Process Safety Management

of Highly Hazardous &

Explosive Chemicals

29CFR1910.119
Clearly Understanding the Standard
Information Provided under OSHA Susan Harwood Grant
#SH-17811-SH-8
Susan Harwood Grant…History
 awarded to
Grants are awarded to provide
provide training
training and
and
education programs for employers and
employees on the recognition, avoidance,
and prevention of safety and health hazards
in their workplaces.

 PSM Was Chosen Given the Clear Need

Past Disasters
 Past
 Current Year Disasters
Perceived Weakness
 Perceived Weakness inin PSM Program
GTRI PSM Susan Harwood
Grant Program
GTRI is Offering:

 Six (6) One Day Courses Around the

Southeastern United States
 Four (4) One Week In-Depth Courses
Around the United States
Goals of the One Day Course
 Understand Why Process Safety Management (PSM)
Was Promulgated
Was Promulgated
 Understand That
Understand That Even
Even with
with PSM,
PSM, Catastrophes
Catastrophes are
are Still
Still
Occurring
Occurring
 Understand Who
Understand Who is
is Covered
Covered & & Exemptions
Exemptions
 Understand the
Understand the Team
Team Process
Process to
to Developing
Developing aa PSM
PSM
Program
Program
 Understand Each
Understand Each of
of the
the Elements
Elements of a Properly
Properly Designed
& Implemented Program and How to Begin the Process
 Understand the Basics of How PSM & RMP Work
Together to
Together to Protect
Protect the
the Workforce
Workforce && Surrounding
Surrounding
Community
Community
Summary of the One Week Course
 This is an In-Depth Study of the
Requirements of the Standard
 Students will Actually Learn through a Real
Life Case Study How to Design Each Element
of the Process Safety Management Standard
Requirements
 Students will Also Review the Basics of EPA
Risk Management Plan (RMP)
Rules of the Course

 This is an Open Discussion Course

 Relax and Learn

Ask Questions
 Ask
Participate in
 Participate in Discussions
 Share Experiences
Share Best Practices
 Share Practices
Enjoy Yourself
 Enjoy
Why Did OSHA Develop PSM?
 Bhopal, India
Bhopal, India (1984)
(1984)
2,000 deaths
 2,000 deaths
Isocyanate release
Isocyanate release
 Pasadena, TX
Pasadena, TX (1989)
(1989)
 23 deaths, 132 injuries
Petroleum explosion
Petroleum explosion
 Cincinnati, OH (1990)
22 deaths
deaths
Explosion
 Sterlington, LA
Sterlington, LA (1991)
(1991)
 8 deaths, 128 injuries
Chemical release
Chemical release
Why Did OSHA Develop PSM?

In 1991, OSHA and

EPA respectively,
Released the
Standards, PSM &
Standards,
RMP that Applies to
Those Companies
Affected by
that are Affected by
The Standards.
Why Did OSHA Develop PSM?
Process Safety
Process Safety
Management is
Management is aa
regulation, promulgated
regulation, promulgated
by OSHA, intended to
prevent an
prevent an incident
incident like
like
the 1984
the 1984 Bhopal
Bhopal Disaster
Disaster

And…to Prevent Release

of:
of:
 Toxic,
Toxic,
 Reactive,
Reactive,
 Flammable,
Flammable, or
or
 Explosive
Explosive chemicals
chemicals
Not Only PSM, But RMP
A great
A great many
many industrial
industrial
facilities must
facilities must comply
comply
with OSHA's
with OSHA's Process
Process
Safety Management
Safety Management
(PSM) regulations
(PSM) regulations as
as
well as
well as the
the quite
quite similar
similar
EPA Risk Management
Program (RMP)
Program (RMP)
regulations (Title 40
CFR Part
CFR Part 68).
68).
PSM vs. RMP - What’s the
Difference?
 PSM - Like HAZCOM  RMP-Like Sara Title III
 Protects the
Protects the  Protects the
Workforce
Workforce Community
Community
 Protects the General
Protects Contractors
 Protects Contractors Public Around
Public Around the
the
Protects Visitors
 Protects Visitors to
to Facility
Facility
the Facility
the Facility Protects Adjacent
 Protects Adjacent
 Basically Protects the Facilities Such
Facilities Such as
as
Workplace
Workplace Schools &
Schools & Hospitals
Hospitals
The Standard Was Promulgated
in 1991 - Is it Working?
The Standard Was Promulgated
in 1991 - Is it Working?
 BP Products Texas
City - January 2005
 15 Workers Killed
 170 Injured
Major Property
 Major Property
Damage
Damage
$21 Million
 $21 Million in
in Fines
Fines
Application

