1 PSM & RMP = OMG! Inspected Lately? Be Prepared Presented by: Raymond C. Davis, CHMM (Fellow), CIPS, CESM, REP, CET, CES, CEHMM President/CEO RL Environmental Consulting & Training Inc. Steve Williams, CHMM President Bighorn Environmental Safety& Health, LLC, PSM & RMP = OMG! Inspected Lately? Be Prepared Process Safety Management of Highly Hazardous Chemicals 29 CFR 1910.119 (PSM) and Chemical Accident Prevention Provisions (CAP) and Risk Management Program (RMP) 40 CFR Part 68 PSM & RMP = OMG! Inspected Lately? Be Prepared Objectives of this Presentation Presenters will: Provide an overview of recent Federal and State OSHA Process Safety Management (PSM) and EPA's CAP (Program 3) Prevention Program and RMP inspections/audits. Review the drivers for change - U.S. Chemical Safety Board (CSB) Recommendations and Executive Order 13650, Improving Chemical Facility Safety and Security.
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PSM & RMP = OMG! Inspected Lately? Be Prepared...To prevent and mitigate accidental releases of regulated substances that present imminent and substantial endangerment to public health
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PSM & RMP = OMG!Inspected Lately? Be Prepared
Presented by:
Raymond C. Davis, CHMM (Fellow), CIPS, CESM, REP, CET, CES, CEHMMPresident/CEORL Environmental Consulting & Training Inc.
Steve Williams, CHMMPresidentBighorn Environmental Safety& Health, LLC,
PSM & RMP = OMG!Inspected Lately? Be Prepared
Process Safety Management of Highly Hazardous Chemicals 29 CFR 1910.119 (PSM)
and Chemical Accident Prevention Provisions (CAP) andRisk Management Program (RMP) 40 CFR Part 68
PSM & RMP = OMG!Inspected Lately? Be Prepared
Objectives of this PresentationPresenters will:
Provide an overview of recent Federal and State OSHA Process Safety Management (PSM) and EPA's CAP (Program 3) Prevention Program and RMP inspections/audits.
Review the drivers for change - U.S. Chemical Safety Board (CSB) Recommendations and Executive Order 13650, Improving Chemical Facility Safety and Security.
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PSM & RMP = OMG!Inspected Lately? Be Prepared
Objectives of this Presentation (continued)
Presenters will: Explain how PSM and CAP/RMP inspection/audit
criteria has changed with more focus on Best Management Practices (BMP) methodology selection.
Review the top 29 questions/items that an inspector will request from your facility.
Historic Incidents That Led to PSM/RMP
Bhopal, India (1984)–Methyl Isocyanate release
Historic Incidents That Led to PSM/RMP
Presented by:
Raymond C. Davis, CHMM (Fellow) CIPS,CESM,REP,CET,CES,CEHMM
President/CEORL Environmental Consulting & Training Inc.
Steve Williams, CHMMPresident
Bighorn Environmental Safety& Health, LLC,
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Current Incidents Associated with PSM/RMP
West, TX (2013)–15 deaths, 100+ injuries
Fertilizer Plant Explosion
Current Incidents Associated with PSM/RMP
La Porte, TX (November 15, 2014)
–- 4 deaths, 1 injured- Methyl mercaptan, toxic chemical release
La Porte, TX Incident Review
- First: Interconnections between the methyl mercaptan supply line and a chemical vent system, allowed a toxic leak into an unexpected location, where workers were exposed with fatal consequences.
- Second: The chemical vent system - had a design shortcoming that allowed liquid to accumulate inside. Manually drained by operators to prevent safety issues from interconnected equipment, such as reactors.
-Third: The vent drain exposed to whatever chemicals were drained from the vent system to open atmosphere.
- Fourth: Inadequate building ventilation design and the ventilation fans were not, in fact, working at the time of the incident.
