Process Safety Management

of Highly Hazardous &

Explosive Chemicals

Contractor Pre-Qualification, Emergency

Preparedness, Incident Investigation, Audits
& EPA Risk Management Plans (RMP)
Now That We’ve Developed
 Process Safety
Process Safety Information
Information
 Process Material Toxicity Information
 Process Hazard
Process Hazard Analysis
Analysis (PHA’s)
(PHA’s)
 Mechanical Integrity
Mechanical Integrity Certificates
Certificates
 Management of
Management of Change
Change
 Inspection/Testing/Maintenance
 Operating Procedures
Operating Procedures
 Safe Work
Safe Work Procedures
Procedures
 Training Programs
Training Programs
 Training for Contractors
Now…
Now…
Contractor Management

1910.119(h)
PSM Contractors
 The employer, when selecting a
contractor, shall obtain and
evaluate information regarding
the contract employer's safety
the
performance and programs.
 The employer shall inform
the
contract employers of the
known potential fire, explosion,
or toxic release hazards related
the contractor's
to the contractor's work
work and the
process
Contractor Pre-Qualification &
Authorization
 The Standard Requires You to:
The
 Explain contractor
Explain contractor qualification
qualification requirements
requirements
 List what
List what is
is required
required forfor contractor
contractor pre-bid
pre-bid
awareness - pre-qualification
 List what is required for contractor post-bid
awareness -- training
awareness training & & orientation
orientation
Specify contractor
 Specify contractor responsibilities
responsibilities
Describe contractor
 Describe contractor 300 300 Log
Log Requirements
Requirements
Evaluate Contractor
 Evaluate Contractor Performance
Performance
List documentation
 List documentation requirements
requirements for
for contractors
contractors to
to
complete
complete
Explain the
 Explain the use
use ofof aa work
work authorization
authorization system
system
Contractor Pre-Qualification &
Authorization
 Typical Pre-Qualification Elements:
Years Experience in Work Process
 Years
Experience Modification Rate
 Experience Rate (EMR)
(EMR)
 OSHA Total Recordable Incident Rate and
Lost Work day Case Rate Information
Lost
 Safety Programs
Training Documentation
 Training Documentation
Emergency Preparedness

1910.119(f)(1)(I)(D)
Emergency Preparedness
 Our Written
Our Written Plan
Plan Must:
Must:

 Define an
Define an emergency
emergency action
action plan
plan
 Define an
Define an emergency
emergency response
response plan
plan
 Describe aa Minimum
Describe Minimum emergency
emergency response
response plan
plan
 Describe procedures for handling small releases
 List the three levels of emergency response
 List procedures for  emergency evacuation
 List requirements of alarm systems
 List training requirements
Emergency Preparedness
 Requires You to:
The Standard Requires
 Develop aa Early
Develop Early Warning
Warning Method
Method for
for Releases
Releases
(Sensors/Alarms)
Train on
 Train on the
the Meaning
Meaning of
of the
the Alarms
Alarms (May
(May be
be Multiple
Multiple
Alarms)
Develop Emergency
 Develop Emergency Evacuation
Evacuation Written
Written Plans,
Plans,
Evacuation Maps & Assembly Points based on
Release Characteristics
Release Characteristics
 Determine Emergency PPE Requirements
 Train Employees & Contractors in the Emergency
Evacuation Plans
Evacuation Plans
 Drill The Emergency Evacuation Plan At Last Once
Per Year
Per Year
Emergency Preparedness
 Warning Systems
must:
 Clearly Notify
Employees of
Employees of the
the
Hazardous Release
Hazardous Release
Employees &
 Employees &
Contractors must
Contractors must be
be
Trained in
Trained in the
the
Meaning of
Meaning of the
the
Alarm(s)
Alarm(s)
Emergency Preparedness
Evacuation Maps
Emergency Preparedness
Assembly Points

Alternate Assembly
Points Depending
on Prevailing
Weather Affecting
Release

Alternate
Assembly
Point
Emergency Preparedness
Emergency PPE
 Hazardous
Chemicals May
Require Emergency
be Worn
PPE to be
 FRP
 Escape Respirators
 Eye Protection i.e..
Refinery Goggles
Refinery Goggles
Emergency Preparedness
Drills
 At Least Annual
Emergency
Preparedness Drills
 Just an
This is not Just
Emergency
Evacuation…
 but Could Include
HAZWOPR
Response
 Must Document
Results
Incident Investigation

