Presentation on theme: "BLR’s Safety Training Presentations"— Presentation transcript:
1 BLR’s Safety Training Presentations Process Safety Management of Highly Hazardous Chemicals 29 CFR (PSM)BLR’s Safety Training PresentationsI. Background for the Trainer:If the regulation ( ) is available, show it to the attendees.II. Speaker’s Notes:This standard is a significant improvement over traditional OSHA standards as it requires a proactive stance by employers.This standard is usually referred to as the process safety management (PSM) standard.
2 Disasters That Led to Process Safety Management Bhopal, India (1984)2,000 deaths Isocyanate releasePasadena, Tex. (1989)23 deaths, 132 injuries Petroleum explosionCincinnati, Ohio (1990)2 deaths ExplosionSterlington, La. (1991)8 deaths, 128 injuries Chemical releaseI. Speaker’s Notes:There are many catastrophes such as those mentioned, but these four in particular led to the establishment of the PSM standard.All of these events were caused by the catastrophic release of hazardous materials.If companies follow the implementation rules found in PSM, it is much less likely that another one of these catastrophes will occur.
3 Clean Air Act Amendments—1990 Required secretary of labor to promulgate a PSM standardPSM standard must include a list of highly hazardous chemicalsHighly hazardous chemicals list must include: toxics, flammables, highly reactive and explosive materialsRequired EPA to establish RMP standardI. Speaker’s Notes:This standard was not just a good idea, it was required under the Clean Air Act Amendments of 1990.Because of this, OSHA had no choice but to promulgate the standard.Required EPA to establish RMP standard.
4 Minimum Program Requirements Written safety informationWorkplace hazard assessmentConsult with employeesEstablish a system to respond to findingsPeriodic review of assessments and responseWritten operating proceduresSafety training and operating informationI. Background for the Trainer:If you have a current written program, show it to the class at this time.II. Speaker’s Notes:The safety information must be specific to elements within the process.The hazard assessment must be formal, in writing, and look at all potential hazards within the process.Operators within a process generally know the most about it.Corrective action relative to findings is a very important factor in increasing process safety.Conduct reviews or audits using various groups to ensure that all aspects of the process are evaluated.These operating procedures may simply be existing standard operating procedures (SOPs).This training must again be specific to the operation and not general in nature.
5 Minimum Program Requirements (cont.) Appropriate information and training for contractorsTrain and educate employees in emergency responseEstablish a quality assurance programEstablish maintenance systemsPrestart-up safety reviewsManagement of changeIncident investigationI. Speaker’s Notes:Contractors who are unfamiliar with the process can create significant additional hazards within the process.The emergency response plan must be specific to chemical-related emergencies.The entire process should be tied in to an overall quality assurance system.Process equipment must be maintained to ensure system integrity.Safety reviews are also important to the success of the program. An operation must be proven safe prior to start-up.The PSM standard also requires that any change necessary in a regulated process be documented and verified as indeed necessary.Any incident must be thoroughly investigated and corrective action initiated.
6 Application of PSM Companies that process highly hazardous materials Flammable liquids and gases in quantities in excess of 10,000 poundsI. Speaker’s Notes:Petroleum refineries are specifically exempted from the PSM standard.However, if your company processes a material on the chemical list in a single operation, above the threshold quantities listed in the standard, then PSM applies to you.Also note that the flammable liquid and gas requirement is in pounds, not gallons. This can be somewhat confusing.
7 Initial Process Hazard Analysis Deadlines 25% complete by May 26, 199450% complete by May 26, 199575% complete by May 26, 1996100% complete by May 26, 1997I. Background for the Trainer:If examples of process hazard analyses are available, provide them to the class.II. Speaker’s Notes:As you can see by the dates on this slide, implementation of the PSM standard was a tiered approach. All process hazard analyses (PHAs) must have been completed by 1997, unless of course a new process is implemented.
