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Chemical Process Safety Standards - Beyond OSHA

Posted by AnnMarie Fauske on 05.24.18

So much information. We want it quick. We need it simple.

What do I need to know to run my plant, shop or facility safely?

Give me the basics, break it down in chunks that I need to know.

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Chemical Process Safety Management (PSM) is really well outlined and defined on the Occupational, Health and Safety Management's (OSHA) site. But here, we will define succinct terms and practical working knowledge to keep you on task.

Process - A single process refers to any interconnected actions, vessels and/or separate vessels located in a way that could involve a highly hazardous chemical in a potential release.

Chemical Process - any mixing, blending, heating, cooling and storing of materials in the course of manufacturing.

Chemical Process Safety - Identifying, testing and taking precautions to protect employees and facilities from any possible adverse reaction of chemicals due to mixing, blending, heating, cooling and storing of materials in the course of manufacturing.

Why? As OSHA states, the problem is "Unexpected releases of toxic, reactive, or flammable liquids and gases in processes involving highly hazardous chemicals have been reported for many years. Incidents continue to occur in various industries that use highly hazardous chemicals which may be toxic, reactive, flammable, or explosive, or may exhibit a combination of these properties. Regardless of the industry that uses these highly hazardous chemicals, there is a potential for an accidental release any time they are not properly controlled. This, in turn, creates the possibility of disaster."

This issue often is, companies assume erroneously that chemicals they use are not toxic, reactive, flammable or explosive... either because they haven't been in the past or assumptions are made due to past interactive behavior with other chemicals or under different conditions.

Are OSHA PSM Standards Law? Most state plans have adopted Federal OSHA regulations and standards verbatim. The Occupational Safety and Health Act of 1970 created OSHA, which sets and enforces protective workplace safety and health standards. Employers must comply with the General Duty Clause of the OSHA Act, which requires them to keep their workplaces free of serious recognized hazards. But, states may set up their own specific requirements beyond this.

In 1990, OSHA published "Process Safety Management of Highly Hazardous Chemicals"- containing requirements for the management of hazards associated with processes using highly hazardous chemicals to help assure safe and healthful workplaces. OSHA's proposed standard emphasized the management of hazards associated with highly hazardous chemicals and established a comprehensive management program that integrated technologies, procedures, and management practices.

But, what about its relation to the laws of EPA? Shortly after the PSM booklet was published, the Clean Air Act Amendments (CAAA) were enacted into law (November 15, 1990). Section 304 of the CAAA requires that the Secretary of Labor, in coordination with the Administrator of the Environmental Protection Agency (EPA), promulgate, pursuant to the Occupational Safety and Heath Act of 1970, a chemical process safety standard to prevent accidental releases of chemicals that could pose a threat to employees.

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It is important to understand the important and parellel relationship of OSHA PSM Standards and the CAAA law. Both require high amounts of ongoing communication and planning - in initial identification as well as in regularly scheduled safety audits.

"The CAAA requires that the standard include a list of highly hazardous chemicals which includes toxic, flammable, highly reactive, and explosive substances. The CAAA also specified minimum elements that the OSHA standard must require employers to do, as follows:

  1. Develop and maintain written safety information identifying workplace chemical and process hazards, equipment used in the processes, and technology used in the processes;
  2. Perform a workplace hazard assessment, including, as appropriate, identification of potential sources of accidental releases, identification of any previous release within the facility that had a potential for catastrophic consequences in the workplace, estimation of workplace effects of a range of releases, and estimation of the health and safety effects of such a range on employees;
  3. Consult with employees and their representatives on the development and conduct of hazard assessments and the development of chemical accident prevention plans and provide access to these and other records required under the standard;
  4. Establish a system to respond to the workplace hazard assessment findings, which shall address prevention, mitigation, and emergency responses;
  5. Review periodically the workplace hazard assessment and response system;
  6. Develop and implement written operating procedures for the chemical processes, including procedures for each operating phase, operating limitations, and safety and health considerations;
  7. Provide written safety and operating information for employees and employee training in operating procedures, by emphasizing hazards and safe practices that must be developed and made available;
  8. Ensure contractors and contract employees are provided with appropriate information and training;
  9. Train and educate employees and contractors in emergency response procedures in a manner as comprehensive and effective as that required by the regulation promulgated pursuant to section 126(d) of the Superfund Amendments and Reauthorization Act;
  10. Establish a quality assurance program to ensure that initial process-related equipment, maintenance materials, and spare parts are fabricated and installed consistent with design specifications;
  11. Establish maintenance systems for critical process-related equipment, including written procedures, employee training, appropriate inspections, and testing of such equipment to ensure ongoing mechanical integrity;
  12. Conduct pre-startup safety reviews of all newly installed or modified equipment;
  13. Establish and implement written procedures managing change to process chemicals, technology, equipment and facilities; and
  14. Investigate every incident that results in or could have resulted in a major accident in the workplace, with any findings to be reviewed by operating personnel and modifications made, if appropriate.

