Process Safety Management (PSM) Safety and Security Conference April 21, 2010 1 Intertek Expert Services Our Knowledge – Your Advantage

Intertek Expert Services Our Knowledge – Your Advantage The Law – Intent “The process safety management standard targets highly hazardous chemicals that have the potential to cause a catastrophic incident. This standard as a whole is to aid employers in their efforts to prevent or mitigate episodic chemical releases that could lead to a catastrophe in the workplace and possibly to the surrounding community.” APPENDIX C TO § 1910.119 2 Intertek Expert Services Our Knowledge – Your Advantage

Intertek Expert Services Our Knowledge – Your Advantage The Law – Intent To prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals “This section contains requirements for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. These releases may result in toxic, fire or explosion hazards.” OSHA interprets “catastrophic” as an incident that results in: A fatality Three or more are hospitalized. 3 Intertek Expert Services Our Knowledge – Your Advantage

Intertek Expert Services Our Knowledge – Your Advantage 29 CFR 1910.119 Covered Processes Materials on site at or above threshold quantities of chemicals listed in appendix A of the standard. Flammable liquids / gases onsite in one location in quantities greater than 10,000 lbs. (Certain exemptions apply) Manufacture of explosives. Manufacture of pyrotechnics List of highly hazardous chemicals (appendix A to 29 CFR 1910.119). § 1910.119 Process safety management of highly hazardous chemicals. Purpose. This section contains requirements for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. These releases may result in toxic, fire or explosion hazards. Section 14 has a copy of the 1910.119 regulation. 4 Intertek Expert Services Our Knowledge – Your Advantage

Elements OSHA Standard 29 CFR 1910.119 Employee Participation Process Safety Information Process Hazard Analysis Operating Procedures Training Contractors Pre-startup Safety Review Mechanical Integrity Hot Work Permits Management Of Change Incident Investigations Emergency Planning And Response Compliance Audit Every 3 Years Trade Secrets. Unions pushed for employee participation (since it was operations personnel that were getting injured / killed by the incidents. OSHA is proactive in supporting union labor participation. However, due to shift rotations, getting bargaining unit employees involved in a risk assessment project is not an easy task. Shift-to-shift variations in operating procedure, particularly in manual operations, is often uncovered during the team risk assessment sessions. 5 Intertek Expert Services Our Knowledge – Your Advantage

Employee Participation Employers shall develop a written plan of action regarding the implementation of the employee participation required by this paragraph. Employers shall consult with employees and their representatives on the conduct and development of process hazards analyses and on the development of the other elements of process safety management in this standard. Employers shall provide to employees and their representatives access to process hazard analyses and to all other information required to be developed under this standard. OSHA’s intent – involve operators in the RA. Particularly bargaining unit employees. § 1910.119 Process safety management of highly hazardous chemicals 6 Intertek Expert Services Our Knowledge – Your Advantage

Process Safety Information (PSI) “In accordance with the schedule set forth in paragraph (e)(1) of this section, the employer shall complete a compilation of written process safety information before conducting any process hazard analysis required by the standard.” § 1910.119 Process safety management of highly hazardous chemicals 7 Intertek Expert Services Our Knowledge – Your Advantage

Intertek Expert Services Our Knowledge – Your Advantage PSI – The Chemicals Information Pertinent to the Highly Hazardous Chemicals of the Process (used or produced): Toxicity Permissible Exposure Limits Physical Data Reactivity Data Corrosivity Data Thermal and Chemical Stability Data Incompatibility data. 8 Intertek Expert Services Our Knowledge – Your Advantage

Intertek Expert Services Our Knowledge – Your Advantage Chemicals – The Intent “The information to be compiled about the chemicals, including process intermediates, needs to be comprehensive enough for an accurate assessment of the fire and explosion characteristics, reactivity hazards, the safety and health hazards to workers, and the corrosion and erosion effects on the process equipment and monitoring tools. Current material safety data sheet (MSDS) information can be used to help meet this requirement which must be supplemented with process chemistry information including runaway reaction and over pressure hazards if applicable.” The Ciba Guidance notes and subsequent material presented in this course is consistent with the laws intent. APPENDIX C TO § 1910.119—COMPLIANCE GUIDELINES AND RECOMMENDATIONS FOR PROCESS SAFETY MANAGEMENT (NONMANDATORY) APPENDIX C TO § 1910.119 9 Intertek Expert Services Our Knowledge – Your Advantage