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Regulation History
Chemical Emergency Preparedness Program. 1985 Mandated by USEPA
SARA Title III.
EPCRA
Hazard Communication Standard New HCS 2012 (GHS)
Clean Air Act Amendments 1990
What is Process Safety Management (PSM)?
PSM is a regulation that provides a 14 Element System for employers to
manage the process of Highly Hazardous Chemicals
What’s the Purpose of PSM?
PSM is intended to “prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable or explosive chemicals…that may result in toxic, fire, or explosion hazards.”
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PSM applies to…
Companies that process Highly Hazardous Chemicals (HHC)
List in Appendix A (137)
Flammable liquids and gases in process quantities of 10,000#
or more
What is the purpose of CAP/RMP?
To prevent and mitigate accidental releases of regulated substances that present imminent and substantial endangerment to public health and the environment. (Chemical Accident Prevention Provisions)
40 CFR 68.130 List of Regulated Substance Thresholds
- Tables 1 and 2
*154 Regulated Toxic Substances
- Tables 3 and 4
*126 Regulated Flammable Substances
PSM & RMP = OMG!Inspected Lately? Be Prepared
EPA CAP Subpart FList of Regulated SubstancesFor Accidental Release PreventionTables 1 to 4
TQ # OSHA PSMList of Hazardous Chemicals, Toxics, ReactivesAppendix A
§ 68.65 Process Safety Information (PSI) PSM standard § 1910.119(d).
§ 68.67 Process Hazard Analysis (PHA) PSM standard § 1910.119(e).
§ 68.69 Operating Procedures (OP) PSM standard § 1910.119(f).
§ 68.71 Training PSM standard § 1910.119(g).
§ 68.73 Mechanical Integrity (MI) PSM standard § 1910.119(j).
§ 68.75 Management of Change (MOC) PSM standard § 1910.119(l).
§ 68.77 Pre-Startup Review (PSSR) PSM standard § 1910.119(I).
§ 68.79 Compliance Audits PSM standard § 1910.119(o).
§ 68.81 Incident Investigation (II) PSM standard § 1910.119(m)
§ 68.83 Employee Participation (EP) PSM standard § 1910.119(c).
§ 68.85 Hot Work Permit PSM standard § 1910.119(k). § 68.87 Contractors PSM standard § 1910.119(h).
*Subpart E Emergency Response (ER) PSM standard § 1910.119(n). Trade Secrets PSM standard § 1910.119(p).
SUMMARY OF PROGRAM 3 PREVENTION PROGRAM (40 CFR PART 68, SUBPART D) and OSHA PSM (29 CFR 1910.119)
Current PSM/RMP Issues
December 1, 2014 U.S. Chemical Safety Board (CSB)- "Modernize U.S. Process Safety Management
Regulations" - “Most Wanted Safety Improvement” for PSM and
RMP reform- Over 20 years of CSB recommendations
August 1, 2013 Executive Order 13650, Improving Chemical Facility Safety and Security - Established Federal Working Group and Improve Operational Coordination with State, Local and Tribal governments
- Develop PSM/RMP Plan for Expanded Coverage- DHS consideration of additions to CFATS COI List
PSM/RMP Recommendations Review
Expand coverage to include the oil and gas exploration and production sector
Cover reactive chemical hazards.
Revise Chemical Accident Release Prevention Provisions in 40 CFR 68 to cover catastrophic reactive hazards
Additional management system elements requiring use of leading and lagging indicators to drive process safety performance
Provide stop work authority to employees
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PSM/RMP Recommendations Review (Cont.)
