inspection & Testing Quality Assurance Quality Assurance Application Application Exclusions Exclusions Definitions Definitions Employee Participation Employee Participation Hazards of the Process Hazards of the Process Toxicity Toxicity Technology of the Process Technology of the Process Equipment in the Process Equipment in the Process Mechanical Integrity Mechanical Integrity Inspection & Testing Inspection & Testing Quality Assurance Quality Assurance The Elements of the PSM Standard Process Hazard Analysis Process Hazard Analysis Management of Change Management of Change Operating Procedures Operating Procedures Safe Work Practices Safe Work Practices Training Training Contractor Management Contractor Management Emergency Planning & Response Emergency Planning & Response Incident Investigation Incident Investigation Compliance Audits Compliance Audits Trade Secrets Trade Secrets 14

15 Application Application Exclusions Exclusions Definitions Definitions Employee Participation Employee Participation Hazards of the Process Hazards of the Process Toxicity Toxicity Technology of the Process Technology of the Process Equipment in the Process Equipment in the Process Mechanical Integrity Mechanical Integrity Inspection & Testing Inspection & Testing Quality Assurance Quality Assurance Application Application Exclusions Exclusions Definitions Definitions Employee Participation Employee Participation Hazards of the Process Hazards of the Process Toxicity Toxicity Technology of the Process Technology of the Process Equipment in the Process Equipment in the Process Mechanical Integrity Mechanical Integrity Inspection & Testing Inspection & Testing Quality Assurance Quality Assurance The Elements of the PSM Standard Process Hazard Analysis Process Hazard Analysis Management of Change Management of Change Operating Procedures Operating Procedures Safe Work Practices Safe Work Practices Training Training Contractor Management Contractor Management Emergency Planning & Response Emergency Planning & Response Incident Investigation Incident Investigation Compliance Audits Compliance Audits Trade Secrets Trade Secrets 15

16 Application Application Exclusions Exclusions Definitions Definitions Employee Participation Employee Participation Hazards of the Process Hazards of the Process Toxicity Toxicity Technology of the Process Technology of the Process Equipment in the Process Equipment in the Process Mechanical Integrity Mechanical Integrity Inspection & Testing Inspection & Testing Quality Assurance Quality Assurance Application Application Exclusions Exclusions Definitions Definitions Employee Participation Employee Participation Hazards of the Process Hazards of the Process Toxicity Toxicity Technology of the Process Technology of the Process Equipment in the Process Equipment in the Process Mechanical Integrity Mechanical Integrity Inspection & Testing Inspection & Testing Quality Assurance Quality Assurance The Elements of the PSM Standard Process Hazard Analysis Process Hazard Analysis Management of Change Management of Change Operating Procedures Operating Procedures Safe Work Practices Safe Work Practices Training Training Contractor Management Contractor Management Emergency Planning & Response Emergency Planning & Response Incident Investigation Incident Investigation Compliance Audits Compliance Audits Trade Secrets Trade Secrets 16

17 Application Application Exclusions Exclusions Definitions Definitions Employee Participation Employee Participation Hazards of the Process Hazards of the Process Toxicity Toxicity Technology of the Process Technology of the Process Equipment in the Process Equipment in the Process Mechanical Integrity Mechanical Integrity Inspection & Testing Inspection & Testing Quality Assurance Quality Assurance Application Application Exclusions Exclusions Definitions Definitions Employee Participation Employee Participation Hazards of the Process Hazards of the Process Toxicity Toxicity Technology of the Process Technology of the Process Equipment in the Process Equipment in the Process Mechanical Integrity Mechanical Integrity Inspection & Testing Inspection & Testing Quality Assurance Quality Assurance The Elements of the PSM Standard Process Hazard Analysis Process Hazard Analysis Management of Change Management of Change Operating Procedures Operating Procedures Safe Work Practices Safe Work Practices Training Training Contractor Management Contractor Management Emergency Planning & Response Emergency Planning & Response Incident Investigation Incident Investigation Compliance Audits Compliance Audits Trade Secrets Trade Secrets 17

18 Application Application Exclusions Exclusions Definitions Definitions Employee Participation Employee Participation Hazards of the Process Hazards of the Process Toxicity Toxicity Technology of the Process Technology of the Process Equipment in the Process Equipment in the Process Mechanical Integrity Mechanical Integrity Inspection & Testing Inspection & Testing Quality Assurance Quality Assurance Application Application Exclusions Exclusions Definitions Definitions Employee Participation Employee Participation Hazards of the Process Hazards of the Process Toxicity Toxicity Technology of the Process Technology of the Process Equipment in the Process Equipment in the Process Mechanical Integrity Mechanical Integrity Inspection & Testing Inspection & Testing Quality Assurance Quality Assurance The Elements of the PSM Standard Process Hazard Analysis Process Hazard Analysis Management of Change Management of Change Operating Procedures Operating Procedures Safe Work Practices Safe Work Practices Training Training Contractor Management Contractor Management Emergency Planning & Response Emergency Planning & Response Incident Investigation Incident Investigation Compliance Audits Compliance Audits Trade Secrets Trade Secrets 18

19 Application Application Exclusions Exclusions Definitions Definitions Employee Participation Employee Participation Hazards of the Process Hazards of the Process Toxicity Toxicity Technology of the Process Technology of the Process Equipment in the Process Equipment in the Process Mechanical Integrity Mechanical Integrity Inspection & Testing Inspection & Testing Quality Assurance Quality Assurance Application Application Exclusions Exclusions Definitions Definitions Employee Participation Employee Participation Hazards of the Process Hazards of the Process Toxicity Toxicity Technology of the Process Technology of the Process Equipment in the Process Equipment in the Process Mechanical Integrity Mechanical Integrity Inspection & Testing Inspection & Testing Quality Assurance Quality Assurance The Elements of the PSM Standard Process Hazard Analysis Process Hazard Analysis Management of Change Management of Change Operating Procedures Operating Procedures Pre-Start up Safety Review Pre-Start up Safety Review Hot Work Permit Hot Work Permit Safe Work Practices Safe Work Practices Training Training Contractor Management Contractor Management Emergency Planning & Response Emergency Planning & Response 19

