Process Safety Management of Highly Hazardous &
Explosive Chemicals
29CFR1910.119
Simple Keys to Compliance

Objectives
 Define what is PSM and who is covered by the standard
 List the elements of the PSM standard
 Locate additional resources
2

What Is Process Safety
Management?
 PSM:
 Addresses the management of Highly
Hazardous Chemicals (HHC)
 Integrates
 Technology
 Operating Procedures
 Standard management protocols
3

Why Did OSHA Develop PSM?
 Past Disasters
 Current Disasters
 Perceived Weakness in PSM
Program
4

Why Did OSHA Develop PSM?
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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
5

Why Did OSHA Develop PSM?
In 1991, OSHA and
EPA respectively,
Released the
Standards, PSM &
RMP that Applies to
Those Companies that are Affected by
The Standards.
6

Why Did OSHA Develop PSM?
Process Safety
Management is a regulation, promulgated by OSHA, intended to prevent an incident like the 1984 Bhopal Disaster
And…to Prevent Release of:
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Toxic,
Reactive,
Flammable, or
Explosive chemicals
7

Not Only PSM, But RMP
A great many industrial facilities must comply with OSHA's Process
Safety Management
(PSM) regulations as well as the CAA 112(r)
EPA Risk
Management Program
(RMP) regulations
(Title 40 CFR Part 68).
8

PSM vs. RMP - What’s the
Difference?
 PSM - Like HAZCOM
 Protects the
Workforce
 Protects Contractors
 Protects Visitors to the Facility
 Basically Protects the
Workplace
 RMP-Like Sara Title III
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Protects the
Community
Protects the General
Public Around the
Facility
Protects Adjacent
Facilities Such as
Schools & Hospitals
9

The Standard Was Promulgated in 1991 - Is it Working?
10

The Standard Was Promulgated in 1991 - Is it Working?
 BP Products Texas
City March 2005
 15 Workers Killed
 170 Injured
 Major Property
Damage
 $50.6 Million in Fines
11

The Elements of the PSM
Standard
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Application
Exclusions
Definitions
Employee Participation
Hazards of the Process
Toxicity
Technology of the
Process
Equipment in the
Process
Mechanical Integrity
Inspection & Testing
Quality Assurance
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Process Hazard
Analysis
Management of Change
Operating Procedures
Safe Work Practices
Training
Contractor
Management
Emergency Planning &
Response
Incident Investigation
Compliance Audits
Trade Secrets
12

The Elements of the PSM
Standard
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Application
Exclusions
Definitions
Employee Participation
Hazards of the Process
Toxicity
Technology of the
Process
Equipment in the
Process
Mechanical
Integrity
Inspection & Testing
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Process Hazard
Analysis
Management of Change
Operating Procedures
Safe Work Practices
Training
Contractor
Management
Emergency Planning &
Response
Incident Investigation
Compliance Audits
Trade Secrets
13

The Elements of the PSM
Standard
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Application
Exclusions
Definitions
Employee Participation
Hazards of the Process
Toxicity
Technology of the
Process
Equipment in the
Process
Mechanical Integrity
Inspection & Testing
Quality Assurance
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Process Hazard
Analysis
Management of
Change
Operating Procedures
Safe Work Practices
Training
Contractor
Management
Emergency Planning &
Response
Incident Investigation
Compliance Audits
Trade Secrets
14

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The Elements of the PSM
Standard
Application
Exclusions
Definitions
Employee Participation
Hazards of the Process
Toxicity
Technology of the
Process
Equipment in the
Process
Mechanical Integrity
Inspection & Testing
Quality Assurance
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Process Hazard
Analysis
Management of
Change
Operating
Procedures
Safe Work Practices
Training
Contractor
Management
Emergency Planning &
Response
Incident Investigation
Compliance Audits
Trade Secrets
15

The Elements of the PSM
Standard
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Application
Exclusions
Definitions
Employee Participation
Hazards of the Process
Toxicity
Technology of the
Process
Equipment in the
Process
Mechanical Integrity
Inspection & Testing
Quality Assurance
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Process Hazard
Analysis
Management of
Change
Operating Procedures
Safe Work Practices
Training
Contractor
Management
Emergency Planning &
Response
Incident Investigation
Compliance Audits
Trade Secrets
16

