Process Safety Management
a. Required by the Environmental Protection Agency's (EPA) Clean Air Act Amendments (CAAA), Section 304
b. Promulgated - February 24, 1992
c. 5 year implementation
d. Proactive identification, evaluation, and mitigation or prevention of chemical releases that could occur as a result of failures in processes, procedures, or equipment
e. 130 highly hazardous chemicals (HHC’s)
f. 10,000 lb. or more of flammable materials that are used at or above their boiling points
g. Pyrotechnics and explosives manufacturers
h. More than 28,000 facilities affected
i. Exemptions:
- fuels used for workplace consumption
- Comfort heating
- Gasoline for vehicles
g. Mandated by CAAA, Section 112 (r), 40 CFR Part 68
h. Promulgated - May 24, 1996
i. Published Federal Register - June 20, 1996
j. More than 100,000 facilities affected
k. Designed to help reduce risk of accidental release of hazardous substances
l. 3 years to implement
m. Affects owners of a stationary source with regulated substances above a threshold quantity (TQ):
- 77 acutely toxic
- 63 flammable
- Department of Transportation (DOT) classified explosive substances
EPA’s Visions for Accidental Release Prevention
a. Emphasize community right-to-know
b. Let information drive action
c. Focus the program at the local level
- EPA support
d. Coordinate communications at local level
Key Features of RMP
a. Prevention program
- 7-elements “mini-PSM” program
- 14 elements OSHA-PSM program expanded to address offsite effects
b. Emergency response program
c. Risk management plan
d. Electronic submission to state and LEPC
- Available to public
e. Regulatory audits
f. 3 Program levels
g. Management system
h. Offsite consequence analysis
- Worst-case scenario
- Alternative release scenario
i. 5-year accident history
j. Summarizes key elements of the RMP program
- Tells a story
- Hazards at the site
- Accident history
- Potential offsite consequences
- Prevention steps
- Response program
Exemptions to Threshold Quantity
a. Articles
b. Laboratories
c. Uses:
- Structural components
- Janitorial maintenance
- Foods, drugs, cosmetics, or other personal items
- Present in process water or non-contact cooling water
- Compressed air or as part of combustion
EPA’s Regulatory Approach
a. Performance-based approach
- Similar to OSHA’s PSM
b. Build on existing programs and standards
c. Scale the requirements to fit the risk
d. Coordinate with OSHA and DOT
Requirements of 112 (r)
a. Established a general duty clause to:
- Identify hazards that may result from releases
- Design and maintain a safe facility
- Minimize the consequences or releases
b. Required EPA to promulgate a list of substances and set thresholds
c. Required EPA to develop a risk management program (RMP) rule
d. Register with EPA
e. Conduct a hazard assessment
f. Develop a prevention program
g. Develop an emergency response program
h. Provide a summary (RMP) to
- EPA
- States
- Locals
- Public
Basic Principles
a. Build on EPCRA
b. Emphasize community right-to-know
c. Focus the program at the local level
- Where the risk is found
d. Accommodate small business concerns
- Provide model RMPs
* Ammonia
* Warehouses with chemicals
* Batch processors
* Refineries/gas plants
- Provide reference tables for offsite consequences analysis
Manufacturing Industries Affected
a. Chemical manufacturers
- Industrial Organics & Inorganics
- Paints
- Pharmaceuticals
- Adhesives,
- Sealants
- Fibers
b. Petrochemical Products
- Refineries
- Industrial Gases
- Plastics and Resins
- Synthetic Rubber
Non-Manufacturing Affected
a. Non-Manufacturing Facilities affected
- Utilities
* Electric and Gas
- Public Sources
* Drinking Water and Waste Water Treatment
- Agriculture
* Fertilizers, Pesticides
Other Manufacturing
a. Electronics
b. Semiconductors
c. Paper
d. Fabricated metals
e. Industrial machinery
f. Furniture
g. Textiles
Other Industries
a. Food and Cold Storage
b. Propane Retail
c. Warehousing
d. Wholesalers
e. Federal sources
- Military and Energy Installations
PSM vs. RMP Requirements
a. PSM’s concern - potential hazard and protection of employees inside a regulated area
b. RMP’s concern - potential incidents that may cause environmental and health hazards outside facility boundaries
c. Editorial changes to PSM to make text consistent with the CAAA's language
Hazard Assessment
a. Offsite consequence data
- Population estimate
- Public receptors
- Environmental receptors
b. Every 5 years
c. Within 6 months of a change that increases or decreased distance by a factor of 2 or more
Overview Worst-Case Scenario (WCS)
a. Greatest quantity from vessel or piping
- May include administrative controls
b. Toxic gases
- Quantity released in 10 minutes
c. Toxic liquids
- Instantaneous spill to ground; volatilization; passive mitigation
d. Toxic gases liquefied by refrigeration
e. All flammable substances
- Quantity for vapor cloud explosion
f. One worst case for each process