20 Application Application Exclusions Exclusions Definitions Definitions Employee Participation Employee Participation Hazards of the Process Hazards of the Process Toxicity Toxicity Technology of the Process Technology of the Process Equipment in the Process Equipment in the Process Mechanical Integrity Mechanical Integrity Inspection & Testing Inspection & Testing Quality Assurance Quality Assurance Application Application Exclusions Exclusions Definitions Definitions Employee Participation Employee Participation Hazards of the Process Hazards of the Process Toxicity Toxicity Technology of the Process Technology of the Process Equipment in the Process Equipment in the Process Mechanical Integrity Mechanical Integrity Inspection & Testing Inspection & Testing Quality Assurance Quality Assurance The Elements of the PSM Standard Process Hazard Analysis Process Hazard Analysis Management of Change Management of Change Operating Procedures Operating Procedures Pre-Start up Safety Review Pre-Start up Safety Review Hot Work Permit Hot Work Permit Safe Work Practices Safe Work Practices Training Training Contractor Management Contractor Management Emergency Planning & Response Emergency Planning & Response 20

21 Application Application Exclusions Exclusions Definitions Definitions Employee Participation Employee Participation Hazards of the Process Hazards of the Process Toxicity Toxicity Technology of the Process Technology of the Process Equipment in the Process Equipment in the Process Mechanical Integrity Mechanical Integrity Inspection & Testing Inspection & Testing Quality Assurance Quality Assurance Application Application Exclusions Exclusions Definitions Definitions Employee Participation Employee Participation Hazards of the Process Hazards of the Process Toxicity Toxicity Technology of the Process Technology of the Process Equipment in the Process Equipment in the Process Mechanical Integrity Mechanical Integrity Inspection & Testing Inspection & Testing Quality Assurance Quality Assurance The Elements of the PSM Standard Process Hazard Analysis Process Hazard Analysis Management of Change Management of Change Operating Procedures Operating Procedures Pre-Start up Safety Review Pre-Start up Safety Review Hot Work Permit Hot Work Permit Safe Work Practices Safe Work Practices Training Training Contractor Management Contractor Management Emergency Planning & Response Emergency Planning & Response 21

22 Application Application Exclusions Exclusions Definitions Definitions Employee Participation Employee Participation Hazards of the Process Hazards of the Process Toxicity Toxicity Technology of the Process Technology of the Process Equipment in the Process Equipment in the Process Mechanical Integrity Mechanical Integrity Inspection & Testing Inspection & Testing Quality Assurance Quality Assurance Application Application Exclusions Exclusions Definitions Definitions Employee Participation Employee Participation Hazards of the Process Hazards of the Process Toxicity Toxicity Technology of the Process Technology of the Process Equipment in the Process Equipment in the Process Mechanical Integrity Mechanical Integrity Inspection & Testing Inspection & Testing Quality Assurance Quality Assurance The Elements of the PSM Standard Process Hazard Analysis Process Hazard Analysis Management of Change Management of Change Operating Procedures Operating Procedures Pre-Start up Safety Review Pre-Start up Safety Review Hot Work Permit Hot Work Permit Safe Work Practices Safe Work Practices Training Training Contractor Management Contractor Management Emergency Planning & Response Emergency Planning & Response 22

23 Application Application Exclusions Exclusions Definitions Definitions Employee Participation Employee Participation Hazards of the Process Hazards of the Process Toxicity Toxicity Technology of the Proce ss Technology of the Proce ss Equipment in the Process Equipment in the Process Mechanical Integrity Mechanical Integrity Inspection & Testing Inspection & Testing Quality Assurance Quality Assurance Application Application Exclusions Exclusions Definitions Definitions Employee Participation Employee Participation Hazards of the Process Hazards of the Process Toxicity Toxicity Technology of the Proce ss Technology of the Proce ss Equipment in the Process Equipment in the Process Mechanical Integrity Mechanical Integrity Inspection & Testing Inspection & Testing Quality Assurance Quality Assurance The Elements of the PSM Standard Process Hazard Analysis Process Hazard Analysis Management of Change Management of Change Operating Procedures Operating Procedures Pre-Start up Safety Review Pre-Start up Safety Review Hot Work Permit Hot Work Permit Safe Work Practices Safe Work Practices Training Training Contractor Management Contractor Management Emergency Planning & Response Emergency Planning & Response 23

24 Application Application Exclusions Exclusions Definitions Definitions Employee Participation Employee Participation Hazards of the Process Hazards of the Process Toxicity Toxicity Technology of the Proce ss Technology of the Proce ss Equipment in the Process Equipment in the Process Mechanical Integrity Mechanical Integrity Inspection & Testing Inspection & Testing Quality Assurance Quality Assurance Application Application Exclusions Exclusions Definitions Definitions Employee Participation Employee Participation Hazards of the Process Hazards of the Process Toxicity Toxicity Technology of the Proce ss Technology of the Proce ss Equipment in the Process Equipment in the Process Mechanical Integrity Mechanical Integrity Inspection & Testing Inspection & Testing Quality Assurance Quality Assurance The Elements of the PSM Standard Process Hazard Analysis Process Hazard Analysis Management of Change Management of Change Operating Procedures Operating Procedures Pre-Start up Safety Review Pre-Start up Safety Review Hot Work Permit Hot Work Permit Safe Work Practices Safe Work Practices Training Training Contractor Management Contractor Management Emergency Planning & Response Emergency Planning & Response 24

