Process Safety Management (PSM) and Risk Management Plan (RMP): - PowerPoint PPT Presentation

Process Safety Management (PSM) and Risk Management Plan (RMP): Identifying the Likelihood of Hazardous Events in Your Facility Conan Reed, GSP Nick Foreman, CSP November 19, 2020

CONAN REED, GSP  Safety & IH Services Project Manager  BS in Occupational Safety and Health, Murray State University  19 Years of Consulting 2

NICK FOREMAN, CSP  Safety & IH Services Group Manager  B.S. in Biology, Texas A&M University  Master of Public Health, Texas A&M University  14 Years of consulting 3 3

PSM/RMP WHAT ARE THEY? 4

Goals of PSM and RMP  Intended to be mirror programs but it didn’t happen that way.  PSM – OSHA’s program to protect workers  RMP – EPA’s program to protect the environment and the community 5

PROCESS SAFETY MANAGEMENT – APPLICABILITY & EXEMPTIONS Who is covered and what is required? 6

Applicability of the PSM Standard?  A process which involves a chemical at or above the specified threshold quantities listed in Appendix A of CFR 1910.119;  A process which involves a Category 1 flammable or a flammable liquid with a flashpoint below 100 degrees Fahrenheit on site in one location, in a quantity of 10,000 pounds or more. 7

Some Example Appendix A Chemicals & Thresholds Chemical OSHA PSM Threshold Chlorine 1,500 lbs. Anhydrous Ammonia 10,000 lbs. Formaldehyde 1,000 lbs. Toluene Diisocyanate (TDI) Not Listed Hydrogen Fluoride 1,000 lbs. Phosgene 100 lbs. USE THE CAS NUMBERS!!!! 8

Businesses with potential PSM-covered processes Asphalt Chemical and Allied Chemical Products- Fabricated Rubber Paving/Roofing Drugs Fabricated Metal Products Misc Products Materials (NAICS 332) (NAICS 4242) (NAICS 4246) (NAICS 42469) (NAICS 32521) (NAICS 32412) Food and Kindred Inorganic Chemical Lumber, Wood Paints, Varnishes, Industrial Organic Natural Gas Liquids Products Manufacturing Products Enamels Chemicals (NAICS (NAICS 2212) 32519) (NAICS 31199) (NAICS 32518) (NAICS 321) (NAICS 3255) Paper and Allied Plastics, Rubber, Primary Metals Plastics Products- Petroleum & Coal Petroleum Refining Products Cellulosics Industries Miscellaneous Products-Misc (NAICS 32411) (NAICS 3261) (NAICS 32419) (NAICS 32229) (NAICS 325211) (NAICS 331) Stone, Glass & Concrete Textile Mill Products Wholesale Trade (NAICS 21232, 3272, (NAICS 3131) (NAICS 42) 3273) 9

PSM Exceptions 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; Flammable liquids with a flashpoint below 100 °F stored in atmospheric tanks or transferred which are kept below their normal boiling point without benefit of chilling or refrigeration. (Note: Atmospheric tanks are storage tanks designed to operate at pressures from atmospheric through 0.5 psig)

Who is not covered by PSM? Retail facilities Oil or gas well drilling Normally unoccupied or servicing operations remote facilities 11

It’s applicable, now what? Start by compiling your existing written process safety information (PSI) Then perform a process hazard analysis (PHA) Then develop your PSM program Pre-Startup Emergency Operating Employee Mechanical Hot Work Incident Compliance 12 PSI PHA Training Contractors Safety MOC Planning and Trade Secrets Procedures Participation Integrity Permitting Investigation Audits Reviews Response

What does a PHA cover?  Process Hazards  Previous Incidents  Engineering and administrative controls  Consequences of a failure of controls  Facility siting  Human Factors 15

Example PHA Methodologies What If/Checklist Hazard and Operability Failure Mode and Fault Tree Analysis Study (HAZOP) Effects Analysis (FMEA) 16

HAZOP Method Setup the HAZOP Study •Identify and Select Nodes Identify Deviations using •Divide system into parts, use guidewords P&IDs or process flow diagrams •Identify Guidewords Identify causes or Identify Safety Measures concequences Assign Risks Provide Recommendations 18

HAZOP Guidewords Parameter Guideword Deviation Flow None, Less, More, Reverse, No flow, Less Flow, More Other, Also, Misdirected Flow, Reverse Flow, Other, Contamination, Misdirected Flow Pressure More, Less (High, Low) More Pressure, Less Pressure Temperature More, Less (High, Low) Higher Temperature, (Product and Ambient) Lower Temperature Viscosity More, Less More Viscosity, Less Viscosity Reaction None, Less, More No Reaction Reaction Incomplete Intense Reaction 19

