HAT TO EXPECT DURINGAN OSHA PROCESS SAFETY MANAGEMENT (PSM) INSPECTION€¦ · · 2015-04-094/9/2015 1 Allen Grisar Occupational Safety and Health Administration Milwaukee Area

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Allen Grisar

Occupational Safety and Health Administration

Milwaukee Area Office

WHAT TO EXPECT DURING AN OSHA PROCESS SAFETY MANAGEMENT (PSM)

INSPECTION

WCS 2015 Conference April 21, 2014

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Process Safety Management of Highly Hazardous Chemicals (HHCs)

29CFR1910.119

Process Safety Management of Highly Hazardous Chemicals (HHCs)

29CFR1910.119

Objectives

• OSHA PSM Inspection process

• Define what is PSM and who is covered by the standard

• Define the elements of the PSM standard

• Recognized and generally accepted good engineering practices (RAGAGEP)

Objectives

• OSHA PSM Inspection process

• Define what is PSM and who is covered by the standard

• Define the elements of the PSM standard

• Recognized and generally accepted good engineering practices (RAGAGEP)

What Is Process Safety Management (PSM)?

What Is Process Safety Management (PSM)?

� PSM:

� Addresses the management of Highly Hazardous Chemicals (HHCs) through a management system, intended to prevent catastrophic events …..

Which….

� Integrates

� Technology of the process

�Operating Procedures

� Standard management protocols

� PSM:

� Addresses the management of Highly Hazardous Chemicals (HHCs) through a management system, intended to prevent catastrophic events …..

Which….

� Integrates

� Technology of the process

�Operating Procedures

� Standard management protocols

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Why Did OSHA Develop PSM?Why Did OSHA Develop PSM?

�Past Disasters

�Current Disasters

�Past Disasters

�Current Disasters

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In 1991, OSHA Released the StandardIn 1991, OSHA Released the Standard

� BP Products Texas City - March 2005

� 15 Workers Killed

� 170 Injured

� Major Property Damage

� $50.6 Million in Fines

� BP Products Texas City - March 2005

� 15 Workers Killed

� 170 Injured

� Major Property Damage

� $50.6 Million in Fines

The Standard Was Promulgated in 1991 - Is it Working?The Standard Was Promulgated in 1991 - Is it Working?

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� Formosa Plastics Corp - Vinyl Chloride Monomer Explosion -Illiopolis IL - 2004. (5 Dead, 3 Injured)

� Formosa Plastics Corp - Vinyl Chloride Monomer Explosion -Illiopolis IL - 2004. (5 Dead, 3 Injured)

Why Did OSHA Develop PSM?Why Did OSHA Develop PSM?

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OSHA National Emphasis Program (NEP)

OSHA National Emphasis Program (NEP)

Process Safety ManagementProcess Safety Management

Purpose of NEP

Program (NEP) for inspecting:

Facilities covered by PSM

Primary Purpose:

• Tool for OSHA CSHOs to determine compliance

with PSM

• Contains policies and procedures to verify

employers’ coverage

• Compliance with OSHA’s PSM standard

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OSHA National Emphasis Program (NEP) for Refineries & Chemical Facilities

OSHA National Emphasis Program (NEP) for Refineries & Chemical Facilities

� Petroleum Refineries NEP

� Issued August 2009

� Chemical Facilities NEP

� Issued July 2010

� Petroleum Refineries NEP

� Issued August 2009

� Chemical Facilities NEP

� Issued July 2010

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Scope Scope

Applies OSHA wide.Applies OSHA wide.

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What Facilities are CoveredApplication - 1910.119(a)

What Facilities are CoveredApplication - 1910.119(a)

� Those Who Use Chemicals in Appendix A: A List of highly hazardous chemicals, toxics and reactive (Mandatory). Contains a listing of toxic and reactive highly hazardous chemicals which present a potential for a catastrophic event at or above the threshold quantity

� Examples

Chemical Threshold Quantity (TQ)

� Anhydrous Ammonia 10,000 lbs

� Chlorine 1,500 lbs

� Those Who Use Chemicals in Appendix A: A List of highly hazardous chemicals, toxics and reactive (Mandatory). Contains a listing of toxic and reactive highly hazardous chemicals which present a potential for a catastrophic event at or above the threshold quantity

� Examples

Chemical Threshold Quantity (TQ)

� Anhydrous Ammonia 10,000 lbs

� Chlorine 1,500 lbs

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� A process which involves a flammable liquid or gas (as defined in 1910.1200(c) of this part) on-site in one location, in a quantity of 10,000 pounds (4535.9 kg) or more

� A process which involves a flammable liquid or gas (as defined in 1910.1200(c) of this part) on-site in one location, in a quantity of 10,000 pounds (4535.9 kg) or more

What Facilities are CoveredWhat Facilities are Covered

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A covered process includes the processing of HHCs within…A covered process includes the processing of HHCs within…

Any group of vessels which are interconnected, andAny group of vessels which are interconnected, and

Separate vesselsSeparate vesselsSeparate vesselsSeparate vessels which are which are which are which are located such that a highly located such that a highly located such that a highly located such that a highly hazardous chemical could hazardous chemical could hazardous chemical could hazardous chemical could be be be be involved in a potential involved in a potential involved in a potential involved in a potential releasereleasereleaserelease

� Important Interpretation: 2007 - 06/11/2007 -OSHA defines "on-site in one location" for Process Safety Management of Highly Hazardous Chemicals standard

OSHA interprets "on-site in one location" to mean that the standard applies when a threshold quantity of a highly hazardous chemical (HHC) exists within an area under the control of an employer or group of affiliated employers. It also applies to any group of vessels that are interconnected, or in separate vessels that are close enough in proximity that the HHC could be involved in a potential catastrophic release.

