PROCESS SAFETY MANAGEMENT VS RISK MANAGEMENT

1
PROCESS SAFETY MANAGEMENT VS RISK MANAGEMENT

• An Overview
• Tracy Estes, CSP
• James E. Roughton, MS, CSP, CRSP, CHMM

2
Process Safety Management

• Required by the Environmental Protection Agency's
  (EPA) Clean Air Act Amendments (CAAA), Section
  304
• Promulgated - February 24, 1992
• 5 year implementation
• Proactive identification, evaluation, and
  mitigation or prevention of chemical releases
  that could occur as a result of failures in
  processes, procedures, or equipment
• 130 highly hazardous chemicals (HHCs)

3
Process Safety Management (continued)

• 10,000 lb. or more of flammable materials that
  are used at or above their boiling points
• Pyrotechnics and explosives manufacturers
• More than 28,000 facilities affected
• Exemptions
• fuels used for workplace consumption
• Comfort heating
• Gasoline for vehicles

4
Risk Management Plan

• Mandated by CAAA, Section 112 (r), 40 CFR Part
  68
• Promulgated - May 24, 1996
• Published Federal Register - June 20, 1996
• More than 100,000 facilities affected
• Designed to help reduce risk of accidental
  release of hazardous substances
• 3 years to implement

5
Risk Management Plan (continued)

• Affects owners of a stationary source with
  regulated substances above a threshold quantity
  (TQ)
• 77 acutely toxic
• 63 flammable
• Department of Transportation (DOT) classified
  explosive substances

6
EPAs Visions for Accidental Release Prevention

• Emphasize community right-to-know
• Let information drive action
• Focus the program at the local level
• EPA support
• Coordinate communications at local level

7
Key Features of RMP

• Prevention program
• 7-elements mini-PSM program
• 14 elements OSHA-PSM program expanded to address
  offsite effects
• Emergency response program
• Risk management plan
• Electronic submission to state and LEPC
• Available to public
• Regulatory audits

8
Key Features (continued)

• 3 Program levels
• Management system
• Offsite consequence analysis
• Worst-case scenario
• Alternative release scenario
• 5-year accident history

9
Key Features (continued)

• Summarizes key elements of the RMP program
• Tells a story
• Hazards at the site
• Accident history
• Potential offsite consequences
• Prevention steps
• Response program

10
Exemptions to Threshold Quantity

• Articles
• Laboratories
• Uses
• Structural components
• Janitorial maintenance
• Foods, drugs, cosmetics, or other personal items
• Present in process water or non-contact cooling
  water
• Compressed air or as part of combustion

11
EPAs Regulatory Approach

• Performance-based approach
• Similar to OSHAs PSM
• Build on existing programs and standards
• Scale the requirements to fit the risk
• Coordinate with OSHA and DOT

12
Requirements of 112 (r)

• Established a general duty clause to
• Identify hazards that may result from releases
• Design and maintain a safe facility
• Minimize the consequences or releases

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Requirements of 112(r) (continued)

• Required EPA to promulgate a list of substances
  and set thresholds
• Required EPA to develop a risk management program
  (RMP) rule
• Register with EPA
• Conduct a hazard assessment
• Develop a prevention program
• Develop an emergency response program

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Requirements of 112 (r) (continued)

• Provide a summary (RMP) to
• EPA
• States
• Locals
• Public

15
Basic Principles

• Build on EPCRA
• Emphasize community right-to-know
• Focus the program at the local level
• Where the risk is found

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Basic Principles (continued)

• Accommodate small business concerns
• Provide model RMPs
• Ammonia
• Warehouses with chemicals
• Batch processors
• Refineries/gas plants
• Provide reference tables for offsite consequences
  analysis

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Manufacturing Industries Affected

• Chemical manufacturers
• Industrial Organics Inorganics
• Paints
• Pharmaceuticals
• Adhesives,
• Sealants
• Fibers

18
Manufacturing Industries Affected (continued)

• Petrochemical Products
• Refineries
• Industrial Gases
• Plastics and Resins
• Synthetic Rubber

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Non-Manufacturing Affected (continued)

• Non-Manufacturing Facilities affected
• Utilities
• Electric and Gas
• Public Sources
• Drinking Water and Waste Water Treatment
• Agriculture
• Fertilizers, Pesticides

