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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 Information Process Safety Information  Process Material Toxicity Information Process Material Toxicity Information  Process Hazard Analysis (PHA’s) Process Hazard Analysis (PHA’s)  Mechanical Integrity Certificates Mechanical Integrity Certificates  Management of Change Management of Change  Inspection/Testing/Maintenance Inspection/Testing/Maintenance  Operating Procedures Operating Procedures  Safe Work Procedures Safe Work Procedures  Training Programs Training Programs  Training for Contractors Training for Contractors Now… Now…
Contractor Management 1910.119(h) 1910.119(h)
PSM Contractors  The employer, when selecting a The employer, when selecting a contractor, shall obtain and contractor, shall obtain and evaluate information regarding evaluate information regarding the contract employer's safety the contract employer's safety performance and programs. performance and programs.  The employer shall inform The employer shall inform contract employers of the contract employers of the known potential fire, explosion, known potential fire, explosion, or toxic release hazards related or toxic release hazards related to the contractor's work and the to the contractor's work and the process process
Contractor Pre-Qualification & Authorization  The Standard Requires You to: The Standard Requires You to:  Explain contractor qualification requirements Explain contractor qualification requirements  List what is required for contractor pre-bid List what is required for contractor pre-bid awareness - pre-qualification awareness - pre-qualification  List what is required for contractor post-bid List what is required for contractor post-bid awareness - training & orientation awareness - training & orientation  Specify contractor responsibilities Specify contractor responsibilities  Describe contractor 300 Log Requirements Describe contractor 300 Log Requirements  Evaluate Contractor Performance Evaluate Contractor Performance  List documentation requirements for contractors to List documentation requirements for contractors to complete complete  Explain the use of a work authorization system Explain the use of a work authorization system
Typical Pre-Qualification Elements: Typical Pre-Qualification Elements:  Years Experience in Work Process Years Experience in Work Process  Experience Modification Rate (EMR) Experience Modification Rate (EMR)  OSHA Total Recordable Incident Rate and OSHA Total Recordable Incident Rate and Lost Work day Case Rate Information Lost Work day Case Rate Information  Safety Programs Safety Programs  Training Documentation Training Documentation Contractor Pre-Qualification & Authorization
Emergency Preparedness 1910.119(f)(1)(I)(D) 1910.119(f)(1)(I)(D)
Emergency Preparedness  Our Written Plan Must: Our Written Plan Must:  Define an emergency action plan Define an emergency action plan  Define an emergency response plan Define an emergency response plan  Describe a Minimum emergency response plan Describe a Minimum emergency response plan  Describe procedures for handling small releases Describe procedures for handling small releases  List the three levels of emergency response List the three levels of emergency response  List procedures for emergency evacuation List procedures for emergency evacuation  List requirements of alarm systems List requirements of alarm systems  List training requirements List training requirements
Emergency Preparedness  The Standard Requires You to: The Standard Requires You to:  Develop a Early Warning Method for Releases Develop a Early Warning Method for Releases (Sensors/Alarms) (Sensors/Alarms)  Train on the Meaning of the Alarms (May be Multiple Train on the Meaning of the Alarms (May be Multiple Alarms) Alarms)  Develop Emergency Evacuation Written Plans, Develop Emergency Evacuation Written Plans, Evacuation Maps & Assembly Points based on Evacuation Maps & Assembly Points based on Release Characteristics Release Characteristics  Determine Emergency PPE Requirements Determine Emergency PPE Requirements  Train Employees & Contractors in the Emergency Train Employees & Contractors in the Emergency Evacuation Plans Evacuation Plans  Drill The Emergency Evacuation Plan At Last Once Drill The Emergency Evacuation Plan At Last Once Per Year Per Year
Emergency Preparedness  Warning Systems Warning Systems must: must:  Clearly Notify Clearly Notify Employees of the Employees of the Hazardous Release Hazardous Release  Employees & Employees & Contractors must be Contractors must be Trained in the Trained in the Meaning of the Meaning of the Alarm(s) Alarm(s)
Emergency Preparedness Evacuation Maps
Emergency Preparedness Assembly Points Alternate Assembly Point Alternate Assembly Points Depending on Prevailing Weather Affecting Release
Emergency Preparedness Emergency PPE  Hazardous Hazardous Chemicals May Chemicals May Require Emergency Require Emergency PPE to be Worn PPE to be Worn  FRP FRP  Escape Respirators Escape Respirators  Eye Protection i.e.. Eye Protection i.e.. Refinery Goggles Refinery Goggles
Emergency Preparedness Drills  At Least Annual At Least Annual Emergency Emergency Preparedness Drills Preparedness Drills  This is not Just an This is not Just an Emergency Emergency Evacuation… Evacuation…  but Could Include but Could Include HAZWOPR HAZWOPR Response Response  Must Document Must Document Results Results
Incident Investigation 1910.119(m) 1910.119(m)
Incident Investigation Program Must Include the Following  Describe the purpose of incident investigation Describe the purpose of incident investigation  List the circumstances or occurrences, which require List the circumstances or occurrences, which require formal incident investigation formal incident investigation  List the major investigation procedures that should be List the major investigation procedures that should be followed followed  Explain the list the responsibilities of the incident Explain the list the responsibilities of the incident investigation team investigation team  Explain the contents of an "Incident Summary" form Explain the contents of an "Incident Summary" form  Explain the contents of an "Incident Description" form Explain the contents of an "Incident Description" form  Explain the contents of an "Approvals, Follow-up and Explain the contents of an "Approvals, Follow-up and Review" form Review" form  Explain the contents of a "Close-out" form Explain the contents of a "Close-out" form  Explain Corrective Actions Taken Explain Corrective Actions Taken
