29CFR1910.119
Process Safety Management is the application of management principles and systems to the identification, understanding, and control of process hazards to protect employees, facility assets and the environment.
Clean Air Act Amendments of 1990-304 gave OSHA directives to create standards to prevent catastrophic releases of highly hazardous chemicals. They responded in 1991 with 29CFR1910.119 or what is known as Process Safety Management for Highly Hazardous Chemicals. (PSM) 3
Written safety information Workplace hazard assessment Consult with employees Establish a system to respond to findings Periodic review of assessments and response Written operating procedures Safety training and operating information 14 ELEMENTS
Appropriate information and training for contractors Train and educate employees in emergency response Establish a quality assurance program Establish maintenance systems Pre-start-up safety reviews Management of change Incident investigation Audits
1910.119 (f)(1) Operating procedures 14.0% (d)(3) PSI 20.9% (e)(3) PHA specific criteria 15.8% (j)(4) MI Inspection & Testing 23.2% (l)(1) MOC implementation 5.5% 7
WILLFUL 49 REPEAT 35 SERIOUS 925 OTHER 108
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-toabate violations. This Instruction replaces OSHA's Enhanced Enforcement Program (EEP). 9
Enhanced Follow-up Inspections Nationwide Inspections of Related Workplaces/Worksites Increased Company Awareness of OSHA Enforcement Enhanced Settlement Provisions Federal Court Enforcement under Section 11(b) of the OSH Act Bottom Line: OSHA is Serious About Compliance and Enforcement of PSM 10
OSHA criticized after BP Texas City for lack of enforcement of PSM standard Chemical Safety Board criticized OSHA 2009 EPA Inspector General Report did the same for EPA Recommended that EPA target higher-priority facilities
Complaint Random Personal Injury Fatality Release Contractor Injury Referral (EPA) MEDIA EVENT?
Facility has a 350,000 gallon above ground Water Tank Water Tank Collapse
What Does A Collapsed Water Tank Have to Do With PSM????????????????
5 Ton Air Compressor sitting on 20 foot mobile trailer, 120 feet from the water tank and 120 feet from the Emergency Ammonia Storage Tank located on the other side of the trailer
350,000 gallon water tank collapsed Wave of water surfed a 20 foot flat trailer with a 5 Ton air compressor sitting on it, over 120 feet Trailer then turned 90 degrees and tilted downward Back of trailer slid under an emergency reserve ammonia tank utilized for pump downs and struck a 1 ½ inch valve, shearing it off the bottom of the tank Resulting in a release of residual ammonia from the tank
Ammonia Loss was at minimum levels (Residual in the bottom of the tank) However, the wind direction pushed the odor toward the plant and entered the plant through the Hog Barns. Plant was evacuated and some (8) employees had complaints of breathing and exposure to ammonia. (all treated for observation and released) Local responders (fire, EMS, police) responded to the scene. Plant operations were halted for 3 days due to water supply and damaged electrical transformers
At the time of the evacuation the outdoor temperature was at 98 degrees with very high humidity Facility management procured every bottle of water and fluids from the only two business s in town Of course the winds shifted and those evacuated had to be moved to a new location Busses were provide to move employees to a local school for shelter out of the heat
OSHA responded to the scene of the incident to conduct an investigation Based on the fact that it was an MEDIA EVENT OSHA determined that a Full PSM NEP was required as well as a Comprehensive Wall-to Wall inspection of the location. The inspection was conducted over a 5 ½ month time-frame with as many as 14 compliance officers from 3 separate Regional OSHA offices, including a Regional Director and a visit from the NC State Bueareau Chief
OSHA STANCE (2) valve tags identifications missing on P&IDs Ventilation fan out of service for more than 30 days did not do recalculate ventilation SOP need a matrix to track, documentation of what is done, is not adequate Actual PM s over a 12 month period could not be verified as closed (most but not all) 3- tone evacuation alarm system (PA, Radio) not adequate One relief stack out of 19 was at 13 9 and not 15
OSHA Stance Continued Annual valve exercising and inspection did not meet Mfg. Rec. of Semi-Annual on some unique valves (12 months vs. 6 months) Response, operator approached release with a meter in hand and a full face respirator, operator evacuated the area when meter reading exceeded his PPE. OSHA, defined this as an unknown concentration and operator should have been equipped in full Level A, SCBA, and back up person.