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The Elements of the PSM
Standard
Application
Exclusions
Definitions
Employee
Participation
Hazards of the Process
Toxicity
Technology of the
Process
Equipment in the Process
Mechanical Integrity
Inspection & Testing
Quality Assurance
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Process Hazard
Analysis
Management of
Change
Operating Procedures
Safe Work Practices
Training
Contractor
Management
Emergency Planning &
Response
Incident Investigation
Compliance Audits
Trade Secrets
17

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The Elements of the PSM
Standard
Application
Exclusions
Definitions
Employee Participation
Hazards of the Process
Toxicity
Technology of the
Process
Equipment in the Process
Mechanical Integrity
Inspection & Testing
Quality Assurance
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Process Hazard
Analysis
Management of
Change
Operating Procedures
Safe Work Practices
Training
Contractor
Management
Emergency Planning &
Response
Incident Investigation
Compliance Audits
Trade Secrets
18

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The Elements of the PSM
Standard
Application
Exclusions
Definitions
Employee Participation
Hazards of the Process
Toxicity
Technology of the
Process
Equipment in the Process
Mechanical Integrity
Inspection & Testing
Quality Assurance
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Process Hazard
Analysis
Management of
Change
Operating Procedures
Pre-Start up Safety
Review
Hot Work Permit
Safe Work Practices
Training
Contractor
Management
Emergency Planning &
Response
19

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The Elements of the PSM
Standard
Application
Exclusions
Definitions
Employee Participation
Hazards of the Process
Toxicity
Technology of the
Process
Equipment in the Process
Mechanical Integrity
Inspection & Testing
Quality Assurance
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Process Hazard
Analysis
Management of
Change
Operating Procedures
Pre-Start up Safety
Review
Hot Work Permit
Safe Work Practices
Training
Contractor
Management
Emergency Planning &
Response
20

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The Elements of the PSM
Standard
Application
Exclusions
Definitions
Employee Participation
Hazards of the Process
Toxicity
Technology of the
Process
Equipment in the Process
Mechanical Integrity
Inspection & Testing
Quality Assurance
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Process Hazard
Analysis
Management of
Change
Operating Procedures
Pre-Start up Safety
Review
Hot Work Permit
Safe Work Practices
Training
Contractor
Management
Emergency
Planning &
Response
21

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The Elements of the PSM
Standard
Application
Exclusions
Definitions
Employee Participation
Hazards of the Process
Toxicity
Technology of the
Process
Equipment in the
Process
Mechanical Integrity
Inspection & Testing
Quality Assurance
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Process Hazard
Analysis
Management of
Change
Operating Procedures
Pre-Start up Safety
Review
Hot Work Permit
Safe Work Practices
Training
Contractor
Management
Emergency Planning
& Response
22

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The Elements of the PSM
Standard
Application
Exclusions
Definitions
Employee Participation
Hazards of the Process
Toxicity
Technology of the
Proce ss
Equipment in the
Process
Mechanical Integrity
Inspection & Testing
Quality Assurance
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Process Hazard
Analysis
Management of
Change
Operating Procedures
Pre-Start up Safety
Review
Hot Work Permit
Safe Work Practices
Training
Contractor
Management
Emergency Planning
& Response
23

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The Elements of the PSM
Standard
Application
Exclusions
Definitions
Employee Participation
Hazards of the Process
Toxicity
Technology of the
Proce ss
Equipment in the
Process
Mechanical Integrity
Inspection & Testing
Quality Assurance
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Process Hazard
Analysis
Management of
Change
Operating Procedures
Pre-Start up Safety
Review
Hot Work Permit
Safe Work Practices
Training
Contractor
Management
Emergency Planning
& Response
24

The Elements of the PSM
Standard
Let ’s Explore Some of the Elements…
25

Application
1910.119(a)
26

What Facilities are Covered
 Those Who Use Chemicals in Appendix A: A List of highly hazardous chemicals, toxics and reactive
(Mandatory). Contains a listing of toxic and reactive highly hazardous chemicals which present a potential for a catastrophic event at or above the threshold quantity
 Examples

Chemical Threshold Quantity (TQ)
Anhydrous Ammonia 10,000 lbs
 Chlorine 1,500 lbs
27

What Facilities are Covered
 A process which involves a flammable liquid or gas (as defined in
1910.1200(c) of this part) on-site in one location, in a quantity of 10,000 pounds (4535.9 kg) or more
28

