Workshop K Best Practices ... Implementation of Process Safety Management (PSM) and Risk Management (RMP) … It’s Not Just a Set of Binders Tuesday, March 26, 2019 11:15 a.m. to 12:30 p.m.
Biographical Information William Lape, Project Director SCS Engineers, 10180 Bald Eagle Trail, Woodbury, MN, 55129 651-207-2748 blape@scsengineers.com Bill started his career as a controls specialist in the glass container industry in 1993. During the subsequent 17 years, he worked as a Process Controls Development Engineer for an aluminum beverage can company, a Project Engineer for a system integrator, specializing in control systems for jails, prisons, and courthouses, and as a Plant Engineering Manager for an aluminum beverage can plant. In 2010, Bill entered the food and beverage industry as a Plant Engineering Manager for Dean Foods, where he quickly discovered a passion for process safety, particularly for ammonia refrigeration systems. In 2014, he was promoted to Senior EHS Manager – Process Safety Management, where he provided process safety assistance to over 50 plants. By 2016, he was leading a team of professionals that were charged with supporting all process safety programs in the company. In 2017, he became Director of EHS Programs and Compliance. In that role, he led a team of professionals that supported all of the company’s process safety programs, all wastewater and storm water compliance, and all safety program support. In July 2018, Bill joined SCS Engineers as a Project Director. His primary responsibilities are to lead a team of professionals that support the process safety programs of over 50 clients, some with multiple facilities across the country, and to continue to find new clients in need of help. Bill is a Certified Industrial Refrigeration Operator and a Certified Refrigeration Service Technician. He is also a member of the National Board of Directors of the Refrigerating Engineers and Technicians Association and a member of the International Institute of Ammonia Refrigeration. He is a graduate of Purdue University with a B.S in Electrical Technology. Ed Johnson, CARO, PSM Engineering Manager Dean Foods, Dallas TX 801-634-4277 hrsafetypro@gmail.com Ed Johnson has over 19 years of experience in Environmental Health and Safety, with 8 years of experience in PSM/RMP compliance and ammonia refrigeration. Ed is also a RETA Certified Assistant Refrigeration Operator, and an Authorized OSHA Outreach Trainer for the 10 and 30-hour General Industry courses. Ed is an active member of RETA and IIAR. Ed is currently certified as an Assistant Refrigeration Operator (CARO) Ed has a Master’s Degree in Human Resources from National University, and has attended several courses at University of Wisconsin-Madison and Garden City Community College. He is a retired U.S. Navy Chief Petty Officer and served in Operation Desert Storm/Desert Shield in the Persian Gulf. Ed currently resides in Utah with his wife and family.
Process Safety Management: It’s Not Just a Set of Binders RAGAGEP: Defining, Documenting Compliance, & Updating
First, a Regulatory Review: What is PSM 29 CFR 1910.119 • Process Safety Management is a system of government regulations designed to prevent the release of highly hazardous chemicals that could lead to catastrophe in the workplace. • OSHA published the proposed standard ‐ “Process Safety Management of Highly Hazardous Chemicals” in the Federal Register on July 17, 1990. • The Federal PSM standard became effective on May 24, 1992 .
First, a Regulatory Review: What is RMP? 40 CFR 68 • The Risk Management Plan is a system of government regulations designed to prevent the release of highly hazardous chemicals that could lead to catastrophe in the surrounding community. − November 1990, Section 304 of the Clean Air Act Amendments (CAAA) required that the Secretary of Labor, in coordination with the Administrator of the EPA, promulgate a chemical process safety standard to prevent accidental releases of chemicals that could pose a threat. − Chemical Accident Prevention Provisions (published on June 21, 1996), requires facilities to develop a Risk Management Program to manage the potential risks associated with processes that use regulated substances (ex: ammonia). • Existing facilities were required to comply by June 21, 1999 .
