ChE 408

Chapter 1: Introduction
Part B
 Codes, Standards and Regulations
A code is a set of rules developed by a team of
knowledgeable people. The knowledgeable people are
most likely associated with an industrial professional
organization. Codes do not have legal authority, but
governments might adopt it into law.

A standard is more elaborate, explaining in a lot more

detail how to meet the code. Codes tell you what you need
to do and the standard tells you how to do it. Codes
likewise do not have legal authority, but governments
might adopt it into law.

A regulation is developed by a government and has legal

authority. It may be based on a code or standard.
Violations of regulations could result in fines and/or jail
time.
 Regulations(examples)
U.S. Occupational Safety and Health Administration (OSHA),
www.osha.gov
29 CFR 1910.119 Process Safety Management of Highly
Hazardous Materials
This applies to manufacturing sites when on-site inventories of
chemicals exceed the threshold values provided in the
regulation.
A prevention program involving 14 elements must be maintained.

U.S. Environmental Protection Agency (EPA), www.epa.gov

40 CFR 68 Risk Management Programs (RMP)
This applies to releases of toxic or flammable materials that have
off-site impacts. If chemicals exceed threshold quantities, a
consequence analysis must be completed to estimate off-site
impacts. A prevention program involving 11 elements must be
maintained.
CFR
Code of Federal Regulations.
 Regulations

U.S. Department of Homeland Security (DHS), www.dhs.gov

6 CFR 27 Chemical Facility Anti-Terrorism Standards
This establishes risk-based performance standards for the
security of chemical facilities. An on-line Chemical Security
Assessment Tool (CFATS) must be completed to identify
your security tier. Each tier has chemical security
requirements.
 Codes

National Fire Protection Association (NFPA),

www.nfpa.org
NFPA 70: National Electrical Code (NEC)
NFPA 101: Life Safety Code

American Society of Mechanical Engineers

(ASME), www.asme.org
ASME Boiler and Pressure Vessel Code
 Standards
National Fire Protection Association (NFPA), www.nfpa.org
NFPA 45: Standard on Fire Protection for Laboratories Using
Chemicals
NFPA 68: Standard on Explosion Venting by Deflagration Venting
NFPA 69: Standard on Explosion Prevention Systems
NFPA 652: Standard on the Fundamentals of Dust Explosions

American Society for Testing and Materials (ASTM), www.astm.org

ASTM D93: Standard Test Methods for Flash Point by Pensky-
Martens Closed Cup Tester
ASTM E681-09 Standard Test Method for Concentration Limits of
Flammability of Chemicals (Gases and Vapors)

American Petroleum Institute (API), www.api.org

API Recommended Practice 521: Selection and Installation of
Pressure Relieving Devices in Refineries
 Protecting Hazards: Safeguards

Hazard Incident Consequences

+ Enabling
Conditions + Conditional Modifiers

Enabling Conditions: Do not independently cause the incident,

but must be present or active for it to proceed. Examples: T or P
at certain values, process in particular state of operation (i.e.
recycle mode), presence of raw material in process, etc.

Conditional Modifiers: Conditions that occur after initiation and

impact a step in the sequence either before or after the incident
has occurred. Examples: weather conditions (wind speed in
certain direction), presence of people, probability of ignition, etc.
 Preventive Safeguards
Preventive Safeguard: prevents an initiating event from
proceeding to a defined, undesirable incident. Also called a
protection layer. The preventive safeguard stops the incident
from proceeding.

• Basic process control system (BPCS)

• Alarm systems
• Operator response to an alarm or process conditions
• Pressure relief system with containment
• Maintenance
• Interlocks
• Emergency shutoff valves
• Emergency cooling systems
• Grounding and bonding to prevent static
accumulation
• Normal testing and inspection
 Mitigative Safeguards
Mitigative Safeguards: reduces the consequences after an
incident has occurred. May already have consequences as
a result of the incident.
• Active fire protection, including sprinklers, sprays
• Emergency fire water system
• Passive fire protection including insulation
• Flammable vapor detectors
• Emergency response, including on-site and off-site
• Plant and equipment layout and spacing
• Diking around storage areas / process.
• Emergency power
• Blast walls
• Water curtains to disperse vapors
• Blast resistant control rooms
• Explosion blow-out panels on process vessels
 Swiss Cheese Model