g. One worse case representing all toxic substances
h. Additional worst case(s) different public receptors
i. Other considerations
- Smaller quantities at higher temperature or pressure
- Source boundary proximity
Alternative Release Scenario (ARS)
a. More likely than a worst case scenario
b. Much reach endpoint offsite
c. One scenario representative of all flammables
ARS Selection
a. Accident history events
b. Process hazard analysis events
c. Worse case with mitigation
d. Example scenarios:
- Piping or hose failures
- Seal failures
- Vessel overfilling or venting
List of Substances and Thresholds
a. Focuses on lethal effects resulting from acute exposures
b. Includes mandated substances
Mandated Substances
- Ammonia
- Anhydrous Ammonia
- Anhydrous Hydrogen Chloride
- Anhydrous Sulfur Dioxide
- Bromine
- Chlorine
- Ethylene Oxide
- Hydrogen Cyanide
- Hydrogen Fluoride
- Hydrogen Sulfide
- Methyl Chloride
- Methyl Isocyanate
- Phosgene
- Sulfur Trioxide
- Toluene Diisocyanate
- Vinyl Chloride
Toxic Substances
a. Extremely hazardous substances under SARA
b. Gases and highly volatile liquids
c. Vapor pressure > 10 mmHg
d. Thresholds ranging from 500-2,000 lbs.
e. Thresholds based on toxicity and volatility
Flammable Substances
a. NFPA 4
- Most dangerous
b. Flammable gases and volatile flammable liquids that could create vapor cloud explosions
c. Thresholds set at 10,000 lbs.
Auditing the Program
Conduct audits of the management system
Program Eligibility Criteria
Three Programs
Program 1 - No impact
a. Register
b. Conduct worst-case hazard assessments
c. Certify no off-site consequences for worst-case scenario
d. Ensure inclusion in LEPC plan
e. Submit RMP document above
Program 3 - Full RMP
a. One comprehensive prevention program that:
- Protects workers
- The public
- The environment
b. Hazard review information
- Hazards
- Controls
- Mitigation
- Changes
c. Register
d. Conduct worst-case and other hazard assessments
e. Implement comprehensive prevention steps (OSHA PSM plus...)
f. Develop emergency response plan
g. Submit RMP
h. Process is subject to OSHA's PSM
i. Processes in specific SIC codes
- Pulp Mills (2611)
- Chlor-Alkali (2812)
- Industrial Inorganic (2819)
- Plastics and Resins (2821)
- Cyclic Crudes (2865)
- Industrial Organics (2869)
- Nitrogen Fertilizers (2873)
- Agricultural Chemicals (2879)
- Petroleum Refineries (2911)
Program 2 - Streamlined Prevention Program
The process is not eligible for Program 1 or 3
a. Statutory requirements
b. Training
c. Maintenance
d. Safety Precautions
e. Monitoring
f. Types of sources:
- Less complex; fewer changes
- Ideal model program and plans
g. Capture good management practices from PSM but less documentation
h. Take advantages of other rules and standards
i. Take advantages of equipment manufacturer or vendor information
j. Process information (SIC, chemicals)
k. List rules, standards, design codes
l. Hazard review information
- Hazards
- Controls
- Mitigation
- Changes
m. Register
n. Conduct worst-case and other hazard assessments
o. Implement seven elements of prevention program
p. Develop emergency response plan
q. Submit RMP
Comparison of Program Requirements
Hazard Assessment
Program 1
Worst-case analysis
Alternative releases
5-year accident history
Program 2
Worst-case analysis
Alternative releases
5-year accident history
Program 3
Worst-case analysis
5-year accident history
Prevention Program
Program 1 Program 2 Program 3
Certify no additional Safety Information Process Safety Information
steps Required Hazard Review Process Hazard Review
Operating Procedures Operating Procedures
Training Training
Maintenance Mechanical Integrity
Incident Investigation Incident Investigation
Compliance Audit Compliance Audit
Management of Change
Pre-Startup Review
Contractors
Employee Participation
Hot Work Permits
Emergency Response Program
Program 1 Program 2 Program 3
Coordinate with Local Develop Plan Develop Plan
Responders and Program and Program
Risk Management Plan Content
Program 1 Program 2 Program 3
Executive Summary Executive Summary Executive Summary
Registration Registration Registration
Worst-Case Data Worst-Case Data Worst-Case Data
5-Year Accident History Alternative Release Data Alternative Release Data
Certification. 5-Year Accident History 5-Year Accident History
Prevention Program Data Prevention Program Data
Emergency Response Data Emergency Response Data
Certification Certification
Editorial Changes
OSHA PSM Requirements EPA Program 3 Requirements
An evaluation of the consequences An evaluation of the consequences
of deviations, including those of deviations
affecting the safety and health
of employees
The identification of any previous The identification of any previous
incident which had a likely potential incident which had a likely potential
for catastrophic consequences in for catastrophic consequences
the workplace
A qualitative evaluation of a range A qualitative evaluation of a range