What Facilities are Covered
 Important Interpretation: 2007 - 06/11/2007 - OSHA defines "on-site in one location" for Process Safety
Management of Highly Hazardous Chemicals standard
OSHA interprets "on-site in one location" to mean that the standard applies when a threshold quantity of a highly hazardous chemical (HHC) exists within an area under the control of an employer or group of affiliated employers. It also applies to any group of vessels that are interconnected, or in separate vessels that are close enough in proximity that the
HHC could be involved in a potential catastrophic release.
29

What Facilities are Covered
Affect of the “Meer” Decision:
MEER ruling and the MEER Memorandum addressed in the
Secretary's letter, OSHA's enforcement policy that the Agency would not cite employers for violations of 1910.119 where stored flammable liquids in atmospheric tanks were connected to a process, unless the process outside of the amount in storage contained more than 10,000 pounds of the substance
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What Types of Industries?
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Industries that Process Chemicals Such As:
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Industrial Organics & Inorganics
Paints
Pharmaceuticals
Adhesives
Sealants and Fibers
Petrochemical facilities
Paper Mills
Food Processing with Anhydrous Ammonia over the TQ
31

Exclusions
1910.119(a)(1)(ii)(A)
32

There are Exclusions
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An employer is exempt from the requirements of PSM when:
A threshold quantity of flammable liquids is stored in atmospheric tanks or transferred without the benefit of chilling or refrigeration
Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling),
 If such fuels are not a part of a process containing another highly hazardous chemical covered by this standard
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There are Exclusions
 Retail facilities;
 Oil or gas well drilling or servicing operations; or,
 Normally unoccupied remote facilities
34

Employee Participation
1910.119(c)
35

Now that we are required to comply, then what?
 Form a Team in
Your Company, i.e..
 Process Engineers
 Operators
 Safety
 Maintenance
 Management
 Consultants
Remember…You Can’t Do it Alone!
36

Now that we are required to comply, then what?
 Form a Plan,
Determine:
 Responsibilities
 Duties
 Reporting
 Document Control
 Progress Reports
 Tracking Changes
Then…Begin the Process of Developing &
Implementing the PSM Program
37

Hazards of the Process
1910.119(d)(1)
38

The Requirements of the Standard
- Hazard Determination
Determine:
 Chemicals in Your Process
 Process Chemistry
 Quantity of Chemicals in lbs
 Compare to Appendix A List with
Threshold Quantities (TQ ’s)
39

Toxicity Information
1910.119(d)(1)(i)
40

The Requirements of the Standard
- Develop Toxicity Information
 Obtain Toxicity
Information on the
Chemical(s) in the
Process
 MSDS are Typical
Resource
 You May Need
Other References,
NIOSH Pocket
Guide, ACGIH TLV ’s
41

Technology of the Process
1910.119(d)(2)
42

The Requirements of the Standard
- Process Technology
 Block flow diagram or process flow diagram
 Process chemistry
 Maximum intended inventory
 Upper and lower limits
 Consequences of deviations
43

The Requirements of the Standard
- Process Equipment
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Materials of construction
Process and instrument drawings (P&ID ’s)
Electrical classification
Relief system design
Ventilation system design
Design codes
Material and energy balances
Safety systems
44

Equipment in the Process
1910.119(d)(3)
45

The Requirements of the Standard
- Process Equipment
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Now:
Identify Each Piece of
Equipment in the
Covered Process by
P&ID, Block Diagram and Number Them
Remember - Must
Follow Form
Must be Able to Track
Each Number Through the Entire Program
46

Mechanical Integrity
1910.119(j)
47

The Requirements of the Standard
- Process Equipment
Mechanical Integrity
Certificates
Must be Obtained for Each
Element of the Process
Must be Marked with
Numbering System that
Follows Form
48

Process Hazard Analysis (PHA)
1910.119(e)
49

Process Hazard Analysis
(PHA’s)
 Arguably the Most Difficult Part of
Performing the Standard
 PHA process is dynamic and subject to revision whenever changes are made
 Performed by Your PSM Team
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Takes Significant Time & Effort
PHA ’s are Never Ending
50

Process Hazard Analysis
A PHA Process Must be
Performed on Each
Element of the Covered
Process:
A PHA From Block
Diagram to P&ID to Every
Equipment Component to
Determine What Might
Happen if an Element of the Covered Process Fails
51

