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PROCESS SAFETY MANAGEMENT VS RISK MANAGEMENT

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Title: PROCESS SAFETY MANAGEMENT VS RISK MANAGEMENT


1
PROCESS SAFETY MANAGEMENT VS RISK MANAGEMENT
  • An Overview
  • Tracy Estes, CSP
  • James E. Roughton, MS, CSP, CRSP, CHMM

2
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 (HHCs)

3
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

4
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

5
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

6
EPAs 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

7
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

8
Key Features (continued)
  • 3 Program levels
  • Management system
  • Offsite consequence analysis
  • Worst-case scenario
  • Alternative release scenario
  • 5-year accident history

9
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

10
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

11
EPAs Regulatory Approach
  • Performance-based approach
  • Similar to OSHAs PSM
  • Build on existing programs and standards
  • Scale the requirements to fit the risk
  • Coordinate with OSHA and DOT

12
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

13
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

14
Requirements of 112 (r) (continued)
  • Provide a summary (RMP) to
  • EPA
  • States
  • Locals
  • Public

15
Basic Principles
  • Build on EPCRA
  • Emphasize community right-to-know
  • Focus the program at the local level
  • Where the risk is found

16
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

17
Manufacturing Industries Affected
  • Chemical manufacturers
  • Industrial Organics Inorganics
  • Paints
  • Pharmaceuticals
  • Adhesives,
  • Sealants
  • Fibers

18
Manufacturing Industries Affected (continued)
  • Petrochemical Products
  • Refineries
  • Industrial Gases
  • Plastics and Resins
  • Synthetic Rubber

19
Non-Manufacturing Affected (continued)
  • Non-Manufacturing Facilities affected
  • Utilities
  • Electric and Gas
  • Public Sources
  • Drinking Water and Waste Water Treatment
  • Agriculture
  • Fertilizers, Pesticides

20
Other Manufacturing
  • Electronics
  • Semiconductors
  • Paper
  • Fabricated metals
  • Industrial machinery
  • Furniture
  • Textiles

21
Other Industries
  • Food and Cold Storage
  • Propane Retail
  • Warehousing
  • Wholesalers
  • Federal sources
  • Military and Energy Installations

22
PSM vs. RMP Requirements
  • PSMs concern - potential hazard and protection
    of employees inside a regulated area
  • RMPs 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

23
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

24
Overview Worst-Case Scenario (WCS)
  • Greatest quantity from vessel or piping
  • May include administrative controls
  • Toxic gases
  • Quantity released in 10 minutes
  • Toxic liquids
  • Instantaneous spill to ground volatilization
    passive mitigation
  • Toxic gases liquefied by refrigeration

25
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

26
Alternative Release Scenario (ARS)
  • More likely than a worst case scenario
  • Much reach endpoint offsite
  • One scenario representative of all flammables

27
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

28
List of Substances and Thresholds
  • Focuses on lethal effects resulting from acute
    exposures
  • Includes mandated substances

29
Mandated Substances
  • Ammonia
  • Anhydrous Ammonia
  • Anhydrous Hydrogen Chloride
  • Anhydrous Sulfur Dioxide
  • Bromine
  • Chlorine
  • Ethylene Oxide
  • Hydrogen Cyanide
  • Hydrogen Fluoride
  • Hydrogen Sulfide
  • Methyl Chloride
  • Methyl Isocyanate
  • Phosgene
  • Sulfur Trioxide
  • Toluene Diisocyanate
  • Vinyl Chloride

30
Toxic Substances
  • Extremely hazardous substances under SARA
  • Gases and highly volatile liquids
  • Vapor pressure gt 10 mmHg
  • Thresholds ranging from 500-2,000 lbs.
  • Thresholds based on toxicity and volatility

31
Flammable Substances
  • NFPA 4
  • Most dangerous
  • Flammable gases and volatile flammable liquids
    that could create vapor cloud explosions
  • Thresholds set at 10,000 lbs.

32
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)

33
Offsite Consequence Analysis
  • Toxic endpoint
  • Flammable endpoints
  • Use appropriate models or guidance
  • Within circle, identify
  • Public receptors and population
  • Environmental receptors

34
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

35
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

36
Auditing the Program
  • Conduct audits of the management system

37
Program Eligibility Criteria
  • Three Programs

38
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

39
Program 3 - Full RMP
  • One comprehensive prevention program that
  • Protects workers
  • The public
  • The environment
  • Hazard review information
  • Hazards
  • Controls
  • Mitigation
  • Changes

40
Program 3 (continued)
  • Register
  • Conduct worst-case and other hazard assessments
  • Implement comprehensive prevention steps (OSHA
    PSM plus...)
  • Develop emergency response plan
  • Submit RMP

41
Program 3 (continued)
  • Process is subject to OSHA's PSM
  • Processes in specific SIC codes
  • 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)