1910.119(a)
What Facilities are Covered
 Those Who
Those Who Use
Use Chemicals
Chemicals in in Appendix
Appendix A: A: A
A List
List of
of
highly hazardous
highly hazardous chemicals,
chemicals, toxics
toxics and
and reactive
reactive
(Mandatory). Contains
(Mandatory). Contains aa listing
listing of
of toxic
toxic and
and reactive
reactive
highly hazardous chemicals which present a potential
for aa catastrophic
for catastrophic event
event at
at or
or above
above the
the threshold
threshold
quantity
quantity

 Examples

Chemical
Chemical Threshold Quantity
Threshold Quantity (TQ)
(TQ)
Anhydrous Ammonia
 Anhydrous Ammonia -- 10,000
10,000 lbs
lbs
 Chlorine - 1,000 lbs
What Facilities are Covered
 A process which
involves a
flammable liquid or
gas (as
gas (as defined inin
1910.1200(c) of
1910.1200(c) of this
this
on-site in one
part) on-site one
location, in a
quantity of 10,000
pounds (4535.9
pounds (4535.9 kg)kg)
or more
What Facilities are Covered
 Important Interpretation:
Important Interpretation: 2007
2007 -- 06/11/2007
06/11/2007 -- OSHA
OSHA
defines "on-site in one location" for Process Safety
Management of
Management of Highly
Highly Hazardous
Hazardous Chemicals
Chemicals standard
standard

OSHA interprets
OSHA interprets "on-site
"on-site in
in one
one location"
location" to
to mean
mean that
that the
the
standard applies when a threshold quantity of a highly
hazardous chemical
hazardous chemical (HHC)
(HHC) exists
exists within
within an
an area
area under
under
the control
the control of
of an
an employer
employer or or group
group of
of affiliated
affiliated
employers. ItIt also
employers. also applies
applies to
to any
any group
group ofof vessels
vessels that
that
are interconnected,
are interconnected, or or in
in separate
separate vessels
vessels that
that are
are
close enough
close enough in in proximity
proximity that
that the
the HHC
HHC could
could bebe
involved in
involved in aa potential
potential catastrophic
catastrophic release.
release.
What Types of Industries?
 Industries that Process Chemicals Such As:
 Industrial Organics & Inorganics
 Paints
Pharmaceuticals
 Pharmaceuticals
Adhesives
 Adhesives
 Sealants and Fibers
 Petrochemical facilities
Paper Mills
 Paper Mills
Food Processing
 Food Processing with
with Anhydrous
Anhydrous Ammonia
Ammonia over
over
the TQ
the TQ
 Exclusions

1910.119(a)(1)(ii)(A)
There are Exclusions
 An employer
An employer isis exempt
exempt fromfrom the
the requirements
requirements of of PSM
PSM
when:
when:
 A threshold
A threshold quantity
quantity ofof flammable
flammable liquids
liquids is
is stored
stored in
in
atmospheric tanks
atmospheric tanks oror transferred
transferred without
without the
the benefit
benefit of
of
chilling or
chilling or refrigeration
refrigeration
 Hydrocarbon fuels
Hydrocarbon fuels used
used solely
solely for
for workplace
workplace
consumption as
consumption as aa fuel
fuel (e.g.,
(e.g., propane
propane usedused for
for comfort
comfort
heating, gasoline for vehicle refueling),
If such
 If such fuels
fuels are
are not
not aa part
part of
of aa process
process containing
containing
another highly hazardous chemical covered by this
standard
standard
There are Exclusions

 Retail facilities;
Retail facilities;
 Oil or gas well drilling or
servicing operations;
servicing operations; or,
or,
 Normally unoccupied
remote facilities
Definitions