There is Much More to PSM
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Inspection & Testing
Quality Assurance
Management of Change
Operating Procedures
Safe Work Practices
Training
Contractor Management
Emergency Planning & Response
Incident Investigation
Compliance Audits
Trade Secrets
52

Management of Change
 Procedures to manage changes to the covered process.
 Exception: “replacement in kind”
 Management of Change includes:
 Process chemicals
 Technology
 Equipment
 Operating Procedures
 Facilities
53

Management of Change Addresses
1.
2.
3.
4.
5.
Technical basis of the change
Impact to employee safety and health
Modification to operating procedures
Time period for change
Authorization of change
54

Operating Procedures
 Develop and implement written operating procedures that are clear instructions for all expected phases of operations.
 AKA – Standard Operating Procedures
(SOPs)
 Must cover:
 Operation phase
 Operational limits
 Safety & health considerations
55

OPs Must Address
 Initial start-up
 Normal operations
 Temporary operations
 Emergency shutdown
 Emergency operations
 Normal shutdown
 Start-up following turnaround
 Consequences of deviation
 Steps required to correct or avoid deviation
56

SOPs
 Must be readily available to employees
 Must be reviewed as needed to ensure they reflect current operating practicce.
 Must cover:
 Process chemicals
 Technology and equipment
 Facilities
 SOPs must be certified annually that they are correct and accurate.
57

Safe Work Practices (SWPs)
 Must be developed and implemented to provide for the control of hazards during work activities such as:
 Lock-out/Tag-out
 Confined space entry
 Opening processes, piping or equipment
SWPs are for:
• Operators
• Maintenance personnel
• Contractors
• Lab personnel
• Or other support personnel
58

Training
 PSM specific training is required
 Must cover:
 Safety and health hazards associated with the covered process
 Safe work practices
 Refresher training is required every 3 years or as needed to ensure employees are complying with all PSM requirements
59

Contractors
 Contractors involved in or around a covered process must be informed of required PSM elements.
 Contract work includes:
 Maintenance and repair
 Turn around
 Major renovations
 Specialty knowledge or services
 Does not include support services not involved with the covered process, like laundry or vending machine supply
60

Emergency Action Plans (EAP)
 Must have EAP for entire facility
 EAP must have provisions for small releases of HHCs
 Develop a Early Warning Method for
Releases
 Train on the Meaning of the Alarms
 Develop Emergency Evacuation Written
Plans, Evacuation Maps & Assembly
Points
61

Incident Investigations
 Must be initiated ASAP, but within 48 hours
 Team must include:
 Person knowledgeable in the process involved
 Includes contractor if work of the contractor involved
 Other persons with appropriate knowledge of the covered process
62

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Incident Investigation Report
Report must be produced with the following:
 Date of incident
 Date of start of investigation
 Description of incident
 Factors contributing to incident
 Recommendations
 System must be established to promptly address recommendations and findings of report
 Resolutions and corrective action must be documented
63

Compliance Audit
 To ensure that PSM is effective, employers must certify every 3 years that they have evaluated compliance with the standard
 Must be completed by at least on person knowledgeable in the process
 Report must be developed and documented
 Deficiency corrections must be documented
 Last two compliance audits must be kept on file
64

Trade Secrets
 Employers must make all necessary information required to comply with
PSM, regardless of trade secrets, available to persons involved in developing or creating:
 Compiling process safety information
 PHAs
 SOPs
 Incident investigations
 Emergency planning and response
 Compliance audits
 Confidentiality agreements are allowed
65

BP Texas City Refinery Case
Study in PSM
 The third largest petroleum refinery in the
United States with a refining capacity of
475,000 barrels of crude per day.
 Located on a 1,200-acre facility in Texas City,
Texas southeast of Houston in Galveston
County.
 1,200 permanent BP employees and hundreds of additional contractors at the facility
66

Anatomy of a Disaster- BP Texas
City
 Things to Think About:
 What went wrong?
 What went right?
 What could/should have been done to prevent this disaster?
67