Update PHA requirements to include documented use of:
- Inherently safer systems
- Hierarchy of controls / Risk reduction*Goal of As Low As Reasonably Practicable (ALARP)
*Layers of Protection Analysis (LOPA)
*Recognized and Generally Accepted Good Engineering Practices (RAGAGEP)
- Damage mechanism hazard reviews
- Sufficient / adequate safeguards
Develop more explicit requirements for: - Facility/process siting
- Human factors, including fatigue
RMP Recommendations Review In addition to PSM program related enhancements
Expand coverage to include: - Reactive chemicals- High and/or low explosives - Ammonium nitrate as regulated substances - Change enforcement policies for retail facilities
Enhance development and reporting of worst case (WCS) and alternate release scenarios
Add new prevention program requirements to include: - Automated detection and monitoring- Contractor selection and oversight- Public disclosure of information
Petroleum refineries- Attributes of goal-setting regulatory approaches
RMP Recommendations Review (Cont)
In addition to PSM program related enhancements
Accidental Release Prevention Requirements-CAP under CAAChemical Accident Prevention Provisions under 40 CFR Part 68 *Goal: Reduce the risk of major accidents to as equivalent to As Low As Reasonably Practicable (ALARP)
“Enforce through the Clean Air Act’s General Duty Clause, section 112(r)(1), 42 U.S.C. §7412(r)(1) the use of inherently safer systems analysis and the hierarchy of controls to the greatest extent feasible when facilities are establishing safeguards for identified process hazards.”
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CSB:PSM/RMP Recommendations
CSB submitted a comprehensive response to OSHA and the EPA Requests for Information (RFI) detailing needed improvements to the existing regulations
RFI resulted from Executive Order 13650, Improving Chemical Facility Safety and Security
To view full list of recommendations related to Appendix A: CSB Recommendations for Process Safety Management Reform access the following link:
National Association of Chemical Distributors (NACD) Representative
Mr. Galassi stated that HCL solutions at the 1% level is covered by PSM
- Change communicated through an Interpretation letter
- 3/2015 U.S. Supreme Court (Perez v. Mortgage Bankers Association)
- Interpretation changes of rules
- Feds don't have to follow public notice & comment procedures
ACC and NACD have filed suit against OSHA
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PSM & RMP = OMG!New PSM Enforcement Policy
EXAMPLE (4) 55-gallon drums of 48 percent by aqueous hydrofluoric
acid solution are stored in a warehouse on a single pallet.
Does a TQ of hydrogen fluoride exist? (TQ = 1,000#)
- At 1.15 g/ml, 55 gallons weighs 527.85#
- At 48%, the weight of HF in each drum is 253.37# x 4 = 1,013.5#
- The aggregate amount of HF is 1013.5#
- Storage of 4 drums on a single pallet is considered a single process
- TQ of HF is present
PSM Covered
PSM & RMP = OMG!Inspected Lately? Be Prepared
Other OSHA Changes:
- Field Operations Manual (FOM) 4-22-11
PSM Covered Chemical Facilities NEP 11-29-11
- 2 Categories
* NH3 for refrigeration and the only HHC
* All other Facilities
PSM Petroleum Refinery NEP 8-18-09
NEP for Programmed/Unprogrammed Inspections
1910.119(c): EMPLOYEE PARTICIPATION
I. PROGRAM SUMMARY
The intent of this paragraph is to require employers to involve employees at an elemental level ofthe PSM program. Minimum requirements for an Employee Participation Program for PSM mustinclude a written plan of action for implementing employee consultation on the development ofprocess hazard analyses and other elements of process hazard management contained within1910.119. The employer must also provide ready access to all the information required to bedeveloped under the standard.
II. QUALITY CRITERIA REFERENCES
A. 1910.119(c): Employee Participation
III. VERIFICATION OF PROGRAM ELEMENTS CRITERIA
REFERENCE
MET
Y/NA. Records Review
1. Does a written program exist regarding employee participation?
Field Note Reference(s):
.119(c)(1)
2. Does the written program include consultation with employees andtheir representatives on the conduct and development of process hazardanalyses and on the development of other elements in the PSMstandard?
Field Note Reference(s):
.119(c)(2)
3. Does the written program provide employees (including contractoremployees) and their representatives access to process hazard analysesand all other information developed as required by the PSM standard?
