Development, Validation, Implementation and Enhancement of a Voluntary Protection Programs Center of

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Development, Validation, Implementation and
Enhancement of a Voluntary Protection Programs
Center of Excellence (VPP CX) Capability for
Department of Defense (DoD)
Process Management Safety
Department of Defense Voluntary Protection
Programs Center of Excellence Operated by
DoD Lead AgentOffice of the Assistant
Secretary of the Army (Installations and
Environment)
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Objectives

• After this training you will be able to
• Understand the history behind the Process Safety
  Management (PSM) standard
• Understand key provisions of the PSM standard.

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What is Process Safety Management?

• PSM is a process involving all managers,
  employees and contract workers, with the purpose
  of minimizing uncontrolled change from design
  and/or operating intent at their facility.

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Why Process Safety Management?

• 1910.119 Federal Standard
• May 26,1992
• 1974-Flixborough, England Explosion killed
  everyone at the plant
• 1976-Seveso, Italy dioxin release
• 1984-Mexico City 500 killed due to LPG explosion
• 1984-Bhopal, India 2,000 deaths as a result of a
  methyl isocyanate release at Union Carbide
• 1985-Institute, W.V. First major release in the
  States. Union Carbide Plant
• 1989-Pasadena, TX. Petrochemical explosion and
  fire. 23 deaths, 132 injuries.

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PSM Rule Provisions
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PSM Rule Provisions
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Employee Participation

• For a written PSM program to be successful, it
  must involve all employees and contractors.
  The employer shall develop the written plan to
  identify
• Who is responsible for the management of the
  program
• How employees can be informed about the
  program and updates
• How suggestions can be submitted for
  improvement.

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Employee Participation

• Communicate PSM program information to employees
• New comer orientation
• Annual training
• Safety or staff meetings
• Email
• Newsletters.
• Inform affected employees of the findings from
  incident investigation, audits and Process Hazard
  Analysis (PHA)
• Involve employees in the investigation process
• Involve employees in standard operating procedure
  updates.

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Employee Participation

• Easy access to important PSM information must be
  available to employees. This includes
• Information on the PSM program (Process Safety
  information (PSI), PHAs, etc.)
• Incident and near miss review information
• Emergency response plans and procedures.

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PSM Rule Provisions
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Comprehensive Process Safety Information
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Process Safety Information (PSI)

• Hazards of the chemical include
• Toxicity information
• Permissible exposure limits
• Physical data
• Reactivity data
• Corrosivity data
• Thermal and chemical stability data
• Hazard effects of inadvertent mixing of different
  materials.

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Process Safety Information (PSI)

• Information Pertaining to the Technology of the
  Chemical
• Block Flow Diagram
• Process Chemistry
• Maximum Intended Inventory
• Safe Upper/Lower Limits
• Evaluation of consequences of deviations,
  including those affecting safety and health of
  employees.

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Process Safety Information (PSI)

• Equipment of the chemical process includes
• Materials of Construction
• Piping and Instrument Diagrams (PIDs)
• Electrical Classifications
• Relief System Design and Design Basis
• Ventilation System Design and Design Basis
• Design Codes and Standards
• Material and Energy Balances for Processes
• Safety Systems
• Equipment complies with recognized and generally
  good engineering practices.
• Equipment designed/constructed to codes/standards
  no longer in general use.

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PSM Rule Provisions
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Process Hazard Analysis (PHA)

• PHA is the systematic process to identify and
  analyze possible hazard scenarios with a PSM
  covered process.
• Potential causes and consequences of fires,
  explosions and toxic releases.
• Equipment failures, human errors and external
  events that may cause accidents.
• One of the following methodologies can be used
• What-If
• Checklist
• What-If/Checklist
• Hazard and Operability Study (HAZOP)
• Failure Modes and Effects Analysis (FMEA)
• Fault Tree Analysis.

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Process Hazard Analysis (PHA)

• PHA is
• Identifying, evaluating and controlling process
  hazards involving hazardous chemicals through a
  systemic means
• Conducted to identify scenarios (e.g., events
  with potential for catastrophic releases)
  associated with the system
• Completed initially and revalidated every five
  years.

