Transcript Process Safety Management - Georgia Tech Occupational

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

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What Is Process Safety
Management?
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PSM:
 Addresses
the management of Highly
Hazardous Chemicals (HHC)
 Integrates
 Technology
 Operating
Procedures
 Standard management protocols
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Why Did OSHA Develop PSM?
 Past
Disasters
 Current Disasters
 Perceived Weakness in PSM
Program
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Why Did OSHA Develop PSM?

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
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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.
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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:
 Toxic,
 Reactive,
 Flammable, or
 Explosive chemicals
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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).
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PSM vs. RMP - What’s the
Difference?
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PSM - Like HAZCOM  RMP-Like Sara Title III
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Protects the
Workforce
Protects Contractors
Protects Visitors to
the Facility
Basically Protects the
Workplace
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Protects the
Community
Protects the General
Public Around the
Facility
Protects Adjacent
Facilities Such as
Schools & Hospitals
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The Standard Was Promulgated
in 1991 - Is it Working?
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The Standard Was Promulgated
in 1991 - Is it Working?

BP Products Texas
City - March 2005
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15 Workers Killed
170 Injured
Major Property
Damage
$50.6 Million in Fines
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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

Process Hazard
Analysis
 Management of Change
 Operating Procedures
 Safe Work Practices
 Training
 Contractor
Management
 Emergency Planning &
Response
 Incident Investigation
 Compliance Audits
 Trade Secrets
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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

Process Hazard
Analysis
 Management of Change
 Operating Procedures
 Safe Work Practices
 Training
 Contractor
Management
 Emergency Planning &
Response
 Incident Investigation
 Compliance Audits
 Trade Secrets
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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

Process Hazard
Analysis

Management of
Change

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Operating Procedures
Safe Work Practices
 Training
 Contractor
Management
 Emergency Planning &
Response
 Incident Investigation
 Compliance Audits
 Trade Secrets
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The Elements of the PSM
Standard
 Process Hazard
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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

Analysis
Management of
Change

Operating
Procedures
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Safe Work Practices
Training
Contractor
Management
Emergency Planning &
Response
Incident Investigation
Compliance Audits
Trade Secrets
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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

Process Hazard
Analysis
 Management of
Change
 Operating Procedures
 Safe Work Practices

Training

Contractor
Management
Emergency Planning &
Response
Incident Investigation
Compliance Audits
Trade Secrets
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The Elements of the PSM
Standard
 Process Hazard
Analysis
 Management of
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Change
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 Operating Procedures
 Employee
 Safe Work Practices
Participation
 Training
 Hazards of the Process
 Contractor
 Toxicity
Management
 Technology of the
 Emergency Planning &
Process
Response
 Equipment in the Process  Incident Investigation
 Mechanical Integrity
 Compliance Audits
 Inspection & Testing
 Trade Secrets
 Quality Assurance

Application
Exclusions
Definitions
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The Elements of the PSM
Standard
 Process Hazard
Analysis
Application
 Management of
 Exclusions
Change
 Definitions
 Operating Procedures
 Employee Participation
 Safe Work Practices
 Hazards of the Process
 Training
 Toxicity
 Contractor
 Technology of the
Management
Process
 Equipment in the Process  Emergency Planning &
Response
 Mechanical Integrity
 Incident Investigation
 Inspection & Testing
 Compliance Audits
 Quality Assurance
 Trade Secrets
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The Elements of the PSM
Standard
 Process Hazard
Analysis
Application
 Management of
 Exclusions
Change
 Definitions
 Operating Procedures
 Employee Participation
 Pre-Start up Safety
 Hazards of the Process
Review
 Toxicity
 Hot Work Permit
 Technology of the
 Safe Work Practices
Process
 Equipment in the Process  Training
 Contractor
 Mechanical Integrity
Management
 Inspection & Testing
 Emergency Planning &
 Quality Assurance
Response
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The Elements of the PSM
Standard
 Process Hazard
Analysis
Application
 Management of
 Exclusions
Change
 Definitions
 Operating Procedures
 Employee Participation
 Pre-Start up Safety
 Hazards of the Process
Review
 Toxicity
 Hot Work Permit
 Technology of the
 Safe Work Practices
Process
 Equipment in the Process  Training
 Contractor
 Mechanical Integrity
Management
 Inspection & Testing
 Emergency Planning &
 Quality Assurance
Response
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The Elements of the PSM
Standard
 Process Hazard
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Application
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 Exclusions
 Definitions
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 Employee Participation
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 Hazards of the Process
 Toxicity
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 Technology of the
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Process
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 Equipment in the Process
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 Mechanical Integrity
 Inspection & Testing
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 Quality Assurance
Analysis
Management of
Change
Operating Procedures
Pre-Start up Safety
Review
Hot Work Permit
Safe Work Practices
Training
Contractor
Management
Emergency
Planning &
Response
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The Elements of the PSM
Standard
 Process Hazard
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Application
Exclusions
Definitions
Employee Participation
Hazards of the Process
Toxicity
Technology of the
Process
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Equipment in the
Process
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Mechanical Integrity
Inspection & Testing
Quality Assurance
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Analysis
Management of
Change
Operating Procedures
Pre-Start up Safety
Review
Hot Work Permit
Safe Work Practices
Training
Contractor
Management
Emergency Planning
& Response
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The Elements of the PSM
Standard
 Process Hazard
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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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Analysis
Management of
Change
Operating Procedures
Pre-Start up Safety
Review
Hot Work Permit
Safe Work Practices
Training
Contractor
Management
Emergency Planning
& Response
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The Elements of the PSM
Standard
 Process Hazard
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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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Analysis
Management of
Change
Operating Procedures
Pre-Start up Safety
Review
Hot Work Permit
Safe Work Practices
Training
Contractor
Management
Emergency Planning
& Response
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The Elements of the PSM
Standard
Let’s Explore Some of the Elements…
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Application
1910.119(a)
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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
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Examples
Chemical
 Anhydrous Ammonia
 Chlorine
Threshold Quantity (TQ)
10,000 lbs
1,500 lbs
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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
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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.
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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
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Exclusions
1910.119(a)(1)(ii)(A)
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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
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Retail facilities;
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Oil or gas well drilling or
servicing operations; or,
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Normally unoccupied
remote facilities
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Employee Participation
1910.119(c)
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Now that we are required to
comply, then what?
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Form a Team in
Your Company, i.e..
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Process Engineers
Operators
Safety
Maintenance
Management
Consultants
Remember…You Can’t Do it Alone!
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Now that we are required to
comply, then what?
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Form a Plan,
Determine:
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Responsibilities
Duties
Reporting
Document Control
Progress Reports
Tracking Changes
Then…Begin the Process of Developing &
Implementing the PSM Program
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Hazards of the Process
1910.119(d)(1)
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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)