Incidents Can Be Minor or Major - Both Require Investigation
Incident Investigation Documentation Must Include Date of incident Date of incident Date investigation began Date investigation began Description of the incident Description of the incident Factors contributing to the incident Factors contributing to the incident Recommendations resulting from Recommendations resulting from the investigation the investigation
Incident Investigation  Will Include Written Will Include Written Documentation of all Documentation of all Required Elements Required Elements
Incident Investigation Might Even Include a Flow Chart
Compliance Audits 1910.119(o) 1910.119(o)
Compliance Audits  1910.119 states, "Employers shall certify that 1910.119 states, "Employers shall certify that they have evaluated compliance with the they have evaluated compliance with the provisions of this section at least every three provisions of this section at least every three years to verify that the procedures and years to verify that the procedures and practices developed under the standard are practices developed under the standard are adequate and are being followed." adequate and are being followed."
Compliance Audits  A List of factors that may increase the A List of factors that may increase the frequency of compliance audits frequency of compliance audits  Results of Any OSHA Compliance Audits Results of Any OSHA Compliance Audits Performed & Citations/Action Items Performed & Citations/Action Items Developed Developed  An Explanation of audit certification An Explanation of audit certification  List Compliance Audit documentation List Compliance Audit documentation
Compliance Audits  Employers shall certify that they have evaluated Employers shall certify that they have evaluated compliance with the provisions of this section at least compliance with the provisions of this section at least every three years to verify that the procedures and every three years to verify that the procedures and practices developed under the standard are adequate practices developed under the standard are adequate and are being followed and are being followed  The compliance audit shall be conducted by at least The compliance audit shall be conducted by at least one person knowledgeable in the process one person knowledgeable in the process  A report of the findings of the audit shall be A report of the findings of the audit shall be developed developed  Compliance Audits Must be Performed Every 3 Years Compliance Audits Must be Performed Every 3 Years
 The Compliance Audit Process Typically The Compliance Audit Process Typically Includes the Following: Includes the Following:  Definition of the guidelines for an audit team Definition of the guidelines for an audit team  A List the PSM elements that must be audited A List the PSM elements that must be audited  A List of the minimum contents of a final report of an A List of the minimum contents of a final report of an audit audit  An An Explanation and list the Compliant Audit reports Explanation and list the Compliant Audit reports that must be retained by the facility that must be retained by the facility Compliance Audits
Compliance Audits OSHA PSM Citations OSHA PSM Citations # # Initial Penalty Initial Penalty Final Penalty Final Penalty 1393 1393$25,058,853 $25,058,853 $18,884,463 $18,884,463
Compliance Audits  Typical Types of OSHA Serious Citations Typical Types of OSHA Serious Citations  failure to maintain and follow normal operating failure to maintain and follow normal operating procedures procedures  failure to provide refresher training to process failure to provide refresher training to process operators operators  failure to correct deficiencies in process equipment in failure to correct deficiencies in process equipment in a safe manner a safe manner  failure to provide necessary training to emergency failure to provide necessary training to emergency responders and fire brigade members responders and fire brigade members  Failure to perform audits as required every 3 years Failure to perform audits as required every 3 years
Compliance Audits There are Companies that have There are Companies that have Covered Process, but have not Covered Process, but have not implemented any PSM Program. implemented any PSM Program. The Regulatory Exposure is to: The Regulatory Exposure is to:  Willful Citations Willful Citations  Criminal Willful Citations Criminal Willful Citations  Serious Citations Serious Citations  Major Citation Penalties Major Citation Penalties
PSM Audit Example Checklist Items (Partial)  Management Commitment to the PSM Program Management Commitment to the PSM Program  Is there evidence that an effective process safety management Is there evidence that an effective process safety management program has been set up and that explicit expectations, objectives program has been set up and that explicit expectations, objectives and goals have been set with clear-cut, desired outputs? and goals have been set with clear-cut, desired outputs?  Have resources been provided in the form of personnel assigned Have resources been provided in the form of personnel assigned to provide implementation and continuation of each element? to provide implementation and continuation of each element?  Have clear lines of responsibility been established and roles and Have clear lines of responsibility been established and roles and responsibilities assigned? responsibilities assigned?  Is management Is management commitment to using all available resources for commitment to using all available resources for enhancing process safety knowledge at all levels of the enhancing process safety knowledge at all levels of the organization clearly demonstrated by actions? organization clearly demonstrated by actions?  Does management encourage active participation in professional Does management encourage active participation in professional and trade associations for key PSM personnel to ensure the PSM and trade associations for key PSM personnel to ensure the PSM system keeps pace withTest Practices? system keeps pace withTest Practices?