BP Texas City Refinery Case
Study in PSM
Fact Sheet on BP 2009 Monitoring Inspection
The U.S. Department of Labor's Occupational Safety and Health Administration (OSHA) has proposed $87,430,000 in propose penalties against BP Products North America, Inc. for 709 alleged failures to comply with the 2005 settlement agreement and citations, and violations of safety and health standards identified during the agency's inspection of the corporation's refinery in Texas City, TX (BPTCR). The inspection of the refinery was conducted from May through October 2009.
BP Texas City Refinery (BPTCR):
The third largest petroleum refinery in the United States with a refining capacity of 475,000 barrels of crude per day.
Located on a 1,200-acre facility in Texas City, Texas southeast of Houston in
Galveston County.
1,200 permanent BP employees and hundreds of additional contractors at the facility
Prior History at BPTCR:
On March 23, 2005, an explosion and fire in the Isomerization Unit of the BP
Texas City Refinery (BPTCR) resulted in the death of 15 contractor employees and injury of at least 170 other BP employees and contractors.
OSHA initiated safety and health inspections into the March 2005 incident and issued citations and fines totaling over $21 million, the highest penalty that OSHA had ever issued.
The Report of the BP U.S. Refineries Independent Safety Review Panel
(aka Baker Report) issued in January 2007 identified a number of
systemic process safety issues at BP refineries in the U.S.
March 2007, U.S. Chemical Safety and Hazard Investigation Board
(CSB) released its report Refinery Explosion and Fire (15 Killed, 180
Injured). CSB found, "The Texas City disaster was caused by
organizational and safety deficiencies at all levels of the BP Corporation".
OSHA has conducted 17 separate inspections at the refinery in the last 4 years.
Prior to the 2005 incident, two employees of BPTCR died due to a breakdown of the company’s lockout and tagout program.
Since the 2005 incident, four more fatal incidents have occurred at the facility, involving one BPTCR employee and 3 contractors.
2005 Settlement Agreement
As a result of the March 2005 explosion and subsequent inspection, BP entered into a settlement agreement with OSHA in September 2005
BP agreed to pay $21 million in penalties
68

JORDAN BARAB
Deputy
Assistant Secretary
After BP-Texas City, Have We Learned Anything?
 Now, in spite of your efforts, we have to acknowledge that something is desperately wrong. The status quo isn't working.
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In the past three months alone, 58 workers have died in explosions, fires and collapses at refineries, coal mines, an oil drilling rig, and a natural-gas-fired power plant construction site.
OSHA is particularly concerned about the recent number of serious incidents at refineries that have scalded, burned or struck down your fellow workers. We are tracking these catastrophes and looking for trends -including problems resulting from aging facilities. Since the BP Texas City explosion in 2005, OSHA has counted over 20 serious incidents in refineries across the country.
69

There is Much More to PSM
Now, The OSHA PSM National Emphasis
Program for Refineries & Chemical
Facilities &
Severe Violator Enforcement
Program (SVEP)
70

OSHA National Emphasis
Program (NEP) for Refineries &
Chemical Facilities
 Petroleum
Refineries NEP
 Issued August
2009
 Chemical Facilities
NEP
 Issued July 2010
71

Typical Standards Cited
 1910.119
 1910.147
 1910.120
PSM – 249 violations
Lock and Tag - 20
Hazwoper - 19
 1910.1200 Hazcom - 12
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1910.146
5A.001
Confined Space - 11
General Duty - 9
 1910.307 Hazardous Locations - 7
72

Most Frequent NEP PSM Citations
1910.119
 (f)(1) Operating procedures…………..38
 (d)(3) PSI pertaining to equipment ….28
 (e)(3) PHA specific criteria……………26
 (j)(4) MI Inspection & Testing ………..21
 (e)(5) PHA recommendation ...………12
 (l)(1) MOC implementation …………..12
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Severe Violator Enforcement
Program (SVEP)
 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-to-abate violations.
This Instruction replaces OSHA's Enhanced
Enforcement Program (EEP).
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Severe Violator Enforcement
Program (SVEP)
References:
 OSHA Instruction CPL 03-00-010, Petroleum
Refinery Process Safety Management
National Emphasis Program, August 18, 2009
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Severe Violator Enforcement
Program (SVEP)





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
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EPA Risk Management Plans
(RMP) Basics
CAA 112(r)
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One More Thing to Discuss…
EPA Risk Management Plans
(RMP)