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Other Manufacturing

• Electronics
• Semiconductors
• Paper
• Fabricated metals
• Industrial machinery
• Furniture
• Textiles

21
Other Industries

• Food and Cold Storage
• Propane Retail
• Warehousing
• Wholesalers
• Federal sources
• Military and Energy Installations

22
PSM vs. RMP Requirements

• PSMs concern - potential hazard and protection
  of employees inside a regulated area
• RMPs concern - potential incidents that may
  cause environmental and health hazards outside
  facility boundaries
• Editorial changes to PSM to make text consistent
  with the CAAA's language

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Hazard Assessment

• Offsite consequence data
• Population estimate
• Public receptors
• Environmental receptors
• Every 5 years
• Within 6 months of a change that increases or
  decreased distance by a factor of 2 or more

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Overview Worst-Case Scenario (WCS)

• Greatest quantity from vessel or piping
• May include administrative controls
• Toxic gases
• Quantity released in 10 minutes
• Toxic liquids
• Instantaneous spill to ground volatilization
  passive mitigation
• Toxic gases liquefied by refrigeration

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Worst-Case Scenario (continued)

• All flammable substances
• Quantity for vapor cloud explosion
• One worst case for each process
• One worse case representing all toxic substances
• Additional worst case(s) different public
  receptors
• Other considerations
• Smaller quantities at higher temperature or
  pressure
• Source boundary proximity

26
Alternative Release Scenario (ARS)

• More likely than a worst case scenario
• Much reach endpoint offsite
• One scenario representative of all flammables

27
ARS Selection

• Accident history events
• Process hazard analysis events
• Worse case with mitigation
• Example scenarios
• Piping or hose failures
• Seal failures
• Vessel overfilling or venting

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List of Substances and Thresholds

• Focuses on lethal effects resulting from acute
  exposures
• Includes mandated substances

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Mandated Substances

• Ammonia
• Anhydrous Ammonia
• Anhydrous Hydrogen Chloride
• Anhydrous Sulfur Dioxide
• Bromine
• Chlorine
• Ethylene Oxide
• Hydrogen Cyanide

• Hydrogen Fluoride
• Hydrogen Sulfide
• Methyl Chloride
• Methyl Isocyanate
• Phosgene
• Sulfur Trioxide
• Toluene Diisocyanate
• Vinyl Chloride

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Toxic Substances

• Extremely hazardous substances under SARA
• Gases and highly volatile liquids
• Vapor pressure gt 10 mmHg
• Thresholds ranging from 500-2,000 lbs.
• Thresholds based on toxicity and volatility

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Flammable Substances

• NFPA 4
• Most dangerous
• Flammable gases and volatile flammable liquids
  that could create vapor cloud explosions
• Thresholds set at 10,000 lbs.

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Threshold Quantity Determination

• Total quantity of a regulated substances
  contained in a process at any one time
• Process included interconnected vessels or
  separate vessels that could be involved in a
  release (OSHA PSM definition)

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Offsite Consequence Analysis

• Toxic endpoint
• Flammable endpoints
• Use appropriate models or guidance
• Within circle, identify
• Public receptors and population
• Environmental receptors

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Registration and Submittal

• Submit a comprehensive RMP to
• EPA
• State Emergency Response Commission (SERC)
• Local Emergency Planning Committee (LEPC)
• The Chemical Safety and Hazard Investigation
  Board

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Registration and Submittal (Continued)

• Name, mailing address, telephone of stationary
  source
• CAS number of all regulated substances greater
  than TQ
• SIC code
• Dun and Bradstreet number
• Certification signed by owner or operator

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Auditing the Program

• Conduct audits of the management system

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Program Eligibility Criteria

• Three Programs

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Program 1 - No impact

• Register
• Conduct worst-case hazard assessments
• Certify no off-site consequences for worst-case
  scenario
• Ensure inclusion in LEPC plan
• Submit RMP document above

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Program 3 - Full RMP

• One comprehensive prevention program that
• Protects workers
• The public
• The environment
• Hazard review information
• Hazards
• Controls
• Mitigation
• Changes

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Program 3 (continued)

• Register
• Conduct worst-case and other hazard assessments
• Implement comprehensive prevention steps (OSHA
  PSM plus...)
• Develop emergency response plan
• Submit RMP