PSM Audit Example Checklist Items (Partial)  Process Hazard Analysis Process Hazard Analysis  Does the PSM program establish a process hazard analysis Does the PSM program establish a process hazard analysis procedure in accordance with the PSM rule? procedure in accordance with the PSM rule?  Have personnel, who will take part in PHA Have personnel, who will take part in PHA 痴 痴 , , been provided with been provided with training in the PHA technique that will be used for their study? training in the PHA technique that will be used for their study?  Does the PHA procedure establish that the hazard identification team Does the PHA procedure establish that the hazard identification team be multi-disciplined in nature, capable of covering such issues as be multi-disciplined in nature, capable of covering such issues as maintenance, operations, design, inspection & testing, safety, health maintenance, operations, design, inspection & testing, safety, health and environment, etc? and environment, etc?  Does the PHA procedure require that the PHA team leader be Does the PHA procedure require that the PHA team leader be specially trained in the technique that will be used? specially trained in the technique that will be used?  Does documentation of the hazard identification process include all Does documentation of the hazard identification process include all issues, not only those resulting in findings or recommendations? issues, not only those resulting in findings or recommendations?  Have PHA Have PHA been conducted on all PSM-covered processes and if not, been conducted on all PSM-covered processes and if not, is there an established schedule for completing all PHA is there an established schedule for completing all PHA’s? ’s?
Compliance Audits Audit Findings must be Documented Audit Findings must be Documented Actions must be Taken on All Actions must be Taken on All Exceptions Exceptions All Actions Affecting P&ID’s, PHA’s, All Actions Affecting P&ID’s, PHA’s, Mechanical Integrity Certificates, Mechanical Integrity Certificates, Inspection/Testing/Maintenance, Inspection/Testing/Maintenance, Operating Procedures & Training Operating Procedures & Training Procedures will Require Revision of Procedures will Require Revision of All of the Above All of the Above
Compliance Audits Remember, Remember, The Audit Process is Determine if there are The Audit Process is Determine if there are any weaknesses in the system or PSM any weaknesses in the system or PSM Program and to provide a report an Program and to provide a report an method to take action. method to take action. These actions can prevent catastrophic These actions can prevent catastrophic release, injury and death. release, injury and death.
Trade Secrets 1910.119(p) 1910.119(p)
Trade Secrets All Information Regarding the Process All Information Regarding the Process Must be Made Available to Persons Must be Made Available to Persons Involved in the PSM Program Including Involved in the PSM Program Including Trade Secrets Trade Secrets Confidentiality Agreements are Allowed Confidentiality Agreements are Allowed
Summary of PSM Elements  Process Safety Information Process Safety Information  Equipment ii the Process Equipment ii the Process  Process Hazard Analysis Process Hazard Analysis  Operating Procedures Operating Procedures  Employee Training Employee Training  Training Contractors Training Contractors  Pre-Startup Safety Review Pre-Startup Safety Review  Mechanical Integrity of Equipment Mechanical Integrity of Equipment  Management of Change Management of Change  Incident Investigation Incident Investigation  Emergency Preparedness Emergency Preparedness  Compliance Audits Compliance Audits  Trade Secrets Trade Secrets
EPA Risk Management Plans (RMP) Basics CAA 112(r) CAA 112(r)
One More Thing to Discuss… EPA Risk Management Plans (RMP) Many Times Companies Who Must Many Times Companies Who Must Comply with PSM, must also Comply Comply with PSM, must also Comply with the Requirements of EPA Risk with the Requirements of EPA Risk Management Plans (RMP) Management Plans (RMP) The RMP Standard was to be a Mirror The RMP Standard was to be a Mirror of the PSM Standard…Didn’t happen! of the PSM Standard…Didn’t happen! Remember…PSM Protects the Remember…PSM Protects the Workforce, RMP Protects the Workforce, RMP Protects the Community Community
EPA RMP Basic Requirements Basic Requirements  Executive summary Executive summary  Registration Registration  Off-site consequence analysis Off-site consequence analysis  Five-year accident history Five-year accident history  Emergency response plan Emergency response plan  Prevention program summary information Prevention program summary information  Certification Certification Sound Much Easier than PSM…Right? Sound Much Easier than PSM…Right?
