Process Safety Management Overview General Charles Williams Process Safety Program Manager 814-865-6391 cmw33@psu.edu Process Safety Management (PSM) • Objectives – Define what is Process Safety Management – Review the key elements • Regulatory requirements • Proposed Penn State elements – Discuss benefits of a Process Safety Management Program Process Safety Management (PSM) • Bhopal India – Union Carbide Plant (Dec. 3, 1984) – > 2,000 people killed in 40 ton chemical release • Piper Alpha (July 6, 1988) – 167 men killed in explosion and fire • Formosa Plastics (April 23, 2004) – 5 workers killed in explosion and fire • BP, Texas City (March 23, 2005) – 15 deaths and more than 170 others injured Process Safety Management (PSM) • Major disasters involving highly hazardous chemicals draw national attention, however, there have been numerous less notable releases. Hazardous chemical releases continue to pose a significant threat to employees, contractors and the public • Several key regulations have been developed to address the unexpected releases of toxic, reactive or flammable liquids and gases including OSHA’s Process Safety Management (29CFR 1910.119) standard and EPA’s Chemical Accident Prevention (40CFR 68) program • Even well designed, constructed and operated unit operations can still pose the potential for an unexpected release of a highly hazardous chemical Process Safety Management (PSM) State University of NY – Potsdam, HazMat Team response on August 13, 2013 after an employee noticed an ammonia leak in the college’s athletic facilities WATERTOWN DAILY TIMES - Hazardous materials teams from several agencies suit up Tuesday to investigate and clean up an ammonia leak in Maxcy Hall on SUNY Potsdam’s campus “Minor Ammonia Leak Closes Rink at Cottage Grove Ice Arena, South Washington Bulletin, MN (Jan. 2014) Cottage Grove Ice Arena – Park High School boys and girls hockey clubs. “What we’ve found is that the piping was supposed to be in a vault and it wasn’t” – City Administrator Process Safety Management (PSM) • Penn State has acknowledged the need to develop and implement a Process Safety Management Program with initial focus on ammonia refrigeration units (e.g. Pegula, Food Science - Berkey Creamery) • PSM is an analytical method focused on managing processes to prevent releases of any highly hazardous chemical and subsequent catastrophic events – fires, explosions, or toxic releases What is Process Safety • Occupational Safety – Protecting against personal injuries • Slips, trips, falls, falling from height, chemical contact • Process Safety – Protecting against catastrophic incidents • Fires, explosions, toxic releases resulting in significant loss of life, property or environmental impact What is Process Safety • The airline industry experiences many back and muscle strains to baggage handlers from lifting and carry luggage • Significant effort is spent trying to prevent these types of injuries However, these efforts will not reduce the number of plane crashes! What is Process Safety • Occupational Safety – Measures to prevent workplace illnesses, accidents, and injuries • Examples: – Selection and use of PPE – Industrial hygiene monitoring – Shoring requirements for excavation projects What is Process Safety • Process Safety – Identifying the hazards that could lead to fires, explosions, or toxic releases: catastrophic events • Examples: – Inspecting and maintaining equipment to prevent loss of containment – Using formal assessment program to review proposed changes to equipment or procedures – Conducting hazard studies to identify the hazards and appropriate safeguards for each process Process Safety Management (PSM) • After reviewing the basic causes of major Process Safety incidents, OSHA concluded that often there is a serious lack of knowledge either in the organization or at the operations level on basic Process Safety Information • OSHA considers 14 key elements of a PSM Program, however, our proposed program contains 17 key elements Process Safety Management (PSM) • • • • • • • • Management System Process Safety Information Process Hazard Analysis Operating Procedures Training & Assessment Contractor Mgmt. Mechanical Integrity Mgmt. System to Address Action Items • • • • • • • • Management of Change Incident Investigation Compliance Audits Trade Secrets Employee Participation Pre-startup Safety Review Emergency Preparedness Process Hazard Analysis Review • Maintenance Systems PSM Key Elements • Management System – – – – Senior Leadership Commitment Written Program Responsibilities Defined Metrics & Continuous Improvement • Process Safety Information – Process Technology – Chemical Data – Equipment Data PSM Key Elements • Process Hazard Analysis – Defined methodology to assess potential releases from process • Management System to Address Action Items – Prioritization process based on risk ranking – Transparent system to assign responsibility and timeframe to accomplish recommendations – Tracking completion PSM Key Elements • Process Hazard Analysis Review – Defined process & frequency to review the process hazard analysis and response systems • Employee Participation – – – – Development of PSM program Process Hazard Analysis Incident Investigation Other elements PSM Key Elements • Operating Procedures – Steps for each operating phase during initial startup, normal operations, temporary operations, emergency shutdown and start-up after emergency shutdown • Emergency Preparedness – Defined actions by individuals when a release occurs and other emergency scenarios PSM Key Elements • Training & Assessment – Program outlining training requirements for Technicians, Contractors and other individuals that can impact covered processes • Contractor Management – Qualification program that factors in EHS performance – Communicate access and safe work practices for covered areas PSM Key Elements • Mechanical Integrity – Defined procedures to maintain the on-going integrity of process equipment – Inspection and Testing requirements • Maintenance Systems – Safe Work Permit program – Hot Work Permit – Program associated with non-routine activities PSM Key Elements • Management of Change (MOC) – Change management program that encompasses proposing changes to affected Departments prior implementation – Authorization required before implementing change • Pre-Startup Safety Review (PSSR) – Program to conduct pre-startup assessments for new or modified facilities/equipment PSM Key Elements • Incident Investigation – Incidents that resulted or could reasonably have resulted in a catastrophic release – Team approach started within 48 hours • Compliance Audits – PSM Program evaluated by 3rd Party every 3 yrs. • Trade Secrets – Mechanism to maintain confidentiality with individuals/group requiring Process Safety Information Penn State Process Safety Model Regulations Technology Equipment Process Hazard Analysis Standards Best Practices Process Incidents & Accidents Personnel Industry Guidelines Risk Management – Reduction/Control 17 Management System Elements (Risk Evaluation) Process Safety Management (PSM) • Various Functions within our PSM Program: – – – – – – – – – – – Ammonia Refrigeration Technicians Area Supervisors Safety Officers Facility/Building Managers Coaches EHS Department HazMat Team Contractors Police Services Interns/Students Event Staff Process Safety Management (PSM) • Program Benefits – Formal management system to enhance and preserve University’s critical equipment – Platform to assist with improving operational effectiveness – Mechanism to engage and solicit input from various stakeholders – Empower employees to be an active program participant with development and on-going sustainability Why PSM at Penn State? • Contractor started working on system while production was on-going • Standard procedure not followed – refrigeration being reapplied to tank considered “not normal” • Employee operating equipment advised that he was fatigued at work due to being shorthanded and overworked • Maintenance employee identified a problem (post-accident) with valves in system not functioning as designed – was not identified previously since “no preventive maintenance program existed on that equipment Why PSM at Penn State? • The results of numerous system failures: Employee Injuries and Equipment Damage Why PSM at Penn State? • Borland Explosion – March 1, 1982 Are our systems robust enough to prevent a similar event today? Questions