of possible safety and health effects of possible safety and health
of failure of controls on employees effects of failure of controls
in the workplace
The employer shall investigate each The owner or operator shall
incident which resulted in, or could investigate each incident which
reasonably have resulted in a catastrophic resulted in, or could reasonably
release of a highly hazardous chemical have resulted in a catastrophic
in the workplace release of a regulated substance
Language Comparison
OSHA’s - PSM EPA’s - RMP
Employer Owner or Operator
Highly Hazardous Chemicals Regulated Substances
Facility Stationary Source
Standard Rule
Workplace Impact Off-Site Consequences
Compliance Procedures
a. Develop an inventory of substances used, stored, manufactured, processed, handled or moved, or any combination of the listed activities
b. Compare the inventory with the TQ, as required
Management System
a. Develop a management system to oversee the implementation of the RMP elements
b. Identify single person or position who has overall responsibility for:
- Development
- Implementation
- Integration of the RMP
Process Safety Information
a. Block flow or process flow diagrams
b. Maximum intended inventory
c. Establish safe limits of the operating parameters
d. Evaluate consequences in deviations of process conditions
e. Equipment information
f. Verify equipment design with regulatory requirements/standard
Process Hazard Analysis
a. Document hazard analysis:
- Nature of the hazard
- Cause of the hazard
- Consequences of the hazard
- Actions to be considered to further protect personnel
b. Document follow-up steps based on recommendations
c. Document previous incidents with the potential to cause catastrophic conditions
d. Document hazards associated with human factors and facility siting
Operating Procedures
a. Develop clear operating procedures addressing steps for each process regarding
- Safe operating limits of processes
- Equipment
b. Provide precautionary instructions to prevent exposure to hazards
c. Develop operating procedures for safety systems
d. Conduct annual review of operating procedures
e. Develop procedures for lockout/tagout, confined space entry, etc.
Employee Training
a. Document training for personnel in the process, operating procedures, and safe work practices applicable to the job tasks
b. Maintain records of training indicating the means used to verify that the employee understood the training
Maintenance (Mechanical Integrity)
a. Provide written procedures to maintain the structural integrity of process equipment
b. Document training for employees involved in maintenance of the process equipment
c. Verify inspections and testing of equipment and deficiencies are corrected
d. Document that spare parts are suitable for the appropriate application
Incident Investigation (Accident Investigation)
a. Incident reporting:
- The date of the incident
- Date of the investigation
- Description of the incident
- Factors contributing to the incident, and recommendations that resulted
b. Verify that the recommendations in the incident report were promptly addressed and resolved
c. Identify root causes as well as initiating events
Compliance Audits
a. Evaluate compliance with program every three years
b. Conduct with at least one person knowledgeable in process
c. Develop report of findings Determine/develop a response to each finding, document that deficiencies have been corrected
d. Retain two most recent audit reports
Management of Change
a. Provide written procedures to manage change to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process
b. Verify that employees in operations and maintenance are trained accordingly
c. Provide evidence that changes are documented
Pre-Startup Review
a. Document that construction and equipment is in accordance with design specifications
b. Review documentation showing that safety, operating, maintenance, and emergency procedures are in place and adequate
c. Document that a PHA was performed, and recommendations were resolved and implemented
d. Verify that modified facilities meet requirements in Management of Change procedures
e. Verify that employee training is completed
Contractors
a. Must established a screening process when hiring and use contractors
b. A site injury and illness log for contractors must be maintained
c. The contractor must ensure that each contract employee is trained in the work practices necessary to safely perform his/her job
Employee Participation
a. Must develop a written plan of action regarding the implementation of employee participation.
b. Required to train and educate employees and to inform all affected employees of the findings from any incident investigations.
c. Must consult with employees and employee representatives:
- Development of PHA and other elements
- Hazard assessments
- The development of chemical accident prevention
d. Must provide access to these records.