Release Plume All Public Facilities in this Release Plume Must be Identified & Surveyed
EPA RMP Emergency Response Plan & Emergency Response Plan & Prevention Plans Must Be Developed to Prevention Plans Must Be Developed to Prevent Accidental Release of the Prevent Accidental Release of the Covered Chemical Covered Chemical
EPA RMP 1998 Changes Compliance Elements Follow-up / completion of PHA Follow-up / completion of PHA recommendation recommendation Re-validation of your PHA every 5 Re-validation of your PHA every 5 years years Compliance audits (required every Compliance audits (required every 3 years) 3 years) Follow-up / completion of Follow-up / completion of compliance audit compliance audit recommendations recommendations
EPA RMP 1998 Changes Compliance Elements Annual review and certification of Annual review and certification of operating procedures operating procedures Employee training Employee training Updates related to system Updates related to system modifications, inventory changes, modifications, inventory changes, operational changes operational changes Off-site consequence analysis Off-site consequence analysis
Process Safety Management of Highly Hazardous & Explosive Chemicals & EPA Risk Management Plans Summary Summary
Goals of the One Day Course  Understand Why Process Safety Management (PSM) Understand Why Process Safety Management (PSM) Was Promulgated Was Promulgated  Understand That Even with PSM, Catastrophes are Still Understand That Even with PSM, Catastrophes are Still Occurring Occurring  Understand Who is Covered & Exemptions Understand Who is Covered & Exemptions  Understand the Team Process to Developing a PSM Understand the Team Process to Developing a PSM Program Program  Understand Each of the Elements of a Properly Designed Understand Each of the Elements of a Properly Designed & Implemented Program and How to Begin the Process & Implemented Program and How to Begin the Process  Understand the Basics of How PSM & RMP Work Understand the Basics of How PSM & RMP Work Together to Protect the Workforce & Surrounding Together to Protect the Workforce & Surrounding Community Community
Resources  GTRI - GTRI - http://www.oshainfo.gatech.edu/index.html http://www.oshainfo.gatech.edu/index.html  OSHA PSM Compliance Guidelines - OSHA PSM Compliance Guidelines - http://www.osha.gov/Publications/osha3133.html http://www.osha.gov/Publications/osha3133.html  OSHA PSM for Construction 1926.64 - OSHA PSM for Construction 1926.64 - http://www.osha.gov/doc/outreachtraining/htmlfile http://www.osha.gov/doc/outreachtraining/htmlfile s/psm.html s/psm.html
PSM One Day Review
PSM One Day Review 1. 1. The Process Safety Management The Process Safety Management Standard was drafted as a requirement Standard was drafted as a requirement of the Clean Air Act. of the Clean Air Act. True or False True or False 2. 2. The PSM program must include a list The PSM program must include a list of highly hazardous chemicals. of highly hazardous chemicals. True or False True or False 3. 3. The initial start-up of a process is not The initial start-up of a process is not included as an operating phase under included as an operating phase under the PSM Standard. the PSM Standard. True or False True or False 4. 4. List three items that the process hazard analysis must List three items that the process hazard analysis must address. address. ___________ ___________, , __________ __________ and _ and __________ _________. . 5. 5. PSM does not apply to contractors, PSM does not apply to contractors, regardless of the work they are doing. regardless of the work they are doing. True or False True or False
PSM One Day Review (cont.) 6. 6. The PSM Standard applies to companies that either process The PSM Standard applies to companies that either process highly _____________ materials or use _____________ liquids highly _____________ materials or use _____________ liquids and gases in excess of 10,000 pounds. and gases in excess of 10,000 pounds. 7. 7. Process safety information includes: Process safety information includes: ______________, _____________ and _____________. ______________, _____________ and _____________. 8. 8. Fault tree analysis is one form of an Fault tree analysis is one form of an approved method of performing a process approved method of performing a process hazard analysis. hazard analysis. True or False True or False 9. 9. A technical basis is not required to change A technical basis is not required to change a process covered by the PSM Standard. a process covered by the PSM Standard. True or False True or False 10. 10. Two types of training required by the PSM Two types of training required by the PSM standard are ________________ and_________________. standard are ________________ and_________________.