� Important Interpretation: 2007 - 06/11/2007 -OSHA defines "on-site in one location" for Process Safety Management of Highly Hazardous Chemicals standard

OSHA interprets "on-site in one location" to mean that the standard applies when a threshold quantity of a highly hazardous chemical (HHC) exists within an area under the control of an employer or group of affiliated employers. It also applies to any group of vessels that are interconnected, or in separate vessels that are close enough in proximity that the HHC could be involved in a potential catastrophic release.


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Affect of the “Meer” Decision:

MEER ruling and the MEER Memorandum addressed in the

Secretary's letter, OSHA's enforcement policy that the Agency would not cite employers for violations of 1910.119 where stored

flammable liquids in atmospheric tanks were connected to a process, unless the process outside of the amount in storage

contained more than 10,000 pounds of the substance.

Affect of the “Meer” Decision:

MEER ruling and the MEER Memorandum addressed in the

Secretary's letter, OSHA's enforcement policy that the Agency would not cite employers for violations of 1910.119 where stored

flammable liquids in atmospheric tanks were connected to a process, unless the process outside of the amount in storage

contained more than 10,000 pounds of the substance.


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What Types of Industries?What Types of Industries?

� Industries that Process Chemicals Such As:

� Industrial Organics & Inorganics

� Paints

� Pharmaceuticals

� Adhesives

� Sealants and Fibers

� Petrochemical facilities

� Paper Mills

� Food Processing with Anhydrous Ammonia over the TQ

� Industries that Process Chemicals Such As:

� Industrial Organics & Inorganics

� Paints

� Pharmaceuticals

� Adhesives

� Sealants and Fibers

� Petrochemical facilities

� Paper Mills

� Food Processing with Anhydrous Ammonia over the TQ

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There are Exclusions1910.119(a)(1)(ii)(A)

There are Exclusions1910.119(a)(1)(ii)(A)

� An employer is exempt from the requirements of PSM when:

� A threshold quantity of flammable liquids is stored in atmospheric tanks or transferred without the benefit of chilling or refrigeration

� Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling),

� If such fuels are not a part of a process containing another highly hazardous chemical covered by this standard

� An employer is exempt from the requirements of PSM when:

� A threshold quantity of flammable liquids is stored in atmospheric tanks or transferred without the benefit of chilling or refrigeration

� Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling),

� If such fuels are not a part of a process containing another highly hazardous chemical covered by this standard

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� Retail facilities;

� Oil or gas well drilling or

servicing operations; or,

� Normally unoccupied

remote facilities

� Retail facilities;

� Oil or gas well drilling or

servicing operations; or,

� Normally unoccupied

remote facilities

ExclusionsExclusions

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PSM Inspection Coverage Process Determination:

PSM Inspection Coverage Process Determination:

Let’s Start the PSM Inspection Process;Let’s Start the PSM

Inspection Process;

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PSM Inspection Coverage Process Determination: PSM Inspection Coverage Process Determination:

� Referral - Result of an Incident?

� Complaint

� Programed PSM “NEP” Inspection

� Follow-Up of previous PSM inspection

� Referral - Result of an Incident?

� Complaint

� Programed PSM “NEP” Inspection

� Follow-Up of previous PSM inspection

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PSM Inspection Coverage Process Determination:PSM Inspection Coverage Process Determination:

� Determine type of process(s) and chemical(s) used – Can be more than one covered process/chemical

� What are the quantities – Do they meet Appendix A Threshold Quantities (TQ) – Maximum Intended Quantity Onsite at one time……

**Requesting of chemical listing and inventory levels of chemicals on site to determine the TQ levels.

� Determine type of process(s) and chemical(s) used – Can be more than one covered process/chemical

� What are the quantities – Do they meet Appendix A Threshold Quantities (TQ) – Maximum Intended Quantity Onsite at one time……

**Requesting of chemical listing and inventory levels of chemicals on site to determine the TQ levels.

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PSM Inspection Coverage Process Determination:PSM Inspection Coverage Process Determination:

Coverage has been determined…..

Initial documentation request provided…

Coverage has been determined…..

Initial documentation request provided…

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PSM Inspection Process: Document RequestPSM Inspection Process: Document RequestRe: OSHA Document Request for Process Safety Management (PSM) Inspection

Please supply the following information. Any items that are not applicable please identify.

1. All contract employee injury and illness logs as required by 1910.119(h)(2)(vi).

2. A list of all Ammonia Anhydrous refrigeration units in the complex and the maximum intended inventories of all.

3. A summary description of the facility’s PSM program.

4. Unit process flow diagram(s).

5. Piping and instrumentation diagrams (P&IDs) including legends.

6. Unit Plot plans.

7. Unit Electrical classification diagrams.

8. Process narrative descriptions.

9. Descriptions of safety systems (e.g. interlocks, detection or Suppression systems).

10. A list of workers presently involved in operating equipment covered under the PSM program.

Re: OSHA Document Request for Process Safety Management (PSM) Inspection

Please supply the following information. Any items that are not applicable please identify.

