ENSURING WORKER SAFETY AND HEALTH IN WATER / WASTEWATER TREATMENT OPERATIONS PROCESS SAFETY MANAGEMENT OF HIGHLY HAZARDOUS CHEMICALS (PSM) Presented By Gerry Dike, BSChEngg, MBA MIOSHA Statewide Disaster Response Administrator 2011 MWEA/AWWA HEALTH & SAFETY CONFERENCE OCT 25, 2011 EAGLE EYE BANQUET FACILITY, EAST LANSING, MI 1 OBJECTIVES OF PRESENTATION � Discuss requirements of MIOSHA Process Safety Management (PSM) standard � Identify common hazards and PPE needs � Identify employer’s safety and health roles and responsibilities � Identify worker safety and health roles and responsibilities � Discuss training requirements and strategies 2 PURPOSE OF THE PSM STANDARD � To prevent or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals � Such releases may result in toxic, fire or explosion hazards resulting in fatalities or serious injuries and/or illnesses 3 1
POSSIBLE RESULT OF NON-COMPLIANCE WITH PSM REQUIREMENTS 4 POSSIBLE RESULT OF NON-COMPLIANCE WITH PSM REQUIREMENTS 5 POSSIBLE RESULT OF NON-COMPLIANCE WITH PSM REQUIREMENTS 6 2
APPLICATION OF THE PSM STANDARD � Processes that involve use of a chemical listed in Appendix A at or above the specified threshold quantities � Processes that involve use of a flammable liquid or gas on site in one location, in a quantity of 10,000 pounds (4535.9 kg) or more. 7 APPLICATION OF THE PSM STANDARD 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 stored in atmospheric tanks which are kept below their normal boiling point without benefit of chilling or refrigeration 8 APPLICATION OF THE PSM STANDARD EXCEPTIONS � Retail facilities � Oil or gas well drilling or servicing operations � Normally unoccupied remote facilities 9 3
PSM COVERED CHEMICALS IN WATER / WASTEWATER TREATMENT OPERATIONS � CHLORINE (Cl2) � TLQ = 1500 lbs � SULFUR DIOXIDE (SO2) � TLQ = 1000 lbs 10 Chlorine Use in Water /Wastewater Chlorine Use in Water /Wastewater Treatment Operations Treatment Operations � Excellent sanitizing agent � Forms hypochlorous acid in solution – active biocidal material Cl 2 + H 2 O � HOCl + HCl � Good residual action – bacteriostatic at 1-5 ppm Cl 2 in water 11 Chlorine Use in Water /Wastewater Treatment Operations � Can form undesirable chlorinated organic materials, e.g., chloromethanes � Chlorine Institute Pamphlet 155 – Water & Wastewater Operators Chlorine Handbook 12 4
Health Effects of Chlorine Health Effects of Chlorine � Chlorine is extremely irritating and can burn the skin and eyes � If inhaled, chlorine causes respiratory distress, and can be fatal � Liquid chlorine releases will form an immediate cloud (flash vapor) and will cool to -29 F. � Exposure to liquid can cause frostbite, as well as chemical burns. 13 Health Effects of Chlorine Exposure Health Effects of Chlorine Exposure Concentration Health Effects (ppm in air) 1-3 ppm Mild mucous membrane irritation 5-15 ppm Upper respiratory tract irritation Immediate chest pain, vomiting, shortness of breath 30 ppm (dyspnea) and cough Inflammation of lung tissues (toxic pneumonitis) and 40-60 ppm fluid accumulation (pulmonary edema) 430 ppm Death within 30 minutes 1,000 ppm Death within a few minutes 14 Exposure Limits for Chlorine Exposure Limits for Chlorine Standard Permissible Setting Exposure Description Body ppm NIOSH 0.5 Recommended Exposure Limit (REL) OSHA 1 Permissible Exposure Limit (PEL) NIOSH 1 Short Term Exposure Limit (STEL) Emergency Response Planning Guideline AIHA 3 Level 2 Immediately Dangerous to Life or Health NIOSH 10 (IDLH) Emergency Response Planning 20 AIHA Guideline Level 3 15 5
KEY ELEMENTS OF THE PSM STANDARD � � Employee participation Employee participation � � Process safety information Process safety information � Process hazard analysis hazard analysis � � Operating procedures Operating procedures � � Training Training 16 KEY ELEMENTS OF THE PSM STANDARD � Contractors � Pre-startup safety review � Mechanical integrity � Hot work permit � Management of change 17 KEY ELEMENTS OF THE PSM STANDARD � Incident investigation � Emergency planning and response � Compliance audits � Trade secrets � Appendix A 18 6