25 The Elements of the PSM Standard Lets Explore Some of the Elements… 25

26 Application (a) (a) 26

27 What Facilities are Covered Those Who Use Chemicals in Appendix A: A List of highly hazardous chemicals, toxics and reactive (Mandatory). Contains a listing of toxic and reactive highly hazardous chemicals which present a potential for a catastrophic event at or above the threshold quantity Those Who Use Chemicals in Appendix A: A List of highly hazardous chemicals, toxics and reactive (Mandatory). Contains a listing of toxic and reactive highly hazardous chemicals which present a potential for a catastrophic event at or above the threshold quantity Examples Examples Chemical Threshold Quantity (TQ) Chemical Threshold Quantity (TQ) Anhydrous Ammonia 10,000 lbs Anhydrous Ammonia 10,000 lbs Chlorine 1,500 lbs Chlorine 1,500 lbs Those Who Use Chemicals in Appendix A: A List of highly hazardous chemicals, toxics and reactive (Mandatory). Contains a listing of toxic and reactive highly hazardous chemicals which present a potential for a catastrophic event at or above the threshold quantity Those Who Use Chemicals in Appendix A: A List of highly hazardous chemicals, toxics and reactive (Mandatory). Contains a listing of toxic and reactive highly hazardous chemicals which present a potential for a catastrophic event at or above the threshold quantity Examples Examples Chemical Threshold Quantity (TQ) Chemical Threshold Quantity (TQ) Anhydrous Ammonia 10,000 lbs Anhydrous Ammonia 10,000 lbs Chlorine 1,500 lbs Chlorine 1,500 lbs 27

28 A process which involves a flammable liquid or gas (as defined in (c) of this part) on-site in one location, in a quantity of 10,000 pounds ( kg) or more A process which involves a flammable liquid or gas (as defined in (c) of this part) on-site in one location, in a quantity of 10,000 pounds ( kg) or more What Facilities are Covered 28

29 Important Interpretation: /11/ OSHA defines "on-site in one location" for Process Safety Management of Highly Hazardous Chemicals standard Important Interpretation: /11/ OSHA defines "on-site in one location" for Process Safety Management of Highly Hazardous Chemicals standard OSHA interprets "on-site in one location" to mean that the standard applies when a threshold quantity of a highly hazardous chemical (HHC) exists within an area under the control of an employer or group of affiliated employers. It also applies to any group of vessels that are interconnected, or in separate vessels that are close enough in proximity that the HHC could be involved in a potential catastrophic release. Important Interpretation: /11/ OSHA defines "on-site in one location" for Process Safety Management of Highly Hazardous Chemicals standard Important Interpretation: /11/ OSHA defines "on-site in one location" for Process Safety Management of Highly Hazardous Chemicals standard OSHA interprets "on-site in one location" to mean that the standard applies when a threshold quantity of a highly hazardous chemical (HHC) exists within an area under the control of an employer or group of affiliated employers. It also applies to any group of vessels that are interconnected, or in separate vessels that are close enough in proximity that the HHC could be involved in a potential catastrophic release. What Facilities are Covered 29

30 Affect of the Meer Decision: MEER ruling and the MEER Memorandum addressed in the Secretary's letter, OSHA's enforcement policy that the Agency would not cite employers for violations of where stored flammable liquids in atmospheric tanks were connected to a process, unless the process outside of the amount in storage contained more than 10,000 pounds of the substance Affect of the Meer Decision: MEER ruling and the MEER Memorandum addressed in the Secretary's letter, OSHA's enforcement policy that the Agency would not cite employers for violations of where stored flammable liquids in atmospheric tanks were connected to a process, unless the process outside of the amount in storage contained more than 10,000 pounds of the substance What Facilities are Covered 30

31 What Types of Industries? Industries that Process Chemicals Such As: Industries that Process Chemicals Such As: Industrial Organics & Inorganics Industrial Organics & Inorganics Paints Paints Pharmaceuticals Pharmaceuticals Adhesives Adhesives Sealants and Fibers Sealants and Fibers Petrochemical facilities Petrochemical facilities Paper Mills Paper Mills Food Processing with Anhydrous Ammonia over the TQ Food Processing with Anhydrous Ammonia over the TQ Industries that Process Chemicals Such As: Industries that Process Chemicals Such As: Industrial Organics & Inorganics Industrial Organics & Inorganics Paints Paints Pharmaceuticals Pharmaceuticals Adhesives Adhesives Sealants and Fibers Sealants and Fibers Petrochemical facilities Petrochemical facilities Paper Mills Paper Mills Food Processing with Anhydrous Ammonia over the TQ Food Processing with Anhydrous Ammonia over the TQ 31

32 Exclusions (a)(1)(ii)(A) (a)(1)(ii)(A) 32

33 There are Exclusions An employer is exempt from the requirements of PSM when: An employer is exempt from the requirements of PSM when: A threshold quantity of flammable liquids is stored in atmospheric tanks or transferred without the benefit of chilling or refrigeration A threshold quantity of flammable liquids is stored in atmospheric tanks or transferred without the benefit of chilling or refrigeration Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling), Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling), If such fuels are not a part of a process containing another highly hazardous chemical covered by this standard If such fuels are not a part of a process containing another highly hazardous chemical covered by this standard An employer is exempt from the requirements of PSM when: An employer is exempt from the requirements of PSM when: A threshold quantity of flammable liquids is stored in atmospheric tanks or transferred without the benefit of chilling or refrigeration A threshold quantity of flammable liquids is stored in atmospheric tanks or transferred without the benefit of chilling or refrigeration Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling), Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling), If such fuels are not a part of a process containing another highly hazardous chemical covered by this standard If such fuels are not a part of a process containing another highly hazardous chemical covered by this standard 33

34 Retail facilities; Retail facilities; Oil or gas well drilling or servicing operations; or, Oil or gas well drilling or servicing operations; or, Normally unoccupied remote facilities Normally unoccupied remote facilities Retail facilities; Retail facilities; Oil or gas well drilling or servicing operations; or, Oil or gas well drilling or servicing operations; or, Normally unoccupied remote facilities Normally unoccupied remote facilities There are Exclusions 34

