Transcript PROCESS SAFETY MANAGEMENT VS RISK MANAGEMENT

PROCESS SAFETY
MANAGEMENT
VS
RISK MANAGEMENT
An Overview
Tracy Estes, CSP
James E. Roughton, MS, CSP, CRSP, CHMM
1
Process Safety Management

Required by the Environmental Protection Agency's
(EPA) Clean Air Act Amendments (CAAA),
Section 304

Promulgated - February 24, 1992

5 year implementation

Proactive identification, evaluation, and mitigation or
prevention of chemical releases that could occur as a
result of failures in processes, procedures, or
equipment

130 highly hazardous chemicals (HHC’s)
2
Process Safety Management
(continued)

10,000 lb. or more of flammable materials that are
used at or above their boiling points

Pyrotechnics and explosives manufacturers

More than 28,000 facilities affected

Exemptions:



fuels used for workplace consumption
Comfort heating
Gasoline for vehicles
3
Risk Management Plan

Mandated by CAAA, Section 112 (r), 40 CFR
Part 68

Promulgated - May 24, 1996

Published Federal Register - June 20, 1996

More than 100,000 facilities affected

Designed to help reduce risk of accidental release of
hazardous substances

3 years to implement
4
Risk Management Plan
(continued)

Affects owners of a stationary source with regulated
substances above a threshold quantity (TQ):



77 acutely toxic
63 flammable
Department of Transportation (DOT) classified explosive
substances
5
EPA’s Visions for Accidental
Release Prevention

Emphasize community right-to-know

Let information drive action

Focus the program at the local level


EPA support
Coordinate communications at local level
6
Key Features of RMP

Prevention program


7-elements “mini-PSM” program
14 elements OSHA-PSM program expanded to address
offsite effects

Emergency response program

Risk management plan

Electronic submission to state and LEPC


Available to public
Regulatory audits
7
Key Features
(continued)

3 Program levels

Management system

Offsite consequence analysis



Worst-case scenario
Alternative release scenario
5-year accident history
8
Key Features
(continued)

Summarizes key elements of the RMP program






Tells a story
Hazards at the site
Accident history
Potential offsite consequences
Prevention steps
Response program
9
Exemptions to Threshold
Quantity

Articles

Laboratories

Uses:





Structural components
Janitorial maintenance
Foods, drugs, cosmetics, or other personal items
Present in process water or non-contact cooling water
Compressed air or as part of combustion
10
EPA’s Regulatory Approach

Performance-based approach

Similar to OSHA’s PSM

Build on existing programs and standards

Scale the requirements to fit the risk

Coordinate with OSHA and DOT
11
Requirements of 112 (r)

Established a general duty clause to:



Identify hazards that may result from releases
Design and maintain a safe facility
Minimize the consequences or releases
12
Requirements of 112(r)
(continued)

Required EPA to promulgate a list of substances and
set thresholds

Required EPA to develop a risk management
program (RMP) rule

Register with EPA

Conduct a hazard assessment

Develop a prevention program

Develop an emergency response program
13
Requirements of 112 (r)
(continued)

Provide a summary (RMP) to




EPA
States
Locals
Public
14
Basic Principles

Build on EPCRA

Emphasize community right-to-know

Focus the program at the local level

Where the risk is found
15
Basic Principles
(continued)

Accommodate small business concerns


Provide model RMPs
» Ammonia
» Warehouses with chemicals
» Batch processors
» Refineries/gas plants
Provide reference tables for offsite consequences analysis
16
Manufacturing Industries Affected

Chemical manufacturers

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Industrial Organics & Inorganics
Paints
Pharmaceuticals
Adhesives,
Sealants
Fibers
17
Manufacturing Industries Affected
(continued)

Petrochemical Products

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Refineries
Industrial Gases
Plastics and Resins
Synthetic Rubber
18
Non-Manufacturing Affected
(continued)

Non-Manufacturing Facilities affected


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Utilities
» Electric and Gas
Public Sources
» Drinking Water and Waste Water Treatment
Agriculture
» Fertilizers, Pesticides
19
Other Manufacturing

