Understanding Process Safety
Management - 29 1910.119
Elizabeth Morales, MS
VPP Recertification Manager
Region VII
816-283-0545 ext.254
Purpose: Prevent Catastrophic Releases of
Highly Hazardous Chemicals
Update FAT/CAT investigations
• DuPont Phosgene Release at Belle, WV- A release of
highly toxic phosgene resulted in one death. (Operator)
Cause: Sudden rupture of a braided steel hose
connected to a one-ton capacity phosgene tank
releasing phosgene into the air. (January 23,2010)
• Tesoro Refinery in Anacortes, WA- An explosion and
fire in a Naphta hydrotreater unit in the refinery led to the
fatal injury of six employees. (April 10,2010)
Purpose of the PSM Standard is….
• To prevent or minimizing the
consequences of catastrophic releases of
chemicals such as:
• Highly toxics
• Reactive
• Flammables
• Explosives
History of the PSM standard
• Proposed rule was
published – July
17,1990
• Final Rule was
published- February
24, 1992.
Final Rule Provisions
1.
2.
3.
4.
5.
6.
7.
8.
Application
Definitions
Employee Participation
Process Safety
Information
Process Hazard Analysis
Operating Procedures
Training
Contractors
9. Pre-start up Safety
Review
10. Mechanical Integrity
11. Hot Work Permit
12. Management of Change
(MOC)
13. Incident Investigations
14. Emergency Planning
15.Compliance Audits
16.Trade Secrets
What’s New with PSM?
• Refinery National Emphasis Program
(NEP)
• Pilot Process Safety Management
“Chemical NEP”
OSHA Inspection Directives
• CPL-2-2.45A-CH1 – Process Safety
Management of Highly Hazardous
Chemicals- Compliance Guidelines and
Enforcement Procedures
• CPL-03-00-004- Petroleum Refinery –
National Emphasis Program (NEP)
Refineries- National Emphasis
Program
Refineries- NEP
• 1,000 hours/inspection
• Full statutory 6 months
for inspection
• Human Resources
intensive (OSHA &
Companies)
• Average
Penalties/inspection~
$110,000
Refinery NEP -Update
• Last update August 18,2009
• Change: To extend timeframe for
completion of NEP inspections
– Region VI until end of Fiscal Year 2011.
Refinery NEP Most Frequently Cited
PSM Elements
Element
Description
Percentage
of Total
Violations
F
*Operating Procedures (OP)
18%
J
*Mechanical Integrity (MI)
17%
E
*Process Hazard Analysis (PHA)
17%
D
*Process Safety Information (PSI)
15%
L
Management of Change (MOC)
9%
M
Incident Investigation (II)
7%
H
Contractors
4%
O
Compliance Audits (CA)
4%
G
Operator Training
3%
N
Emergency Response (ER)
2%
OSHA Compliance Inspection Time Frame
•
•
PSM on-site inspections~ 6 weeks up to
6 months
Time depends on many factors such
as…
* Size
* Number of deficiencies
* Violation Classifications
PSM Covered Chemical Facilities
National Emphasis Program-09-06(CPL
PSM Covered
02) ---- CHEMICAL
NEPChemical
Facilities National Emphasis
Program-09-06-(CPL-02)
CHEMICAL NEP
Chemical NEP
• VPP sites are NOT subject to programmed
inspections.
• Applies to OSHA-wide for unprogrammed
PSM related inspections:
* Accidents
* Complaints
* Referrals
* Catastrophes
Chemical National Emphasis Program
• Effective July 27,2009
• Different approach for
inspecting PSM
covered chemical
facilities
• NOT Comprehensive
• Less resource
intensive (OSHA &
Employers)
Chemical NEP- Pilot Program
• 1 year PILOT program for planned
inspections in 3 OSHA REGIONS:
• Region 1- CT, MA, ME, NH, RI
• Region VII- Nebraska, Kansas and
Missouri
• Region X- Idaho
• Voluntary for State Plans
Most Frequent Chemical NEP Violations
PSM Standard Cited
(j)(2)
Description
(d)(3)(ii)
Mechanical Integrity
procedures
*RAGAGEP compliance
(d)(3)(i)(B)
Piping &IDs
(e)(6)
PHA update/revalidations
(g)(2)
Operator refresher training
(l)(1)
MOC development &
implementation
NEW!!!
VPP –PSM requirements- New Applicants
and existing sites.
• New VPP-PSM applicants are required to
include with their VPP application + Supplement
A.
• Existing VPP-PSM sites- Also are required to
submit by February 15- Submit annual report +
Supplement B
• During onsite VPP-PSM evaluation –
Supplement A & Supplement C will be use to
evaluate your PSM program.
Supplement A
• Evaluate your PSM
program.