Why PSM/RMP? • Established as a response to several high profile, deadly incidents in the chemical industry in the 1970s and 80s. − 1974: Flixborough ‐ Cyclohexane vapor release exploded ‐28 killed − 1976: Seveso ‐ 6 ton release of chemicals including 2,3,7,8‐tetrachlorodibenzodioxin (TCDD) poisoned a 7 square mile radius − 1984: Bhopal ‐ 30 ton release of methyl Isocyanate – thousands killed 3/7/2019 3/7/2019 4 4
The straw that broke the camel’s back − Phillips 66 Chemical Complex Explosion – Pasadena, TX • Flammable vapor release explosion threw debris 6 miles ‐ 23 killed
But those are chemical plants! What about Ammonia? Dixie Cold Storage 1984 Millard Ref. Services ‐ 2010 Bordon Ice Cream 1983 Stavis Seafoods ‐ 2016 Goodyear Tire & Rubber ‐ 2008 Fernie Arena ‐ 2017
What facilities must follow PSM/RMP? Covers plants which: • Any facility that handles, stores, uses, or produces in excess of the threshold quantity of a listed regulated substance (ex: ammonia, chlorine, sulfur dioxide) in any Ammonia threshold for both PSM and RMP single process. (Appendix A of is 10,000 lbs 1910.119) Process = any group of • RMP List of chemicals and their interconnected vessels and thresholds vary somewhat from separate vessels located PSM such that a highly hazardous chemical could be involved in a potential release.
What facilities must follow PSM/RMP? Also covers plants which: • Have flammable liquids OR gases in processes in quantities of 10,000 pounds and above. • Manufacturers of explosives and pyrotechnics It DOES NOT cover: • Hydrocarbon fuels used solely for workplace consumption as a fuel • Retail facilities • Oil & gas well drilling & servicing • Normally unoccupied, remote facilities 3/7/2019
Regulatory Review: Overlap EPA RMP • RMP*eSubmit • Hazard Assessment • Confidential • Management Programs Information • Emergency Coordination OSHA PSM • PSI • PSSR • PHA • MOC • SOPs • Incident • Training Investigation • Mechanical • Hot Work Permits Integrity • Emergency Plan • Contractors • Employee Participation • Compliance Audit • Safe Work Practices • Trade Secrets
PSM/RMP Elements • Employee Participation • Incident Investigation • Process Safety Information • Emer. Planning & Response • Process Hazard Analysis • Compliance Audits • Operating Procedures • Trade Secrets • Employee Training • Contractor Control • Pre‐Startup Safety Reviews • Mechanical Integrity • Hot Work • Management of Change Source: Wikipedia
All ChemNEP Citations by PSM Element FY 14 thru FY 18 Element Description % of PSM Citations J Mechanical Integrity 23.7% D Process Safety Information 22.0% E Process Hazard Analysis 15.0% F Operating Procedures 14.6% L Management of Change 5.4% O Compliance Audits 4.5% H Contractors 3.9% G Training 3.4% N Emergency Planning & Response 3.1% M Incident Investigation 1.8% C Employee Participation 1.6% I Pre‐Startup Safety Review 1.0% K Hot Work 0.2% P Trade Secret 0.0% 11
All Food Manf./Cold Strg. ChemNEP Citations by PSM Element FY 14 thru FY 18 Element Description % of PSM Citations D Process Safety Information 26.1% J Mechanical Integrity 25.4% F Operating Procedures 15.8% E Process Hazard Analysis 10.0% L Management of Change 4.9% O Compliance Audits 4.1% N Emergency Planning & Response 3.6% G Training 3.2% H Contractors 3.2% I Pre‐Startup Safety Review 1.6% C Employee Participation 0.9% M Incident Investigation 0.9% K Hot Work 0.1% P Trade Secrets 0.0%
All ChemNEP Citations by PSM Sub‐element FY 14 thru FY 18 Sub‐element Description % of PSM Citations 1910.119(j)(2) MI Written Procedures 7.2% 1910.119(d)(3)(ii) PSI RAGAGEP Compliance 6.8% 1910.119(d)(3)(i)(B) PSI P&IDs 4.2% 1910.119(f)(1) OP Developed & Implemented 3.7% 1910.119(j)(4)(i) MI I&T Not Performed 3.5% 1910.119(j)(5) MI Equipment Deficiencies 3.5% 1910.119(l)(1) Management of Change Dev & Imp 3.2% 1910.119(n) Emergency Planning & Response 3.1% 1910.119(j)(4)(iii) MI Inspection Frequency Not to RAGAGEP 3.0% 1910.119(e)(5) PHA Findings & Recommendations 2.8% 1910.119(e)(1) PHA Hazards of the Process 2.7% 1910.119(f)(3) OP ‐ Review 2.6% 1910.119(j)(4)(iv) MI I&T Documentation 2.6% 1910.119(o)(1) CA Not Performed 2.3% 13
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