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Toxicity Information
1910.119(d)(1)(i)
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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
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Technology of the Process
1910.119(d)(2)
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The Requirements of the Standard
- Process Technology
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Block flow diagram
or process flow
diagram
Process chemistry
Maximum intended
inventory
Upper and lower
limits
Consequences of
deviations
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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
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Equipment in the Process
1910.119(d)(3)
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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
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Mechanical Integrity
1910.119(j)
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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
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Process Hazard Analysis (PHA)
1910.119(e)
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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
 Takes Significant Time & Effort
 PHA’s are Never Ending
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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
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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
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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
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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
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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:
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 Operation
phase
 Operational limits
 Safety & health considerations
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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
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SOPs
Must be readily available to employees
 Must be reviewed as needed to ensure
they reflect current operating practicce.
 Must cover:
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 Process
chemicals
 Technology and equipment
 Facilities
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SOPs must be certified annually that
they are correct and accurate.
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Safe Work Practices (SWPs)
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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
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Training
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PSM specific training is required
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Must cover:
 Safety
and health hazards associated with
the covered process
 Safe work practices
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Refresher training is required every 3
years or as needed to ensure
employees are complying with all PSM
requirements
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Contractors
Contractors involved in or around a
covered process must be informed of
required PSM elements.
 Contract work includes:
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 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
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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
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Incident Investigations
Must be initiated ASAP, but within 48
hours
 Team must include:
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 Person
knowledgeable in the process
involved
 Includes contractor if work of the contractor
involved
 Other persons with appropriate knowledge
of the covered process
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Incident Investigation Report
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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
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documented
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Compliance Audit
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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
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Trade Secrets
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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
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Confidentiality agreements are allowed 65
BP Texas City Refinery Case
Study in PSM
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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
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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?
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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
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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.
 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.
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There is Much More to PSM
Now, The OSHA PSM National Emphasis
Program for Refineries & Chemical
Facilities & Severe Violator Enforcement
Program (SVEP)
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OSHA National Emphasis
Program (NEP) for Refineries &
Chemical Facilities
Petroleum
Refineries NEP
 Issued August
2009
 Chemical Facilities
NEP
 Issued July 2010

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Typical Standards Cited
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
1910.119
1910.147
1910.120
1910.1200
1910.146
5A.001
1910.307
PSM – 249 violations
Lock and Tag - 20
Hazwoper - 19
Hazcom - 12
Confined Space - 11
General Duty - 9
Hazardous Locations - 7
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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).
74
Severe Violator Enforcement
Program (SVEP)
References:

OSHA Instruction CPL 03-00-010, Petroleum
Refinery Process Safety Management
National Emphasis Program, August 18, 2009
75
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)
77
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
78
EPA RMP

Basic Requirements
 Executive summary
 Registration
 Off-site consequence analysis
 Five-year accident history
 Emergency response plan
 Prevention program summary information
 Certification
79
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
81
Tools for Additional PSM
Assistance

PSM Checklist
 www.oshainfo.gatech.edu

OSHA Website
 www.osha.gov

Chemical Safety Board Website
 www.csb.gov
82
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).
83
For More Information
www.psmtraining.com
www.oshainfo.gatech.edu
www.pe.gatech.edu/safety
84
Contact Information

Michelle Dunham, MSPH, MSM
 [email protected]
 404-407-8284

Bob Hendry
 [email protected]

Art Wickman, CIH
 [email protected]

Georgia Tech Occupational Safety & Health Program
 www.oshainfo.gatech.edu
85
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
86