Standards & Regulations
Requirements on Process
Safety
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Instructional Learning Objectives
After completing this chapter, students should be
able to do the following:
• Appreciate importance of standards & regulations
• Identify and understand basic of relevant process
safety standards &regulations:
– Occupational Safety and Health Act 1994
– CIMAH Regulations 1996
– Other International Safety Legislations: OSHA PSM (US),
EPA RMP (US), SEVESO DIRECTIVES
• Relate the standards and regulations’
requirements with the application of process
safety fundamental to prevent losses
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Most major incidents had occurred and
will be occurring because of
MANAGERIAL and ORGANISATIONAL
short comings
To overcome this problem, a more
SYSTEMATIC and STRUCTURED
approach is needed for an effective way
to MANAGE SAFETY in Business.
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System for Managing Safety?
Set of CONTROLS which are used to MANAGE
proactively all types of HAZARDS & RISKS, and the
CONSEQUENCES, associated with the running of
BUSINESS activities and functions;
It is also to provide ASSURANCE to all STAKE
HOLDERS that the risks in the business are being
managed to a comfortable level, that is “AS LOW AS
REASONABLY PRACTICABLE” (ALARP).
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System for Managing Safety is for…
Achieving Safety Excellence
How best you can identify and assess elements of
your current management practices – in term of
knowing their strengths and their weaknesses, and
to be able to establish the “gaps”, from which you
can see ways how best to improve your respective
workplace safety performance.
BUT HOW TO MAKE/ENSURE THAT
INDUSTRIES APPLY SYSTEM FOR
MANAGING SAFETY?
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Evolution of Safety Related Regulations
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Evolution of Safety Related Regulations
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Preventive vs. Performance-based
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Malaysia Regulatory
Requirements
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Summary of Acts and Regulations
▪ Total number of Acts and Regulations = 41
▪ O C C U P A T I O N A L S A F E T Y & H E A LT H A C T 1 9 9 4 ( O S H A ` 9 4 )
• Control of Industrial Major Accident Hazards (CIMAH) Regulations 1996
• Safety & Health Committee Regulations 1996
• Classification, Packaging & Labelling of Hazardous Chemicals Regulations
1997
• Safety & Health Officer Regulations 1997
• Uses and Standards of Exposure to Chemicals Hazardous to Health
Regulations 2000
• Notification of Accident, Dangerous Occurrence, Occupational Poisoning
and Occupational Disease Regulations 2004
▪ FA C T O R I E S A N D M A C H I N E RY A C T 1 9 6 7 ( F M A ‘ 6 7 )
• Steam Boiler and Unfired Pressure Vessel Regulations 1970
• Fencing of Machinery and Safety Regulations 1970
• Person-in-charge Regulations 1970
• Certificates of Competency - Examinations Regulations 1970
• Notification, Certificates of Fitness and Inspection Regulations 1970
• Building Operations & Works of Engineering Construction Regulations 1986
• Noise Exposure Regulations 1989
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Summary of Acts and Regulations
▪ E N V I R O N M E N TA L Q UA L I T Y A C T 1 9 7 4 ( E Q A 1 9 7 4 )
• Sewerage & Industrial Effluents Regulations 1997
• Clean Air Regulations 1978
• Licensing Regulations 1997
• Scheduled Wastes Treatment & Disposal Facilities Order 1989
• Scheduled Wastes Regulations 1989
• Scheduled Wastes Treatment & Disposal Facilities Regulations
1989
• Delegation of Powers on Marine Pollution Control Order 1993
• Prohibition on the Use of CFCs and other Gases as Propellants
& Blowing Agents Order 1993
• Environmental Impact Assessment Order 1987
• Delegation of Powers on Marine Pollution Control Order 1994
• Refrigerant Management Regulations 1999
• Halon Management Regulations 1999
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Summary of Acts and Regulations
▪ AT O M I C E N E R G Y L I C E N S I N G A C T 1 9 8 4 ( A E L A ‘ 8 4 )
• Radiation Protection (Licensing) Regulations 1986
• Radiation Protection (Basic Safety Standards) Regulations 1988
• Radiation Protection (Transport) Regulations 1989
• LEM/TEK/13 - A guide for the appointment and Duties of a Radiation