Safeguards
Preventive Mitigative

Consequences
Hazards

Incident

Defects in safeguards
 2007: AICHE/CCPS Risk Based Process Safety
(RBPS)
Twenty total elements under four major foundation groups:
• Commit to Process Safety
1. Process safety culture
2. Compliance with standards
3. Process safety competency
4. Workforce involvement
5. Stakeholder outreach
• Understand Hazards and Risk
6. Process knowledge management
7. Hazard identification and risk analysis
• Manage Risk
8. Operating procedures
9. Safe work practices
10. Asset integrity and reliability
11. Contractor management
12. Training and performance assurance
13. Management of change
14. Operational readiness
15. Conduct of operations
16. Emergency management
 AICHE/CCPS Risk Based Process Safety - 2007

• Learn from Experience

17. Incident investigation
18. Measurement and metrics
19. Auditing
20. Management review and continuous improvement

Reference Material on RBPS (all free!).

Please download and read!

2-page summary:
http://www.aiche.org/sites/default/files/docs/summaries/short-sum
mary-of-risk-based-process-safety.pdf

38-page reference:
http://www.aiche.org/sites/default/files/docs/summaries/overview-o
f-risk-based-06-25-14.pdf
 Temple of Doom!
RISK
EXPERIENCE &
MANAGE RISK COMMIT TO PROCESS SAFETY
LEARN FROM HAZARDS
UNDERSTAND
M
a
n
a
g H
e
m a
e z
n A a P P C
t E M C r
d r S ro o
R M m C O s O o t W m P
e In o p a o s
e S I
d c a c
e r
e a c e n e n n a p e e k o p o
s r
g r a rt t f e n s e r s
s il c
iv
e u
id d a g a I
n e ra t s h fk a e
w r e e u t e c t W o o S n s
A e n n io m T t e it fii
c S l
d r a c s
u m t c tc n r o g o n a a e c
e e S
& I
n y o a e a r r g f
e r
fe
C d e v M f l n i
n M ir
ty k P it
o I ty w a
ti n e O R t a P n t
y E n it fe
o in t s a p o in n & ro n v
o C h t
n g & n e e f g a ra c & In g o S y
it M it
g a r a C g R c e fo a l
v m C
n a g a d h e e t d R g e ta u
u e e t in a m l ic u i
s rm e m p n
o rt
ti
o m io e n
ia e k m e e d lt
u
u ic n e n s g e b s
re a e n te a r
s s n s s e n s A ti
o n t n r e
I
m t t itil
y n n t c d
a y s
p ly
r
o s
v is
e
m
e
n
t
Management
Process Safety
 Element 1: Process Safety Culture

A positive environment where employees at all levels

are committed to process safety. This starts at the
highest levels of the organization and is shared by all.
Process safety leaders nurture this process.
Activities associated with this Element:
• Develop or deploy corporate process safety culture
programs.
• Identify process safety culture issues and influence
corporate changes.
• Involvement in maintaining a strong process safety
culture within team members.
• Involvement in formal assessments to identify gaps
and recommend improvements in process safety
culture.
 Element 2: Compliance with Standards

Applicable regulations, standards, codes, and other

requirements issued by national, state/provincial, and
local governments, consensus standards organizations,
and the corporation. Interpretation and implementation of
these requirements. Includes development activities for
corporate, consensus, and governmental standards.

Activities Associated with this Element:

• Interpret or apply standards for internal use.
• Participate in standards development.
• Develop a system to identify standards and uniformly
administer and maintain the information.
 Element 3: Process Safety Competency

Skills and resources that the company needs to have in

the right places to manage its process hazards.
Verification that the company collectively has these skills
and resources. Application of this information in
succession planning and management of organizational
change.

This does not mean individual competency, but rather

corporate competency!

Activities Associated with this Element:

• Develop a training program to increase worker’s level
of competency.
• Develop competency profiles for critical process
safety positions.
• Evaluate a unit to determine gaps in competency.
 Element 4: Workforce Involvement

Broad involvement of operating and maintenance

personnel in process safety activities, to make sure that
lessons learned by the people closest to the process are
considered and addressed.

Activities Associated with this Element:

• Develop, lead or participate in organizing workforce
involvement efforts at the corporate, business, plant or
unit level.
• As a supervisor, regularly lead discussions around
process safety concerns or issues with operating
personnel.
• As a worker, provide constructive feedback aimed at
improving process safety and track feedback to
resolution.
 Element 5: Stakeholder Outreach

A process for identifying, engaging and maintaining

good relationships with appropriate external stakeholder
groups. This would include the surrounding community,
suppliers of raw materials, customers, government
agencies and regulators, professional societies,
contractors, etc.