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5_psm_emergency_preparedness and training .ppt

  • 1. Process Safety Management of Highly Hazardous & Explosive Chemicals Contractor Pre-Qualification, Emergency Preparedness, Incident Investigation, Audits & EPA Risk Management Plans (RMP)
  • 2. Now That We’ve Developed  Process Safety Information Process Safety Information  Process Material Toxicity Information Process Material Toxicity Information  Process Hazard Analysis (PHA’s) Process Hazard Analysis (PHA’s)  Mechanical Integrity Certificates Mechanical Integrity Certificates  Management of Change Management of Change  Inspection/Testing/Maintenance Inspection/Testing/Maintenance  Operating Procedures Operating Procedures  Safe Work Procedures Safe Work Procedures  Training Programs Training Programs  Training for Contractors Training for Contractors Now… Now…
  • 4. PSM Contractors  The employer, when selecting a The employer, when selecting a contractor, shall obtain and contractor, shall obtain and evaluate information regarding evaluate information regarding the contract employer's safety the contract employer's safety performance and programs. performance and programs.  The employer shall inform The employer shall inform contract employers of the contract employers of the known potential fire, explosion, known potential fire, explosion, or toxic release hazards related or toxic release hazards related to the contractor's work and the to the contractor's work and the process process
  • 5. Contractor Pre-Qualification & Authorization  The Standard Requires You to: The Standard Requires You to:  Explain contractor qualification requirements Explain contractor qualification requirements  List what is required for contractor pre-bid List what is required for contractor pre-bid awareness - pre-qualification awareness - pre-qualification  List what is required for contractor post-bid List what is required for contractor post-bid awareness - training & orientation awareness - training & orientation  Specify contractor responsibilities Specify contractor responsibilities  Describe contractor 300 Log Requirements Describe contractor 300 Log Requirements  Evaluate Contractor Performance Evaluate Contractor Performance  List documentation requirements for contractors to List documentation requirements for contractors to complete complete  Explain the use of a work authorization system Explain the use of a work authorization system
  • 6. Typical Pre-Qualification Elements: Typical Pre-Qualification Elements:  Years Experience in Work Process Years Experience in Work Process  Experience Modification Rate (EMR) Experience Modification Rate (EMR)  OSHA Total Recordable Incident Rate and OSHA Total Recordable Incident Rate and Lost Work day Case Rate Information Lost Work day Case Rate Information  Safety Programs Safety Programs  Training Documentation Training Documentation Contractor Pre-Qualification & Authorization
  • 8. Emergency Preparedness  Our Written Plan Must: Our Written Plan Must:  Define an emergency action plan Define an emergency action plan  Define an emergency response plan Define an emergency response plan  Describe a Minimum emergency response plan Describe a Minimum emergency response plan  Describe procedures for handling small releases Describe procedures for handling small releases  List the three levels of emergency response List the three levels of emergency response  List procedures for emergency evacuation List procedures for emergency evacuation  List requirements of alarm systems List requirements of alarm systems  List training requirements List training requirements
  • 9. Emergency Preparedness  The Standard Requires You to: The Standard Requires You to:  Develop a Early Warning Method for Releases Develop a Early Warning Method for Releases (Sensors/Alarms) (Sensors/Alarms)  Train on the Meaning of the Alarms (May be Multiple Train on the Meaning of the Alarms (May be Multiple Alarms) Alarms)  Develop Emergency Evacuation Written Plans, Develop Emergency Evacuation Written Plans, Evacuation Maps & Assembly Points based on Evacuation Maps & Assembly Points based on Release Characteristics Release Characteristics  Determine Emergency PPE Requirements Determine Emergency PPE Requirements  Train Employees & Contractors in the Emergency Train Employees & Contractors in the Emergency Evacuation Plans Evacuation Plans  Drill The Emergency Evacuation Plan At Last Once Drill The Emergency Evacuation Plan At Last Once Per Year Per Year
  • 10. Emergency Preparedness  Warning Systems Warning Systems must: must:  Clearly Notify Clearly Notify Employees of the Employees of the Hazardous Release Hazardous Release  Employees & Employees & Contractors must be Contractors must be Trained in the Trained in the Meaning of the Meaning of the Alarm(s) Alarm(s)
  • 12. Emergency Preparedness Assembly Points Alternate Assembly Point Alternate Assembly Points Depending on Prevailing Weather Affecting Release
  • 13. Emergency Preparedness Emergency PPE  Hazardous Hazardous Chemicals May Chemicals May Require Emergency Require Emergency PPE to be Worn PPE to be Worn  FRP FRP  Escape Respirators Escape Respirators  Eye Protection i.e.. Eye Protection i.e.. Refinery Goggles Refinery Goggles
  • 14. Emergency Preparedness Drills  At Least Annual At Least Annual Emergency Emergency Preparedness Drills Preparedness Drills  This is not Just an This is not Just an Emergency Emergency Evacuation… Evacuation…  but Could Include but Could Include HAZWOPR HAZWOPR Response Response  Must Document Must Document Results Results
  • 16. Incident Investigation Program Must Include the Following  Describe the purpose of incident investigation Describe the purpose of incident investigation  List the circumstances or occurrences, which require List the circumstances or occurrences, which require formal incident investigation formal incident investigation  List the major investigation procedures that should be List the major investigation procedures that should be followed followed  Explain the list the responsibilities of the incident Explain the list the responsibilities of the incident investigation team investigation team  Explain the contents of an "Incident Summary" form Explain the contents of an "Incident Summary" form  Explain the contents of an "Incident Description" form Explain the contents of an "Incident Description" form  Explain the contents of an "Approvals, Follow-up and Explain the contents of an "Approvals, Follow-up and Review" form Review" form  Explain the contents of a "Close-out" form Explain the contents of a "Close-out" form  Explain Corrective Actions Taken Explain Corrective Actions Taken