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Process Hazard Analysis (PHA)

• PHA Identifies
• Hazards of the process
• Previous incident
• Engineering administrative controls
• Consequences of failures
• Facility sitting
• Human factors
• Possible health safety effects on associates
  should there be a release.

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PSM Rule Provisions
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Standard Operating Procedures (SOP)

• Operating procedures must implement safe work
  practices
• Lockout/tagout
• Confined space entry
• Line Breaks
• Opening process equipment or piping
• Control over facility entrance
• Operating procedures must be annually certified
  that they are current and accurate with the
  process.
• Operating procedures must be specific to the
  covered process and be developed by the employees
  operating the process
• Operating procedures must be accessible to
  employees that work the process.

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Standard Operating Procedures (SOP)

• Procedures must include steps for each operating
  phase
• Initial startup
• Normal operations
• Temporary operations
• Emergency shutdown
• Emergency operations
• Normal shutdown
• Startup following a turnaround.

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Standard Operating Procedures (SOP)

• Operating Limits
• Consequences of deviation
• Steps required to correct or avoid deviation.

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Standard Operating Procedures (SOP)

• Safety Health Considerations
• Properties of hazards presented by the
  chemicals used
• Precautions necessary to prevent exposure
• Control measures to be taken if physical contact
  or airborne exposure occurs
• Quality control for raw materials
• Any special or unique hazards
• Safety systems their functions.

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Standard Operating Procedures (SOP)

• The employer shall
• Be readily available to refrigeration associates
• Be reviewed as often as necessary for accuracy
• Be certified as being current and accurate at
  least annually
• Develop and implement safe work practices such as
  LOTO, confined space entry, line opening, and
  control over entrance into the facility by
  maintenance, contractors, laboratory or other
  support personnel.

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PSM Rule Provisions
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Training

• Employees operating the process must receive
  initial and refresher training.
• Initial Training
• Employees shall be trained in an overview of the
  process and in the operating procedures, which
  includes
• Emphasis on the specific safety and health
  hazards
• Emergency operations including shutdown
• Safe work practices
• Refresher Training
• Shall be provided every three years to assure the
  employee understands and adheres to the current
  operating procedures of the process.
• Consult with employees to determine the
  appropriate frequency of refresher training.

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PSM Rule Provisions
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Contractors

• Contractor Provisions
• Apply to contractors performing maintenance,
  repair, turnaround, major renovation or specialty
  work on or adjacent to a covered process
• Require that process owners screen and hire
  contractors that perform work safely
• Contractors should implement their own safety
  programs
• All must work to ensure good communication.

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Contractors

• Process Owners Responsibilities
• Ensure that contract employees are trained in the
  work practices necessary to perform their job
  safely
• Ensure that contract employees follows the safety
  rules of the facility including the required safe
  work practices required in the operating
  procedures of the standard
• Document that each contract employee has received
  and understood the training required.

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Contractors

• Contractor Responsibilities
• Assure each employee is trained in practices
  necessary to safely perform their job.
• Assure each employee is instructed in the known
  potential fire, explosion, or toxic release
  hazards and the applicable provisions of the
  emergency action plan.
• Document that each employee received and
  understood the training required. Prepare a
  record, which identifies the employee, date of
  training and means used to verify employee
  understood the training.
• Assure employee follows the safety rules of the
  facility.
• Advise employee of any unique hazards presented
  by employers work or of any hazards found by
  employers work.

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PSM Rule Provisions
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Mechanical Integrity

• Mechanical Integrity strives to ensure all
  equipment, piping, instrumentation, electrical
  systems and other items are designed, constructed
  and maintained to the appropriate standards thus
  decreasing the probability of failure.
• Mechanical integrity applies to
• Pressure vessels and storage tanks
• Piping systems including valves an other
  components
• Relief, vent systems and devices
• Emergency shutdown systems
• Controls
• Pumps.