1. All contract employee injury and illness logs as required by 1910.119(h)(2)(vi).

2. A list of all Ammonia Anhydrous refrigeration units in the complex and the maximum intended inventories of all.

3. A summary description of the facility’s PSM program.

4. Unit process flow diagram(s).

5. Piping and instrumentation diagrams (P&IDs) including legends.

6. Unit Plot plans.

7. Unit Electrical classification diagrams.

8. Process narrative descriptions.

9. Descriptions of safety systems (e.g. interlocks, detection or Suppression systems).

10. A list of workers presently involved in operating equipment covered under the PSM program.23

PSM Inspection Process: Document RequestPSM Inspection Process: Document Request

11. The initial Process Hazard Analysis (PHA) and the most recent update or revalidation for the covered system. Include PHA reports, PHA Worksheets, actions to address findings and recommendations, written schedules for actions to be completed, and documentation of findings and recommendations.

12. Provide operating procedures that have been developed for the operation of the ammonia refrigeration systems and equipment.

13. Provide the emergency action plan / procedure that have been developed to cover the release of ammonia at the facility.

14. Provide procedure for accomplishment of Management of Change (MOC).

15. Provide Procedure for Incident Investigation and documentation of incident investigations conducted.

16. Provide Mechanical Integrity (MI) Procedure.

17. Compliance Audits of the PSM program to include the two most recent audit reports.

18. Training plan and documentation of employee understanding and knowledge of the PSM Program.

19. Employee Participation plan.

If any of these items are not available/applicable please note accordingly. Please provide these items by___________________.

11. The initial Process Hazard Analysis (PHA) and the most recent update or revalidation for the covered system. Include PHA reports, PHA Worksheets, actions to address findings and recommendations, written schedules for actions to be completed, and documentation of findings and recommendations.

12. Provide operating procedures that have been developed for the operation of the ammonia refrigeration systems and equipment.

13. Provide the emergency action plan / procedure that have been developed to cover the release of ammonia at the facility.

14. Provide procedure for accomplishment of Management of Change (MOC).

15. Provide Procedure for Incident Investigation and documentation of incident investigations conducted.

16. Provide Mechanical Integrity (MI) Procedure.

17. Compliance Audits of the PSM program to include the two most recent audit reports.

18. Training plan and documentation of employee understanding and knowledge of the PSM Program.

19. Employee Participation plan.

If any of these items are not available/applicable please note accordingly. Please provide these items by___________________. 24

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PSM Inspection Process: Initial Walk AroundPSM Inspection Process: Initial Walk Around

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• Initial evaluation of the covered process and equipment

• If more than one process – use this initial walk around to

help determine the process to be selected for inspection –

may select more than one process.

• Will take pictures, video and conduct brief employee

interview(s)

(Review of initial documentation request will also be used to

select process for inspection)

PSM Inspection Process: Main Body of InspectionPSM Inspection Process: Main Body of Inspection

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• Evaluation of each PSM Element

• Review written program documentation for each element

implementation

• Interview Employees – Management, Process Operators,

Maintenance Employees, and Contractors

• Take samples of compounds if required

• Identify hazards / deficiencies identified as the inspection

progresses.