Activities Associated with this Element:

• Lead community action panel (CAP) meetings.
• Work with the local community to create area CAP
and facilitate meetings.
• Develop site or corporate practices or standards to
coordinate and manage major off-site accident risks
to include communications with stakeholders.
• Coordinate an emergency response simulation or
drill in the community.
 Element 6: Process Knowledge Management

The assembly and management of all information needed

to perform process safety activities. Verification of the
accuracy of this information. Confirmation that this
information is correct and up-to-date. This information
must be readily available to those who need it to safely
perform their jobs.

Activities Associated with this Element:

• Validate existing P&IDs with actual plant configuration.
• Develop safe operating limits and consequences of
deviations for a process unit.
• Update process safety knowledge following management
of change (MOC).
• Write internal standards for the company.
• Develop database for relief devices.
 Element 7: Hazard Identification and Risk Analysis

Identification of process safety hazards and their

potential consequences. Definition of the risk posed by
these hazard scenarios. Recommendations to reduce or
eliminate hazards, reduce potential consequences,
reduce frequency of occurrence. Analysis may be
qualitative or quantitative depending on the level of risk.

Activities Associated with this Element:

• Develop and/or implement corporate methods and
procedures for hazards analysis and risk assessment.
• Develop consequence assessment simulations.
• Lead or participate in process hazards analysis (PHA).
 Element 8: Operating Procedures

Written instructions for a manufacturing operation that

describes how the operation is to be carried out safely,
explaining the consequences of deviation from
procedures, describing key safeguards, and addressing
special situations and emergencies.

Activities Associated with this Element:

• Write or revise operating procedures to make them
clearer and more usable.
• Review and update operational procedures for a site.
• Identify safe operating limits for a process.
 Element 9: Safe Work Practices

Procedures to safely maintain and repair equipment

such as permits-to-work, line breaking, and hot work
permits. This applies to non-routine operations!

Activities Associated with this Element:

• Participate in confined space operations.
• Certify confined space attendants.
• Participate / develop and/or audit line breaking, lock-
out / tag out (LOTO), and other procedures.
• Develop a corporate work permit policy.
• Audit / improve safe work practices.
 Element 10: Asset Integrity and Reliability

Activities to ensure that important equipment remains

suitable for its intended purpose throughout its service.
Includes proper selection of materials of construction;
inspection, testing, and preventive maintenance; and
design for maintainability.

Activities Associated with this Element:

• Review and assess data from inspections and draw
conclusions and make recommendations.
• Develop or implement practices / procedures /
strategies to manage the integrity in a facility, site or
company.
• Look up corrosion rates to provide general guidance
for developing specifications.
 Element 11: Contractor Management

Practices to ensure that contract workers can perform

their jobs safely, and that contracted services do not
add to or increase facility operational risks

Activities Associated with this Element:

• Audit contractors for safety.
• Developed recommendations / actions to improve
contractor performance.
• Developed process safety requirements for hiring
new site contractors.
 Element 12: Training and Performance Assurance

Practical instruction in job and task requirements and

methods for operations and maintenance workers,
supervisors, engineers, leaders, and process safety
professionals. Verification that the trained skills are
being practiced proficiently.

Activities Associated with this Element:

• Develop process safety training programs.
• Oversight of corporate or site process safety training
program.
• Give or receive process safety training.
 Element 13: Management of Change (MOC)

Process of reviewing and authorizing proposed changes

to facility design, operations, organization, or activities
prior to implementing them, and that the process safety
information is updated accordingly.

Activities Associated with this Element:

• Develop corporate procedures for change
management.
• Participate in management of change reviews.
• Author MOC documentation.
• MOC coordinator.
 Element 14: Operational Readiness

Evaluation of the process before start-up or restart to

ensure the process can be safely started. Applies to
restart of facilities after being shut down or idled as well
as after process changes and maintenance. Also applies
to start-up of new facilities.

Activities Associated with this Element:

• Lead / participate in pre-startup safety reviews (PSSR).
• Develop commissioning and start-up plans.
• Identify critical process safety information (PSI)
required to operate safely.
• Start up a process that is ready to operate.
 Element 15: Conduct of Operations

Means by which management and operational tasks

required for process safety are carried out in a deliberate,
faithful, and structured manner. Managers insure workers
carry out the required tasks and prevent deviations from
expected performance.