1910.119(m)
Incident Investigation Program
Must Include the Following
 Describe the
Describe the purpose
purpose ofof incident
incident investigation
investigation
 List the
List the circumstances
circumstances or or occurrences,
occurrences, which
which require
require
formal incident
formal incident investigation
investigation
 List the
List the major
major investigation
investigation procedures
procedures that
that should
should bebe
followed
followed
 Explain the
Explain the list
list the
the responsibilities
responsibilities of
of the
the incident
incident
investigation team
investigation team
 Explain the
Explain the contents
contents of of an
an "Incident
"Incident Summary"
Summary" formform
 Explain the
Explain the contents
contents of of an
an "Incident
"Incident Description"
Description" form
form
 Explain the contents of an "Approvals, Follow-up and
Review" form
Review" form
 Explain the contents of a "Close-out" form
 Explain Corrective
Explain Corrective Actions
Actions Taken
Taken
Incidents Can Be Minor or Major -
Both Require Investigation
Incident Investigation
Documentation Must Include
 Date of incident
 Date investigation began
 Description of the incident
 Factors contributing to the incident
 Recommendations resulting from
the investigation
Incident Investigation

 Include Written
Will Include
Documentation of all
Required Elements
Incident Investigation

Might Even Include a Flow Chart

Compliance Audits

1910.119(o)
Compliance Audits
 1910.119 states, "Employers shall certify that
evaluated compliance with the
they have evaluated
provisions of this section at least every three
procedures and
years to verify that the procedures
practices developed under the standard are
adequate and are being followed."
Compliance Audits
 A List of factors that may increase the
frequency of compliance audits
frequency audits
 Results of Any OSHA Compliance Audits
Performed & Citations/Action Items Developed
An Explanation of audit certification
 An
 List Compliance Audit documentation
Compliance Audits
 Employers shall
Employers shall certify
certify that
that they
they have
have evaluated
evaluated
compliance with
compliance with the
the provisions
provisions of of this
this section
section at
at least
least
every three
every three years
years to
to verify
verify that
that the
the procedures
procedures and
and
practices developed
practices developed under
under thethe standard
standard areare adequate
adequate
and are
and are being
being followed
followed
 The compliance audit shall be conducted by at least
one person
one person knowledgeable
knowledgeable in in the
the process
process
 A report
A report of
of the
the findings
findings ofof the
the audit
audit shall
shall be
be
developed
 Compliance Audits Must be Performed Every 3 Years
Compliance Audits
 The Compliance Audit Process Typically
Includes the Following:
Includes

 Definition of the guidelines for an audit team

 A List the PSM elements that must be audited
 A List of the minimum contents of a final report of an
audit
audit
Explanation and
An Explanation
 An and list
list the
the Compliant
Compliant Audit
Audit reports
reports
that must be retained by the facility
 Compliance Audits

 OSHA PSM Citations

# Initial Penalty Final Penalty

1393 $25,058,853 $18,884,463

Compliance Audits
 Typical Types
Typical Types of
of OSHA
OSHA Serious
Serious Citations
Citations
 failure to
failure to maintain
maintain and
and follow
follow normal
normal operating
operating
procedures
procedures
 failure to
failure to provide
provide refresher
refresher training
training to
to process
process
operators
 failure to correct deficiencies in process equipment in
aa safe
safe manner
manner
 failure to
failure to provide
provide necessary
necessary training
training to
to emergency
emergency
responders and fire brigade members
 Failure to perform audits as required every 3 years
Compliance Audits

 There are Companies that have

Covered Process, but have not
implemented any PSM Program.
 The Regulatory Exposure is to:
Willful Citations
 Willful
Criminal Willful Citations
 Criminal
 Serious Citations
Major Citation Penalties
 Major Penalties
PSM Audit Example Checklist
Items (Partial)
 Management Commitment to the PSM Program
 Is there
Is there evidence
evidence that
that an
an effective
effective process
process safety
safety management
management
program has
program has been
been set
set up
up and
and that
that explicit
explicit expectations,
expectations, objectives
objectives
and goals have been set with clear-cut, desired outputs?
 Have resources been provided in the form of personnel assigned
to provide
to provide implementation
implementation and
and continuation
continuation of
of each
each element?
element?

 Have clear lines of responsibility been established and roles and

responsibilities assigned?
responsibilities assigned?
 Is management
Is management commitment
commitment toto using
using all
all available
available resources
resources for
for
enhancing process
enhancing process safety
safety knowledge
knowledge atat all
all levels
levels of
of the
the
organization clearly demonstrated by actions?
 Does management
Does management encourage
encourage active
active participation
participation in in professional
professional
and trade
and trade associations
associations for
for key
key PSM
PSM personnel
personnel to to ensure
ensure the
the PSM
PSM
system keeps pace withTest Practices?
PSM Audit Example Checklist
Items (Partial)
 Process Hazard Analysis
 Does the
Does the PSM
PSM program
program establish
establish aa process
process hazard
hazard analysis
analysis
procedure in accordance with the PSM rule?
 Have personnel,
Have personnel, who
who will
will take
take part
part in PHA 痴
in PHA 痴 ,, been
been provided
provided with
with
training in the PHA technique that will be used for their study?
 Does the
Does the PHA
PHA procedure
procedure establish
establish that
that the
the hazard
hazard identification
identification team
team
be multi-disciplined in nature, capable of covering such issues as
maintenance, operations,
maintenance, operations, design,
design, inspection
inspection & & testing,
testing, safety,
safety, health
health
and environment, etc?
 Does the
Does the PHA
PHA procedure
procedure require
require that
that the
the PHA
PHA team
team leader
leader be
be
specially trained in the technique that will be used?
 Does documentation
Does documentation ofof the
the hazard
hazard identification
identification process
process include
include all
all
issues, not only those resulting in findings or recommendations?