• Identify areas of
excellence
• **Identify areas for
significant
improvements
• Best practices
Section I. Management of Change
Original Design Rate
May 1992
Changes –All Safety
& Health
Temporary
& Permanent
Changes (MOC’s)
Chemicals,
Technology,
Equipment and
Procedures
Section II. Relief Design
MOC’s
Review/Analysis
of the system
(Increase flow)
PHA- design
PSI-codes
& standards
Open vents &
safe discharge
locations
Inspecting,
testing,
maintaining &
repairing relief devices
Section III. Vessels- Mechanical Integrity
Type of Pressure
Vessels
Thickness
measurement
Locations (TLM)
Inspections
Corrosion
under
Insulation (CUI)
Testing & Repairs
Deficiencies
Credentials
Safety system
MOC’s
Section IV: Piping- Mechanical Integrity
Written Piping
Inspection
procedures
“Thickness”
Documentation
of thickness
measurements
Classification
& consequences
Piping inspectors
welders’ qualifications
Section V. Operating Procedures
Normal Operating
Procedures
Emergency
Shutdown
Procedures
Emergency Operations
Procedures
Section VI. Process Hazard Analysis,
Incident investigations & audit findingsrecommendations
• PHA
• Incident
Investigations
• MOC’s
• Compliance Audits
***All corrective actions
must be completed in
timely manner and
documented.
Section VII: PHA -Facility Sitting/ Human
Factors
• Sitting of all occupied
structures- PHA
• Enough time for
operators to escape
during an upset
condition
• Identify human errors
and consequences of
these errors.
Section VIII: Operator Training
• Procedures
• Fully qualified to
perform shutdown
and emergency
procedures safely
• Fully trained to make
difficult safe decisions
in timely manner.
Section IX: Safe Work Procedures
• Motorized equipment to enter operating units or close to
piping systems.
• Opening process equipment, vessel entry, control of
entrance to a facility or covered process.
• Employees and contractors must follow the work practice
procedures.
Section X. Incident Investigations
• Document all the
incidents and nearmiss incidents.
• Provide a detail list (1
year information)
Section IX: Blowdown Drums and Vent
Stacks
• Documentation of the
original designs if the site
has blowdowns should be
maintained.
• Document blowdowns are
discharging to a safe
location.
• Inspection, calibration,
testing, maintenance &
control documents.
• Operators must be
trained.
VPP- PSM Recertification- What to
expect?
• OSHA 300 logs (three
years)- Reviewed
• Team Leader- Review of
your PSM program
• Walkthrough the facility
including covered
process
• Review of Supplement B
(annual evaluation)
• Supplement A
• Supplement C known
as the Dynamic list
of questions provided
by the National
Office)
GENERAL INFORMATION- Supplements B,
A and C
• On February 15 – Every VPP –PSM site
must include: Annual report + Supplement
B Questionnaire.
• NEW VPP-PSM SITES-required to include
with their VPP Application only
Supplement A.
• EXISTING VPP-PSM sites-during on site
visit Supplement A and C will be used.
Do not forget -PSM and other interface
standards
• LOTO Program
• Confined Space
• Emergency
Procedures
• Respiratory
Protection
• Consensus Standards
such as API, NFPA,
and others…
VPP-PSM Best Practices in Region VII
• LOTO Procedures- Specific Procedures
with photos.
• Labeling system – big and legible tags
• Mechanical Integrity Program
• Contractor Safety Program
• Operator training
VPP - PSM Star sites
• Actually, in Region VII, we only have 10
VPP-STAR sites.
• Kansas - 3 sites
• Missouri - 4 sites
• Nebraska - 3 sites
Successful PSM evaluations- TIPS!!
• Promote continuous
leadership development.
• Employee participation
• Document all significant
changes in writing.
• Managers & Operators
are properly trained.
• PSM Coordinator/ group
• Solid Mechanical Integrity
Program.
• Avoid procrastination!!
References
•
•
•
•
•
www. CBS.gov
www.osha.gov
American Petroleum Institute
National Fire Protection Association
www. National Geographic
Special Thanks to…. PSM sites & SGE’s
•
•
•
•
•
•
•
Cargill, Blair NE
Oxychem, Kansas
Cargill, California,MO
Butterball, Carthage, MO
Omaha Steaks, Omaha,NE
Kraftfoods,Kirksville,MO
All SGE’s
Disclamer
• This information has been developed by an
OSHA Compliance Assistance Specialist and is
intended to assist employers, workers, and
others as they strive to improve workplace
health and safety. While we attempt to
thoroughly address specific topics [or hazards],
it is not possible to include discussion of
everything necessary to ensure a healthy and
safe working environment in a presentation of
this nature. Please visit our webpage
www.osha.gov
Thanks….
End
• Questions????