35 Employee Participation (c) (c) 35

36 Now that we are required to comply, then what? Form a Team in Your Company, i.e.. Form a Team in Your Company, i.e.. Process Engineers Process Engineers Operators Operators Safety Safety Maintenance Maintenance Management Management Consultants Consultants Form a Team in Your Company, i.e.. Form a Team in Your Company, i.e.. Process Engineers Process Engineers Operators Operators Safety Safety Maintenance Maintenance Management Management Consultants Consultants Remember…You Cant Do it Alone! 36

37 Form a Plan, Determine: Form a Plan, Determine: Responsibilities Responsibilities Duties Duties Reporting Reporting Document Control Document Control Progress Reports Progress Reports Tracking Changes Tracking Changes Form a Plan, Determine: Form a Plan, Determine: Responsibilities Responsibilities Duties Duties Reporting Reporting Document Control Document Control Progress Reports Progress Reports Tracking Changes Tracking Changes Now that we are required to comply, then what? Then…Begin the Process of Developing & Implementing the PSM Program 37

38 Hazards of the Process (d)(1) (d)(1) 38

39 The Requirements of the Standard - Hazard Determination Determine: Chemicals in Your Process Chemicals in Your Process Process Chemistry Process Chemistry Quantity of Chemicals in lbs Quantity of Chemicals in lbs Compare to Appendix A List with Threshold Quantities (TQs) Compare to Appendix A List with Threshold Quantities (TQs)Determine: Chemicals in Your Process Chemicals in Your Process Process Chemistry Process Chemistry Quantity of Chemicals in lbs Quantity of Chemicals in lbs Compare to Appendix A List with Threshold Quantities (TQs) Compare to Appendix A List with Threshold Quantities (TQs) 39

40 Toxicity Information (d)(1)(i) (d)(1)(i) 40

41 The Requirements of the Standard - Develop Toxicity Information Obtain Toxicity Information on the Chemical(s) in the Process Obtain Toxicity Information on the Chemical(s) in the Process MSDS are Typical Resource MSDS are Typical Resource You May Need Other References, NIOSH Pocket Guide, ACGIH TLVs You May Need Other References, NIOSH Pocket Guide, ACGIH TLVs Obtain Toxicity Information on the Chemical(s) in the Process Obtain Toxicity Information on the Chemical(s) in the Process MSDS are Typical Resource MSDS are Typical Resource You May Need Other References, NIOSH Pocket Guide, ACGIH TLVs You May Need Other References, NIOSH Pocket Guide, ACGIH TLVs 41

42 Technology of the Process (d)(2) (d)(2) 42

43 The Requirements of the Standard - Process Technology Block flow diagram or process flow diagram Block flow diagram or process flow diagram Process chemistry Process chemistry Maximum intended inventory Maximum intended inventory Upper and lower limits Upper and lower limits Consequences of deviations Consequences of deviations Block flow diagram or process flow diagram Block flow diagram or process flow diagram Process chemistry Process chemistry Maximum intended inventory Maximum intended inventory Upper and lower limits Upper and lower limits Consequences of deviations Consequences of deviations 43

44 The Requirements of the Standard - Process Equipment Materials of construction Materials of construction Process and instrument drawings (P&IDs) Process and instrument drawings (P&IDs) Electrical classification Electrical classification Relief system design Relief system design Ventilation system design Ventilation system design Design codes Design codes Material and energy balances Material and energy balances Safety systems Safety systems Materials of construction Materials of construction Process and instrument drawings (P&IDs) Process and instrument drawings (P&IDs) Electrical classification Electrical classification Relief system design Relief system design Ventilation system design Ventilation system design Design codes Design codes Material and energy balances Material and energy balances Safety systems Safety systems 44

45 Equipment in the Process (d)(3) (d)(3) 45

46 The Requirements of the Standard - Process Equipment Now: Now: Identify Each Piece of Equipment in the Covered Process by P&ID, Block Diagram and Number Them Identify Each Piece of Equipment in the Covered Process by P&ID, Block Diagram and Number Them Remember - Must Follow Form Remember - Must Follow Form Must be Able to Track Each Number Through the Entire Program Must be Able to Track Each Number Through the Entire Program Now: Now: Identify Each Piece of Equipment in the Covered Process by P&ID, Block Diagram and Number Them Identify Each Piece of Equipment in the Covered Process by P&ID, Block Diagram and Number Them Remember - Must Follow Form Remember - Must Follow Form Must be Able to Track Each Number Through the Entire Program Must be Able to Track Each Number Through the Entire Program 46

47 Mechanical Integrity (j) (j) 47

48 Mechanical Integrity Certificates Must be Obtained for Each Element of the Process Must be Marked with Numbering System that Follows Form Mechanical Integrity Certificates Must be Obtained for Each Element of the Process Must be Marked with Numbering System that Follows Form The Requirements of the Standard - Process Equipment 48

49 Process Hazard Analysis (PHA) (e) (e) 49

50 Process Hazard Analysis (PHAs) Arguably the Most Difficult Part of Performing the Standard Arguably the Most Difficult Part of Performing the Standard PHA process is dynamic and subject to revision whenever changes are made PHA process is dynamic and subject to revision whenever changes are made Performed by Your PSM Team Performed by Your PSM Team Takes Significant Time & Effort Takes Significant Time & Effort PHAs are Never Ending PHAs are Never Ending Arguably the Most Difficult Part of Performing the Standard Arguably the Most Difficult Part of Performing the Standard PHA process is dynamic and subject to revision whenever changes are made PHA process is dynamic and subject to revision whenever changes are made Performed by Your PSM Team Performed by Your PSM Team Takes Significant Time & Effort Takes Significant Time & Effort PHAs are Never Ending PHAs are Never Ending 50