PHA Team Don’t try to do this on your own! The PHA Team should consist of the following:  Experts in the engineering and process operations  Employees who have specific knowledge of the process  A member that is knowledgeable in the specific PHA methodology being used (typically 3 rd party) 21

How often must I audit and perform PHA updates? An audit should be performed every 3 years to ensure compliance and that the procedures and practices put into remain adequate. The PHA should be updated/revalidated every 5 years after the initial assessment. 22

PSM Applicability Scenario Large Manufacturer of AC Units Large Propane tank 10,000 lbs. as a reserve in case natural gas was not available. Natural gas used for heating and for brazing operations. Propane was used as backup. Is the propane tank exempt? 23

National Emphasis Program (NEP)?  OSHA currently has nine Active NEPs  Lead  Process Safety  Primary Metal Industries Management  Shipbreaking  Combustible Dust  Silica  Hazardous Machinery  Trenching & Excavation  Hexavalent Chromium 24

RISK MANAGEMENT PROGRAMS – APPLICABILITY & EXEMPTIONS 40 CFR Part 68 25

Who falls under the RMP Standard? Stationary facilities holding more than a threshold quantity of a regulated substance in a process are required to comply with EPA’s Risk Management Program regulations. 26

RMP Applicability Flow Chart You are subject to the Assign Program levels Yes rule! to covered processes. Do you have a regulated substance Yes above a threshold STOP! quantity in a process? Is your facility a No You are not covered stationary source? by the rule. STOP! No You are not covered by the rule. 27

RMP Exemptions: Ammonia  Ammonia: when held by a farmer for use on a farm as a fertilizer. It does not apply to agricultural suppliers or the fertilizer manufacturer. It does not apply to farm cooperatives or to groups of farmers who buy, use, and sell ammonia.  In the event that a farmer stores one or more other regulated substance above threshold quantities, that storage would be covered. 28

RMP Exemptions: Flammable Fuels  Flammable Fuels: Flammable substances listed in § 68.130 are excluded from coverage under part 68 when they are used as a fuel or held for sale as a fuel at a retail facility.  A retail facility is defined as a stationary source at which more than half of the income is obtained from direct sales to end users or at which more than one-half of the fuel sold, by volume, is sold through a cylinder exchange program. 29

RMP Exemptions: Transportation Activities  Transportation Activities: The rule applies only to stationary sources. It does not apply to transportation, including storage incident to transportation.  Transportation includes, but is not limited to:  transportation subject to oversight or regulation under 49 CFR parts 192 (Federal safety standards for transportation of natural and other gas by pipeline), 193 (Federal safety standards for liquefied natural gas facilities), or 195 (Federal safety standards for transportation of hazardous liquids by pipeline), or a state natural gas or hazardous liquid program for which the state has in effect a certification to DOT under 49 U.S.C. 60105. 30

RMP Applicability Scenario?  West, Texas  Fertilizer Plant  >50,000 lbs of Ammonium Nitrate  Large explosion  Covered by RMP??? 31

Some Example Listed Chemicals & Thresholds Chemical OSHA PSM Threshold EPA RMP Threshold Chlorine 1,500 lbs. 2,500 lbs. Anhydrous Ammonia 10,000 lbs. 10,000 lbs. Formaldehyde 1,000 lbs. 15,000 lbs. Toluene Diisocyanate (TDI) Not Listed 10,000 lbs. Hydrogen Fluoride 1,000 lbs. Anhydrous 1,000 lbs. Phosgene 100 lbs. 500 lbs. USE THE CAS NUMBERS!!!! 32

What does the RMP require? Each facility's program should address three areas:  Hazard assessment  Prevention program  Emergency response program 33

RMP Program Levels  Program 1: Processes which would not affect the public in the case of a worst-case release and with no accidents with specific offsite consequences within the past five years are eligible for Program 1.  Limited hazard assessment requirements and minimal prevention and emergency response requirements.  Program 3: Processes not eligible for Program 1 and either subject to OSHA's PSM standard under federal or state OSHA programs or classified in one of ten specified NAICS codes  Imposes OSHA’s PSM standard as the prevention program as well as additional hazard assessment, management, and ER requirements. 32211, 32411, 32511, 325181, 325188, 325192, 34 325199, 325211, 325311, or 32532.