� Application

� Exclusions

� Definitions

� Employee Participation

� Hazards of the Process

� Toxicity

� Technology of the Process

� Equipment in the Process

� Mechanical Integrity

� Inspection & Testing

� Quality Assurance

� Application

� Exclusions

� Definitions



� Toxicity






The Elements of the PSM StandardThe Elements of the PSM Standard

� Process Hazard Analysis

� Management of Change

� Operating Procedures

� Safe Work Practices

� Training

� Contractor Management

� Emergency Planning & Response

� Incident Investigation

� Compliance Audits

� Trade Secrets





� Training





� Trade Secrets

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� Application

� Exclusions

� Definitions



� Toxicity



� Mechanical Integrity� Inspection & Testing

� Application

� Exclusions

� Definitions



� Toxicity



� Mechanical Integrity� Inspection & Testing






� Training





� Trade Secrets





� Training





� Trade Secrets

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� Application

� Exclusions

� Definitions



� Toxicity






� Application

� Exclusions

� Definitions



� Toxicity











� Training





� Trade Secrets





� Training





� Trade Secrets

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� Application

� Exclusions

� Definitions



� Toxicity






� Application

� Exclusions

� Definitions



� Toxicity









� Operating Procedures� Safe Work Practices

� Training





� Trade Secrets



� Operating Procedures� Safe Work Practices

� Training





� Trade Secrets

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� Application

� Exclusions

� Definitions



� Toxicity






� Application

� Exclusions

� Definitions



� Toxicity











� Training� Contractor Management




� Trade Secrets





� Training� Contractor Management




� Trade Secrets

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� Application

� Exclusions

� Definitions

� Employee Participation� Hazards of the Process

� Toxicity






� Application

� Exclusions

� Definitions

� Employee Participation� Hazards of the Process

� Toxicity











� Training





� Trade Secrets





� Training





� Trade Secrets

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� Application

� Exclusions

� Definitions



� Toxicity






� Application

� Exclusions

� Definitions



� Toxicity











� Training





� Trade Secrets





� Training





� Trade Secrets

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� Application

� Exclusions

� Definitions



� Toxicity






� Application

� Exclusions

� Definitions



� Toxicity










� Pre-Start up Safety Review

� Hot Work Permit


� Training







� Hot Work Permit


� Training



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� Application

� Exclusions

� Definitions



� Toxicity






� Application

� Exclusions

� Definitions



� Toxicity











� Hot Work Permit� Safe Work Practices

� Training







� Hot Work Permit� Safe Work Practices

� Training



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� Application

� Exclusions

� Definitions



� Toxicity






� Application

� Exclusions

� Definitions



� Toxicity











� Hot Work Permit


� Training







� Hot Work Permit


� Training



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� Application

� Exclusions

� Definitions



� Toxicity






� Application

� Exclusions

� Definitions



� Toxicity











� Hot Work Permit


� Training







� Hot Work Permit


� Training



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� Application

� Exclusions

� Definitions



� Toxicity

� Technology of the Process� Equipment in the Process


� Inspection & Testing� Quality Assurance

� Application

� Exclusions

� Definitions



� Toxicity



� Inspection & Testing� Quality Assurance






� Hot Work Permit


� Training







� Hot Work Permit


� Training



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� Application

� Exclusions

� Definitions



� Toxicity





� Application

� Exclusions

� Definitions



� Toxicity










� Hot Work Permit


� Training







� Hot Work Permit


� Training



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The Elements of the PSM Standard

The Elements of the PSM Standard

• We determined coverage

• Document Request Provided

Let’s Explore Some of the Elements to be evaluated for implementation and

performance…

• We determined coverage

• Document Request Provided

Let’s Explore Some of the Elements to be evaluated for implementation and

performance…

Employee Participation(Cross Function of Personnel)

(Need a written Plan of Action regarding how employee participation implementation

is to function across all employee groups)

Employee Participation(Cross Function of Personnel)

(Need a written Plan of Action regarding how employee participation implementation

is to function across all employee groups)

1910.119(c)1910.119(c)

How is Employee Participation Implemented?How is Employee Participation Implemented?

� Team members directly involved in the program and those on periphery of the program, i.e.…

� Process Engineers

� Operators

� Safety

� Maintenance

� Management

� Consultants

� Team members directly involved in the program and those on periphery of the program, i.e.…

� Process Engineers

� Operators

� Safety

� Maintenance

� Management

� Consultants

Remember;You Can’t Do it Alone!

Not a One Person Responsibility!42

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� How is the Plan Developed

Determine:

� Responsibilities

� Duties

� Reporting

� Document Control

� Progress Reports

� Tracking Changes

� Developing Procedures, PHAs

� How is the Plan Developed

Determine:

� Responsibilities

� Duties

� Reporting

� Document Control

� Progress Reports

� Tracking Changes

� Developing Procedures, PHAs

How is Employee Participation Implemented?How is Employee Participation Implemented?

Remember;You Can’t Do it Alone!

Not a One Person Responsibility!

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PROCESS SAFETY INFORMATION(PSI)

Hazards of the Process

PROCESS SAFETY INFORMATION(PSI)

Hazards of the Process

1910.119(d)(1)1910.119(d)(1)

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(PSI)The Requirements of the Standard -

Hazard Determination

(PSI)The Requirements of the Standard -

Hazard Determination

Determine:

� Chemicals in Your Process

� Process Chemistry

� Quantity of Chemicals in lbs

� Compare to Appendix A List with Threshold Quantities (TQ’s)

Determine:

� Chemicals in Your Process

� Process Chemistry

� Quantity of Chemicals in lbs

� Compare to Appendix A List with Threshold Quantities (TQ’s)

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(PSI)Toxicity Information

(PSI)Toxicity Information

1910.119(d)(1)(i)1910.119(d)(1)(i)

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The Requirements of the Standard - Develop Toxicity Information

The Requirements of the Standard - Develop Toxicity Information

� Obtain Toxicity Information on the Chemical(s) in the Process

� (SDSs) MSDs are Typical Resource (Most Instances will fulfill Toxicity Information)

� You May Need Other References, NIOSH Pocket Guide, ACGIH TLV’s

� Obtain Toxicity Information on the Chemical(s) in the Process

� (SDSs) MSDs are Typical Resource (Most Instances will fulfill Toxicity Information)

� You May Need Other References, NIOSH Pocket Guide, ACGIH TLV’s

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(PSI)Technology of the Process

(PSI)Technology of the Process

1910.119(d)(2)1910.119(d)(2)

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The Requirements of the Standard - Process Technology

The Requirements of the Standard - Process Technology

� Block flow diagram or process flow diagram

� Process chemistry

� Maximum intended inventory

� Upper and lower limits

� Consequences of deviations

� Block flow diagram or process flow diagram

� Process chemistry

� Maximum intended inventory

� Upper and lower limits

� Consequences of deviations

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The Requirements of the Standard - Process Equipment


� Materials of construction

� Process and instrument drawings (P&ID’s)

� Electrical classification

� Relief system design

� Ventilation system design

� Design codes

� Material and energy balances

� Safety systems

� Materials of construction

� Process and instrument drawings (P&ID’s)

� Electrical classification

� Relief system design

� Ventilation system design

� Design codes

� Material and energy balances

� Safety systems

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(PSI)Equipment in the Process

(PSI)Equipment in the Process

1910.119(d)(3)1910.119(d)(3)

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� Identify Each Piece of Equipment in the Covered Process by P&ID, Block Diagram and Number /Label Them.