51 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 Component to Determine What Might Happen if an Element of the Covered Process Fails A PHA Process Must be Performed on Each Element of the Covered Process: A PHA From Block Diagram to P&ID to Every Equipment Component to Determine What Might Happen if an Element of the Covered Process Fails 51

52 There is Much More to PSM Inspection & Testing Inspection & Testing Quality Assurance Quality Assurance Management of Change Management of Change Operating Procedures Operating Procedures Safe Work Practices Safe Work Practices Training Training Contractor Management Contractor Management Emergency Planning & Response Emergency Planning & Response Incident Investigation Incident Investigation Compliance Audits Compliance Audits Trade Secrets Trade Secrets Inspection & Testing Inspection & Testing Quality Assurance Quality Assurance Management of Change Management of Change Operating Procedures Operating Procedures Safe Work Practices Safe Work Practices Training Training Contractor Management Contractor Management Emergency Planning & Response Emergency Planning & Response Incident Investigation Incident Investigation Compliance Audits Compliance Audits Trade Secrets Trade Secrets 52

53 Management of Change Procedures to manage changes to the covered process. Procedures to manage changes to the covered process. Exception: replacement in kind Exception: replacement in kind Management of Change includes: Management of Change includes: Process chemicals Process chemicals Technology Technology Equipment Equipment Operating Procedures Operating Procedures Facilities Facilities Procedures to manage changes to the covered process. Procedures to manage changes to the covered process. Exception: replacement in kind Exception: replacement in kind Management of Change includes: Management of Change includes: Process chemicals Process chemicals Technology Technology Equipment Equipment Operating Procedures Operating Procedures Facilities Facilities 53

54 Management of Change Addresses 1. Technical basis of the change 2. Impact to employee safety and health 3. Modification to operating procedures 4. Time period for change 5. Authorization of change 1. Technical basis of the change 2. Impact to employee safety and health 3. Modification to operating procedures 4. Time period for change 5. Authorization of change 54

55 Operating Procedures Develop and implement written operating procedures that are clear instructions for all expected phases of operations. Develop and implement written operating procedures that are clear instructions for all expected phases of operations. AKA – Standard Operating Procedures (SOPs) AKA – Standard Operating Procedures (SOPs) Must cover: Must cover: Operation phase Operation phase Operational limits Operational limits Safety & health considerations Safety & health considerations Develop and implement written operating procedures that are clear instructions for all expected phases of operations. Develop and implement written operating procedures that are clear instructions for all expected phases of operations. AKA – Standard Operating Procedures (SOPs) AKA – Standard Operating Procedures (SOPs) Must cover: Must cover: Operation phase Operation phase Operational limits Operational limits Safety & health considerations Safety & health considerations 55

56 OPs Must Address Initial start-up Initial start-up Normal operations Normal operations Temporary operations Temporary operations Emergency shutdown Emergency shutdown Emergency operations Emergency operations Normal shutdown Normal shutdown Start-up following turnaround Start-up following turnaround Consequences of deviation Consequences of deviation Steps required to correct or avoid deviation Steps required to correct or avoid deviation Initial start-up Initial start-up Normal operations Normal operations Temporary operations Temporary operations Emergency shutdown Emergency shutdown Emergency operations Emergency operations Normal shutdown Normal shutdown Start-up following turnaround Start-up following turnaround Consequences of deviation Consequences of deviation Steps required to correct or avoid deviation Steps required to correct or avoid deviation 56

57 SOPs Must be readily available to employees Must be readily available to employees Must be reviewed as needed to ensure they reflect current operating practicce. Must be reviewed as needed to ensure they reflect current operating practicce. Must cover: Must cover: Process chemicals Process chemicals Technology and equipment Technology and equipment Facilities Facilities SOPs must be certified annually that they are correct and accurate. SOPs must be certified annually that they are correct and accurate. Must be readily available to employees Must be readily available to employees Must be reviewed as needed to ensure they reflect current operating practicce. Must be reviewed as needed to ensure they reflect current operating practicce. Must cover: Must cover: Process chemicals Process chemicals Technology and equipment Technology and equipment Facilities Facilities SOPs must be certified annually that they are correct and accurate. SOPs must be certified annually that they are correct and accurate. 57

58 Safe Work Practices (SWPs) Must be developed and implemented to provide for the control of hazards during work activities such as: Must be developed and implemented to provide for the control of hazards during work activities such as: Lock-out/Tag-out Lock-out/Tag-out Confined space entry Confined space entry Opening processes, piping or equipment Opening processes, piping or equipment Must be developed and implemented to provide for the control of hazards during work activities such as: Must be developed and implemented to provide for the control of hazards during work activities such as: Lock-out/Tag-out Lock-out/Tag-out Confined space entry Confined space entry Opening processes, piping or equipment Opening processes, piping or equipment 58 SWPs are for: OperatorsOperators Maintenance personnelMaintenance personnel ContractorsContractors Lab personnelLab personnel Or other support personnelOr other support personnel

59 Training PSM specific training is required PSM specific training is required Must cover: Must cover: Safety and health hazards associated with the covered process Safety and health hazards associated with the covered process Safe work practices Safe work practices Refresher training is required every 3 years or as needed to ensure employees are complying with all PSM requirements Refresher training is required every 3 years or as needed to ensure employees are complying with all PSM requirements PSM specific training is required PSM specific training is required Must cover: Must cover: Safety and health hazards associated with the covered process Safety and health hazards associated with the covered process Safe work practices Safe work practices Refresher training is required every 3 years or as needed to ensure employees are complying with all PSM requirements Refresher training is required every 3 years or as needed to ensure employees are complying with all PSM requirements 59