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Mechanical Integrity

• Written procedures must be established and
  implemented to maintain the integrity of the
  equipment.
• Employees involved in maintaining the equipment
  muse receive training on
• The process and its hazards
• Maintenance procedures
• Safe work practices
• Proper use of equipment.

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Mechanical Integrity

• Equipment must be inspected and tested and
  documented to include
• Date
• Name of person performing the inspection or test
• Identification of equipment
• Test/Inspection description
• Test/Inspection results.
• Treat mechanical integrity procedures like
  operating procedures.
• Annual certification.

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PSM Rule Provisions
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Pre-Start Safety Review (PSSR)

• Before the chemical is introduced into the
  system, the process owner must confirm
• Construction and equipment are in accordance with
  design specs
• Safety, operating, maintenance and emergency
  procedures are in place
• A PHA has been performed and recommendations have
  been resolved or implemented before start-up.

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Pre-Start Safety Review (PSSR)

• In existing facilities Management of Change
  requirements must be met
• Training for each employee involved in operating
  the process must be completed.

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PSM Rule Provisions
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Hot Work Permits

• Hot work involves
• Cutting
• Brazing
• Grinding
• Electric or gas welding
• Burning
• Exposure of energized electrical conductors.
• Any work that creates a spark and is outside of
  designated hot work shops.

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PSM Rule Provisions
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Management of Change (MOC)

• Shall establish written procedures to manage
  changes to
• Process chemicals
• Process technology
• Equipment
• Procedures
• Facilities that affect a covered process.
• Does not apply to replacements in kind
• Are replacements that satisfy the design
  specifications.

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Management of Change (MOC)

• Written procedures must address prior to the
  change
• Technical basis for the change
• Impact the change will have on safety and health
• Modifications to operating procedures
• Necessary time period for the change
• Authorization requirements for proposed change
• Employees involved in operating the process,
  maintenance and contract employees shall be
  informed of and trained in the change prior to
  start-up.

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PSM Rule Provisions
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Incident Investigations

• Investigate each incident, which resulted in, or
  could reasonably have resulted in a catastrophic
  release of highly hazardous chemical.
• Incident investigation shall be initiated as
  promptly as possible, but no later than 48 hours
  following the incident.
• Incident investigation team
• One person knowledgeable in the process
• Contract employee if incident involved their work
• People with knowledge and experience to
  thoroughly investigate and analyze the incident.

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PSM Rule Provisions
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Emergency Planning and Response

• Establish and implement an emergency action plan
  per 29 CFR 1910.38
• Emergency action plan at a minimum, must have
  procedures for
• Reporting a fire or other emergency
• Emergency evacuation, including type of
  evacuation and exit route assignments
• Employees to remain to operate critical plant
  operations before they evacuate
• Accounting for all employees after evacuation
• Employees performing rescue or medical duties
• The name and job title of every employee who may
  be contacted by employees who need more
  information about the plan.

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Emergency Planning and Response

• Emergency action plan must be in writing and kept
  in the workplace and made available to employees
  for review.
• Must have and maintain an employee alarm system,
  which uses a distinctive signal for each purpose
  and complies with 29 CFR 1910.165
• Must review the emergency action plan with each
  employee covered by the plan.

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PSM Rule Provisions
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Compliance Audits

• Audit the compliance of your PSM program every 3
  years to verify PSM procedures are adequate and
  being followed.
• The audit must be conducted by at least one
  person knowledgeable in the process.
• Develop a report of the audit findings and
  document appropriate response to each finding.
• Document when deficiencies have been corrected.
• Retain two most recent compliance audit reports.

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PSM Rule Provisions
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Trade Secrets

• A trade secret could be a formula, device,
  pattern or compilation of information used in
  ones business and provides them the opportunity
  for advantage over competitors.
• Employers shall make information available to
  comply with the PSM standard to
• Compile PSI
• Assist the development of PHA(s)
• Developing operating procedures
• Individuals involved with incident
  investigations, emergency planning and compliance
  audits.

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PSM Rule Provisions
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Questions?