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Program 3 (continued)

• Process is subject to OSHA's PSM
• Processes in specific SIC codes
• Pulp Mills (2611)
• Chlor-Alkali (2812)
• Industrial Inorganic (2819)
• Plastics and Resins (2821)
• Cyclic Crudes (2865)
• Industrial Organics (2869)
• Nitrogen Fertilizers (2873)
• Agricultural Chemicals (2879)
• Petroleum Refineries (2911)

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Program 2 - Streamlined Prevention Program

• The process is not eligible for Program 1 or 3

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Program 2 (continued)

• Statutory requirements
• Training
• Maintenance
• Safety Precautions
• Monitoring

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Program 2 (continued)

• Types of sources
• Less complex fewer changes
• Ideal model program and plans
• Capture good management practices from PSM but
  less documentation
• Take advantages of other rules and standards
• Take advantages of equipment manufacturer or
  vendor information

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Program 2 (continued)

• Process information (SIC, chemicals)
• List rules, standards, design codes
• Hazard review information
• Hazards
• Controls
• Mitigation
• Changes

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Program 2 (continued)

• Register
• Conduct worst-case and other hazard assessments
• Implement seven elements of prevention program
• Develop emergency response plan
• Submit RMP

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Comparison of Program Requirements

• Hazard Assessment
• Program 1 Program 2 Program 3
• Worst-case analysis Worst-case
  analysis Worst-case analysis
• Alternative releases Alternative releases
• 5-year accident history 5-year accident
  history 5-year accident history

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Comparison (continued)

• Management Program Document
• Program 1 Program 2 Program 3
• Management System Management System

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Comparison (continued)

• Prevention Program
• Program 1 Program 2 Program 3
• Certify no additional Safety Information
  Process Safety Information
• steps Required Hazard Review Process Hazard
  Review
• Operating Procedures Operating Procedures
• Training Training
• Maintenance Mechanical Integrity
• Incident Investigation Incident Investigation

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Comparison (continued)

• Prevention Program (continued)
• Program 1 Program 2 Program 3
• Compliance Audit Compliance Audit
• Management of Change
• Pre-Startup Review
• Contractors
• Employee Participation
• Hot Work Permits

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Comparison (continued)

• Emergency Response Program
• Program 1 Program 2 Program 3
• Coordinate with Local Develop Plan Develop
  Plan
• Responders and Program and Program

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Comparison (continued)

• Risk Management Plan Content
• Program 1 Program 2 Program 3
• Executive Summary Executive Summary Executive
  Summary
• Registration Registration Registration
• Worst-Case Data Worst-Case Data Worst-Case
  Data
• 5-Year Accident History Alternative Release
  Data Alternative Release Data
• Certification. 5-Year Accident History 5-Year
  Accident History

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Comparison (continued)

• Risk Management Plan Content (continued)
• Program 1 Program 2 Program 3
• Prevention Program Data Prevention Program Data
• Emergency Response Data Emergency Response Data
• Certification Certification

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Editorial Changes (continued)

• OSHA PSM Requirements EPA Program 3 Requirements
• An evaluation of the consequences An evaluation
  of the consequences
• of deviations, including those of deviations
• affecting the safety and health
• of employees
• The identification of any previous The
  identification of any previous
• incident which had a likely potential incident
  which had a likely potential
• for catastrophic consequences in for
  catastrophic consequences
• the workplace

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Editorial Changes (continued)

• OSHA PSM Requirements EPA Program 3
  Requirements
• A qualitative evaluation of a range A
  qualitative evaluation of a range
• of possible safety and health effects of possible
  safety and health
• of failure of controls on employees effects of
  failure of controls
• in the workplace
• The employer shall investigate each The owner or
  operator shall
• incident which resulted in, or could investigate
  each incident which
• reasonably have resulted in a catastrophic
  resulted in, or could reasonably
• release of a highly hazardous chemical have
  resulted in a catastrophic
• in the workplace release of a regulated
  substance

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Language Comparison

• OSHAs - PSM EPAs - RMP
• Employer Owner or Operator
• Highly Hazardous Chemicals Regulated Substances
• Facility Stationary Source
• Standard Rule
• Workplace Impact Off-Site Consequences