Many Times Companies Who Must Comply with PSM, must also Comply with the
Requirements of EPA Risk Management
Plans (RMP)
The RMP Standard was to be a Mirror of the
PSM Standard…Didn’t happen!
Remember…PSM Protects the Workforce,
RMP Protects the Community
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EPA RMP
 Basic Requirements
 Executive summary
 Registration
 Off-site consequence analysis
 Five-year accident history
 Emergency response plan
 Prevention program summary information
 Certification
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All Public Facilities in this Release
Plume Must be
Identified &
Surveyed
Release
Plume
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OSHA PSM Summary






PSM is a Comprehensive, Difficult Standard
Although it was Promulgated in 1991,
Catastrophes Continue to Occur
Recognizing these Facts, OSHA has
Developed a National Emphasis Program for
Refineries and Chemical Manufacturers
More Emphasis Planned for all PSM Sites
There is Much More Work to be Done…
RMP Must Also be Considered for Many
Facilities
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Tools for Additional PSM
Assistance
 PSM Checklist
 www.oshainfo.gatech.edu
 OSHA Website
 www.osha.gov
 Chemical Safety Board Website
 www.csb.gov
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PSM Checklist
Use this checklist to help determine employer compliance with the Process Safety Management Standard issued by the
Occupational Safety and Health Administration.
Please note that the checklist does not include all of the standard’s requirements and does not reflect all OSHA letters of interpretation or compliance directives in particular situations.
There are 3 elements to a review of a PSM program:
1.
Documentation review – examination of the documentation of the programs required by the standard.
2.
Field Inspection & Verification – examination of the physical covered process; its equipment, piping, instrumentation, procedures, and operation.
3.
Interviews – discussions with employees and contractors to determine if the implemented program matches the program outlined in the documentation.
In order to gather the information needed to audit a PSM program the following questions need to be asked for each PSM program element
 Who  What  When  Where  Why  How
 Who – Who is responsible for developing and implementing each of the program elements?
 What – What are the requirements and contents of each program element?
 When – When are the required actions for each element completed and when were they required to be completed?
 Where – Where have actions been implemented or changed?
 Why – Why have the implementation decisions and priorities been made as recorded in the documentation?
 How – How is the program implemented and how is the program’s effectiveness evaluated and improved?
An essential part of verifying program implementation is to audit the flow of information and activities among the elements. When information in one element is changed or when action takes place in one element that affects other elements, an auditor/reviewer should examine a sample of the related elements to see if the appropriate changes and followup actions have taken place.
The following example demonstrates the interrelationship among the elements:
During a routine inspection of equipment ( Mechanical Integrity ), the maintenance worker discovers a valve that no longer meets the applicable code and must be changed. Because the type of valve is no longer made, a different type of valve must be selected and installed ( Management of Change ). The type of valve selected may mandate different steps for the operators (Operating Procedures) who will require training and verification in the new procedures ( Training ).
The rationale for selecting the type of valve must be made available for review by employees and their representatives
( Employee Participation ).
When the new valve is installed by the supplier ( Contractors ), a qualified and safe contractor must be selected to perform the work (Contractor Management). The work will involve shutting down part of the process ( Pre-startup Safety
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Review ) as well as brazing some of the lines ( Safe Work Practices - Hot Work Permit ). The employer must review the response plan ( Emergency Planning ) to ensure that procedures are adequate for the installation hazards. Although
Management of Change provisions cover interim changes, after the new valve is in place the Process Safety
Information will have to be updated before the ( Process Hazard Analysis ) is updated or revalidated, to account for potential hazards associated with the new equipment. Also, inspection and maintenance procedures and training will need to be updated ( Mechanical Integrity ).
In summary, 12 PSM elements can be affected by changing one valve. A reviewer/inspector/auditor/compliance officer would check a representative number of these 11 elements to confirm that the required follow-up activities have been implemented for the new valve.

For More Information www.psmtraining.com
www.oshainfo.gatech.edu
www.pe.gatech.edu/safety
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Contact Information
 Michelle Dunham, MSPH, MSM
 michelle.dunham@gtri.gatech.edu
 404-407-8284
 Bob Hendry
 bob.hendry@gtri.gatech.edu
 Art Wickman, CIH
 art.wickman@gtri.gatech.edu
 Georgia Tech Occupational Safety & Health Program
 www.oshainfo.gatech.edu
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Funding
Funding for:
Process Safety Management of Highly
Hazardous and Explosive Chemicals:
Simple Keys to Compliance
By special funding from the Occupational
Safety and Health Administration
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