Process Safety Management ( PSM ) Risk Management Plan (RMP)
PSM Application of management principles and systems to the identification, understanding, and control of process hazards to protect the workplace. Focused on prevention of, preparedness for, mitigation of, response to, and restoration from catastrophic releases of chemicals or energy from a process associated with a facility. “Process” is any use, storage, manufacturing, handling, or on-site movement of highly hazardous chemicals, or combination of these activities. 3
RMP Focus is to prevent accidental releases of substances that can cause serious harm to the public and the environment and to mitigate the severity of releases that do occur. Must develop and implement a program and maintain documentation of the program at the site and filing w/EPA. Includes an analysis of the potential offsite consequences of a worst-case accidental release, a five-year accident history, a release prevention program, and emergency planning. 4
Threats If process safety fails: – Casualties (employees) – Casualties (community) – Environmental Damage – Legal – Business and reputation (leadership, brand, customers) – Management distracted from the business
PSM vs. EPA Risk Management Plans(RMP) The PSM Standard contains 14 elements. 1. Employee participation 2. Process safety information 3. Process hazard analysis 4. Operating procedures 5. Training 6. Contractors’ obligations 7. Pre-startup safety review 8. Mechanical integrity 9. Hot work permit 10. Management of change 11. Incident investigation 12. Emergency planning and response 13. Compliance audits 14. Trade secrets RMP Program includes: Hazard review Operating Procedures Training Maintenance Incident Investigation Compliance audit Management of Change Pre-startup review Contractors Employee Participation Hot Work Permits RMP Contents: Executive summary Registration Worst-case data 5-year accident history Prevention program Emergency response Certification 7
PSM vs. EPA Risk Management Plans(RMP) The principal differences: – Different chemical list and Threshold Quantities (TQ) for some chemicals. e.g., Chlorine 1500 lbs. (PSM) v. 2500 lbs. (RMP) – EPA requires hazard assessments that include analyses of the “worst case” accident consequences – EPA requires preparation of written risk management plans to document the risk management program. The plans must be submitted to EPA and are available to the public.
Case Studies: Enforcement U.S. v. Tyson Foods, Inc., et al. (May, 2013) – 60 Page Complaint; 23 Counts – 23 facilities – $3.95M Penalty – $300k SEP – $3M+? Attys fees – Hundreds of hours of employee time – Bad Press – Customers 10
So how did all this start? On EPA’s Radar Dec. 2006 release at Hutchinson KS – 10 injured treated – 43.71 lbs Dec. 2006 release at Omaha – 5 injured; plant evac – SRV – no doc of change out; MI not implemented 11
Case Study: Enforcement U.S. v. Hershey (Sept, 2008) 2 facilities @ w/10,000 lbs Ammonia Had RMP/PSM program OSHA PSM inspections, EPA information request and inspection
Self-audit revealed: – RMP as written not followed (despite certification by company officers) – Plan had deficiencies – lack of mgmt, insufficient process haz analysis, no emergency evac. plan, etc. EPA initiated criminal investigation against company and supervising employees for RMP violations Company pleaded to a misdemeanor and $100,000 fine. First reported RMP criminal prosecution
Case Study: Process Safety Info Element Employers must assemble written process safety information prior to conducting a hazard analysis. Purpose: assist in identifying the hazards and risks associated with the process. Information included: chemicals used or produced, toxicity, permissible exposure limits, physical data, reactivity, corrosivity, chemical stability, thermal stability, and hazards associated with inadvertent mixing. Block flow diagrams, piping and instrument diagrams (P&IDs), material and energy balances, and Material Safety Data Sheets (MSDS). 15
Case Study: Process Safety Info Concept Sciences, Allentown, Pennsylvania. February 19, 1999 - employees starting up a new process for the first time distilling an aqueous solution of hydroxylamine and potassium sulfate. Hydroxylamine exploded. – 4 employees and a manager from a nearby business killed. – 4 other people in nearby facilities injured. – 10 buildings were damaged in the explosion. CSB concluded that the safety management systems at the company were insufficient to properly address the hazards inherent in the manufacture of hydroxylamine. – Company did not collect and analyze safety information properly prior to start up. – “[This incident] demonstrates the need for effective process safety management and engineering throughout the development, design, construction, and startup of a hazardous chemical production process.” 16