� Must be Able to Track Each piece of equipment Through the Entire Program

� Identify Each Piece of Equipment in the Covered Process by P&ID, Block Diagram and Number /Label Them.

� Must be Able to Track Each piece of equipment Through the Entire Program

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PROCESS SAFETY INFORMATIONDETERMINATION:PROCESS SAFETY INFORMATIONDETERMINATION:

INTERVIEWS

�PSM coordinator

�Operators at all levels

�Process engineers

� Inspection dept.

�Operating supervisors

� Instrument technicians

Document Review Continues

INTERVIEWS

�PSM coordinator

�Operators at all levels

�Process engineers

� Inspection dept.

�Operating supervisors

� Instrument technicians

Document Review Continues

Process Hazard Analysis (PHA)Process Hazard Analysis (PHA)

1910.119(e)1910.119(e)

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Process Hazard Analysis (PHA’s)Process Hazard Analysis (PHA’s)

� Arguably the Most Difficult Part of Performing the Standard

� PHA process is dynamic and subject to revision whenever changes are made

� Performed by Your PSM Team

� Takes Significant Time & Effort

� PHA’s are Never Ending

� Arguably the Most Difficult Part of Performing the Standard

� PHA process is dynamic and subject to revision whenever changes are made

� Performed by Your PSM Team

� Takes Significant Time & Effort

� PHA’s are Never Ending

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Process Hazard AnalysisProcess Hazard Analysis

A PHA Process Must be

Performed on Each Element

of the Covered Process:

A PHA From Block Diagram to

P&ID to Every Equipment

Component to Determine

What Might Happen if an

Element of the Covered

Process Fails.

A PHA Process Must be

Performed on Each Element

of the Covered Process:

A PHA From Block Diagram to

P&ID to Every Equipment

Component to Determine

What Might Happen if an

Element of the Covered

Process Fails.

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PROCESS HAZARD ANALYSISPROCESS HAZARD ANALYSIS

DOCUMENTS� Current and previous PHA� Recertification and the PHA

which was recertified� Timetable for PHA’s� PHA recommendations� Resolution documentation� Action item tracking� RMP worst case and alternate case scenarios� Near miss reports� PSM incident reports

DOCUMENTS� Current and previous PHA� Recertification and the PHA

which was recertified� Timetable for PHA’s� PHA recommendations� Resolution documentation� Action item tracking� RMP worst case and alternate case scenarios� Near miss reports� PSM incident reports

What is a

“guide word”

anyway??

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�Check the PHA’s for timeliness� Initial and recertification

�Document the methodology used� Is it appropriate?

�Who conducted the PHA?�Was an hourly employee

involved?� Describe.

�Were participants trained in the methodology, including employee(s)?� Review the training.

�Check the PHA’s for timeliness� Initial and recertification

�Document the methodology used� Is it appropriate?

�Who conducted the PHA?�Was an hourly employee

involved?� Describe.

�Were participants trained in the methodology, including employee(s)?� Review the training.

Documentation • Review the system used to track action items to closure.– Are the items tracked and on

schedule?

• Document delays and the reasons for the delays.– Are they valid or does it

appear to be procrastination?

• Does anyone assure that the items were actually corrected or is it just paper shuffling?


�Review the PHA� Are all systems analyzed?� Are all systems identified?

�Check the validity of the mitigation systems identified in the PHA� Relief valve vs. sizing criteria

�Kill systems� Do they work or is injection

pressure less than operating pressure?

�Review the PHA� Are all systems analyzed?� Are all systems identified?

�Check the validity of the mitigation systems identified in the PHA� Relief valve vs. sizing criteria

�Kill systems� Do they work or is injection

pressure less than operating pressure?

Documentation• Equipment inspections

– When inspection program is

poor

• Review rejected PHA

recommendations– Document the rationale and

test it for accuracy

– Were the hazards of rejected

items resolved in another

manner?

• Verify that facility siting

and human factors were

adequately addressed

There is Much More to PSMThere is Much More to PSM






� Training





� Trade Secrets






� Training





� Trade Secrets60

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Mechanical Integrity (MI)(Critical Element)

Procedures, Inspection and Testing

� Process to ensure function of all equipment and systems are working as designed by manufacturer and RAGAGEP standards

� Procedures developed to ensure equipment and processes are inspected and tested according to design specifications and RAGAGEP

� All mechanical integrity process functions documented

Mechanical Integrity (MI)(Critical Element)

Procedures, Inspection and Testing

� Process to ensure function of all equipment and systems are working as designed by manufacturer and RAGAGEP standards

� Procedures developed to ensure equipment and processes are inspected and tested according to design specifications and RAGAGEP

� All mechanical integrity process functions documented

1910.119(j)1910.119(j)61

Mechanical Integrity (MI)Mechanical Integrity (MI)

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Equipment and Documents

• Pumps

• Motors

• Mixers

• Piping Data (Material Type, Schedule Grade etc.)• Piping isometrics• Piping retirement schedule

• Pressure Safety Relief Valves (PSRV) and all

pressure relief systems

• Valves

• Ventilation / Exhaust Systems

• Safety Instrumented Systems (Temperature

monitoring devices, level monitoring systems,

vibration monitoring devices etc.)