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Compliance Procedures

• Develop an inventory of substances used, stored,
  manufactured, processed, handled or moved, or any
  combination of the listed activities
• Compare the inventory with the TQ, as required

58
Management System

• Develop a management system to oversee the
  implementation of the RMP elements
• Identify single person or position who has
  overall responsibility for
• Development
• Implementation
• Integration of the RMP

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Elements of the Program
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Process Safety Information

• Block flow or process flow diagrams
• Maximum intended inventory
• Establish safe limits of the operating parameters
  

61
Process Safety Information (continued)

• Evaluate consequences in deviations of process
  conditions
• Equipment information
• Verify equipment design with regulatory
  requirements/standard

62
Process Hazard Analysis

• Document hazard analysis
• Nature of the hazard
• Cause of the hazard
• Consequences of the hazard
• Actions to be considered to further protect
  personnel
• Document follow-up steps based on recommendations

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Process Hazard Analysis (continued)

• Document previous incidents with the potential to
  cause catastrophic conditions
• Document hazards associated with human factors
  and facility siting

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Operating Procedures

• Develop clear operating procedures addressing
  steps for each process regarding
• Safe operating limits of processes
• Equipment
• Provide precautionary instructions to prevent
  exposure to hazards

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Operating Procedures (continued)

• Develop operating procedures for safety systems
• Conduct annual review of operating procedures
• Develop procedures for lockout/tagout, confined
  space entry, etc.

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Employee Training

• Document training for personnel in the process,
  operating procedures, and safe work practices
  applicable to the job tasks
• Maintain records of training indicating the means
  used to verify that the employee understood the
  training

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Maintenance (Mechanical Integrity)

• Provide written procedures to maintain the
  structural integrity of process equipment
• Document training for employees involved in
  maintenance of the process equipment
• Verify inspections and testing of equipment and
  deficiencies are corrected
• Document that spare parts are suitable for the
  appropriate application

68
Incident Investigation(Accident Investigation)

• Incident reporting
• The date of the incident
• Date of the investigation
• Description of the incident
• Factors contributing to the incident, and
  recommendations that resulted
• Verify that the recommendations in the incident
  report were promptly addressed and resolved
• Identify root causes as well as initiating events

69
Compliance Audits

• Evaluate compliance with program every three
  years
• Conduct with at least one person knowledgeable in
  process
• Develop report of findings Determine/develop a
  response to each finding, document that
  deficiencies have been corrected
• Retain two most recent audit reports

70
Management of Change

• Provide written procedures to manage change to
  process chemicals, technology, equipment, and
  procedures, and changes to facilities that affect
  a covered process
• Verify that employees in operations and
  maintenance are trained accordingly
• Provide evidence that changes are documented

71
Pre-Startup Review

• Document that construction and equipment is in
  accordance with design specifications
• Review documentation showing that safety,
  operating, maintenance, and emergency procedures
  are in place and adequate
• Document that a PHA was performed, and
  recommendations were resolved and implemented

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Pre-Startup Review (continued)

• Verify that modified facilities meet requirements
  in Management of Change procedures
• Verify that employee training is completed

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Contractors

• Must established a screening process when hiring
  and use contractors
• A site injury and illness log for contractors
  must be maintained
• The contractor must ensure that each contract
  employee is trained in the work practices
  necessary to safely perform his/her job

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Employee Participation

• Must develop a written plan of action regarding
  the implementation of employee participation.
• Required to train and educate employees and to
  inform all affected employees of the findings
  from any incident investigations.

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Employee Participation (continued)

• Must consult with employees and employee
  representatives
• Development of PHA and other elements
• Hazard assessments
• The development of chemical accident prevention
• Must provide access to these records.

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Permit Systems

• A work authorization notice or permit system
  should be developed
• To describe the steps the maintenance supervisor,
  contractor representative or other person need to
  follow in order to obtain the necessary clearance
  to get the job done.
• These procedures need to address such issues as
• Lockout/tagout procedures
• Line breaking procedures
• Confined space entry procedures
• Hot work permits

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Permit Systems (continued)

• Procedures must provide clear steps to follow
  once the job is completed to provide closure for
  those that need to know the job is completed and
  equipment can be returned to normal operations.

