Process Safety Management of Highly Hazardous Chemicals 29 CFR 1910.119 (PSM)

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Process Safety Management of Highly Hazardous
Chemicals29 CFR 1910.119 (PSM)
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Disasters That Led to Process Safety Management

• Bhopal, India (1984)
• 2,000 deaths Isocyanate release
• Pasadena, TX (1989)
• 23 deaths, 132 injuries Petroleum explosion
• Cincinnati, OH (1990)
• 2 deaths Explosion
• Sterlington, LA (1991)
• 8 deaths, 128 injuries Chemical release

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Clean Air Act Amendments1990

• Requires Secretary of Labor along with EPA to
  promulgate a PSM standard
• PSM standard must include a list of highly
  hazardous chemicals
• Highly hazardous chemicals list must include
  toxics, flammables, highly reactive and
  explosive materials

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Minimum Program Requirements

• 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

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Minimum Program Requirements (cont.)

• 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

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Application of PSM

• Companies that process highly hazardous
  materials
• Flammable liquids and gases in quantities in
  excess of 10,000 pounds

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Initial Process Hazard Analysis Deadlines

• 25 complete by May 26, 1994
• 50 complete by May 26, 1995
• 75 complete by May 26, 1996
• 100 complete by May 26, 1997

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Process Safety Information

• Toxicity
• Permissible Exposure Limits
• Physical Data
• Reactivity Data
• Corrosivity Data
• Thermal and Chemical Stability Data

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Process Technology

• Block flow diagram or process flow diagram
• Process chemistry
• Maximum intended inventory
• Upper and lower limits
• Consequences of deviations

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Information on Process Equipment

• Materials of construction
• Piping and instrument diagrams (PIDs)
• Electrical classification
• Relief system design
• Ventilation system design
• Design codes
• Material and energy balances
• Safety systems

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Items the PHA Must Address

• Hazards of the process
• Identification of previous incidents
• Engineering and administrative controls
• Consequences of failure
• Facility siting
• Human factors
• Qualitative evaluation of S and H effects

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Operating Phases

• Initial start-up
• Normal operations
• Temporary operations
• Emergency shutdown
• Emergency operations
• Normal shutdown
• Start-up following turnaround

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Operating Limits

• Consequences of deviation
• Steps required to correct or avoid deviation

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Safety and Health Considerations

• Properties and hazards of the chemicals
• Precautions to prevent exposures
• Control measures to be taken
• Quality control for raw materials/control of
  inventory
• Special or unique hazards
• Safety systems and their functions

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Management of Change

• Technical basis for the proposed change
• Impact of the change on safety and health
• Modifications of the operating procedures
• Necessary time period for the change
• Authorization requirements for the change

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Training Requirements

• Initial training
• Prior to work assignment
• Waved for those already in a process
• Refresher training
• Every three years
• Training documentation

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Contractor Requirements

• PSM applies to contractors in or adjacent to a
  process performing
• Maintenance
• Repair
• Turnaround
• Major renovation
• Specialty work
• Does not apply to incidental contractors
• Food service
• Laundry
• Delivery, etc.

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Incident Investigation Reports

• Date of incident
• Date investigation began
• Description of the incident
• Factors contributing to the incident
• Recommendations resulting from the investigation

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Quiz

• 1. The Process Safety Management Standard was
  drafted as a requirement of the Clean Air Act.
  True or False
• 2. The PSM program must include a list of highly
  hazardous chemicals. True or False
• 3. The initial start-up of a process is not
  included as an operating phase under the PSM
  Standard. True or False
• 4. 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 False

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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 False
• 9. A technical basis is not required to change a
  process covered by the PSM Standard. True or
  False
• 10. Two types of training required by the PSM
  standard are ________________ and________________
  _.

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Quiz Answers

• 1. True. The Process Safety Management 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 citing, 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.

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Quiz Answers (cont.)

• 6. The PSM Standard applies to companies that
  either process highly hazardous materials or use
  flammable liquids and gases in excess of 10,000
  pounds.
• 7. Process safety information includes toxicity,
  permissible exposure limits, physical data,
  reactivity data, corrosivity data, and thermal
  and chemical stability data.
• 8. True. Fault Tree Analysis is one form of an
  approved method of performing a process hazard
  analysis.
• 9. False. All change must have a technical basis
  in order to be authorized.
• 10. Two types of training required by the PSM
  standard are initial and refresher.