Intertek Expert Services Our Knowledge – Your Advantage PSI – The Process Information Pertinent to the Technology of the Process: Block Flow Diagrams or simplified Process Flow Diagram Process Chemistry Maximum Intended Inventory Safe upper and lower limits such as temperature, pressure, flows An evaluation of the consequences of deviation including those affecting safety and health of employees The following items are included Process Technology section of the Ciba McIntosh site SAFETY POLICY AND PROCEDURE 15-X-11.00, “Process Safety Information, but are not explicitly required in the OSHA 1910.119 standard: Data on previous incidents related to the process or operation Ecotoxicity. 10 Intertek Expert Services Our Knowledge – Your Advantage

Intertek Expert Services Our Knowledge – Your Advantage What is a Process? “Process means any activity involving a highly hazardous chemical including any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or combination of these activities. For purposes of this definition, any group of vessels which are inter-connected and separate vessels which are located such that a highly hazardous chemical could be involved in a potential release shall be considered a single process.” § 1910.119 Process safety management of highly hazardous chemicals, Definitions 11 Intertek Expert Services Our Knowledge – Your Advantage

Intertek Expert Services Our Knowledge – Your Advantage PSI -- Equipment Materials of construction P & id's Electrical classifications Relief systems & design basis Ventilation systems Design codes Material / energy balances (for processes built after 5-26-92) Safety systems / interlocks  12 Intertek Expert Services Our Knowledge – Your Advantage

PSI – Incidents (Intent) The intent of an incident investigation is for employers to learn from past experiences and thus avoid repeating past mistakes. The incidents for which OSHA expects employers to become aware and to investigate are the types of events which result in or could reasonably have resulted in a catastrophic release. Some of the events are sometimes referred to as ‘‘near misses,’’ meaning that a serious consequence did not occur, but could have. APPENDIX C TO § 1910.119 13 Intertek Expert Services Our Knowledge – Your Advantage

Critical Limits – The Law’s Intent “Process technology information will be a part of the process safety information package and it is expected that it will include diagrams of the type shown in appendix B of this section as well as employer established criteria for maximum inventory levels for process chemicals; limits beyond which would be considered upset conditions; and a qualitative estimate of the consequences or results of deviation that could occur if operating beyond the established process limits.” Appendix B has the block flow and and process flow diagrams. APPENDIX C TO § 1910.119 14 Intertek Expert Services Our Knowledge – Your Advantage

Intertek Expert Services Our Knowledge – Your Advantage PHA Scope The process hazard analysis shall address: The hazards of the process. The identification of any previous incident which had a likely potential for catastrophic consequences in the workplace. Engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases. Consequences of failure of engineering and administrative controls. Facility siting. Human factors. A qualitative evaluation of a range of the possible safety and health effects of failure of controls on employees in the workplace. 15 Intertek Expert Services Our Knowledge – Your Advantage

Intertek Expert Services Our Knowledge – Your Advantage PHA Requirements (e)(1) Prioritize processes and perform initial PHAs within 5 years. (e)(2) Use specified methodologies or equivalent (e)(3) Address hazards of the process and six specific concerns in the PHA. (e)(4) Include proper expertise and experience on the PHA team. (e)(5) Establish a system to track the handling of the PHA recommendations. (e)(6) Update and revalidate PHAs every 5 years. (e)(7) Retain PHA documentation for the life of the process. 16 Intertek Expert Services Our Knowledge – Your Advantage

Intertek Expert Services Our Knowledge – Your Advantage The RA Team “The process hazard analysis shall be performed by a team with expertise in engineering and process operations, and the team shall include at least one employee who has experience and knowledge specific to the process being evaluated. Also, one member of the team must be knowledgeable in the specific process hazard analysis methodology being used.” OSHA 1910.119 17 Intertek Expert Services Our Knowledge – Your Advantage

Intertek Expert Services Our Knowledge – Your Advantage Methodology What-If Checklist What-If/Checklist Hazard and Operability Study, (HAZOP) Failure Mode and Effects Analysis (FMEA) Fault Tree Analysis, or An appropriate equivalent methodology. The PHA output (record) should indicate why a particular method or method(s) were chosen. FMEA supports quantification risk assessments. Three methodologies that are defensible for regulatory compliance: What-If/Checklist Hazard and Operability Study, (HAZOP) Failure Mode and Effects Analysis (FMEA) 18 Intertek Expert Services Our Knowledge – Your Advantage