  • 17. Incidents Can Be Minor or Major - Both Require Investigation
  • 18. Incident Investigation Documentation Must Include Date of incident Date of incident Date investigation began Date investigation began Description of the incident Description of the incident Factors contributing to the incident Factors contributing to the incident Recommendations resulting from Recommendations resulting from the investigation the investigation
  • 19. Incident Investigation  Will Include Written Will Include Written Documentation of all Documentation of all Required Elements Required Elements
  • 20. Incident Investigation Might Even Include a Flow Chart
  • 22. Compliance Audits  1910.119 states, "Employers shall certify that 1910.119 states, "Employers shall certify that they have evaluated compliance with the they have evaluated compliance with the provisions of this section at least every three provisions of this section at least every three years to verify that the procedures and years to verify that the procedures and practices developed under the standard are practices developed under the standard are adequate and are being followed." adequate and are being followed."
  • 23. Compliance Audits  A List of factors that may increase the A List of factors that may increase the frequency of compliance audits frequency of compliance audits  Results of Any OSHA Compliance Audits Results of Any OSHA Compliance Audits Performed & Citations/Action Items Performed & Citations/Action Items Developed Developed  An Explanation of audit certification An Explanation of audit certification  List Compliance Audit documentation List Compliance Audit documentation
  • 24. Compliance Audits  Employers shall certify that they have evaluated Employers shall certify that they have evaluated compliance with the provisions of this section at least compliance with the provisions of this section at least every three years to verify that the procedures and every three years to verify that the procedures and practices developed under the standard are adequate practices developed under the standard are adequate and are being followed and are being followed  The compliance audit shall be conducted by at least The compliance audit shall be conducted by at least one person knowledgeable in the process one person knowledgeable in the process  A report of the findings of the audit shall be A report of the findings of the audit shall be developed developed  Compliance Audits Must be Performed Every 3 Years Compliance Audits Must be Performed Every 3 Years
  • 25.  The Compliance Audit Process Typically The Compliance Audit Process Typically Includes the Following: Includes the Following:  Definition of the guidelines for an audit team Definition of the guidelines for an audit team  A List the PSM elements that must be audited A List the PSM elements that must be audited  A List of the minimum contents of a final report of an A List of the minimum contents of a final report of an audit audit  An An Explanation and list the Compliant Audit reports Explanation and list the Compliant Audit reports that must be retained by the facility that must be retained by the facility Compliance Audits
  • 26. Compliance Audits OSHA PSM Citations OSHA PSM Citations # # Initial Penalty Initial Penalty Final Penalty Final Penalty 1393 1393$25,058,853 $25,058,853 $18,884,463 $18,884,463
  • 27. Compliance Audits  Typical Types of OSHA Serious Citations Typical Types of OSHA Serious Citations  failure to maintain and follow normal operating failure to maintain and follow normal operating procedures procedures  failure to provide refresher training to process failure to provide refresher training to process operators operators  failure to correct deficiencies in process equipment in failure to correct deficiencies in process equipment in a safe manner a safe manner  failure to provide necessary training to emergency failure to provide necessary training to emergency responders and fire brigade members responders and fire brigade members  Failure to perform audits as required every 3 years Failure to perform audits as required every 3 years
  • 28. Compliance Audits There are Companies that have There are Companies that have Covered Process, but have not Covered Process, but have not implemented any PSM Program. implemented any PSM Program. The Regulatory Exposure is to: The Regulatory Exposure is to:  Willful Citations Willful Citations  Criminal Willful Citations Criminal Willful Citations  Serious Citations Serious Citations  Major Citation Penalties Major Citation Penalties
  • 29. PSM Audit Example Checklist Items (Partial)  Management Commitment to the PSM Program Management Commitment to the PSM Program  Is there evidence that an effective process safety management Is there evidence that an effective process safety management program has been set up and that explicit expectations, objectives program has been set up and that explicit expectations, objectives and goals have been set with clear-cut, desired outputs? and goals have been set with clear-cut, desired outputs?  Have resources been provided in the form of personnel assigned Have resources been provided in the form of personnel assigned to provide implementation and continuation of each element? to provide implementation and continuation of each element?  Have clear lines of responsibility been established and roles and Have clear lines of responsibility been established and roles and responsibilities assigned? responsibilities assigned?  Is management Is management commitment to using all available resources for commitment to using all available resources for enhancing process safety knowledge at all levels of the enhancing process safety knowledge at all levels of the organization clearly demonstrated by actions? organization clearly demonstrated by actions?  Does management encourage active participation in professional Does management encourage active participation in professional and trade associations for key PSM personnel to ensure the PSM and trade associations for key PSM personnel to ensure the PSM system keeps pace withTest Practices? system keeps pace withTest Practices?