Protection Officer (PRO)
• LEM/TEK/17 - License Application Guide for Radiation and X-Ray
Gauging activities
• LEM/TEK/30 SEM.2 - Guidelines on Radiological Monitoring of Oil &
Gas Operators Associated with TENORMS
• LEM/TEK/33 - Code of Practice on Radiation Protection in Industrial
Radiography
▪ PETROLEUM (SAFETY MEASURES) ACT (302) 1984
• PETROLEUM (SAFETY MEASURES) (Transportation of Petroleum by
Water) Regulations 1985
• PETROLEUM (SAFETY MEASURES) (Transportation of Petroleum by
pipeline) Regulations 1985
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Summary of Acts and Regulations
▪ FIRE SERVICES ACT 1988
▪ POISON ACT 1952
• Poisons Regulations 1952
• Poisons (Sodium Hydroxide) Regulations 1962
▪ CUSTOMS (PROHIBITION OF EXPORT) (AMENDMENT NO 2)
ORDER 1993
▪ BASEL CONVENTION ON THE CONTROL OF TRANS-BOUNDARY
MOVEMENTS OF HAZARDOUS WASTES AND THEIR DISPOSAL
▪ MONTREAL PROTOCOL ON SUBSTANCES THAT DEPLETE THE
OZONE LAYER
▪ UNIFORM BUILDING BY-LAWS 1984
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OSHACT 1994
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Objectives of Occupational Safety & Health
Act 1994 (OSHAct 1994)
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Regulations under OSHAct 1994
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Control of Industrial Major Accident Hazards
Regulations (CIMAH) 1996
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Control of Industrial Major Accident Hazards
Regulations (CIMAH) 1996 – Schedule 2
Part 1 : Named Substances
Where a substance or group of substances listed in Part 1 also falls within a
category of Part 2 the quantities set out in Part 1 shall be used.
Substance
Threshold Quantity
Group 1 - Toxic Substances (quantity  1 tonne)
4-Aminodiphenyl
1 kilogram
Arsenic pentoxide, arsenic (V) acid and salts
500 kilograms
Arsenic trioxide, arsenious (III) acid and salts
100 kilograms
Arsine (Arsenic hydride)
10 kilograms
Group 2 - Toxic Substances (quantity  1 tonne)
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Allyamine
200 tonnes
Ammonia
100 tonnes
Bromine
10 tonnes
Carbon disulphide
200 tonnes
Chlorine
10 tonnes
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Control of Industrial Major Accident Hazards
Regulations (CIMAH) 1996
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Control of Industrial Major Accident Hazards
Regulations (CIMAH) 1996
Identif ication & Notification of an Industrial
Activity
The authority will determine whether the installation :
➢ is a major hazard installation even though quantity of
hazardous substance less than threshold quantity, if the
authority feels that installation may cause a major
accident.
➢ is not a major hazard installation even though equal or
exceed threshold quantity, if the authority feels that
installation is incapable of causing a major accident.
Any change of the status of installation shall be notified to the
authority.
Major Hazard Installation - an industrial activity which produces, processes,
handles, uses, disposes of or stores, permanently or temporarily, one or more
hazardous substances equal of exceed the threshold quantity;
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Control of Industrial Major Accident Hazards
Regulations (CIMAH) 1996
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Control of Industrial Major Accident Hazards
Regulations (CIMAH) 1996
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US Regulatory Requirements
PSM (RMP)
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PSM Background – Pasadena 1989
Plastics Manufacture Plant
Fire following vapour cloud
explosion
▪ Poor Maintenance
procedures, Contractor
control and Management
of change
▪ 23 Fatalities
132 Injured
US$1,400 Million Damage
▪ Outcomes
– US OSHA PSM
regulations
– CCPS established
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OSHA: PROCESS SAFETY
MANAGEMENT STANDARDS
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OSHA Process Safety Management Standard
▪
Performance-based standard with 14 program
PSM is a performance (not specification) standard prevent or
minimize the consequences of catastrophic releases of chemicals
that are:
•
Toxic
•
Reactive
•
Flammable
•
Explosive
PSM is the proactive identification, evaluation and mitigation or
prevention of chemical releases that could occur as a result of
failures in processes, procedures, or equipment.