SFD Opportunities SCAP covers 11 different Process Safety topics SRVs – Is there an up to date list – Is there a schedule (5-year) change out – Can you demonstrate facility is tracking Sioux Falls 17
Case Study: PHA Element Thorough, orderly, systematic approach for identifying, evaluating, and controlling the hazards of processes involving highly hazardous chemicals. Key area - provides information to help management and operators make informed decisions to reduce risk. 18
First Chemical Corp., Pascagoula, Mississippi October 31, 2002, facility had a mononitrotoluene distillation column. This distillation column was in standby mode, and employees thought it was isolated by the use of a manual valve. – The distillation column is used to separate chemical compounds for final use. Column exploded. – 3 workers killed and several buildings damaged. CSB determined distillation column was inadvertently heated because of a leak in steam isolation valves. Valves leaked because corrosion prevented seating properly. (Heating caused some material to be vaporized, and this material was carried up the column and accumulated on the chimney tray at the top where the pressure increase reached a level high enough to cause the explosion.) CSB stated that the company had failed to conduct a formal hazard analysis for mononitrotoluene, specifically to determine instabilities in the process. Because the hazard analysis was not performed, the hazards were not known and controls for an unstable process were not instituted. 19
SFD Opportunities SCAP covers 10 topics PHA team members – Is there a list – Does it include experienced refrig ops – Does it include non-mgmt Written action plan with dates for completion – Mgmt cannot arb override team – $ cannot be rationale 20
Case Study: Training Element Provides employees with the knowledge and tools to fully understand the risks in working with hazardous chemicals. All employees, including contractor employees and maintenance personnel, must be trained to understand the MSDS, safe work practices and operating procedures. Particular importance - emergency response, including conditions for evacuation and shelter-in-place and the use of personal protective equipment. The employer must identify who is to be trained, the goals of the training, and what the training will cover. This training should be tailored for the organization and operations. The training should include a mix of classroom and hands-on training to increase its effectiveness. The training should be periodically evaluated and updated as conditions and operations changes. 21
Case Study DPC Enterprises, Glendale Arizona Repackaging chlorine from larger railcars into smaller containers. Process allows chlorine gas capture using a scrubber; this scrubber used sodium hydroxide to convert chlorine gas into bleach. November 17, 2003, sodium hydroxide had become depleted, making the scrubber ineffective and allowing release of toxic chlorine compounds into the atmosphere. – Large portions of Glendale and Phoenix evacuated. – 5 resident and several police hospitalized. CSB faulted the operator training, stating that “Operator training, based on the operating procedure, did not address the sensitivity of the scrubber to over-chlorination or the safety and environmental consequences of over-chlorination.” The CSB also faulted the company for deficiencies in its auditing program in detecting problems with procedures, training, and hazard assessment. “Without written procedures, training was conducted in an informal, on-the-job manner, relying upon physical demonstration and word of mouth.” According to the report, none of the operators had seen any written procedures at the plant, and the procedures used varied by operator. Management had developed a generic operating procedure, but it did not address all phases of operation and did not include emergency procedures. 22
SFD Opportunities SCAP cover 10 areas PSM operator training – Can you document certified training? Employees – All affected employees? 23
Case Study: Contractor Element Responsibility of the employer to assure that the contractors who work in and around hazardous chemicals have the appropriate skills and knowledge Employer must obtain appropriate certifications from that contractor Employer should screen the contractor to assure that they can perform the tasks safely. 24