  • 30. PSM Audit Example Checklist Items (Partial)  Process Hazard Analysis Process Hazard Analysis  Does the PSM program establish a process hazard analysis Does the PSM program establish a process hazard analysis procedure in accordance with the PSM rule? procedure in accordance with the PSM rule?  Have personnel, who will take part in PHA Have personnel, who will take part in PHA 痴 痴 , , been provided with been provided with training in the PHA technique that will be used for their study? training in the PHA technique that will be used for their study?  Does the PHA procedure establish that the hazard identification team Does the PHA procedure establish that the hazard identification team be multi-disciplined in nature, capable of covering such issues as be multi-disciplined in nature, capable of covering such issues as maintenance, operations, design, inspection & testing, safety, health maintenance, operations, design, inspection & testing, safety, health and environment, etc? and environment, etc?  Does the PHA procedure require that the PHA team leader be Does the PHA procedure require that the PHA team leader be specially trained in the technique that will be used? specially trained in the technique that will be used?  Does documentation of the hazard identification process include all Does documentation of the hazard identification process include all issues, not only those resulting in findings or recommendations? issues, not only those resulting in findings or recommendations?  Have PHA Have PHA been conducted on all PSM-covered processes and if not, been conducted on all PSM-covered processes and if not, is there an established schedule for completing all PHA is there an established schedule for completing all PHA’s? ’s?
  • 31. Compliance Audits Audit Findings must be Documented Audit Findings must be Documented Actions must be Taken on All Actions must be Taken on All Exceptions Exceptions All Actions Affecting P&ID’s, PHA’s, All Actions Affecting P&ID’s, PHA’s, Mechanical Integrity Certificates, Mechanical Integrity Certificates, Inspection/Testing/Maintenance, Inspection/Testing/Maintenance, Operating Procedures & Training Operating Procedures & Training Procedures will Require Revision of Procedures will Require Revision of All of the Above All of the Above
  • 32. Compliance Audits Remember, Remember, The Audit Process is Determine if there are The Audit Process is Determine if there are any weaknesses in the system or PSM any weaknesses in the system or PSM Program and to provide a report an Program and to provide a report an method to take action. method to take action. These actions can prevent catastrophic These actions can prevent catastrophic release, injury and death. release, injury and death.
  • 34. Trade Secrets All Information Regarding the Process All Information Regarding the Process Must be Made Available to Persons Must be Made Available to Persons Involved in the PSM Program Including Involved in the PSM Program Including Trade Secrets Trade Secrets Confidentiality Agreements are Allowed Confidentiality Agreements are Allowed
  • 35. Summary of PSM Elements  Process Safety Information Process Safety Information  Equipment ii the Process Equipment ii the Process  Process Hazard Analysis Process Hazard Analysis  Operating Procedures Operating Procedures  Employee Training Employee Training  Training Contractors Training Contractors  Pre-Startup Safety Review Pre-Startup Safety Review  Mechanical Integrity of Equipment Mechanical Integrity of Equipment  Management of Change Management of Change  Incident Investigation Incident Investigation  Emergency Preparedness Emergency Preparedness  Compliance Audits Compliance Audits  Trade Secrets Trade Secrets
  • 36. EPA Risk Management Plans (RMP) Basics CAA 112(r) CAA 112(r)
  • 37. One More Thing to Discuss… EPA Risk Management Plans (RMP) Many Times Companies Who Must Many Times Companies Who Must Comply with PSM, must also Comply Comply with PSM, must also Comply with the Requirements of EPA Risk with the Requirements of EPA Risk Management Plans (RMP) Management Plans (RMP) The RMP Standard was to be a Mirror The RMP Standard was to be a Mirror of the PSM Standard…Didn’t happen! of the PSM Standard…Didn’t happen! Remember…PSM Protects the Remember…PSM Protects the Workforce, RMP Protects the Workforce, RMP Protects the Community Community
  • 38. EPA RMP Basic Requirements Basic Requirements  Executive summary Executive summary  Registration Registration  Off-site consequence analysis Off-site consequence analysis  Five-year accident history Five-year accident history  Emergency response plan Emergency response plan  Prevention program summary information Prevention program summary information  Certification Certification Sound Much Easier than PSM…Right? Sound Much Easier than PSM…Right?
