Transcript U.S. Regulatory requirements for Risk Analysis

Process Safety Management
(PSM)
Safety and Security
Conference
April 21, 2010
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The Law – Intent
“The process safety management standard targets
highly hazardous chemicals that have the potential to
cause a catastrophic incident. This standard as a
whole is to aid employers in their efforts to prevent or
mitigate episodic chemical releases that could lead to
a catastrophe in the workplace and possibly to the
surrounding community.”
APPENDIX C TO § 1910.119
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The Law – Intent
To prevent or minimize
the consequences of
catastrophic releases of
toxic, reactive,
flammable, or explosive
chemicals
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29 CFR 1910.119 Covered
Processes
• Materials on site at or above threshold quantities
of chemicals listed in appendix A of the standard.
• Flammable liquids / gases onsite in one location in
quantities greater than 10,000 lbs. (Certain
exemptions apply)
• Manufacture of explosives.
• Manufacture of pyrotechnics
• List of highly hazardous chemicals
(appendix A to 29 CFR 1910.119).
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Elements OSHA Standard 29 CFR
1910.119
• Employee Participation
• Process Safety
Information
• Process Hazard Analysis
• Operating Procedures
• Training
• Contractors
• Pre-startup Safety
Review
•
•
•
•
•
Mechanical Integrity
Hot Work Permits
Management Of Change
Incident Investigations
Emergency Planning And
Response
• Compliance Audit Every
3 Years
• Trade Secrets.
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Employee Participation
1. Employers shall develop a written plan of action
regarding the implementation of the employee
participation required by this paragraph.
2. Employers shall consult with employees and their
representatives on the conduct and development of
process hazards analyses and on the development of
the other elements of process safety management in
this standard.
3. Employers shall provide to employees and their
representatives access to process hazard analyses
and to all other information required to be developed
under this standard.
§ 1910.119 Process safety management of highly hazardous chemicals
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Process Safety Information (PSI)
“In accordance with the schedule set forth in
paragraph (e)(1) of this section, the
employer shall complete a compilation of
written process safety information before
conducting any process hazard analysis
required by the standard.”
§ 1910.119 Process safety management of highly hazardous chemicals
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PSI – The Chemicals
Information Pertinent to the Highly Hazardous
Chemicals of the Process (used or produced):
• Toxicity
• Permissible Exposure Limits
• Physical Data
• Reactivity Data
• Corrosivity Data
• Thermal and Chemical
Stability Data
• Incompatibility data.
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PSI – The Process
Information Pertinent to the Technology of the
Process:
• Block Flow Diagrams or simplified Process Flow
Diagram
• Process Chemistry
• Maximum Intended Inventory
• Safe upper and lower limits such as temperature,
pressure, flows
• An evaluation of the consequences of deviation
including those affecting safety and health of
employees
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PSI -- Equipment
•
•
•
•
•
•
•
Materials of construction
P & id's
Electrical classifications
Relief systems & design basis
Ventilation systems
Design codes
Material / energy balances
(for processes built after 5-2692)
• Safety systems / interlocks
HE-001
V-001
?!
xxx
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P-001
PSI – Incidents (Intent)
The intent of an incident investigation is for
employers to learn from past experiences and thus
avoid repeating past mistakes. The incidents for
which OSHA expects employers to become aware
and to investigate are the types of events which
result in or could reasonably have resulted in a
catastrophic release.
Some of the events are sometimes referred to as
‘‘near misses,’’ meaning that a serious consequence
did not occur, but could have.
APPENDIX C TO § 1910.119
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Critical Limits – The Law’s Intent
“Process technology information will be a part of
the process safety information package and it is
expected that it will include diagrams of the type
shown in appendix B of this section as well as
employer established criteria for maximum inventory
levels for process chemicals; limits beyond which
would be considered upset conditions; and a
qualitative estimate of the consequences or results
of deviation that could occur if operating beyond
the established process limits.”
APPENDIX C TO § 1910.119
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PHA Scope
The process hazard analysis shall address:
• The hazards of the process.
• The identification of any previous incident which had a
likely potential for catastrophic consequences in the
workplace.
• Engineering and administrative controls applicable to the
hazards and their interrelationships such as appropriate
application of detection methodologies to provide early
warning of releases.
• Consequences of failure of engineering and administrative
controls.
• Facility siting.
• Human factors.
• A qualitative evaluation of a range of the possible safety
and health effects of failure of controls on employees in the
workplace.
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PHA Requirements
(e)(1)
Prioritize processes and perform initial PHAs within
5 years.
(e)(2)
Use specified methodologies or equivalent
(e)(3)
Address hazards of the process and six specific
concerns in the PHA.