Cabin Creek Hydroelectric Plant near Georgetown, Colorado. Contractors were working in a confined space, recoating a tunnel with an epoxy coating material, when the fire occurred. On October 2, 2007, five workers were killed and three others were injured in a chemical fire at the The CSB report stated that the flammable solvent used to clean the epoxy likely ignited, and the fire grew as additional buckets of epoxy material and solvent also ignited. The workers had only one way to exit the tunnel, and that exit was blocked by the flames. The report stated that the workers communicated with other personnel for 45 minutes before losing their lives to smoke inhalation. The CSB report stated that the company and its contractor failed to plan and coordinate the recoating project, and therefore did not analyze or prepare for the confined space hazards. The CSB report stated that, “the serious safety hazards of using a flammable solvent inside the confined space were not identified or addressed.” Because of a failure to perform such safety analyses, controls such as substituting a non-flammable solvent, monitoring the work area, providing adequate ventilation, eliminating ignition sources, and providing confined space rescue teams were not considered. The report also identified concerns with the poor safety record of the contractor and the inadequate training of its personnel. According to the report, “The majority of [contractor] employees working at Cabin Creek had not received comprehensive formal safety training; effective training on company policies; or site-specific instruction addressing confined space safety, the safe handling of flammable liquids, the hazard of static discharge, emergency response and rescue, and fire prevention.” The report also stated that, although the work created the potential for life threatening exposure to a flammable atmosphere with a need for immediate emergency response, the only emergency plan was to call 9-1-1 emergency dispatch. No emergency responders were on site on the day of the accident, and the response time for trained personnel was over an hour. The workers died before trained emergency response crews could arrive 25
SFD Opportunities SCAP cover 12 topics 300 logs for contractors working near syst Do your contractor PSM/RMP forms go to those working near systems? Do you conduct annual evaluations? 26
Other Opportunities Pre-startup safety review – Closed our MOCs? – MOCs and SOPs cannot be on the same day Labeling Mech. Integrity – MI audit every 3 years – + manufacturer recs + visual every year Incident Investigations – Near misses, too 27
Take Aways Best enforcement roadmap: – routine audit findings not addressed – regulatory inspections items not addressed – Release cause (even if not RQs) not addressed Make sure PM and PE are looping you in on CARs Make sure you communicate concerns to Corp Safety Dirs, ECs and PSM Coordinators 28
Regulations and Purpose 1990 CAA PSM 29 CFR 1910.119 RMP 40 CFR 68 Aimed at the prevention of accidental releases of substances that can cause serious harm.
PSM/RMP Qualifications A facility must comply with PSM/RMP regulations when: amount of regulated chemical in a process > Threshold Quantity (TQ) A process which involves a flammable liquid or gas on site in one location, in a quantity of 10,000 pounds (4535.9 kg) or more – e.g., 10,000 lbs. of Methane = 223,714 ft 3 at STP The list of flammable and acutely toxic chemicals and their TQ’s can be found in 40 CFR 68.
Appendix A Examples Chemical Name CAS TQ (lbs) Ammonia, Anhydrous 7664-41-71000010,000 Chlorine7782-50-515001500 Hydrogen Sulfide 7783-06-41500 NOTE: 1500 lbs. of Hydrogen Sulfide = 16,760 ft 3 at NTP NTP – Normal Temperature and Pressure - is defined as air at 20 o C (293.15 K, 68°F) and 1 atm ( 101.325 kN/m 2, 101.325 kPa, 14.7 psia, 0 psig, 30 in Hg, 760 torr) STP – Standard Temperature and Pressure - is defined as air at 0 o C (273.15 K, 32 o F) and 1 atm (101.325 kN/m 2, 101.325 kPa, 14.7 psia, 0 psig, 30 in Hg, 760 torr)
Elements Process Safety Information-Requires compilation of written process safety information (PSI) including hazard information. Employee Involvement-Requires developing a written plan of action regarding employee participation; consulting with employees and their representatives on the conduct and development of process hazard analyses and process safety management. Process Hazard Analysis-Specifies that process hazard analyses (PHA's) must be conducted. Process hazard analyses must be updated and revalidated at least every five years and must be retained for the life of the process. Operating Procedures-Must be in writing and provide clear instructions for safely conducting activities involving covered process consistent with PSI. Training-Employees operating a covered process must be trained in the overview of the process and in the operating procedures addressed previously. Documented refresher training is required at least every three years.
