Transcript Process Safety Management - Environmental Health and Safety

Process Safety Management
Overview
General
Charles Williams
Process Safety Program Manager
814-865-6391
[email protected]
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)
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Management System
Process Safety Information
Process Hazard Analysis
Operating Procedures
Training & Assessment
Contractor Mgmt.
Mechanical Integrity
Mgmt. System to Address
Action Items
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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
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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
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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:
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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