8 Process Safety Information ToxicityPermissible Exposure LimitsPhysical DataReactivity DataCorrosivity DataThermal and Chemical Stability DataI. Background for the TrainerIf an applicable material safety data sheet (MSDS) is available, pass it out at this time or show it to the attendees.II. Speaker’s Notes:Toxicity deals with how the chemical affects humans.Permissible exposure limits (PELs) are legal levels to which workers can be exposed to a hazardous substance.Physical data include information such as boiling point, vapor pressure, pH, etc.Reactivity is important relative to possible adverse reactions.Is the chemical acidic or alkaline, and what is its strength (pH)?Is the chemical stable under normal use, and is it unstable when heated?
9 Process Technology Block flow diagram or process flow diagram Process chemistryMaximum intended inventoryUpper and lower limitsConsequences of deviationsI. Speaker’s Notes:All of this information is a “blueprint of hazards” relative to the process itself, not just the material in use.All of this information should be documented in your written process documents.How the material is processed and the consequences of deviating from standard procedure are of the utmost importance in disaster planning.
10 Information on Process Equipment Materials of constructionPiping and instrument diagrams (PIDs)Electrical classificationRelief system designVentilation system designDesign codesMaterial and energy balancesSafety systemsI. Speaker’s Notes:Depending on the materials of construction, there could be additional reactivity or integrity concerns.The PIDs will identify where the material is transported during the process.Electrical classifications are important because of the explosive issues related to the electrical equipment installations.Pressure bleed-off is important in pressurized systems and can help prevent a release of chemicals or an explosion.Ventilation systems are important to control routine chemical emissions, which will help protect the workers.Part of the overall PSM plan should include installations that meet all applicable building codes.It is important to know what the inherent safety systems in the process are and how they work.All the information listed here should be available through design engineering documents.By law, this information must be documented for processes that must comply with PSM.
11 Items the PHA Must Address Hazards of the processIdentification of previous incidentsEngineering and administrative controlsConsequences of failureFacility sitingHuman factorsQualitative evaluation of safety and health effectsI. Background for the Trainer:If a PHA is available, show it to the attendees at this time and discuss how it complies with these requirements.II. Speaker’s Notes:Each individual hazard must be identified.Safety specialists should review previous incidents to see if changes were made to help reduce the likelihood of recurrence.Control methods that do not rely on the human factor are most successful (i.e., local exhaust vs. respiratory protection).If there is a failure, what is the worst-case scenario, and what is it that is most likely to happen?Facility siting is very important in the event of a release based on surrounding communities, landscape, etc.The human interaction is important because the more human involvement, the greater the opportunity for error.
12 Operating Phases Initial start-up Normal operations Temporary operationsEmergency shutdownEmergency operationsNormal shutdownStart-up following turnaroundI. Speaker’s Notes:It is imperative that all levels of operation be included in the PHA.It is easy to look at the normal operation, but plans must be made for emergency shutdowns and start-up following repair or turnaround.When changes take place in any of these phases, additional analyses may be necessary.
13 Operating Limits Consequences of deviation Steps required to correct or avoid deviationI. Speaker’s Notes:Preventing a recurrence or a catastrophic release is essential.Any deviation should be followed up with corrective action.
14 Safety and Health Considerations Properties and hazards of the chemicalsPrecautions to prevent exposuresControl measures to be takenQuality control for raw materials/control of inventorySpecial or unique hazardsSafety systems and their functionsI. Background for the Trainer:Many of the issues listed on the slide are dealt with in the company safety and health program. At this time, describe your company’s program to the class.II. Speaker’s Notes:Hazards of the chemicals are typically found in the product MSDS.What control measures are necessary to prevent exposures?Which types of control measures are required in the routine operation? Are they readily available?Inventory must be stringently maintained because of the threshold quantity requirements of the PSM standard.Some special or unique hazards include corrosivity, reactivity, radioactivity, etc.If the system is already in place, it is not necessary to reinvent the wheel; simply use the safety system that works for your company.