Electronics

Semiconductors

Paper

Fabricated metals

Industrial machinery

Furniture

Textiles
20
Other Industries

Food and Cold Storage

Propane Retail

Warehousing

Wholesalers

Federal sources

Military and Energy Installations
21
PSM vs. RMP Requirements



PSM’s concern - potential hazard and protection of
employees inside a regulated area
RMP’s concern - potential incidents that may cause
environmental and health hazards outside facility
boundaries
Editorial changes to PSM to make text consistent
with the CAAA's language
22
Hazard Assessment

Offsite consequence data



Population estimate
Public receptors
Environmental receptors

Every 5 years

Within 6 months of a change that increases or
decreased distance by a factor of 2 or more
23
Overview Worst-Case Scenario
(WCS)

Greatest quantity from vessel or piping


Toxic gases

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Quantity released in 10 minutes
Toxic liquids


May include administrative controls
Instantaneous spill to ground; volatilization; passive
mitigation
Toxic gases liquefied by refrigeration
24
Worst-Case Scenario
(continued)

All flammable substances

Quantity for vapor cloud explosion

One worst case for each process

One worse case representing all toxic substances

Additional worst case(s) different public receptors

Other considerations


Smaller quantities at higher temperature or pressure
Source boundary proximity
25
Alternative Release Scenario
(ARS)

More likely than a worst case scenario

Much reach endpoint offsite

One scenario representative of all flammables
26
ARS Selection

Accident history events

Process hazard analysis events

Worse case with mitigation

Example scenarios:



Piping or hose failures
Seal failures
Vessel overfilling or venting
27
List of Substances and
Thresholds

Focuses on lethal effects resulting from acute
exposures

Includes mandated substances
28
Mandated Substances

Ammonia

Hydrogen Fluoride

Anhydrous Ammonia

Hydrogen Sulfide

Anhydrous Hydrogen Chloride

Methyl Chloride

Anhydrous Sulfur Dioxide

Methyl Isocyanate

Bromine

Phosgene

Chlorine

Sulfur Trioxide

Ethylene Oxide

Toluene Diisocyanate

Hydrogen Cyanide

Vinyl Chloride
29
Toxic Substances

Extremely hazardous substances under SARA

Gases and highly volatile liquids

Vapor pressure > 10 mmHg

Thresholds ranging from 500-2,000 lbs.

Thresholds based on toxicity and volatility
30
Flammable Substances

NFPA 4

Most dangerous

Flammable gases and volatile flammable liquids that
could create vapor cloud explosions

Thresholds set at 10,000 lbs.
31
Threshold Quantity Determination

Total quantity of a regulated substances contained in
a process at any one time

Process included interconnected vessels or separate
vessels that could be involved in a release (OSHA
PSM definition)
32
Offsite Consequence Analysis

Toxic endpoint

Flammable endpoints

Use appropriate models or guidance

Within circle, identify

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Public receptors and population
Environmental receptors
33
Registration and Submittal

Submit a comprehensive RMP to:




EPA
State Emergency Response Commission (SERC)
Local Emergency Planning Committee (LEPC)
The Chemical Safety and Hazard Investigation Board
34
Registration and Submittal
(Continued)

Name, mailing address, telephone of stationary
source

CAS number of all regulated substances greater than
TQ

SIC code

Dun and Bradstreet number

Certification signed by owner or operator
35
Auditing the Program

Conduct audits of the management system
36
Program Eligibility Criteria

Three Programs
37
Program 1 - No impact

Register

Conduct worst-case hazard assessments

Certify no off-site consequences for worst-case
scenario

Ensure inclusion in LEPC plan

Submit RMP document above
38
Program 3 - Full RMP

One comprehensive prevention program that:


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Protects workers
The public
The environment
Hazard review information




Hazards
Controls
Mitigation
Changes
39
Program 3
(continued)

Register

Conduct worst-case and other hazard assessments

Implement comprehensive prevention steps (OSHA
PSM plus...)