- Paragraph (e)(7)(i)(d) Positive pressure w/clean makeup air
* Use of ordinary wiring, clocks, digital display units
13) Descriptions of Safety systems (interlocks, detection or suppression systems) Company Response – EHS Staff
- PSI-PHA Gap Process 001 to 0?? – Dated
- MI Equipment List P&ID# 001-0?? – Dated
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PSM & RMP = OMG!The 29 Questions/Items Request
14) Lockout-tag out Program and Specific Procedures pertaining to the process
Company Response – EHS/Maint. Staff
- LOTO Standard-Permits (Line-breaking) Dated* LOTO Energy Control Inspection Form
* LOTO Emergency Lockout Removal Form
- PSM MI Written Program Dated (PM Schedule Software)
- PSM MI Equipment List P&ID# 001-0?? Dated
15) Safety Data Sheets for the process chemicals (ingredients and final product). (RM, Batch and SDS-GHS)
Company Response – EHS Staff
PSM & RMP = OMG!The 29 Questions/Items Request
16) Engineering Data and Documentation on interaction of chemicals with process components. This includes process component descriptions and manuals (i.e., pump data, piping requirements, etc) as well as original design specifications.
Company Response – EHS/Eng./Maint. Staff
- PSM PSI-PHA Gap Process 001 to 0?? – Dated
- PSM MI Equipment List P&ID# 001-0?? – Dated
- Current P&IDs - Dated
PSM & RMP = OMG!The 29 Questions/Items Request
17) Operating Procedures pertaining to the Process (listing of all SOP's) Company Response – EHS Staff/PSM Team
- PSM Operating Procedures Standard Dated
- Current PSM SOPs Table of Contents
- Current Non-PSM SOPs Table of Contents
18) Compliance Audit reports (last two) Every 3 years
29 CFR 1910.106(iv) Ventilation Inside Storage Room Design- Air changes occur approximately 30 times per hour vs 6 per OSHA
- Makeup ventilation is 39,600CFM (not counting exhaust)
- Process area is 6,600 square ft (120 ft x 55 ft)
- Current Process Area Ventilation Diagrams and the Past HVAC
Contractor email that had gone out of business.
Process Area Ventilation Review
Old system had (2) 42” fans exhausting 6500 CFM and (2) 30” Fans exhausting 6000 CFM each totaling 25,000 CFM total exhaust.
Process room dimensions are 120ft x 55ft x12ft high = 79,200 cubic feet.
Past HVAC contractor recommended room to be ventilated a minimum of 30 air changes per hour equating to the need of 39,600 CFM.
Past HVAC contractor recommended installation of (2) natural gas fired make-up air units rated at 20,000 CFM each and supplement existing wall exhaust fans in the process area with new installation of wall or roof exhaust fan rated at (39,600 – 25,000) 14,600 CFM.
Serious NOV $5K .119(d)(3)(i)(H) “failed to maintain the design documentation of the ventilation system for the process”
PSM & RMP = OMG!The 29 Questions/Items Request
29) Hot work permits for the past 6 months for the covered process. This should include the Mechanical Integrity or SOP section covering Hot Work.
Company Response – EHS/Eng./Maint. Staff
- Hot Work Standard-Permit Dated
- Fire Watch Permit Dated
- PSM MI Written Program Dated (ITPM)
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This OSHA PSM Audit started in May and finished in November
Proposed NOV Penalties 27KHigh GBP and Reductions 19K
PSM Consultant and Legal were present for all onsite CHSO Team visits
Questions?
PSM & RMP = OMG!Inspected Lately? Be Prepared
Thank you for attending!
Raymond C. Davis, CHMM (Fellow), CIPS, CESM, REP, CET, CES, CEHMMPresident/CEORL Environmental Consulting & Training Inc.
Steve Williams, CHMMPresidentBighorn Environmental Safety& Health, LLC,