Also the CAAA, identifies specific duties for EPA relative to the prevention of accidental releases (see section 301 (r)). Generally, EPA must develop a list of chemicals and a Risk Management Plan."

PSM and PHA - Process Safety Management (PSM) includes a thorough and ongoing Process Hazards Analysis (PHA). The key provision of PSM is a PHA - a careful review of what could go wrong and what safeguards must be implemented to prevent releases of hazardous chemicals. Most companies will begin their PSM planning with a PHA on the most obvious potentially hazardous areas of production. This can make it easier to set key indicators with which to begin comparing all processes. The help of a third party safety engineering and consulting firm can bring important fresh perspective and experience when starting this process.

PSM:

  • clarifies the responsibilities of employers and contractors involved in work that affects or takes place near covered processes to ensure safety
  • mandates written operating procedures; employee training; prestartup safety reviews; evaluation of mechanical integrity of critical equipment; and written procedures for managing change
  • specifies a permit system for hot work; investigation of incidents involving releases or near misses of covered chemicals; emergency, action plans; compliance audits at least every three years(unless process changes occurs); and trade secret protection.

PHA:

Per OSHA, the PHA must contain a minimum requirement of information. This information is key to providing an orderly and document-able system for planning, organization and maintenance of all activities involved in process safety. "These include:

  • Toxicity
  • Permissible exposure limits
  • Physical data
  • Reactivity data
  • Corrosivity data, and
  • Thermal and chemical stability data, and hazardous effects of inadvertent mixing of different materials

Information on the technology of the process must include at least the following:

  • A block flow diagram or simplified process flow diagram
  • Process chemistry
  • Maximum intended inventory
  • Safe upper and lower limits for such items as temperatures, pressures, flows or compositions, and
  • An evaluation of the consequences of deviations, including those affecting the safety and health of employees

Where the original technical information no longer exists, such information may be developed in conjunction with the process hazard analysis in sufficient detail to support the analysis.

Information on the equipment in the process must include the following:

  • Materials of construction
  • Piping and instrument diagrams (P&IDs)
  • Electrical classification
  • Relief system design and design basis
  • Ventilation system design
  • Design codes and standards employed
  • Material and energy balances for processes built after May 26, 1992, and
  • Safety systems (e.g., interlocks, detection, or suppression systems).

The employer shall document that equipment complies with recognized and generally accepted good engineering practices."

Again, it is important to note, a full service third party testing lab can provide onsite consulting and auditing, preliminary testing or retesting, batch testing, and testing under a number of conditions for a comprehensive PHA and PSM.

Essentially, the PHA will provide any and all What-If scenarios and provide the all important checklist. This will include a Hazard and Operability Study (HAZOP) and a Failure Mode and Effects Analysis (FMEA) along with other methods to systematically and consistently identify all potential risks.

Management of Change (MOC) - It's also important to introduce the MOC procedure in the PSM as part of or immediately following the PHA. "OSHA believes that contemplated changes to a process must be thoroughly evaluated to fully assess their impact on employee safety and health and to determine needed changes to operating procedures. To this end, the standard contains a section on procedures for managing changes to processes. Written procedures to manage changes (except for “replacements in kind”) to process chemicals, technology, equipment, and procedures, and change to facilities that affect a covered process, must be established and implemented. These written procedures must ensure that the following considerations are addressed prior to any change:

  • The technical basis for the proposed change,
  • Impact of the change on employee safety and health,
  • Modifications to operating procedures,
  • Necessary time period for the change, and
  • Authorization requirements for the proposed change.

Employees who operate a process and maintenance as well as contract employees whose job tasks will be affected by a change in the process must be informed of, and trained in, the change prior to startup of the process or startup of the affected part of the process. If a change covered by these procedures results in a change in the required process safety information, such information also must be updated accordingly. If a change covered by these procedures changes the required operating procedures or practices, they also must be updated."

So what's left? Lots. But, here are the highlights. In order to meet OSHA Standards and go beyond, you must be prepared to provide:

  • Operating procedures on any and all equipment in writing
  • Pr- job startup safety procedures and training, scheduled consistently and reviewed in writing
  • More resources for "Recognized And Generally Accepted Good Engineering Practices" (RAGAGEP)
  • Regular safety inspections and written documentation verifying all equipment
  • Regular employee and contractor safety and incident report training and written verification of training
  • Emergency Planning and Response Training
  • Training, training, and training. Be consistent, do it often, get it documented. Design a system for constant feedback and improvement each time. Reward employees for this. 
  • Develop a Safety First Culture - one that accepts no less than everyone's best questioning attitude and commitment every day. Regularly schedule safety awareness activities and reward safe practices as well.  

Other Terms to Know:

You want to run your shop safely.  We are here to help.  Please don't hesitate to pick our brains.  info@fauske.com, 630-323-8750, www.fauske.com  

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Topics: chemical process safety, Process Safety Managment, OSHA

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