Develop emergency response plan

Submit RMP
40
Program 3
(continued)

Process is subject to OSHA's PSM

Processes in specific SIC codes

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Pulp Mills (2611)
Chlor-Alkali (2812)
Industrial Inorganic (2819)
Plastics and Resins (2821)
Cyclic Crudes (2865)
Industrial Organics (2869)
Nitrogen Fertilizers (2873)
Agricultural Chemicals (2879)
Petroleum Refineries (2911)
41
Program 2 - Streamlined
Prevention Program

The process is not eligible for Program 1 or 3
42
Program 2
(continued)

Statutory requirements

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Training
Maintenance
Safety Precautions
Monitoring
43
Program 2
(continued)

Types of sources:

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Less complex; fewer changes
Ideal model program and plans

Capture good management practices from PSM but
less documentation

Take advantages of other rules and standards

Take advantages of equipment manufacturer or
vendor information
44
Program 2
(continued)

Process information (SIC, chemicals)

List rules, standards, design codes

Hazard review information




Hazards
Controls
Mitigation
Changes
45
Program 2
(continued)

Register

Conduct worst-case and other hazard assessments

Implement seven elements of prevention program
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Develop emergency response plan

Submit RMP
46
Comparison of Program
Requirements
Hazard Assessment
Program 1
Program 2
Program 3
Worst-case analysis
Worst-case analysis
Worst-case analysis
Alternative releases
Alternative releases
5-year accident history
5-year accident history
5-year accident history
47
Comparison
(continued)
Management Program Document
Program 1
Program 2
Program 3
Management System
Management System
48
Comparison
(continued)
Prevention Program
Program 1
Program 2
Program 3
Certify no additional
Safety Information
Process Safety Information
steps Required
Hazard Review
Process Hazard Review
Operating Procedures
Operating Procedures
Training
Training
Maintenance
Mechanical Integrity
Incident Investigation
Incident Investigation
49
Comparison
(continued)
Prevention Program (continued)
Program 1
Program 2
Program 3
Compliance Audit
Compliance Audit
Management of Change
Pre-Startup Review
Contractors
Employee Participation
Hot Work Permits
50
Comparison
(continued)
Emergency Response Program
Program 1
Program 2
Program 3
Coordinate with Local
Responders
Develop Plan
and Program
Develop Plan
and Program
51
Comparison
(continued)
Risk Management Plan Content
Program 1
Program 2
Program 3
Executive Summary
Executive Summary
Executive Summary
Registration
Registration
Registration
Worst-Case Data
Worst-Case Data
Worst-Case Data
5-Year Accident History
Alternative Release Data
Alternative Release Data
Certification.
5-Year Accident History
5-Year Accident History
52
Comparison
(continued)
Risk Management Plan Content (continued)
Program 1
Program 2
Program 3
Prevention Program Data
Prevention Program Data
Emergency Response Data
Emergency Response Data
Certification
Certification
53
Editorial Changes
(continued)
OSHA PSM Requirements
EPA Program 3 Requirements
An evaluation of the consequences
of deviations, including those
affecting the safety and health
of employees
An evaluation of the consequences
of deviations
The identification of any previous
incident which had a likely potential
for catastrophic consequences in
the workplace
The identification of any previous
incident which had a likely potential
for catastrophic consequences
54
Editorial Changes
(continued)
OSHA PSM Requirements
EPA Program 3
Requirements
A qualitative evaluation of a range
of possible safety and health effects
of failure of controls on employees
in the workplace
A qualitative evaluation of a range
of possible safety and health
effects of failure of controls
The employer shall investigate each
incident which resulted in, or could
reasonably have resulted in a catastrophic
release of a highly hazardous chemical
in the workplace
The owner or operator shall
investigate each incident which
resulted in, or could reasonably
have resulted in a catastrophic
release of a regulated substance
55
Language Comparison
OSHA’s - PSM
EPA’s - RMP
Employer
Owner or Operator
Highly Hazardous Chemicals
Regulated Substances
Facility
Stationary Source
Standard
Rule
Workplace Impact
Off-Site Consequences
56
Compliance Procedures