DOCUMENTS� Pressure vessel data (U1) reports

� Storage tank specs

� Inspection records for tanks, pressure vessels and piping

� Written mechanical integrity program

� Rotating equipment inspection records

� Removal from service criteria

� Instrument calibration records and inspection schedule

� Ventilation specs

� Ventilation test records

� Non-destructive testing procedures

DOCUMENTS� Pressure vessel data (U1) reports

� Storage tank specs

� Inspection records for tanks, pressure vessels and piping

� Written mechanical integrity program

� Rotating equipment inspection records

� Removal from service criteria

� Instrument calibration records and inspection schedule

� Ventilation specs

� Ventilation test records

� Non-destructive testing procedures

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DOCUMENTS

• Thickness monitoring location criteria

• Inspection schedules for the equipment

• Relief valve inspection reports and schedules

• Near miss and EPA spill reports

• Inspector training– records

– certifications

• Repair history– for equipment

• Inspection codes

DOCUMENTS

• Thickness monitoring location criteria

• Inspection schedules for the equipment

• Relief valve inspection reports and schedules

• Near miss and EPA spill reports

• Inspector training– records

– certifications

• Repair history– for equipment

• Inspection codes


INTERVIEWS

• Chief inspector• Piping and pressure vessel inspectors

• Maintenance superintendent • Maintenance employees• Instrument repair/technicians• Process operators• Corrosion engineers

INTERVIEWS

• Chief inspector• Piping and pressure vessel inspectors

• Maintenance superintendent • Maintenance employees• Instrument repair/technicians• Process operators• Corrosion engineers

Vibration study

MI: Inspection FindingsMI: Inspection Findings

66

Relief To Safe

Location?

Unknown Piping and UseRelief to work

environment; not

piped to a safe

location

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67

Inspection of Piping

– PSM (Mechanical Integrity deficiencies – 1910.119(4) inspection and

testing deficiencies)

– NDI Inspection of piping – Ultrasound, Visual - on a schedule as

determined by Recognized and Generally Accepted Good Engineering

Practices (RAGAGEP)

Corrosion /

Flaking

Corrosion

HazardsHazards� PSM (Mechanical Integrity deficiencies – 1910.119(5)

equipment deficiencies)

� Duct Tape is not a RAGAGEP

� PSM (Mechanical Integrity deficiencies – 1910.119(5) equipment deficiencies)

� Duct Tape is not a RAGAGEP

68

69

MI – Quality Assurance Requirement: Ensure all materials

used meet RAGAGEP AND ARE SUITABLE FOR

PROCESS APPLICATION; Example: Ensure piping is of

correct material and schedule type - Schedule 40 vs.

schedule 80

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RAGAGEP(Recognized and Generally Accepted Good Engineering Practices)

RAGAGEP(Recognized and Generally Accepted Good Engineering Practices)

� Manufacturers specifications for maintenance, inspection, testing and operating equipment/processes.

� Industry Standards

� ANSI (American National Standards Institute)� B31.1, B31.3 Piping

� ASME (American Society of Mechanical Engineers)

� API (American Petroleum Institute)

� API 570 Piping inspection

� IIAR (International Institute of Ammonia Refrigeration)

� NFPA

� Manufacturers specifications for maintenance, inspection, testing and operating equipment/processes.

� Industry Standards

� ANSI (American National Standards Institute)� B31.1, B31.3 Piping

� ASME (American Society of Mechanical Engineers)

� API (American Petroleum Institute)

� API 570 Piping inspection

� IIAR (International Institute of Ammonia Refrigeration)

� NFPA

70

Management of ChangeManagement of Change

� Procedures to manage changes to the covered process. (Heavily associated with “Mechanical Integrity”)

� Exception: “replacement in kind”

� Management of Change includes:

� Process chemicals

� Technology

� Equipment


� Facilities

� Procedures to manage changes to the covered process. (Heavily associated with “Mechanical Integrity”)

� Exception: “replacement in kind”

� Management of Change includes:


� Technology

� Equipment


� Facilities

71

Management of Change AddressesManagement of Change Addresses

1. Technical basis of the change

2. Impact to employee safety and health

3. Modification to operating procedures

4. Time period for change

5. Authorization of change

1. Technical basis of the change

2. Impact to employee safety and health

3. Modification to operating procedures

4. Time period for change

5. Authorization of change

72

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Operating ProceduresOperating Procedures

� Develop and implement written operating procedures that are clear instructions for all expected phases of operations.

� AKA – Standard Operating Procedures (SOPs)

� Must cover:

� Operation phase

� Operational limits

� Safety & health considerations

� Develop and implement written operating procedures that are clear instructions for all expected phases of operations.

� AKA – Standard Operating Procedures (SOPs)

� Must cover:

� Operation phase

� Operational limits

� Safety & health considerations

73

Operating Procedures Must Address (SOPs)Operating Procedures Must Address (SOPs)

� Initial start-up

� Normal operations

� Temporary operations

� Emergency shutdown

� Emergency operations

� Normal shutdown

� Start-up following turnaround

� Consequences of deviation

� Steps required to correct or avoid deviation

� Initial start-up

� Normal operations

� Temporary operations

� Emergency shutdown

� Emergency operations

� Normal shutdown

� Start-up following turnaround

� Consequences of deviation

� Steps required to correct or avoid deviation

74

SOPsSOPs

� Must be readily available to employees

� Must be reviewed as needed to ensure they reflect current operating practice.