60 Contractors Contractors involved in or around a covered process must be informed of required PSM elements. Contractors involved in or around a covered process must be informed of required PSM elements. Contract work includes: Contract work includes: Maintenance and repair Maintenance and repair Turn around Turn around Major renovations Major renovations Specialty knowledge or services Specialty knowledge or services Does not include support services not involved with the covered process, like laundry or vending machine supply Does not include support services not involved with the covered process, like laundry or vending machine supply Contractors involved in or around a covered process must be informed of required PSM elements. Contractors involved in or around a covered process must be informed of required PSM elements. Contract work includes: Contract work includes: Maintenance and repair Maintenance and repair Turn around Turn around Major renovations Major renovations Specialty knowledge or services Specialty knowledge or services Does not include support services not involved with the covered process, like laundry or vending machine supply Does not include support services not involved with the covered process, like laundry or vending machine supply 60

61 Emergency Action Plans (EAP) Must have EAP for entire facility Must have EAP for entire facility EAP must have provisions for small releases of HHCs EAP must have provisions for small releases of HHCs Develop a Early Warning Method for Releases Develop a Early Warning Method for Releases Train on the Meaning of the Alarms Train on the Meaning of the Alarms Develop Emergency Evacuation Written Plans, Evacuation Maps & Assembly Points Develop Emergency Evacuation Written Plans, Evacuation Maps & Assembly Points Must have EAP for entire facility Must have EAP for entire facility EAP must have provisions for small releases of HHCs EAP must have provisions for small releases of HHCs Develop a Early Warning Method for Releases Develop a Early Warning Method for Releases Train on the Meaning of the Alarms Train on the Meaning of the Alarms Develop Emergency Evacuation Written Plans, Evacuation Maps & Assembly Points Develop Emergency Evacuation Written Plans, Evacuation Maps & Assembly Points 61

62 Incident Investigations Must be initiated ASAP, but within 48 hours Must be initiated ASAP, but within 48 hours Team must include: Team must include: Person knowledgeable in the process involved Person knowledgeable in the process involved Includes contractor if work of the contractor involved Includes contractor if work of the contractor involved Other persons with appropriate knowledge of the covered process Other persons with appropriate knowledge of the covered process Must be initiated ASAP, but within 48 hours Must be initiated ASAP, but within 48 hours Team must include: Team must include: Person knowledgeable in the process involved Person knowledgeable in the process involved Includes contractor if work of the contractor involved Includes contractor if work of the contractor involved Other persons with appropriate knowledge of the covered process Other persons with appropriate knowledge of the covered process 62

63 Incident Investigation Report Report must be produced with the following: Report must be produced with the following: Date of incident Date of incident Date of start of investigation Date of start of investigation Description of incident Description of incident Factors contributing to incident Factors contributing to incident Recommendations Recommendations System must be established to promptly address recommendations and findings of report System must be established to promptly address recommendations and findings of report Resolutions and corrective action must be documented Resolutions and corrective action must be documented Report must be produced with the following: Report must be produced with the following: Date of incident Date of incident Date of start of investigation Date of start of investigation Description of incident Description of incident Factors contributing to incident Factors contributing to incident Recommendations Recommendations System must be established to promptly address recommendations and findings of report System must be established to promptly address recommendations and findings of report Resolutions and corrective action must be documented Resolutions and corrective action must be documented 63

64 Compliance Audit To ensure that PSM is effective, employers must certify every 3 years that they have evaluated compliance with the standard To ensure that PSM is effective, employers must certify every 3 years that they have evaluated compliance with the standard Must be completed by at least on person knowledgeable in the process Must be completed by at least on person knowledgeable in the process Report must be developed and documented Report must be developed and documented Deficiency corrections must be documented Deficiency corrections must be documented Last two compliance audits must be kept on file Last two compliance audits must be kept on file To ensure that PSM is effective, employers must certify every 3 years that they have evaluated compliance with the standard To ensure that PSM is effective, employers must certify every 3 years that they have evaluated compliance with the standard Must be completed by at least on person knowledgeable in the process Must be completed by at least on person knowledgeable in the process Report must be developed and documented Report must be developed and documented Deficiency corrections must be documented Deficiency corrections must be documented Last two compliance audits must be kept on file Last two compliance audits must be kept on file 64

65 Trade Secrets Employers must make all necessary information required to comply with PSM, regardless of trade secrets, available to persons involved in developing or creating: Employers must make all necessary information required to comply with PSM, regardless of trade secrets, available to persons involved in developing or creating: Compiling process safety information Compiling process safety information PHAs PHAs SOPs SOPs Incident investigations Incident investigations Emergency planning and response Emergency planning and response Compliance audits Compliance audits Confidentiality agreements are allowed Confidentiality agreements are allowed Employers must make all necessary information required to comply with PSM, regardless of trade secrets, available to persons involved in developing or creating: Employers must make all necessary information required to comply with PSM, regardless of trade secrets, available to persons involved in developing or creating: Compiling process safety information Compiling process safety information PHAs PHAs SOPs SOPs Incident investigations Incident investigations Emergency planning and response Emergency planning and response Compliance audits Compliance audits Confidentiality agreements are allowed Confidentiality agreements are allowed 65

66 BP Texas City Refinery Case Study in PSM The third largest petroleum refinery in the United States with a refining capacity of 475,000 barrels of crude per day. The third largest petroleum refinery in the United States with a refining capacity of 475,000 barrels of crude per day. Located on a 1,200-acre facility in Texas City, Texas southeast of Houston in Galveston County. Located on a 1,200-acre facility in Texas City, Texas southeast of Houston in Galveston County. 1,200 permanent BP employees and hundreds of additional contractors at the facility 1,200 permanent BP employees and hundreds of additional contractors at the facility The third largest petroleum refinery in the United States with a refining capacity of 475,000 barrels of crude per day. The third largest petroleum refinery in the United States with a refining capacity of 475,000 barrels of crude per day. Located on a 1,200-acre facility in Texas City, Texas southeast of Houston in Galveston County. Located on a 1,200-acre facility in Texas City, Texas southeast of Houston in Galveston County. 1,200 permanent BP employees and hundreds of additional contractors at the facility 1,200 permanent BP employees and hundreds of additional contractors at the facility 66