Operating Procedures Is every SOP reviewed by every operator and when? How do you know every operator reviewed every SOP (Management Tracking) Does SOP for Emergency Shutdown include the Emergency Shutoff button outside the engine room? Are operators able to communicate / demonstrate exactly as prescribed in the SOP? Are SOP s current with MOC changes? including documented refresher training of all operators? DO SOP s compare with Non-Routine situations identified in the PHA?
Process Safety Information (PSI) Are inspections of (valves) concurrent with OEM? How is it confirmed that all valves, equipment scheduled for annual inspection (PM s) were completed? (tracking of each valve, equipment, etc.) Confirm that each valve group is current with the P&ID (they are picking out specific sections) tag numbers, etc. What is the procedure for a temporary tag if an operator identifies a missing tag or label? Do you have a Tag and Label inspection process separate from Mechanical Integrity? Have letter of documentation to verify electrical classification. Pick an area, walk it with P&ID to verify tags, numbers, etc., match the P&IDs
Process Safety Information (PSI) Emergency STOPS outside of engine room (SOP s) Ventilation calculations (current) Do E-Stops or alarms activate exhaust fans? Do roof top air units (AMU) have automatic shutdown tied in with alarms?
Process Hazard Analysis (PHA) * Without saying, Address OPEN recommendations? * Does PHA include Fall Protection for areas on roof where operators access valves? Lighting? * If an unseen event should occur, you will be questioned as to why it was not in the PHA? Have you conducted a PHA when ventilation is modified? Does it reflect in the ventilation calculation? Can you evidence that the PHA results were communicated as part of Employee Participation?
Process Hazard Analysis (PHA) PHA Legend of Rankings Can you be cited for completing a recommendation? PHA RANKING LEGEND (included in all Audits) 1 =(complete in 6 months) 2= (complete in 1 year) Project rated as a 2 completed in 15 months = citation
Mechanical Integrity - Inspections & Testing Again, close open recommendations Are all Preventative Maintenance (PM s) not only scheduled & completed? Do they meet OEM and recommended practices (IIAR)? Are all PM s closed out? Are annual internal inspections documented and completed between the required MI audits? (list / matrix) Can you evidence competence of outside services performing MI audits? Are all meters, alarms, detectors, etc being calibrated and bench tested per OEM Be prepared to show training of operators on PM s
Training Do you have a matrix of all training required for operators and when required? Completed? What is required to be completed by a new operator before they work alone? Do you have a tracking method of who has completed what training? What is left to complete? Is every SOP reviewed annually by each operator Does your Emergency Action Plan include, Who has authority to start an evacuation? Are they trained?
Emergency Response What is the role of the IC, are they trained? Ensure that initial responders treat the situation as an unknown concentration and follow their training (Drills) All Drills, Mocks, and actual events require a critique. Detailed response plan including outside responders Ensure that all HAZMAT team members training is within a 12-month window, remove responders from list that are not, keep list updated Can operators / responders get to an egress on the roof without crossing over or under pipes (all valve groups)? What about lighting?
OSHA continues to targeting refrigerated companies (especially in the meat industry) OSHA is going beyond the surface in initial reviews OSHA is utilizing other resources and references beyond CFR (Mfg. Recommend Practices, IIAR, RMP, REGAGAP, etc.. OSHA is identifying companies through other opportunities (complaints / referrals) Releases of any amount if reported by the media could result in a NEP or a Wall-to-Wall
QUESTIONS????? P SAFETY MANAGER S M