Intertek Expert Services Our Knowledge – Your Advantage Corrective Action “The employer shall establish a system to promptly address the team’s findings and recommendations: Assure that the recommendations are resolved in a timely manner and that the resolution is documented Document what actions are to be taken; Complete actions as soon as possible; Develop a written schedule of when these actions are to be completed; Communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions.” An employer can justifiably decline to adopt a recommendation when the employer can document, in writing and based upon adequate evidence that: The analysis upon which the recommendation is based contains material factual errors; The recommendation is not necessary to protect the health and safety of the employer’s own employees, or the employees of contractors (I do not think this is currently applicable with EPA’s RMP regulation that extends responsibility beyond the plant fence line, LDF). An alternative measure would provide a sufficient level of protection; or The recommendation is infeasible. OSHA considers an employer to have “resolved” the team’s findings and recommendations when the employer either has adopted the recommendations or has justifiably declined to do so. When a recommendation is rejected, the employer must communicate this to the team, and expeditiously resolve any subsequent recommendations to the team. 19 Intertek Expert Services Our Knowledge – Your Advantage

Corrective Action Tracking Process – Basic Process Re-opened If Not Effective New Action Added Person Assigned To Action Person Assigned Emailed Action Completed Action Taken Verified By Owner Action Closed 20 Intertek Expert Services Our Knowledge – Your Advantage

Intertek Expert Services Our Knowledge – Your Advantage Contractors Contractor Safety Train on Work Practices Inform Contractor Hazards Emergency Action Plan Control and Track Evaluate Maintain Injury and Illness Log 21 Intertek Expert Services Our Knowledge – Your Advantage

Written Operating Procedures Requirements Steps for each operating phase Initial startup Normal operations Temporary shutdowns Emergency shutdowns Emergency operations Normal shutdowns Startup after shutdowns Operating limits / deviations Safety & health considerations Safety systems & their functions 22 Intertek Expert Services Our Knowledge – Your Advantage

Pre-startup Safety Review Requirements Construction is in accordance with design specifications Safety, operating, maintenance, and emergency procedures are in place and adequate Process hazards analysis recommendations have been addressed Employee training completed 23 Intertek Expert Services Our Knowledge – Your Advantage

Mechanical Integrity Scope Pressure vessels Storage tanks Piping systems Relief / vent systems & devices Emergency shutdown systems Process Controls (e.G.: Sensors, alarms, interlocks, etc.) Pumps 24 Intertek Expert Services Our Knowledge – Your Advantage

Mechanical Integrity Requirements Written procedures Training program Inspections / testing Records / documentation Corrective action program Quality assurance in new installations 25 Intertek Expert Services Our Knowledge – Your Advantage

Management Of Change Procedure Requirements Technical basis of change Impact of change on safety, health & ecology Modifications to operating procedures Necessary time period for change Authorization requirements Employee training requirements 26 Intertek Expert Services Our Knowledge – Your Advantage

MOC/PSSR Process – Basic Process 27 Intertek Expert Services Our Knowledge – Your Advantage

Incident Investigations Scope: incidents which resulted in, or could reasonably have resulted in a catastrophic release of a highly hazardous chemical in the workplace. Investigation initiated within 48 hours Investigation by knowledgeable team Report content: Date of incident Date investigation began Incident description Contributing factors Recommendations Corrective action systems Communication of report Retention of report for 5 years 28 Intertek Expert Services Our Knowledge – Your Advantage

AIIMS Process – Basic Process 29 Intertek Expert Services Our Knowledge – Your Advantage

Emergency Planning & Response Requirements Evacuation procedures / routes Critical equipment operation Head count procedures Rescue & medical duties Notification Alarm systems Types of evacuation Training Procedures for handling small releases As per OSHA 29 CFR 1910.38a, 1910.119, & 1910.120 30 Intertek Expert Services Our Knowledge – Your Advantage

Intertek Expert Services Our Knowledge – Your Advantage Thank You for Your Time Shawn Blenis Intertek USA 251-610-1337 Shawn.blenis@intertek.com 31 Intertek Expert Services Our Knowledge – Your Advantage