67 Anatomy of a Disaster- BP Texas City Things to Think About: Things to Think About: What went wrong? What went wrong? What went right? What went right? What could/should have been done to prevent this disaster? What could/should have been done to prevent this disaster? Things to Think About: Things to Think About: What went wrong? What went wrong? What went right? What went right? What could/should have been done to prevent this disaster? What could/should have been done to prevent this disaster? 67

68 BP Texas City Refinery Case Study in PSM 68

69 JORDAN BARAB Deputy Assistant Secretary After BP-Texas City, Have We Learned Anything? After BP-Texas City, Have We Learned Anything? Now, in spite of your efforts, we have to acknowledge that something is desperately wrong. The status quo isn't working. Now, in spite of your efforts, we have to acknowledge that something is desperately wrong. The status quo isn't working. In the past three months alone, 58 workers have died in explosions, fires and collapses at refineries, coal mines, an oil drilling rig, and a natural-gas-fired power plant construction site. In the past three months alone, 58 workers have died in explosions, fires and collapses at refineries, coal mines, an oil drilling rig, and a natural-gas-fired power plant construction site. OSHA is particularly concerned about the recent number of serious incidents at refineries that have scalded, burned or struck down your fellow workers. We are tracking these catastrophes and looking for trends -- including problems resulting from aging facilities. Since the BP Texas City explosion in 2005, OSHA has counted over 20 serious incidents in refineries across the country. OSHA is particularly concerned about the recent number of serious incidents at refineries that have scalded, burned or struck down your fellow workers. We are tracking these catastrophes and looking for trends -- including problems resulting from aging facilities. Since the BP Texas City explosion in 2005, OSHA has counted over 20 serious incidents in refineries across the country. After BP-Texas City, Have We Learned Anything? After BP-Texas City, Have We Learned Anything? Now, in spite of your efforts, we have to acknowledge that something is desperately wrong. The status quo isn't working. Now, in spite of your efforts, we have to acknowledge that something is desperately wrong. The status quo isn't working. In the past three months alone, 58 workers have died in explosions, fires and collapses at refineries, coal mines, an oil drilling rig, and a natural-gas-fired power plant construction site. In the past three months alone, 58 workers have died in explosions, fires and collapses at refineries, coal mines, an oil drilling rig, and a natural-gas-fired power plant construction site. OSHA is particularly concerned about the recent number of serious incidents at refineries that have scalded, burned or struck down your fellow workers. We are tracking these catastrophes and looking for trends -- including problems resulting from aging facilities. Since the BP Texas City explosion in 2005, OSHA has counted over 20 serious incidents in refineries across the country. OSHA is particularly concerned about the recent number of serious incidents at refineries that have scalded, burned or struck down your fellow workers. We are tracking these catastrophes and looking for trends -- including problems resulting from aging facilities. Since the BP Texas City explosion in 2005, OSHA has counted over 20 serious incidents in refineries across the country. 69

70 There is Much More to PSM Now, The OSHA PSM National Emphasis Program for Refineries & Chemical Facilities & Severe Violator Enforcement Program (SVEP) 70

71 OSHA National Emphasis Program (NEP) for Refineries & Chemical Facilities Petroleum Refineries NEP Issued August 2009 Chemical Facilities NEP Issued July

72 Typical Standards Cited PSM – 249 violations PSM – 249 violations Lock and Tag Lock and Tag Hazwoper Hazwoper Hazcom Hazcom Confined Space Confined Space A.001 General Duty - 9 5A.001 General Duty Hazardous Locations Hazardous Locations PSM – 249 violations PSM – 249 violations Lock and Tag Lock and Tag Hazwoper Hazwoper Hazcom Hazcom Confined Space Confined Space A.001 General Duty - 9 5A.001 General Duty Hazardous Locations Hazardous Locations

73 Most Frequent NEP PSM Citations (f)(1) Operating procedures…………..38 (f)(1) Operating procedures…………..38 (d)(3) PSI pertaining to equipment ….28 (d)(3) PSI pertaining to equipment ….28 (e)(3) PHA specific criteria……………26 (e)(3) PHA specific criteria……………26 (j)(4) MI Inspection & Testing ………..21 (j)(4) MI Inspection & Testing ………..21 (e)(5) PHA recommendation...………12 (e)(5) PHA recommendation...………12 (l)(1) MOC implementation …………..12 (l)(1) MOC implementation …………..12 (f)(1) Operating procedures…………..38 (f)(1) Operating procedures…………..38 (d)(3) PSI pertaining to equipment ….28 (d)(3) PSI pertaining to equipment ….28 (e)(3) PHA specific criteria……………26 (e)(3) PHA specific criteria……………26 (j)(4) MI Inspection & Testing ………..21 (j)(4) MI Inspection & Testing ………..21 (e)(5) PHA recommendation...………12 (e)(5) PHA recommendation...………12 (l)(1) MOC implementation …………..12 (l)(1) MOC implementation …………

74 Severe Violator Enforcement Program (SVEP) This Instruction establishes enforcement policies and procedures for OSHA's Severe Violator Enforcement Program (SVEP), which concentrates resources on inspecting employers who have demonstrated indifference to their OSH Act obligations by willful, repeated, or failure-to-abate violations. This Instruction replaces OSHA's Enhanced Enforcement Program (EEP). This Instruction establishes enforcement policies and procedures for OSHA's Severe Violator Enforcement Program (SVEP), which concentrates resources on inspecting employers who have demonstrated indifference to their OSH Act obligations by willful, repeated, or failure-to-abate violations. This Instruction replaces OSHA's Enhanced Enforcement Program (EEP). 74