Contractors-Identifies responsibilities of work site employer and contract employers with respect to contract employees involved in maintenance, repair, turnaround, major renovation or specialty work, on or near covered processes. Pre-startup Safety Review-Mandates a safety review for new facilities and significantly modified work sites to confirm that the construction and equipment of a process are in accordance with design specifications. Mechanical Integrity-Requires the on-site employer to establish and implement written procedures for the ongoing integrity of process equipment particularly those components which contain and control a covered process. Hot Work-Hot work permits must be issued for hot work operations conducted on or near a covered process. Management of Change-The work site employer must establish and implement written procedures to manage changes except "replacements in kind" to facilities that effect a covered process.
Incident Investigation Each incident must be investigated that resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical in the workplace. The investigation must be initiated no later than 48 hours following the incident. An incident investigation team that consists of persons knowledgeable in the incident process must be established and the team must thoroughly investigate and analyze the incident.
Incident investigation (continued) A report must be prepared at the conclusion of the investigation. A system must be developed to promptly address, resolve and document the incident report findings, recommendations and corrective actions. The incident report must be made available to affected employees as well as contractors; and, The report must be retained for at least five years.
Emergency Planning and Response An Emergency Action Plan (EAP) must be developed to ensure the safe evacuation of employees Plan must address all foreseeable emergency situations (e.g., fire, weather, chemical releases, etc.) In addition, an Emergency Response Plan must be developed if employees will respond to the chemical release Plan must address the means and methods necessary to protect employees responding to an uncontrolled release of a process chemical
Compliance Audits The adequacy of the employer’s procedures and practices must be evaluated and certified at least every three years. The compliance audit must be conducted by at least one person knowledgeable in the process. A report of the findings of the audit must be developed. The employer must document an appropriate response and any corrective action for each of the findings in the audit. Prompt response to audit findings and documentation that deficiencies are corrected The two most recent compliance audit reports must be retained.
Training Emphasis on the specific safety and health hazards of the process Emergency operations including shutdown, Safe work practices applicable to the employee's job tasks Refresher training at least every three years Prepare a record which contains: – The identity of the employee, – The date of training, and – The means used to verify that employees understood the training
Risk Management Program Contents: – Hazards Assessment – Management Program – Prevention Program – Emergency Response Program A Risk Management Plan (RMP) must be submitted to the EPA Exact RMP contents are dictated by the Program the facility falls within (1,2, or 3)
RMP Decision Tree Does the process contain a regulated substance > threshold quantity ? Within the past 5 years did the process have a significant release? PROGRAM 1 Is the process one of these SIC codes: 2611 2821 2873 2819 2865 2879 2819 2869 2911 Is the process subject to OSH PSM? Will a worst-case release result in significant offsite impact? Not subject to 112(r) YES NO PROGRAM 3 PROGRAM 2 Three Risk Management Programs
Program 1Program 2Program 3 Hazard Assessment Worst-Case Analysis 5-Year Accident History Worst-Case Analysis Alternative Releases Analysis 5-Year Accident History Worst-Case Analysis Alternative Releases Analysis 5-Year Accident History Management Program Document Management System Prevention Program Certify No Additional Steps NeededHazard Review Operating Procedures Training Maintenance Incident Investigation Compliance Audit Hazard Review and Operating Procedures Training and Maintenance Incident Investigation Compliance Audit and Hot Work Permits Management of Change Pre-Startup Review and Contractor Requirements Employee Participation Emergency Response Coordinate with Local RespondersDevelop Plan and Program Risk Management Plan Contents Executive Summary Registration Worst-Case Data 5-Year Accident History Certification Executive Summary Registration Worst-Case and Alternative Release Data 5-Year Accident History Prevention Program Emergency Response Certification Executive Summary Registration Worst-Case Data and Alternative Release 5-Year Accident History Prevention Program Emergency Response Certification