42
Program 2 - Streamlined Prevention Program
  • The process is not eligible for Program 1 or 3

43
Program 2 (continued)
  • Statutory requirements
  • Training
  • Maintenance
  • Safety Precautions
  • Monitoring

44
Program 2 (continued)
  • Types of sources
  • 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

45
Program 2 (continued)
  • Process information (SIC, chemicals)
  • List rules, standards, design codes
  • Hazard review information
  • Hazards
  • Controls
  • Mitigation
  • Changes

46
Program 2 (continued)
  • Register
  • Conduct worst-case and other hazard assessments
  • Implement seven elements of prevention program
  • Develop emergency response plan
  • Submit RMP

47
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

48
Comparison (continued)
  • Management Program Document
  • Program 1 Program 2 Program 3
  • Management System Management System

49
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

50
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

51
Comparison (continued)
  • Emergency Response Program
  • Program 1 Program 2 Program 3
  • Coordinate with Local Develop Plan Develop
    Plan
  • Responders and Program and Program

52
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

53
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

54
Editorial Changes (continued)
  • OSHA PSM Requirements EPA Program 3 Requirements
  • An evaluation of the consequences An evaluation
    of the consequences
  • of deviations, including those of deviations
  • affecting the safety and health
  • of employees
  • The identification of any previous The
    identification of any previous
  • incident which had a likely potential incident
    which had a likely potential
  • for catastrophic consequences in for
    catastrophic consequences
  • the workplace

55
Editorial Changes (continued)
  • OSHA PSM Requirements EPA Program 3
    Requirements
  • A qualitative evaluation of a range A
    qualitative evaluation of a range
  • of possible safety and health effects of possible
    safety and health
  • of failure of controls on employees effects of
    failure of controls
  • in the workplace
  • The employer shall investigate each The owner or
    operator shall
  • incident which resulted in, or could investigate
    each incident which
  • reasonably have resulted in a catastrophic
    resulted in, or could reasonably
  • release of a highly hazardous chemical have
    resulted in a catastrophic
  • in the workplace release of a regulated
    substance

56
Language Comparison
  • OSHAs - PSM EPAs - RMP
  • Employer Owner or Operator
  • Highly Hazardous Chemicals Regulated Substances
  • Facility Stationary Source
  • Standard Rule
  • Workplace Impact Off-Site Consequences

57
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

58
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

59
Elements of the Program
60
Process Safety Information
  • Block flow or process flow diagrams
  • Maximum intended inventory
  • Establish safe limits of the operating parameters

61
Process Safety Information (continued)
  • Evaluate consequences in deviations of process
    conditions
  • Equipment information
  • Verify equipment design with regulatory
    requirements/standard

62
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

63
Process Hazard Analysis (continued)
  • Document previous incidents with the potential to
    cause catastrophic conditions
  • Document hazards associated with human factors
    and facility siting

64
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

65
Operating Procedures (continued)
  • Develop operating procedures for safety systems
  • Conduct annual review of operating procedures
  • Develop procedures for lockout/tagout, confined
    space entry, etc.

66
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

67
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

68
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

69
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

70
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

71
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

72
Pre-Startup Review (continued)
  • Verify that modified facilities meet requirements
    in Management of Change procedures
  • Verify that employee training is completed

73
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

74
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.

75
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.

76
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

77
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.

78
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

79
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

80
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

81
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

82
Communicating RMP to Public
83
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

84
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

85
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 cant reduce your inventory of
    regulated substances

86
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

87
Audience
  • Neighbors
  • Implementing agencies
  • LEPC
  • Emergency responders
  • City and county officials

88
Audience (continued)
  • Business and community leaders
  • Educators
  • Local media
  • State legislators

89
Other Programs
  • Risk communications training
  • Training on handling the with media
  • Informing industrial neighbors

90
Summary - Developing an RMP Implementation Plan
91
Implementation Strategy - Technical
  • Acquire/understand regulatory information
  • Determine coverage
  • Determine technical capabilities/needs
  • Prepare RMP implementation plan

92
Implementation Strategy - Technical (continued)
  • Perform program level screening
  • Develop hazard assessment protocol
  • Perform hazard assessment
  • Compile 5-year accident history

93
Implementation Strategy - Technical (continued)
  • Implement/upgrade PSM program to consider offsite
    effects
  • Review/upgrade emergency response activities and
    plan
  • Prepare and submit the RMP

94
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

95
Available Resources
  • Chemical Emergency Preparedness and Prevention
    Office (CEPPO)
  • Internet - (http//www.epa.gov/swercepp/acc-pre.ht
    ml)

96
Suggested Team Members
  • Health and safety Professionals
  • Program development and review
  • Chemical, electrical, and mechanical engineering
  • Process safety information and hazard analysis
    development
  • Air Quality Specialist/Industrial Hygienist
  • Air modeling dispersion.
  • Identify acute health effects

97
Suggested Team Members (continued)
  • Risk Assessment Specialist
  • Population exposure and environmental effects
  • Communications Specialists
  • Communicating with the public

98
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

99
Summary - Final Word (continued)
  • Audits are to be comprehensive, involving
    systematic assessment of all elements of the
    program
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