Permit Systems
a. A work authorization notice or permit system should be developed
- To describe the steps the maintenance supervisor, contractor representative or other person need to follow in order to obtain the necessary clearance to get the job done.
b. These procedures need to address such issues as
- Lockout/tagout procedures
- Line breaking procedures
- Confined space entry procedures
- Hot work permits
c. Procedures must provide clear steps to follow once the job is completed to provide closure for those that need to know the job is completed and equipment can be returned to normal operations.
Emergency Planning and Response
a. Document that an emergency plan has been established and implemented in accordance with 29 CFR 1910.38 and 1910.120, as applicable
b. Emergency action plan that include procedures for handling releases
c. Document specific actions to be taken in response to an accidental release of a regulated substance to protect humans and the environment
- Conduct drills
- Exercise to test plan
Emergency Response Plan - Basic Requirements
a. Emergency response plan
b. Procedures for use of emergency response equipment and for it inspection, testing, and maintenance
c. Training for all employees in relevant procedures
d. Procedures to review and update of the plan to reflect changes at the facility and ensure that employees are informed of changes
Elements - Legislative Requirements
a. Procedures for informing the public and local emergency response agencies
b. Documentation of proper first-aid and emergency medical treatment necessary to treat accidental human exposures
c. Procedures and measures for emergency response after a release
d. Written plan must comply with other federal regulations
e. Coordinate with local LEPC
Planning Option - One-Plan Guidance for Integrated Contingency Plan (ICP)
a. Intended to:
- Provide a mechanism for consolidating multiple facility response plans
- Improve coordination of response activities
- Minimize duplication and simplify plan development and maintenance
- Ensure regulatory compliance with all relevant federal requirements
Communication
a. Rule does not specify
- How communication should take place
- When it should take place
- How much risk communication
b. Anyone putting public at risk must show how risk is addressed/prevented and responded to
Regulatory Approach
a. Industry tells government and the public how it will address risk for preventing major accidents
b. Government and public can review what industry has presented
c. Government and community can respond to industry, communicate concerns, and make recommendation
Communicating the RMP
a. Start now
b. Explain the program
c. Tell the public what to expect with your WCS and when to expect it
d. Explain your WCS
e. Detail chemical(s) on site that can cause explosions, environmental impacts, etc.
f. Explain why you can’t reduce your inventory of regulated substances
Community Outreach Suggestions
a. Open house/plant tours
b. Local citizen groups/civic organization
c. High school programs
d. Community survey
- What does the community think about you?
e. Neighborhood meetings
f. Plant newsletter
g. Community advisory panels
Audience
a. Neighbors
b. Implementing agencies
c. LEPC
d. Emergency responders
e. City and county officials
f. Business and community leaders
g. Educators
h. Local media
i. State legislators
Other Programs
a. Risk communications training
b. Training on handling the with media
c. Informing industrial neighbors
Implementation Strategy - Technical
a. Acquire/understand regulatory information
b. Determine coverage
c. Determine technical capabilities/needs
d. Prepare RMP implementation plan
e. Perform program level screening
f. Develop hazard assessment protocol
g. Perform hazard assessment
h. Compile 5-year accident history
i. Implement/upgrade PSM program to consider offsite effects
j. Review/upgrade emergency response activities and plan
h. Prepare and submit the RMP
Implementation Strategy - Communication
a. Determine internal risk communication capabilities/needs
b. Survey community outreach status
c. Establish/improve community outreach
d. Prepare communication plan
e. Improve internal risk communication capabilities
f. Communicate the RMP to the public
Available Resources
Chemical Emergency Preparedness and Prevention Office (CEPPO)
Suggested Team Members
a. Health and safety Professionals
- Program development and review
b. Chemical, electrical, and mechanical engineering
- Process safety information and hazard analysis development
c. Air Quality Specialist/Industrial Hygienist
- Air modeling dispersion.
- Identify acute health effects
d. Risk Assessment Specialist
- Population exposure and environmental effects
e. Communications Specialists
- Communicating with the public
Summary - Final Word
a. PSM and RMP outlines requirements for facilities to reduce risks associated with accidental releases
b. A good communications program will help reduce misinformation, distrust, and build good community relations
c. Reduction in inventory will result in a reduction of the risk and potential for a catastrophic incident
d. Audits are to be comprehensive, involving systematic assessment of all elements of the progr