In response to Executive Order 13650, OSHA requests comment by March 10, 2014 on potential revisions to its Process Safety Management (PSM) and Prevention of Major Chemical Accidents standard and its Explosives and Blasting Agents standard, potential updates to its Flammable Liquids standard and Spray Finishing standard, and potential changes to PSM enforcement policies. In this Request for Information (RFI), the Agency asks for information and data on specific rulemaking and policy options, and the workplace hazards they address. OSHA will use the information received in response to this RFI to determine what action, if any, it may take.
Following a series of recent disasters, the President issued an executive order for OSHA and other agencies to take steps to improve chemical facility safety and security. Expansion of the PSM standard is under consideration. In November, OSHA, the Environmental Protection Agency and the Department of Homeland Security hosted "listening sessions" to gather input from stakeholders.
Per the January 2014 issue of Safety & Health Magazine, OSHA is considering options to:
- "clarify the PSM exemption for atmospheric storage tanks
- expand coverage and requirements of reactivity hazards, and
- cover the mechanical integrity of safety-critical equipment"
According to Amy Theis, Manager, Risk Management Services Fauske & Associates, LLC (FAI), “With these potential changes, companies should evaluate whether their facilities are adequately prepared for an OSHA PSM inspection. It is helpful to be proactive in this effort. An external PSM inspection can identify weaknesses in a company’s PSM program and potential OSHA violations, avoiding costly fines. Other options may include participation in OSHA’s Voluntary Protection Program (VPP) or OSHA Consultation’s Safety and Health Achievement Recognition Program (SHARP). Ultimately, professional assistance is the most decisive and cost-effective option.”
In FAI's Fall 2011 Process Safety News, Tim Cullina, PE, Senior Consulting Engineer published:
Case Study: PSM Ignorance Resulted in Damaging Consequences
This case study highlights a recent project where a company did not properly implement Process Hazard Analysis (PHA) and other Process Safety Management (PSM) elements. Consequently, a series of events led to several explosions, contaminated water affecting surrounding neighborhoods, millions of dollars in EPA and OSHA fines and lost production time of 20 months over multiple product lines. The series of events is outlined below followed by lessons learned and considerations for your own company’s PSM program.
Timeline of Critical Events
1:32 am Lightning strike causes power outage
1:35 am Back-up generator begins
- Power restored to Control Room, water system, essential lighting systems
- Process feed remains off
- Pressure and temperature gauges from reactors #1 and #2 are not reporting
- Temperatures in reactors #3, 4, and 5, are operating and within the acceptable range
1:38 am (Time est.) Production supervisor interrupts cooling water supply to maintain reactor temperatures
- This information is not immediately relayed to the control center
1:40 am Control Center reaches the Plant Owner/Operator by telephone and reports status
1:42 am Owner instructs them not to restart chemical supply; let the process cool down
1:45 am Production supervisor tells Control Center that cooling water is shut down
- Control Center reports Plant Owner directive to Production Supervisor
1:50-2:00 am Control Center Operators report that temperature and pressure rise continue in reactors #3, 4, and 5
1:55 am Control center requests reactor cooling assistance
- First Fire Department responders arrive
- Fire department directs plant to evacuate all non-essential personnel
2:14 am Reactor #1 explodes
- Small fires started
- Operators begin evacuation of Control Center
- Three more reactors fail during the evacuation
Fortunately, the explosions and fires caused no fatalities and only minor injuries. Firefighters continued suppression activities for 10 hours. During this time the effluent from the damaged process and water from the fire hoses eventually ran offsite, onto undeveloped property, and down to a local creek. Assessments after the incident indicated a local fish kill.
What Went Wrong?
Several elements of PSM were lacking at this facility; however, the root causes go much deeper. Management did not establish a safety culture at this facility; the focus was on “desktop compliance”, not proper implementation. Resources were not deployed to achieve PSM compliance.
The following are some lessons learned and for key elements of the PSM program.
Process Safety Information
The supervisor wanted to prevent a loss in production caused by an extended “cooling event” during an earlier incident. Subsequent investigation revealed that the previous owner “ran hot” the last year to improve production numbers. The focus was on production, not on safety.
The PSI element requires complete and accurate process information sufficient to conduct PHAs, to support hazard communication requirements, and to document the design configuration of each process. Specifically, the operators and production supervisor lacked a complete understanding of safe operating parameters and the potential consequences. The potential for a runaway reaction to occur if cooling (or power) was lost had not been investigated, documented or understood.
Process Hazard Analysis
The owner did not review the PHA. None of the original participants of the PHA still worked on site. The PHA had been completed by a previous owner over ten years earlier and only revalidated. The revalidation was little more than a verification that the PHA report could be found if OSHA arrived on site. There was no evidence that recommendations were tracked, evaluated, implemented or rejected.
The objective of the PHA is to determine areas of excessive risk where preventative and mitigative measures may be warranted to better control the hazards. Merely performing a PHA is not enough if it is not properly inclusive and the recommendations not followed up.
Procedures did not include steps for emergency situations including a loss of power.
Good procedures provide clear written instructions for safely conducting activities of each covered process. These instructions should address operating limits, safety and health considerations, and safety systems and their functions. Procedures need to exist for every mode of operation such as routine start up and shut down, and emergency situations. Note that this element also includes maintenance procedures.
A written MI program did not exist but a preventive maintenance schedule did. The PM schedule included pumps, heat exchangers, the emergency generator, and the pressure relief valves. However, accurate records of PM were not maintained. Completed work orders were stored in a desk drawer.
A robust MI program will ensure the integrity and safe operation of process equipment through inspection, testing, preventive maintenance, and quality assurance. This element is one of the most cited PSM elements by OSHA.
Management of Change
There was an MOC Program. Unfortunately there was no apparent linkage between MOC, PSI, Training and PHA.
The plant operators must establish and implement written procedures to manage changes (except for replacements in kind) to process chemicals, technology, equipment, and procedures, and to facilities that affect a covered process. Changes that effect or alter PSI must be integrated through the other elements.
PSM Due Diligence in Mergers & Acquisitions
The company that experienced this loss had recently acquired the reactive chemical processing plant approximately 6 months earlier. A due diligence process was completed that considered environmental and plant safety factors. The ASTM Phase 1 and 2 inspections provided no show stoppers. The safety review efforts raised no workman compensation flags and no history with OSHA. In fact, the incident rate bettered the industry average.
The owner accepted responsibility for PSM as part of the due diligence process. He only considered 2 of the PSM elements and did not have the time or expertise to address them properly. The cost of PSM compliance was not understood because the owner did not perform a gap analysis.
FAI is focused on providing customers safety solutions to identify and prevent such high risk events from causing devastating consequences such as these. FAI offers PSM development & support as well as due diligence assistance for Mergers and Acquisitions or compliance auditing purposes.
FAI has extensive experience performing safety reviews for hazardous processes, PSM evaluations and chemical engineering support. This includes more than 34 years of hazardous system testing and categorization. “PSM areas of specialty at FAI include Process Hazard Analysis (PHA) and reactive system testing that supports the element of Process Safety Information (PSI),” states Theis. "FAI’s experience in this area makes us uniquely qualified to facilitate and support PHA’s for reactive chemical systems.
READER NOTE: Submit comments and additional material for OSHA's request to: Request for Information by March 10, 2014.