Activities Associated with this Element:

• Implement practices intended to maintain the
operational discipline at a facility.
• As a front line worker, cooperate with peers to insure
that performed tasks are done exactly as prescribed
over a long period of time.
• Actively monitor and make corrective action plans
related to the performance of process safety operating
tasks.
 Element 16: Emergency Management

Plans for possible emergencies that define actions in an

emergency, resources to execute those actions, practice
drills, continuous improvement, training or informing
employees, contractors, neighbors, and local authorities,
and communications with stakeholders in the event an
incident does occur.

Activities Associated with this Element:

• Set up or participate in emergency response drills with
community responders.
• Work with corporate to perform emergency drills or
table-top drills.
• Participate in planning and addressing potential plant
emergencies.
 Element 17: Incident Investigation

Process of reporting, tracking, and investigating

incidents and near-misses to identify root causes, taking
corrective actions, evaluating incident trends, and
communicating lessons learned.

Activities Associated with this Element:

• Participate in an incident investigation.
• Manage incident investigation action items.
• Develop / implement corporate procedures for incident
investigation.
 Element 18: Measurement and Metrics

Leading and lagging indicators of process safety

performance, including incident and near-miss rates as
well as metrics that show how well key process safety
elements are being performed. This information is used
to drive improvement in process safety.

Activities Associated with this Element:

• Site lead for or participation in collecting and
reporting metrics.
• Prepare reports on process safety metrics.
• Develop and implement site or company metrics.
 Element 19: Auditing

Periodic critical review of process safety management

system performance by auditors not assigned to the site
to identify gaps in performance and identify improvement
opportunities, and track closure of these gaps to
completion.

Activities Associated with this Element:

• Participate in process safety audits, either as auditor
or audited.
• Develop process safety audit methods.
• Manage audit recommendations to insure they are
implemented.
 Element 20: Management Review and Continuous
Improvement

The practice of managers at all levels of setting process

safety expectations and goals with their staff and
reviewing performance and progress towards those
goals. May take place in a staff or “leadership team”
meeting or one-on-one. May be facilitated by process
safety lead but is owned by the line manager.
Activities Associated with this Element:
• Participate in management reviews.
• Evaluate results from management reviews and
proposed / reviewed recommendations for
improvement.
• Engage management to follow-up and close out
actions derived from management reviews.
 Inherently Safer Design

Safeguards are used to prevent initiating events

from propagating into an incident with
consequences. These safeguards add considerable
cost to the process and also require testing and
maintenance – and the safeguards can still fail.

If we could design a process with fewer hazards,

then the process would be simplified, and the
safeguards reduced. This is the essence of
inherently safety design – to eliminate hazards
rather than to provide complex safeguard
hierarchies around the hazards.
 Inherently Safer Design

An inherently safer plant uses the elimination of

hazards to prevent accidents, rather than depending
on control systems, interlocks, redundancy, special
management systems, complex operating
instructions or elaborate procedures. Inherently
safer plants are tolerant of errors and are often cost
effective. Inherently safer plants are simpler, easier
to operate, and more reliable.
Inherently safer designs permanently and
inseparably reduce or eliminate process hazards
that must be contained and controlled to avoid
accidents.
 Inherently Safer Design

“The essence of the inherently safer

approach to plant design is the
avoidance of hazards rather than
their control by added-on protective
equipment.”
T. A. Kletz, Plant Design for Safety: A User-Friendly Approach (NY:
Hemisphere, 1991)
Crowl’s Lion Farm
 Crowl’s Lion Farm
Hazard: Lions

Incident: Driver loses control of pick-up truck.

Scenario: Truck drives thru Lion cage fence.

Lions walk thru hole in fence.
Lions prowl around community.

Incident Outcome: Local community is

alarmed, people are attacked, several dogs
disappear.
 Crowl’s Lion Farm

Inherently Safer Design Approachvg, why not

use lambs instead? This way, the hazard is
eliminated, control is simplified, fences are
reduced in strength, and emergency response is
eliminated.
Inherently Safer Design Strategies

• MINIMIZE

• SUBSTITUTE

• MODERATE

• SIMPLIFY
Minimize

= Reduce hazardous
material/energy quantity
– Reduces energy
– Reduces potential accident severity
Substitute

= Replace with a less hazardous

material
– Reduces/eliminates available
chemical energy
– Reduces/eliminates potential
accident severity
Moderate
= Use under less hazardous
conditions
– Available energy may be the
same, but
– Passively reduces potential
loss event impacts
– For chemical processes, this
usually means lower
temperatures, pressures,
concentrations, etc.
 Simplify

= Reduce unnecessary complexity

– Reduces likelihood of an accident
 Hierarchy of Process
Risk Management Strategies

More robust towards top!