  • 39. Release Plume All Public Facilities in this Release Plume Must be Identified & Surveyed
  • 40. EPA RMP Emergency Response Plan & Emergency Response Plan & Prevention Plans Must Be Developed to Prevention Plans Must Be Developed to Prevent Accidental Release of the Prevent Accidental Release of the Covered Chemical Covered Chemical
  • 41. EPA RMP 1998 Changes Compliance Elements Follow-up / completion of PHA Follow-up / completion of PHA recommendation recommendation Re-validation of your PHA every 5 Re-validation of your PHA every 5 years years Compliance audits (required every Compliance audits (required every 3 years) 3 years) Follow-up / completion of Follow-up / completion of compliance audit compliance audit recommendations recommendations
  • 42. EPA RMP 1998 Changes Compliance Elements Annual review and certification of Annual review and certification of operating procedures operating procedures Employee training Employee training Updates related to system Updates related to system modifications, inventory changes, modifications, inventory changes, operational changes operational changes Off-site consequence analysis Off-site consequence analysis
  • 43. Process Safety Management of Highly Hazardous & Explosive Chemicals & EPA Risk Management Plans Summary Summary
  • 44. Goals of the One Day Course  Understand Why Process Safety Management (PSM) Understand Why Process Safety Management (PSM) Was Promulgated Was Promulgated  Understand That Even with PSM, Catastrophes are Still Understand That Even with PSM, Catastrophes are Still Occurring Occurring  Understand Who is Covered & Exemptions Understand Who is Covered & Exemptions  Understand the Team Process to Developing a PSM Understand the Team Process to Developing a PSM Program Program  Understand Each of the Elements of a Properly Designed Understand Each of the Elements of a Properly Designed & Implemented Program and How to Begin the Process & Implemented Program and How to Begin the Process  Understand the Basics of How PSM & RMP Work Understand the Basics of How PSM & RMP Work Together to Protect the Workforce & Surrounding Together to Protect the Workforce & Surrounding Community Community
  • 45. Resources  GTRI - GTRI - http://www.oshainfo.gatech.edu/index.html http://www.oshainfo.gatech.edu/index.html  OSHA PSM Compliance Guidelines - OSHA PSM Compliance Guidelines - http://www.osha.gov/Publications/osha3133.html http://www.osha.gov/Publications/osha3133.html  OSHA PSM for Construction 1926.64 - OSHA PSM for Construction 1926.64 - http://www.osha.gov/doc/outreachtraining/htmlfile http://www.osha.gov/doc/outreachtraining/htmlfile s/psm.html s/psm.html
  • 46. PSM One Day Review
  • 47. PSM One Day Review 1. 1. The Process Safety Management The Process Safety Management Standard was drafted as a requirement Standard was drafted as a requirement of the Clean Air Act. of the Clean Air Act. True or False True or False 2. 2. The PSM program must include a list The PSM program must include a list of highly hazardous chemicals. of highly hazardous chemicals. True or False True or False 3. 3. The initial start-up of a process is not The initial start-up of a process is not included as an operating phase under included as an operating phase under the PSM Standard. the PSM Standard. True or False True or False 4. 4. List three items that the process hazard analysis must List three items that the process hazard analysis must address. address. ___________ ___________, , __________ __________ and _ and __________ _________. . 5. 5. PSM does not apply to contractors, PSM does not apply to contractors, regardless of the work they are doing. regardless of the work they are doing. True or False True or False
  • 48. PSM One Day Review (cont.) 6. 6. The PSM Standard applies to companies that either process The PSM Standard applies to companies that either process highly _____________ materials or use _____________ liquids highly _____________ materials or use _____________ liquids and gases in excess of 10,000 pounds. and gases in excess of 10,000 pounds. 7. 7. Process safety information includes: Process safety information includes: ______________, _____________ and _____________. ______________, _____________ and _____________. 8. 8. Fault tree analysis is one form of an Fault tree analysis is one form of an approved method of performing a process approved method of performing a process hazard analysis. hazard analysis. True or False True or False 9. 9. A technical basis is not required to change A technical basis is not required to change a process covered by the PSM Standard. a process covered by the PSM Standard. True or False True or False 10. 10. Two types of training required by the PSM Two types of training required by the PSM standard are ________________ and_________________. standard are ________________ and_________________.