75 Severe Violator Enforcement Program (SVEP) References: OSHA Instruction CPL , Petroleum Refinery Process Safety Management National Emphasis Program, August 18, 2009 OSHA Instruction CPL , Petroleum Refinery Process Safety Management National Emphasis Program, August 18, 2009References: 75

76 Severe Violator Enforcement Program (SVEP) Enhanced Follow-up Inspections Enhanced Follow-up Inspections Nationwide Inspections of Related Workplaces/Worksites Nationwide Inspections of Related Workplaces/Worksites Increased Company Awareness of OSHA Enforcement Increased Company Awareness of OSHA Enforcement Enhanced Settlement Provisions Enhanced Settlement Provisions Federal Court Enforcement under Section 11(b) of the OSH Act Federal Court Enforcement under Section 11(b) of the OSH Act Bottom Line: OSHA is Serious About Compliance and Enforcement of PSM Enhanced Follow-up Inspections Enhanced Follow-up Inspections Nationwide Inspections of Related Workplaces/Worksites Nationwide Inspections of Related Workplaces/Worksites Increased Company Awareness of OSHA Enforcement Increased Company Awareness of OSHA Enforcement Enhanced Settlement Provisions Enhanced Settlement Provisions Federal Court Enforcement under Section 11(b) of the OSH Act Federal Court Enforcement under Section 11(b) of the OSH Act Bottom Line: OSHA is Serious About Compliance and Enforcement of PSM 76

77 EPA Risk Management Plans (RMP) Basics CAA 112(r) 77

78 One More Thing to Discuss… EPA Risk Management Plans (RMP) Many Times Companies Who Must Comply with PSM, must also Comply with the Requirements of EPA Risk Management Plans (RMP) Many Times Companies Who Must Comply with PSM, must also Comply with the Requirements of EPA Risk Management Plans (RMP) The RMP Standard was to be a Mirror of the PSM Standard…Didnt happen! The RMP Standard was to be a Mirror of the PSM Standard…Didnt happen! Remember…PSM Protects the Workforce, RMP Protects the Community Remember…PSM Protects the Workforce, RMP Protects the Community Many Times Companies Who Must Comply with PSM, must also Comply with the Requirements of EPA Risk Management Plans (RMP) Many Times Companies Who Must Comply with PSM, must also Comply with the Requirements of EPA Risk Management Plans (RMP) The RMP Standard was to be a Mirror of the PSM Standard…Didnt happen! The RMP Standard was to be a Mirror of the PSM Standard…Didnt happen! Remember…PSM Protects the Workforce, RMP Protects the Community Remember…PSM Protects the Workforce, RMP Protects the Community 78

79 EPA RMP Basic Requirements Basic Requirements Executive summary Executive summary Registration Registration Off-site consequence analysis Off-site consequence analysis Five-year accident history Five-year accident history Emergency response plan Emergency response plan Prevention program summary information Prevention program summary information Certification Certification Basic Requirements Basic Requirements Executive summary Executive summary Registration Registration Off-site consequence analysis Off-site consequence analysis Five-year accident history Five-year accident history Emergency response plan Emergency response plan Prevention program summary information Prevention program summary information Certification Certification 79

80 All Public Facilities in this Release Plume Must be Identified & Surveyed Release Plume 80

81 OSHA PSM Summary PSM is a Comprehensive, Difficult Standard PSM is a Comprehensive, Difficult Standard Although it was Promulgated in 1991, Catastrophes Continue to Occur Although it was Promulgated in 1991, Catastrophes Continue to Occur Recognizing these Facts, OSHA has Developed a National Emphasis Program for Refineries and Chemical Manufacturers Recognizing these Facts, OSHA has Developed a National Emphasis Program for Refineries and Chemical Manufacturers More Emphasis Planned for all PSM Sites More Emphasis Planned for all PSM Sites There is Much More Work to be Done… There is Much More Work to be Done… RMP Must Also be Considered for Many Facilities RMP Must Also be Considered for Many Facilities PSM is a Comprehensive, Difficult Standard PSM is a Comprehensive, Difficult Standard Although it was Promulgated in 1991, Catastrophes Continue to Occur Although it was Promulgated in 1991, Catastrophes Continue to Occur Recognizing these Facts, OSHA has Developed a National Emphasis Program for Refineries and Chemical Manufacturers Recognizing these Facts, OSHA has Developed a National Emphasis Program for Refineries and Chemical Manufacturers More Emphasis Planned for all PSM Sites More Emphasis Planned for all PSM Sites There is Much More Work to be Done… There is Much More Work to be Done… RMP Must Also be Considered for Many Facilities RMP Must Also be Considered for Many Facilities 81

82 Tools for Additional PSM Assistance PSM Checklist PSM Checklist OSHA Website OSHA Website Chemical Safety Board Website Chemical Safety Board Website PSM Checklist PSM Checklist OSHA Website OSHA Website Chemical Safety Board Website Chemical Safety Board Website 82

83 83

84 For More Information 84

85 Contact Information Michelle Dunham, MSPH, MSM Michelle Dunham, MSPH, MSM Bob Hendry Bob Hendry Art Wickman, CIH Art Wickman, CIH Georgia Tech Occupational Safety & Health Program Georgia Tech Occupational Safety & Health Program Michelle Dunham, MSPH, MSM Michelle Dunham, MSPH, MSM Bob Hendry Bob Hendry Art Wickman, CIH Art Wickman, CIH Georgia Tech Occupational Safety & Health Program Georgia Tech Occupational Safety & Health Program 85

86 Funding Funding for: Process Safety Management of Highly Hazardous and Explosive Chemicals: Simple Keys to Compliance By special funding from the Occupational Safety and Health Administration Funding for: Process Safety Management of Highly Hazardous and Explosive Chemicals: Simple Keys to Compliance By special funding from the Occupational Safety and Health Administration 86


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