▪
Purpose: prevent, mitigate catastrophic releases
▪
Emphasis on management systems:
“…a holistic approach that integrates technologies, procedures,
and management practices”
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OSHA PSM Application
Highly Hazardous Chemical processing where
•
Toxic or reactive chemical(s) are present in processes at or above
a listed threshold quantity (Appendix A Material – example as
shown below)
•
Flammable liquids or gases are present in processes in quantities
10,000 pounds and above
•
Explosives or pyrotechnics are manufactured
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Compliance is required if you…..
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Process Safety Management (PSM) Elements
29 CFR 1910.119 - OSHA’s Process Safety Management Standard
1.
2.
3.
4.
5.
6.
7.
Employee Participation
Process Safety Information (PSI)
Process Hazard Analysis (PHA)
Operating Procedures
Training
Contractors
Pre-startup Safety Review
8. Mechanical Integrity
9. Hot-work Permits
10. Management of Change
11. Incident Investigations
12. Emergency Planning & Response
13. Compliance Safety Audits
14. Trade Secrets
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US ENVIRONMENTAL PROTECTION
AGENCY (EPA): RISK MANAGEMENT
PROGRAM
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EPA Risk Management Program Standard
▪ 40 CFR 68, “Risk Management Programs for Chemical
Accident Release Prevention”
▪ Final list of substances 31/1/94; final Rules 20/6/96.
▪ Focus on “substances which, in an accidental release,
are known to cause or may be reasonably anticipated to
cause death, injury, or serious adverse effects to human
health or the environment”
▪ Facility must implement a risk management program and
prepare a risk management plan
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EPA Risk Management Program Standard
▪ Hazard Assessment
▪ Analysis of off-site consequences associated with
worst-case and alternative release scenarios
▪ Preparation of 5-years accident history
▪ Prevention Program
▪ Comprehensive management system for process
safety
▪ Replaces “worker” by “general public and
environment”
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EPA Risk Management Program Standard
▪ Emergency Response Program
▪ Ensure facility has planned for emergencies
involving listed substances
▪ Coordinate with other facility plans and rules
▪ RM Plan
▪ Electronic submission to EPA
▪ Publicly available information
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EPA RMP Prevention Program
▪ A “ prevention program” (integrated management system)
must be implemented for each facility having a substance
above TQ. Electronic submission to EPA
▪ Evaluate, find best ways to control hazard
▪ 10 elements overlap OSHA PSM Standard
▪ (29CFR 10.110)
▪ Management System
▪ Process Hazard Analysis
▪ Process Safety Information
▪ Standard Operating Procedures
▪ Training
▪ Maintenance (Mechanical Integrity)
▪ Pre-startup Review
▪ Management of Change
▪ Safety Audits
▪ Accident Investigation
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Summary:
✓ Process safety regulations are an integral part of maintaining the safety of
workers, the public, and the environment
✓ There are primarily two approaches of the safety regulatory regime:
✓ prescriptive-based
✓ performance-based
✓ There are both advantages and disadvantages in both the regulatory
regimes
✓ Important safety regulation in Malaysia: OSH Act 1994, CIMAH Regulation
1996
✓ Important safety regulation in other countries: CFR1910.119 Process Safety
Mgmt. Standard (US) / Seveso-III-Directive (2012/18/EU)(Europe)
Q&A
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