Develop an inventory of substances used, stored,
manufactured, processed, handled or moved, or any
combination of the listed activities

Compare the inventory with the TQ, as required
57
Management System

Develop a management system to oversee the
implementation of the RMP elements

Identify single person or position who has overall
responsibility for:



Development
Implementation
Integration of the RMP
58
Elements of the Program
59
Process Safety Information

Block flow or process flow diagrams

Maximum intended inventory

Establish safe limits of the operating parameters
60
Process Safety Information
(continued)

Evaluate consequences in deviations of process
conditions

Equipment information

Verify equipment design with regulatory
requirements/standard
61
Process Hazard Analysis

Document hazard analysis:





Nature of the hazard
Cause of the hazard
Consequences of the hazard
Actions to be considered to further protect personnel
Document follow-up steps based on
recommendations
62
Process Hazard Analysis
(continued)

Document previous incidents with the potential to
cause catastrophic conditions

Document hazards associated with human factors
and facility siting
63
Operating Procedures

Develop clear operating procedures addressing steps
for each process regarding



Safe operating limits of processes
Equipment
Provide precautionary instructions to prevent
exposure to hazards
64
Operating Procedures
(continued)

Develop operating procedures for safety systems

Conduct annual review of operating procedures

Develop procedures for lockout/tagout, confined
space entry, etc.
65
Employee Training

Document training for personnel in the process,
operating procedures, and safe work practices
applicable to the job tasks

Maintain records of training indicating the means
used to verify that the employee understood the
training
66
Maintenance
(Mechanical Integrity)

Provide written procedures to maintain the structural
integrity of process equipment

Document training for employees involved in
maintenance of the process equipment

Verify inspections and testing of equipment and
deficiencies are corrected

Document that spare parts are suitable for the
appropriate application
67
Incident Investigation
(Accident Investigation)

Incident reporting:




The date of the incident
Date of the investigation
Description of the incident
Factors contributing to the incident, and recommendations
that resulted

Verify that the recommendations in the incident
report were promptly addressed and resolved

Identify root causes as well as initiating events
68
Compliance Audits

Evaluate compliance with program every three years

Conduct with at least one person knowledgeable in
process

Develop report of findings Determine/develop a
response to each finding, document that deficiencies
have been corrected

Retain two most recent audit reports
69
Management of Change

Provide written procedures to manage change to
process chemicals, technology, equipment, and
procedures, and changes to facilities that affect a
covered process

Verify that employees in operations and maintenance
are trained accordingly

Provide evidence that changes are documented
70
Pre-Startup Review

Document that construction and equipment is in
accordance with design specifications

Review documentation showing that safety,
operating, maintenance, and emergency procedures
are in place and adequate

Document that a PHA was performed, and
recommendations were resolved and implemented
71
Pre-Startup Review
(continued)

Verify that modified facilities meet requirements in
Management of Change procedures

Verify that employee training is completed
72
Contractors

Must established a screening process when hiring
and use contractors

A site injury and illness log for contractors must be
maintained

The contractor must ensure that each contract
employee is trained in the work practices necessary
to safely perform his/her job
73
Employee Participation

Must develop a written plan of action regarding the
implementation of employee participation.

Required to train and educate employees and to
inform all affected employees of the findings from
any incident investigations.
74
Employee Participation
(continued)

Must consult with employees and employee
representatives:




Development of PHA and other elements
Hazard assessments
The development of chemical accident prevention
Must provide access to these records.
75
Permit Systems

A work authorization notice or permit system should
be developed


To describe the steps the maintenance supervisor,
contractor representative or other person need to follow in
order to obtain the necessary clearance to get the job done.
These procedures need to address such issues as




Lockout/tagout procedures
Line breaking procedures
Confined space entry procedures
Hot work permits
76
Permit Systems
(continued)

Procedures must provide clear steps to follow once
the job is completed to provide closure for those that
need to know the job is completed and equipment
can be returned to normal operations.
77
Emergency Planning and
Response