Inherent – already discussed.

Passive
Active
Procedural
 Passive

Passive – minimizes the hazard thru process and

equipment design features that reduce either the
frequency or consequence without the active
functioning of any device.
• Using equipment with a higher pressure rating
than the max. possible pressure.
• Blast walls around equipment to reduce blast
overpressures.
• Dikes around storage vessels to contain spills.
• Separation of equipment in plant layout to reduce
prepagation of impacts.
 Active

Requires an active response. These systems are

commonly referred to as engineering controls,
although human intervention is also included.
• Alarms, with operator response.
• Process control systems, including basic process
control system (BPCS), safety instrumented
systems (SIS) and safety instrumented functions
(SIF).
• Sprinklers and water deluge systems.
• Pressure relief devices.
• Inerting and purging systems.
• Water curtains to knock-down gas releases.
• Flares
 Procedural

Based on an established or official way of doing

something. These are commonly referred to as
administrative controls.
• Policies
• Operating procedures
• Safe work practices, such as lock-out tag out
(LOTO), vessel entry, hot work, etc.
• Emergency response procedures
• Training
Bhopal, India Incident
December 3, 1984

Image by Daniel Willey from a photograph by Wil Lipkowski

 Bhopal, India Incident - Background

• Plant was jointly owned by Union Carbide

(USA) and Union Carbide India Limited (UCIL).
• Pesticide production plant using methyl
isocyanate as an intermediate chemical.
• Plant was under extreme financial pressure and
could not sell all of its product line.
• Plant was originally in the open country, but a
shanty town grew around the plant against
zoning laws. Local officials looked the other
way.
• The plant had two large MIC storage tanks on
site containing over 16,000 gallons of material.
Bhopal, India Incident - MIC

Boiling point: 39.1°C

Vapor pressure at 20°C: 348 mm HG
Molecular weight: 57
Vapor density (Rel to Air) 2
Flash point temperature: -7oC = 19oF
Reacts exothermically with water!
An extreme toxin: TLV-TWA or 0.02 ppm
 Bhopal, India Incident - Safeguards

• Nitrogen padding for the storage tanks (15 psig) – this

reduces flammability hazard.
• Refrigeration for storage tanks to keep MIC from heating
to boiling point.
• Proper relief valve sizing to prevent high pressure in the
storage tanks.
• A NaOH scrubber system to handle small releases.
• A flare tower to burn releases. Flare

Status of Safeguards at time of incident:

• Refrigeration: off to save money
• Scrubber: out of service to save money.
• Flare: not working due to corroded pipeline.
 Bhopal, India Incident – Steps

1. Somehow the MIC storage tank became contaminated

with water. No definitive evidence has been provided for
how this occurred.
2. The MIC reacted with the water, heating the MIC to its
boiling point.
3. The pressure inside the storage tank increased until the
relief device opened, discharging MIC vapor into the
atmosphere.
4. The atmospheric conditions were such that the wind
speed was low, causing little dispersion of the vapors.
5. It was nighttime so most folks in the shanty town were
asleep.
6. No emergency response plan was in place, either at the
plant or the local community. Medical response was
totally inadequate.
Bhopal, India Incident – Consequences
• An estimated 2,500 people were killed. There is great uncertainty
in this number, with some estimates as high as 5,000 or more.
• As many as 20,000 suffered severe exposure effects – some still
suffer today.
• Prior to the accident Union Carbides annual sales were $9 billion,
with 116,000 employees and 500 sites. It was a “must interview”
company and a very desirable employer.
• It was the beginning of the end for Union Carbide. After the
accident the company took a big stock hit and was the target of a
hostile stock takeover.
• Union Carbide paid a settlement to India
of $470 million.
• Union Carbide continued its downward
spiral until it was purchased in 1999 by
Dow Chemical.
• The chemical industry and chemical
engineering were impacted negatively, forever. Many new
regulations originated from this incident.
 Bhopal, India Incident – Current Site

• Union Carbide decided to remove the remaining MIC by

operating the plant to produce product.
• The site was never properly cleaned and remediated, and is
currently overgrown with weeds.
End of Chapter 1!

Questions?