1910.119(b)
Definitions
 Atmospheric tank
Atmospheric tank means
means aa storage
storage tank
tank which
which
has been
has been designed
designed toto operate
operate atat pressures
pressures
from atmospheric
from atmospheric through
through 0.5
0.5 p.s.i.g.
p.s.i.g. (pounds
(pounds
per square inch gauge, 3.45 Kpa).
 Boiling point
Boiling point means
means thethe boiling
boiling point
point of
of aa liquid
liquid
at a pressure of 14.7 pounds per square inch
absolute (p.s.i.a.)
absolute (p.s.i.a.) (760
(760 mm.).
mm.).
 Catastrophic release
Catastrophic release means
means aa major
major
uncontrolled emission, fire, or explosion,
involving one
involving one or
or more
more highly
highly hazardous
hazardous
chemicals, that
chemicals, that presents
presents serious
serious danger
danger to to
employees in the workplace.
Definitions
 Facility means
Facility means thethe buildings,
buildings, containers
containers or or equipment which
contain aa process.
contain process.
 Highly hazardous chemical means a substance possessing
toxic, reactive, flammable, or explosive properties and
specified by
specified by paragraph
paragraph (a)(1)
(a)(1) of
of this
this section.
 Hot work
Hot work means
means work
work involving
involving electric
electric or
or gas
gas welding,
cutting, brazing, or similar flame or spark-producing
operations.
 Normally unoccupied
Normally unoccupied remote
remote facility
facility means
means aa facility
facility which
which
is operated, maintained or serviced by employees who visit
the facility only periodically to check its operation and to
perform necessary
perform necessary operating
operating or
or maintenance
maintenance tasks.
tasks. NoNo
employees are
employees are permanently
permanently stationed
stationed at
at the facility.
facility.
Definitions
 Process means
Process means any any activity
activity involving
involving aa highly
highly
hazardous chemical
hazardous chemical including
including any
any use,
use, storage,
storage,
manufacturing, handling,
manufacturing, handling, or or the
the on-site
on-site movement
movement of of
such chemicals,
such chemicals, or or combination
combination of of these
these activities.
activities.
For purposes
For purposes of of this
this definition,
definition, any
any group
group of
of vessels
vessels
which are
which are interconnected
interconnected and and separate
separate vessels
vessels which
which
are located such that a highly hazardous chemical
could be
could be involved
involved in in aa potential
potential release
release shall
shall be
be
considered a single process.
 Replacement in kind" means a replacement which
satisfies the
satisfies the design
design specification.
specification.
 "Trade secret"
"Trade secret" means
means any any confidential
confidential formula,
formula,
pattern, process, device, information or compilation of
information that
information that is
is used
used inin an
an employer's
employer's business
business
Employee Participation

1910.119(c)
Now that we are required to
comply, then what? First…
 Form a Team in
Your Company, i.e..
 Process Engineers
 Operators
Safety
 Safety
Maintenance
 Maintenance
Management
 Management
Consultants
 Consultants

Remember…You Can’t Do it Alone!

Now that we are required to
comply, then what? Second…
 Form a Plan,
Determine:
 Responsibilities
 Duties
Reporting
 Reporting
Document Control
 Document Control
Progress Reports
 Progress Reports
Tracking Changes
 Tracking Changes
 Now that we are required to
comply, then what? Third…
 Review Scope
Review Scope of
of Project:
Project:

 Process Safety Information 

 Equipment in
Equipment in the
the Process
Process

 Process Hazard
Process Hazard Analysis
Analysis

 Operating Procedures

 Employee Training
Employee Training

 Training Contractors
Training Contractors

 Pre-Startup Safety Review

 Mechanical Integrity
Mechanical Integrity of
of Equipment 
Equipment 

 Management of Change

 Incident Investigation
Incident Investigation

 Emergency Preparedness
Emergency Preparedness

 Compliance Audits   

 Trade Secrets
Trade Secrets
Now that we are required to
comply, then what? …Let’s Begin
 In the Next Session,
we will Begin to
Explore Each
Element of the
Standard and What
is Required to
Comply