15 Management of Change Technical basis for the proposed change Impact of the change on safety and healthModifications of the operating proceduresNecessary time period for the changeAuthorization requirements for the changeI. Speaker’s Notes:If a process is regulated under PSM, any minor or typical change that affects the process must be justified and documented.Documentation must also verify whether the change will have an impact on safety and health.No change should be implemented without the proper authorization of management officials.The authorization should not just be a management signature. The official signing the change is responsible for verifying that the change has been adequately implemented.
16 Training Requirements Initial trainingPrior to work assignmentWaved for those already in a processRefresher trainingEvery three yearsTraining documentationI. Speaker’s Notes:As is the case with almost any regulatory training, workers involved in the process must be trained on key components and hazards prior to initiating work.Refresher training must also be provided at least every three years.All training should be documented for compliance purposes.Make certain that when a significant change is implemented in a process, that training is provided to affected employees.
17 Contractor Requirements PSM applies to contractors in or adjacent to a process performingMaintenanceRepairTurnaroundMajor renovationSpecialty workPSM does not apply to incidental contractorsFood serviceLaundryDelivery, etc.I. Speaker’s Notes:Workers under contract and involved in the hazardous process must be trained and included in the PSM program just like a full-time employee.However, if the contract work is incidental or peripheral, the PSM program does not apply.The main concern is with individuals whose job has a direct impact on the process itself.
18 Incident Investigation Reports Date of incidentDate investigation beganDescription of the incidentFactors contributing to the incidentRecommendations resulting from the investigationI. Speaker’s Notes:The final element of an effective PSM program is incident investigation.If the unfortunate incident does happen, the investigation is the key to providing lessons learned so that a recurrence can be avoided.Most safety professionals can use their standard accident investigation skills to handle a PSM incident.It is important to document the incident as well as all corrective action planned as a result of the incident.
19 Quiz Review Coming Up I. Speaker’s Notes: The final element of an effective PSM program is incident investigation.If the unfortunate incident does happen, the investigation is the key to providing lessons learned so that a recurrence can be avoided.Most safety professionals can use their standard accident investigation skills to handle a PSM incident.It is important to document the incident as well as all corrective action planned as a result of the incident.
20 Quiz1. The PSM standard was drafted as a requirement of the Clean Air Act. True or False2. The PSM program must include a list of highly hazardous chemicals. True or False3. The initial start-up of a process is not included as an operating phase under the PSM standard. True or False4. List three items that the process hazard analysis must address: ___________, __________, and __________.5. PSM does not apply to contractors, regardless of the work they are doing. True or FalseI. Background for the Trainer:Hand out the quiz copies. Go over the questions verbally and have the employees write their answers on their quiz sheets.
21 Quiz (cont.)6. The PSM standard applies to companies that either process highly _____________ materials or use _____________ liquids and gases in excess of 10,000 pounds.7. Process safety information includes: ______________, _____________, and _____________.8. Fault tree analysis is one form of an approved method of performing a process hazard analysis. True or False9. A technical basis is not required to change a process covered by the PSM standard. True or False10. Two types of training required by the PSM standard are _____________ and _________________.
22 Quiz Answers1. True. The PSM standard was drafted as a result of the Clean Air Act Amendments of 1990.2. True.3. False. The initial start-up of a process is an operating phase that must be included.4. The items that a process hazard analysis must address include hazards of the process, identification of previous accidents, engineering and administrative controls, consequences of failure, facility siting, human factors, and qualitative evaluation of S and H effects.5. False. PSM does apply to contractors who work on or adjacent to a process.
23 Quiz Answers1. True. The PSM standard was drafted as a result of the Clean Air Act Amendments of 1990.2. True.3. False. The initial start-up of a process is an operating phase that must be included.4. The items that a process hazard analysis must address include hazards of the process, identification of previous accidents, engineering and administrative controls, consequences of failure, facility siting, human factors, and qualitative evaluation of S and H effects.5. False. PSM does apply to contractors who work on or adjacent to a process.