� Must cover:


� Technology and equipment

� Facilities

� SOPs must be certified annually that they are correct and accurate.

� Must be readily available to employees

� Must be reviewed as needed to ensure they reflect current operating practice.

� Must cover:


� Technology and equipment

� Facilities

� SOPs must be certified annually that they are correct and accurate.

75

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PROCEDURES (SOPs)PROCEDURES (SOPs)

� DOCUMENTS

� Operating procedures for all phases� Lockout/tagout� Confined space entry� Line breaking� Other types of permit systems� Process logs

� INTERVIEWS� All operator levels and shifts� Operational managers and supervisors� Certifying official� Procedure developer

� DOCUMENTS

� Operating procedures for all phases� Lockout/tagout� Confined space entry� Line breaking� Other types of permit systems� Process logs

� INTERVIEWS� All operator levels and shifts� Operational managers and supervisors� Certifying official� Procedure developer

Opening

process

systems

PROCEDURES (SOPs)PROCEDURES (SOPs)

DOCUMENTATION� Review the procedure format and check for

consistency between processes.

� Document the dates of certification and who is the certifying official.

� Review the certification process to determine how, or if, the procedures are reviewed prior to certification.

� Cross check changes made with the Management of Change procedures.

� Review the safe work practices and verify that they are being used in the day to day operations. This includes contractors. Especially note line breaking activities.

DOCUMENTATION� Review the procedure format and check for

consistency between processes.

� Document the dates of certification and who is the certifying official.

� Review the certification process to determine how, or if, the procedures are reviewed prior to certification.

� Cross check changes made with the Management of Change procedures.

� Review the safe work practices and verify that they are being used in the day to day operations. This includes contractors. Especially note line breaking activities.

Plant

Operating

Procedures

Safe Work Practices (SWPs)Safe Work Practices (SWPs)

� Must be developed and implemented to provide for the control of hazards during work activities such as:

� Lock-out/Tag-out

� Confined space entry

� Opening processes, piping or equipment

� Must be developed and implemented to provide for the control of hazards during work activities such as:

� Lock-out/Tag-out

� Confined space entry

� Opening processes, piping or equipment

78

SWPs are for:

• Operators

• Maintenance personnel

• Contractors

• Lab personnel

• Or other support

personnel

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TrainingTraining

� PSM specific training is required

� Must cover:

� Safety and health hazards associated with the covered process

� Safe work practices

� Procedures

� Refresher training is required every 3 years or as needed to ensure employees are complying with all PSM requirements(Change In Procedures).

� PSM specific training is required

� Must cover:

� Safety and health hazards associated with the covered process

� Safe work practices

� Procedures

� Refresher training is required every 3 years or as needed to ensure employees are complying with all PSM requirements(Change In Procedures).

79

ContractorsContractors

� Contractors involved in or around a covered process must be informed of required PSM elements.

� Contract work includes:

� Maintenance and repair

� Turn around

� Major renovations

� Specialty knowledge or services

� Does not include support services not involved with the covered process, like laundry or vending machine supply

� Contractors involved in or around a covered process must be informed of required PSM elements.

� Contract work includes:

� Maintenance and repair

� Turn around

� Major renovations

� Specialty knowledge or services

� Does not include support services not involved with the covered process, like laundry or vending machine supply

80

Emergency Action Plans (EAP)Emergency Action Plans (EAP)

� Must have EAP for entire facility

� EAP must have provisions for small releases of HHCs

� Develop a Early Warning Method for Releases

� Train on the Meaning of the Alarms

� Develop Emergency Evacuation Written Plans, Evacuation Maps & Assembly Points

� Must have EAP for entire facility

� EAP must have provisions for small releases of HHCs

� Develop a Early Warning Method for Releases

� Train on the Meaning of the Alarms

� Develop Emergency Evacuation Written Plans, Evacuation Maps & Assembly Points

81

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Incident InvestigationsIncident Investigations

� Must be initiated ASAP, but within 48 hours

� Team must include:

�Person knowledgeable in the process involved

� Includes contractor if work of the contractor involved

�Other persons with appropriate knowledge of the covered process

� Must be initiated ASAP, but within 48 hours

� Team must include:

�Person knowledgeable in the process involved

� Includes contractor if work of the contractor involved

�Other persons with appropriate knowledge of the covered process

82

Incident Investigation ReportIncident Investigation Report� Report must be produced with the following:

� Date of incident

� Date of start of investigation

� Description of incident

� Factors contributing to incident

� Recommendations

� System must be established to promptly address recommendations and findings of report

� Resolutions and corrective action must be documented

� Report must be produced with the following:

� Date of incident

� Date of start of investigation

� Description of incident

� Factors contributing to incident

� Recommendations

� System must be established to promptly address recommendations and findings of report

� Resolutions and corrective action must be documented

83

INCIDENT INVESTIGATIONSINCIDENT INVESTIGATIONS

DOCUMENTS

� PSM incident investigations� Near miss reports� EPA spill reports� Fire brigade call outs� Hazmat team call outs� Operations logs

(for shutdowns or upsets)� “Emergency” work orders

DOCUMENTS

� PSM incident investigations� Near miss reports� EPA spill reports� Fire brigade call outs� Hazmat team call outs� Operations logs