(e)(4)
Include proper expertise and experience on the
PHA team.
(e)(5)
Establish a system to track the handling of the
PHA recommendations.
(e)(6)
Update and revalidate PHAs every 5 years.
(e)(7)
Retain PHA documentation for the life of the
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The RA Team
“The process hazard analysis shall be performed
by a team with expertise in engineering and
process operations, and the team shall include at
least one employee who has experience and
knowledge specific to the process being
evaluated. Also, one member of the team must
be knowledgeable in the specific process
hazard analysis methodology being used.”
OSHA 1910.119
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Methodology
• What-If
• Checklist
• What-If/Checklist
• Hazard and Operability Study, (HAZOP)
• Failure Mode and Effects Analysis (FMEA)
• Fault Tree Analysis, or
• An appropriate equivalent methodology.
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Corrective Action
“The employer shall establish a system to promptly
address the team’s findings and recommendations:
• Assure that the recommendations are resolved in a
timely manner and that the resolution is
documented
• Document what actions are to be taken;
• Complete actions as soon as possible;
• Develop a written schedule of when these actions
are to be completed;
• Communicate the actions to operating,
maintenance and other employees whose work
assignments are in the process and who may be
affected by the recommendations or actions.”
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Corrective Action Tracking
Process – Basic Process
Re-opened
If Not
Effective
New
Action
Added
Person
Assigned
To Action
Person
Assigned
Emailed
Action
Completed
Action
Taken
Verified By
Owner
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Action
Closed
Contractors
• Contractor Safety
• Train on Work Practices
• Inform Contractor
– Hazards
– Emergency Action Plan
• Control and Track
• Evaluate
• Maintain Injury and Illness Log
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Written Operating Procedures
Requirements
• Steps for each operating phase
– Initial startup
– Normal operations
– Temporary shutdowns
– Emergency shutdowns
– Emergency operations
– Normal shutdowns
– Startup after shutdowns
• Operating limits / deviations
• Safety & health considerations
• Safety systems & their functions
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Pre-startup Safety Review
Requirements
• Construction is in accordance with design
specifications
• Safety, operating, maintenance, and
emergency procedures are in place and
adequate
• Process hazards analysis
recommendations have been addressed
• Employee training completed
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Mechanical Integrity Scope
• Pressure vessels
• Storage tanks
• Piping systems
• Relief / vent systems & devices
• Emergency shutdown systems
• Process Controls (e.G.: Sensors, alarms,
interlocks, etc.)
• Pumps
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Mechanical Integrity Requirements
• Written procedures
• Training program
• Inspections / testing
• Records / documentation
• Corrective action program
• Quality assurance in new installations
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Management Of Change
Procedure Requirements
• Technical basis of change
• Impact of change on safety, health & ecology
• Modifications to operating procedures
• Necessary time period for change
• Authorization requirements
• Employee training requirements
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MOC/PSSR Process – Basic
Process
Originator
emailed if
rejected
Process
Change
Request Form
(PCRF)
Head Of Area
(HOA)
Approval
Originator and
HOA emailed if
rejected
Technical
Representative
(TR) Assigned
TR Approval
Pre Startup
Safety Review
(PSSR)
Task Creation
And
Assignment
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Tasks
Completed
Approval And
Authorisation
For Startup
Incident Investigations
• Scope: incidents which resulted in, or could reasonably have
resulted in a catastrophic release of a highly hazardous
chemical in the workplace.
• Investigation initiated within 48 hours
• Investigation by knowledgeable team
• Report content:
– Date of incident
– Date investigation began
– Incident description
– Contributing factors
– Recommendations
• Corrective action systems
• Communication of report
• Retention of report for 5 years
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AIIMS Process – Basic Process
Status Set As
Disputed If
Not Aproved
New Accident
/ Incident
Added
Investigation
Team And
Actions Setup
Submitted For
Review By
Team Leader
Team Leader
Ammends &
Submits To
Head Of Area
(HOA)
HOA Approves
AIIMS Plan
Tasks Re
Opened
Actions
Created And
Responsible
Persons
Emailed
Tasks
Completed
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All Tasks
Completed
AIIMS
Complete
Emergency Planning &
Response Requirements
•
•
•
•
•
•
•
•
•
Evacuation procedures / routes
Critical equipment operation
Head count procedures
Rescue & medical duties
Notification
Alarm systems
Types of evacuation
Training
Procedures for handling small releases
As per OSHA 29 CFR 1910.38a, 1910.119, & 1910.120
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Thank You for Your Time
Shawn Blenis
Intertek USA
251-610-1337
[email protected]
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