 Have PHA been conducted on all PSM-covered processes and if not,

is there
is there an
an established
established schedule
schedule for
for completing
completing all
all PHA
PHA’s?
’s?
Compliance Audits
 Audit Findings must be Documented
 Actions must be Taken on All
Exceptions
 All Actions Affecting P&ID’s, PHA’s,
Mechanical Integrity Certificates,
Inspection/Testing/Maintenance,
Operating Procedures & Training
Procedures will Require Revision of
All of the Above
Compliance Audits

 Remember,

The Audit Process is Determine if there are

any weaknesses in the system or PSM
Program and to provide a report an
method to take action.
These actions can prevent catastrophic
release, injury and death.
Trade Secrets

1910.119(p)
Trade Secrets

 All Information Regarding the Process

Must be Made Available to Persons
Involved in the PSM Program Including
Trade Secrets
 Confidentiality Agreements are Allowed
Summary of PSM Elements
 Process Safety
Process Safety Information 
Information 
 Equipment iiii the
Equipment the Process
Process
Process Hazard
 Process Hazard Analysis
Analysis
 Operating Procedures
 Employee Training
Training Contractors
 Training Contractors
Pre-Startup Safety
 Pre-Startup Safety Review
Review
Mechanical Integrity
 Mechanical Integrity ofof Equipment 
Equipment 
Management of
 Management of Change
Change
 Incident Investigation
 Emergency Preparedness
 Compliance Audits   
Trade Secrets
 Trade Secrets
EPA Risk Management Plans
(RMP) Basics
CAA 112(r)
One More Thing to Discuss…
EPA Risk Management Plans
(RMP)
 Many Times Companies Who Must
Comply with PSM, must also Comply
with the Requirements of EPA Risk
Management Plans (RMP)
 The RMP Standard was to be a Mirror
of the PSM Standard…Didn’t happen!
 Remember…PSM Protects the
Workforce, RMP Protects the
Community
EPA RMP
 Basic Requirements
 Executive summary
Registration
 Registration
Off-site consequence analysis
 Off-site
Five-year accident history
 Five-year
Emergency response plan
 Emergency plan
 Prevention program summary information
Certification
 Certification

than PSM…Right?
Sound Much Easier than
All Public Facilities
in this Release Release
Plume Must be Plume
Identified &
Surveyed
EPA RMP

 Emergency Response Plan &

Prevention Plans Must Be Developed to
Prevent Accidental Release of the
Covered Chemical
EPA RMP 1998 Changes
Compliance Elements
 Follow-up / completion of PHA
recommendation
 Re-validation of your PHA every 5
years
 Compliance audits (required every
3 years)
 Follow-up / completion of
compliance audit recommendations
EPA RMP 1998 Changes
Compliance Elements
 Annual review and certification of
operating procedures
 Employee training
 Updates related to system
modifications, inventory changes,
operational changes
 Off-site consequence analysis
Process Safety Management of
Highly Hazardous & Explosive
Chemicals & EPA Risk
Management Plans

Summary
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
Resources
 GTRI -
http://www.oshainfo.gatech.edu/index.html
 OSHA PSM Compliance Guidelines --
http://www.osha.gov/Publications/osha3133.html
 OSHA PSM for Construction 1926.64 -
http://www.osha.gov/doc/outreachtraining/htmlfile
s/psm.html
PSM One Day Review
PSM One Day Review
1. The Process Safety Management
Standard was drafted as a requirement
of the Clean Air Act. True or False
2. The PSM program must include a list
of highly hazardous chemicals. True or False
3. The initial start-up of a process is not
included as an operating phase under
the PSM Standard. True or False
4. List three items that the process hazard analysis must
address. ___________, __________ and __________.
5. PSM does not apply to contractors,
regardless of the work they are doing. True or False
PSM One Day Review (cont.)
6. The PSM Standard applies to companies that either process
highly _____________ materials or use _____________
liquids and gases in excess of 10,000 pounds.
7. Process safety information includes:
______________, _____________ and _____________.
8. Fault tree analysis is one form of an
approved method of performing a process
hazard analysis. True or False
9. A technical basis is not required to change
a process covered by the PSM Standard. True or False
10. Two types of training required by the PSM
standard are ________________ and_________________.