Document that an emergency plan has been
established and implemented in accordance with 29
CFR 1910.38 and 1910.120, as applicable

Emergency action plan that include procedures for
handling releases

Document specific actions to be taken in response to
an accidental release of a regulated substance to
protect humans and the environment


Conduct drills
Exercise to test plan
78
Emergency Response Plan Basic Requirements

Emergency response plan

Procedures for use of emergency response equipment
and for it inspection, testing, and maintenance

Training for all employees in relevant procedures

Procedures to review and update of the plan to reflect
changes at the facility and ensure that employees are
informed of changes
79
Elements - Legislative
Requirements

Procedures for informing the public and local
emergency response agencies

Documentation of proper first-aid and emergency
medical treatment necessary to treat accidental human
exposures

Procedures and measures for emergency response after
a release

Written plan must comply with other federal
regulations

Coordinate with local LEPC
80
Planning Option - One-Plan Guidance
for Integrated Contingency Plan (ICP)

Intended to:




Provide a mechanism for consolidating multiple facility
response plans
Improve coordination of response activities
Minimize duplication and simplify plan development and
maintenance
Ensure regulatory compliance with all relevant federal
requirements
81
Communicating RMP to Public
82
Communication

Rule does not specify




How communication should take place
When it should take place
How much risk communication
Anyone putting public at risk must show how risk is
addressed/prevented and responded to
83
Regulatory Approach

Industry tells government and the public how it will
address risk for preventing major accidents

Government and public can review what industry has
presented

Government and community can respond to industry,
communicate concerns, and make recommendation
84
Communicating the RMP

Start now

Explain the program

Tell the public what to expect with your WCS and
when to expect it

Explain your WCS

Detail chemical(s) on site that can cause explosions,
environmental impacts, etc.

Explain why you can’t reduce your inventory of
regulated substances
85
Community Outreach
Suggestions

Open house/plant tours

Local citizen groups/civic organization

High school programs

Community survey

What does the community think about you?

Neighborhood meetings

Plant newsletter

Community advisory panels
86
Audience

Neighbors

Implementing agencies

LEPC

Emergency responders

City and county officials
87
Audience
(continued)

Business and community leaders

Educators

Local media

State legislators
88
Other Programs

Risk communications training

Training on handling the with media

Informing industrial neighbors
89
Summary - Developing an RMP
Implementation Plan
90
Implementation Strategy Technical

Acquire/understand regulatory information

Determine coverage

Determine technical capabilities/needs

Prepare RMP implementation plan
91
Implementation Strategy Technical (continued)

Perform program level screening

Develop hazard assessment protocol

Perform hazard assessment

Compile 5-year accident history
92
Implementation Strategy Technical (continued)

Implement/upgrade PSM program to consider offsite
effects

Review/upgrade emergency response activities and
plan

Prepare and submit the RMP
93
Implementation Strategy Communication

Determine internal risk communication
capabilities/needs

Survey community outreach status

Establish/improve community outreach

Prepare communication plan

Improve internal risk communication capabilities

Communicate the RMP to the public
94
Available Resources

Chemical Emergency Preparedness and Prevention
Office (CEPPO)

Internet - (http://www.epa.gov/swercepp/acc-pre.html)
95
Suggested Team Members

Health and safety Professionals


Chemical, electrical, and mechanical engineering


Program development and review
Process safety information and hazard analysis
development
Air Quality Specialist/Industrial Hygienist


Air modeling dispersion.
Identify acute health effects
96
Suggested Team Members
(continued)

Risk Assessment Specialist


Population exposure and environmental effects
Communications Specialists

Communicating with the public
97
Summary - Final Word

PSM and RMP outlines requirements for facilities to
reduce risks associated with accidental releases

A good communications program will help reduce
misinformation, distrust, and build good community
relations

Reduction in inventory will result in a reduction of
the risk and potential for a catastrophic incident
98
Summary - Final Word
(continued)

Audits are to be comprehensive, involving
systematic assessment of all elements of the program
99