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Emergency Planning and Response

• Document that an emergency plan has been
  established and implemented in accordance with 29
  CFR 1910.38 and 1910.120, as applicable
• Emergency action plan that include procedures for
  handling releases
• Document specific actions to be taken in response
  to an accidental release of a regulated substance
  to protect humans and the environment
• Conduct drills
• Exercise to test plan

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Emergency Response Plan - Basic Requirements

• Emergency response plan
• Procedures for use of emergency response
  equipment and for it inspection, testing, and
  maintenance
• Training for all employees in relevant procedures
• Procedures to review and update of the plan to
  reflect changes at the facility and ensure that
  employees are informed of changes

80
Elements - Legislative Requirements

• Procedures for informing the public and local
  emergency response agencies
• Documentation of proper first-aid and emergency
  medical treatment necessary to treat accidental
  human exposures
• Procedures and measures for emergency response
  after a release
• Written plan must comply with other federal
  regulations
• Coordinate with local LEPC

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Planning Option - One-Plan Guidance for
Integrated Contingency Plan (ICP)

• Intended to
• Provide a mechanism for consolidating multiple
  facility response plans
• Improve coordination of response activities
• Minimize duplication and simplify plan
  development and maintenance
• Ensure regulatory compliance with all relevant
  federal requirements

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Communicating RMP to Public
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Communication

• Rule does not specify
• How communication should take place
• When it should take place
• How much risk communication
• Anyone putting public at risk must show how risk
  is addressed/prevented and responded to

84
Regulatory Approach

• Industry tells government and the public how it
  will address risk for preventing major accidents
• Government and public can review what industry
  has presented
• Government and community can respond to industry,
  communicate concerns, and make recommendation

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Communicating the RMP

• Start now
• Explain the program
• Tell the public what to expect with your WCS and
  when to expect it
• Explain your WCS
• Detail chemical(s) on site that can cause
  explosions, environmental impacts, etc.
• Explain why you cant reduce your inventory of
  regulated substances

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Community Outreach Suggestions

• Open house/plant tours
• Local citizen groups/civic organization
• High school programs
• Community survey
• What does the community think about you?
• Neighborhood meetings
• Plant newsletter
• Community advisory panels

87
Audience

• Neighbors
• Implementing agencies
• LEPC
• Emergency responders
• City and county officials

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Audience (continued)

• Business and community leaders
• Educators
• Local media
• State legislators

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Other Programs

• Risk communications training
• Training on handling the with media
• Informing industrial neighbors

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Summary - Developing an RMP Implementation Plan
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Implementation Strategy - Technical

• Acquire/understand regulatory information
• Determine coverage
• Determine technical capabilities/needs
• Prepare RMP implementation plan

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Implementation Strategy - Technical (continued)

• Perform program level screening
• Develop hazard assessment protocol
• Perform hazard assessment
• Compile 5-year accident history

93
Implementation Strategy - Technical (continued)

• Implement/upgrade PSM program to consider offsite
  effects
• Review/upgrade emergency response activities and
  plan
• Prepare and submit the RMP

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Implementation Strategy - Communication

• Determine internal risk communication
  capabilities/needs
• Survey community outreach status
• Establish/improve community outreach
• Prepare communication plan
• Improve internal risk communication capabilities
• Communicate the RMP to the public

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Available Resources

• Chemical Emergency Preparedness and Prevention
  Office (CEPPO)
• Internet - (http//www.epa.gov/swercepp/acc-pre.ht
  ml)

96
Suggested Team Members

• Health and safety Professionals
• Program development and review
• Chemical, electrical, and mechanical engineering
• Process safety information and hazard analysis
  development
• Air Quality Specialist/Industrial Hygienist
• Air modeling dispersion.
• Identify acute health effects

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Suggested Team Members (continued)

• Risk Assessment Specialist
• Population exposure and environmental effects
• Communications Specialists
• Communicating with the public

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Summary - Final Word

• PSM and RMP outlines requirements for facilities
  to reduce risks associated with accidental
  releases
• A good communications program will help reduce
  misinformation, distrust, and build good
  community relations
• Reduction in inventory will result in a reduction
  of the risk and potential for a catastrophic
  incident

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Summary - Final Word (continued)

• Audits are to be comprehensive, involving
  systematic assessment of all elements of the
  program