(for shutdowns or upsets)� “Emergency” work orders

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Compliance AuditCompliance Audit

� To ensure that PSM is effective, employers must certify every 3 years that they have evaluated compliance with the standard

� Must be completed by at least on person knowledgeable in the process

� Report must be developed and documented

� Deficiency corrections must be documented

� Last two compliance audits must be kept on file

� To ensure that PSM is effective, employers must certify every 3 years that they have evaluated compliance with the standard

� Must be completed by at least on person knowledgeable in the process

� Report must be developed and documented

� Deficiency corrections must be documented

� Last two compliance audits must be kept on file

85

Trade SecretsTrade Secrets

� Employers must make all necessary information required to comply with PSM, regardless of trade secrets, available to persons involved in developing or creating:

� Compiling process safety information

� PHAs

� SOPs

� Incident investigations

� Emergency planning and response

� Compliance audits

� Confidentiality agreements are allowed

� Employers must make all necessary information required to comply with PSM, regardless of trade secrets, available to persons involved in developing or creating:

� Compiling process safety information

� PHAs

� SOPs

� Incident investigations

� Emergency planning and response

� Compliance audits

� Confidentiality agreements are allowed

86

Typical Standards CitedTypical Standards Cited

� 1910.119 PSM

� 1910.147 Lock and Tag

� 1910.120 Hazwoper

� 1910.1200 Hazcom

� 1910.146 Confined Space

� 5A.001 General Duty

� 1910.307 Hazardous Locations

� 1910.119 PSM

� 1910.147 Lock and Tag

� 1910.120 Hazwoper

� 1910.1200 Hazcom

� 1910.146 Confined Space

� 5A.001 General Duty

� 1910.307 Hazardous Locations

87

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Most Frequent NEP PSM CitationsMost Frequent NEP PSM Citations

� (f)(1) Operating procedures…………..

� (d)(3) PSI pertaining to equipment ….

� (e)(3) PHA specific criteria……………

� (j)(4) MI Inspection & Testing ………..

� (e)(5) PHA recommendation ...………

� (l)(1) MOC implementation …………..

� (f)(1) Operating procedures…………..

� (d)(3) PSI pertaining to equipment ….

� (e)(3) PHA specific criteria……………

� (j)(4) MI Inspection & Testing ………..

� (e)(5) PHA recommendation ...………

� (l)(1) MOC implementation …………..

1910.119

88

Tools for Additional PSM AssistanceTools for Additional PSM Assistance

� OSHA Website

� www.osha.gov

� Chemical Safety Board Website

� www.csb.gov

� Local Area OSHA Office – Ask Lots of Questions!

� OSHA Website

� www.osha.gov

� Chemical Safety Board Website

� www.csb.gov

� Local Area OSHA Office – Ask Lots of Questions!

89

PSM Checklist

Use this checklist to help determine employer compliance with the Process Safety Management Standard issued by the Occupational Safety and Health Administration. Please note that the checklist does not include all of the standard’s

requirements and does not reflect all OSHA letters of interpretation or compliance directives in particular

situations.

There are 3 elements to a review of a PSM program:

1. Documentation review – examination of the documentation of the programs required by the standard. 2. Field Inspection & Verification – examination of the physical covered process; its equipment, piping,

instrumentation, procedures, and operation. 3. Interviews – discussions with employees and contractors to determine if the implemented program matches the

program outlined in the documentation.

In order to gather the information needed to audit a PSM program the following questions need to be asked for each PSM program element

� Who � What � When � Where � Why � How

� Who – Who is responsible for developing and implementing each of the program elements? � What – What are the requirements and contents of each program element?

� When – When are the required actions for each element completed and when were they required to be completed?

� Where – Where have actions been implemented or changed? � Why – Why have the implementation decisions and priorities been made as recorded in the documentation?

� How – How is the program implemented and how is the program’s effectiveness evaluated and improved?

An essential part of verifying program implementation is to audit the flow of information and activities among the elements. When information in one element is changed or when action takes place in one element that affects other

elements, an auditor/reviewer should examine a sample of the related elements to see if the appropriate changes and followup actions have taken place.

The following example demonstrates the interrelationship among the elements: During a routine inspection of equipment (Mechanical Integrity), the maintenance worker discovers a valve that no

longer meets the applicable code and must be changed. Because the type of valve is no longer made, a different type of valve must be selected and installed (Management of Change). The type of valve selected may mandate different steps

for the operators (Operating Procedures) who will require training and verification in the new procedures (Training). The rationale for selecting the type of valve must be made available for review by employees and their representatives 90

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OSHA PSM SUMMARY and

TAKE AWAYS

OSHA PSM SUMMARY and

TAKE AWAYS

� PSM is a Comprehensive Standard

� Although it was Promulgated in 1991, Catastrophes Continue to Occur

� Written PSM program - Implemented into production processes/operations

� Need all levels of Management involved –Not Just a designated individual responsibility

� PSM is a Comprehensive Standard

� Although it was Promulgated in 1991, Catastrophes Continue to Occur

� Written PSM program - Implemented into production processes/operations

� Need all levels of Management involved –Not Just a designated individual responsibility

91

Questions?Questions?

92

Contact InformationContact Information

Allen Grisar

Milwaukee Area OSHA Office

414-297-3315

[email protected]

Allen Grisar

Milwaukee Area OSHA Office

414-297-3315

[email protected]