Employee participation � Employers shall develop a written plan of action regarding the implementation of the employee participation � Employers shall consult with employees and their representatives on the conduct and development of process hazards analyses and on the development of the other elements of process safety management in this standard � Employers shall provide to employees and their representatives access to process hazard analyses and to all other information required to be developed under this standard 19 Process Safety Information (PSI) Process Safety Information (PSI) 1910.119 (d) 1910.119 (d) � The employer shall complete a compilation of written process safety information. The written process safety information is to enable the employer and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals . 20 Process Safety Information Process Safety Information 1910.119 (d) 1910.119 (d) � The process safety information shall include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process. 21 7
Process Safety Information Process Safety Information Information pertaining to the hazards of the highly hazardous chemicals (Can use MSDS) � Toxicity information � Permissible exposure limits � Physical data � Reactivity data � Corrosivity data � Thermal and chemical stability data � Hazardous effects of inadvertent mixing of different materials that could foreseeably occur 22 Process Safety Information Process Safety Information Information pertaining to the technology of the process � Block flow diagram or simplified process flow diagram � Process chemistry � Maximum intended inventory � Safe upper and lower limits for such items as temperatures, pressures, flows or compositions � An evaluation of the consequences of deviations, including those affecting the safety and health of employees 23 Process Safety Information Process Safety Information Information pertaining to the equipment in the process � Materials of construction � Piping and instrument diagrams (P & ID’s) � Electrical classification � Relief system design and design basis � Ventilation system design � Design codes and standards employed � Material and energy balances � Safety systems (e.g. interlocks, detection or suppression systems). 24 8
Process Safety Information Process Safety Information 1910.119 (d): Piping 1910.119 (d): Piping � Do materials for piping and components comply with Chlorine Institute recommendations – for metallurgy, schedule, and welding? (CI 6 Sec 2) � Are materials for threaded connections PTFE tape or non-reactive pipe dope? (CI 1 and 6 Sec. 3) 25 Process Safety Information Process Safety Information 1910.119 (d): Piping Cont. 1910.119 (d): Piping Cont. � Are gaskets compatible with liquid and gaseous chlorine? (CI 95 Sec 3) 26 Process Safety Information Process Safety Information 1910.119 (d): Piping Cont. 1910.119 (d): Piping Cont. � Is piping adequately supported and braced? (CI 6 Sec 10) � Is piping system protected from vehicular traffic? (CI 6 Sec 10) � If piping is underground, is it continuously leak monitored? (CI 60 Sec 3) 27 9
Process Safety Information Process Safety Information 1910.119 (d): Piping Cont. 1910.119 (d): Piping Cont. � Are there expansion pots where liquid Cl 2 can be blocked in? (CI 5 Sec 5) � Is the expansion pot isolated by rupture disk and monitored? (CI 6 Sec 5) 28 Process Safety Information Process Safety Information 1910.119 (d): Piping Cont. 1910.119 (d): Piping Cont. � Are liquid valves designed to prevent trapping Cl 2 in the body? (CI 6 Sec 4) � When Cl2 pressure is lower than process pressure, is there backflow prevention? (CI 9 Sec 4 and 5) 29 Process Safety Information (d) Process Safety Information (d) (Vaporizers) (Vaporizers) � Is the vaporizer heating medium non-organic and limited to 250 F? (CI 9 Sec 3) � Is the heating medium pressure lower than the chlorine supply pressure? (CI 9 Sec 3) � Is the vaporizer designed for a minimum metal temperature of -40 F? (CI 9 Sec 3) � Does the vaporizer outlet have a pressure relief valve? (CI 9 Sec 4) � Is there a program in place to monitor NCl 3 levels? (CI 9 Sec 5 and CI 152 Sec 5) 30 10
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