Process Safety Management Train-the-Trainer This material was produced

Process Safety Management Train-the-Trainer This material was produced under grant number SH20844SH0 from the Occupational Safety and Health Administration, U.S. Department of Labor. It does not necessarily reflect the views or policies of the U.S. Department of Labor, nor does mention of trade names, commercial products, or organizations imply endorsement by the U.S. Government.

What Rights Do You Have Under OSHA? You have the right to: A safe and healthful workplace Know about hazardous chemicals Information about injuries and illnesses in your workplace Complain or request hazard correction from employer Training Hazard exposure and medical records File a complaint with OSHA Participate in an OSHA inspection Be free from retaliation for exercising safety and health rights, whistleblower and 11c. Employer rights and responsibilities

10-1254-NAT Sept. 9, 2010 Contact: Diana Petterson Jason Surbey E-mail: [email protected] [email protected] Phone: 202-693-1898 202-693-4668 US Department of Labor's OSHA awards 8 million in safety and health training grants WASHINGTON - The U.S. Department of Labor's Occupational Safety and Health Administration today awarded 8 million in Susan Harwood Capacity Building Grants to 45 organizations, including nonprofit and community/faith-based groups, employer associations, labor unions, joint labor/management associations, and colleges and universities. The grants will assist these organizations in providing safety and health training, and educational programs for workers and employers. Grant Announcement "Ensuring that workers and employers have the information they need is critical to safe and healthy workplaces," said Secretary of Labor Hilda L. Solis. "These grants will help provide training and education aimed at identifying hazards, understanding rights and responsibilities, protecting health and saving lives." The Susan Harwood Capacity Building Grants support training programs that educate workers and employers in industries with high injury and fatality rates; low literacy, young, limited English proficiency and otherwise vulnerable workers; and small business employers. They fund long-term programs that build safety and health competency within organizations. OSHA awarded approximately 6.7 million to 30 organizations already providing occupational safety and health training, education and related assistance to their constituents, and that are seeking to expand and develop their capacity. Another 1.3 million in smaller pilot grants was awarded to 15 organizations that seek to lay the groundwork for a robust safety and health education program. The agency received a total of 166 applications for the capacity building grants.

Purpose This section contains requirements for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. These releases may result in toxic, fire or explosion hazards.

Process safety management of highly hazardous chemicals (a) Application. (b) Definitions. (c) Employee participation. (d) Process safety information. (e) Process hazard analysis. (f) Operating procedures. (g) Training. (h) Contractors. (i) Pre‑startup safety review. (j) Mechanical integrity. (k) Hot work permit. (l) Management of change. (m) Incident investigation. (o) Compliance Audits. (p) Trade secrets.

Catastrophic Failure

Hazards Hazards are substances or conditions which can cause injury or harm to people, processes, equipment and the environment and which are associated with the properties and behaviors of process materials.

Examples of Hazards CHEMICAL HAZARDS Hydrogen H2S (toxicity) Nitrogen Steam Hot water Pyrophoric materials Corrosive materials Explosive materials PHYSICAL HAZARDS Electrical energy Potential energy Hydraulic Energy High temperature surfaces Radiation Weather Security

Chemical Hazards Chemical processes involve mixing and interaction between different materials. Reactions can release thermal energy or create a rapid increase in volume/pressure which can lead to mechanical failure or loss of containment. Upsets can cause situations that can interfere with the operation and result in conditions that favor other triggers for loss of containment – Fouling, Corrosion, Phase Change etc

Definition of Process Safety Process Safety – OSHA Definition: – “The Purpose of Process Safety is 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.” Secondary Definition: – A set of principles and practices that deal with the integrity and operation of process plant equipment to prevent catastrophic release of highly hazardous chemicals.

Did You Know? 1 kg of light hydrocarbon can: - heat a small home for 2 hours heat 45 kettles of water (500 cups of coffee) produce enough heat to melt steel destroy a home or small office (explosion) 1 kg of toxic vapor can harm people several hundred meters away in 3-5 min 1 kg of toxic waste can contaminate several km of a major waterway.

Process Safety Incident Impact

Process Safety Incident Impact Bhopal, India 1984 – 1754 fatalities, 100,000’s injured

Process Safety Incident Impact Feyzin, France 1966 – 18 fatalities

Process Safety Incident Impact Texas City 2005: 15 fatalities

Process Safety Incident Impact Other Examples . Flixborough - 1974 - 28 Fatalities Mexico City LPG - 1984 - 542 Fatalities Piper Alpha - 1988 - 167 Fatalities Phillips -1989 - 24 Fatalities Arco Chemicals - 1990 - 17 Fatalities

“Keep it in the pipes” Process Safety focuses on controlling the potential release of hazardous substances caused by: MECHANICAL FAILURES PROCESS UPSETS PROCEDURES / HUMAN ERROR

Focus: Incident Prevention People, Plant, Process H A Z A R D TOP EVENT BARRIERS BARRIERS ESCALATION ESCALATIONCONTROLS CONTROLS C O N S E Q U E N C E OSHA Elements aim to assure integrity of these boundaries.

What is Covered Listed chemicals in Appendix A 10,000 pounds or 4535.6 kg of flammable liquids or gasses

Process Safety Management OSHA 1910.119 Performance Based 14 Elements List of Highly Hazardous Chemicals Applies to Processes that Exceed the Total Quantity Exemption for Remote, Um occupioed

Elements of OSHA 1910.119 Employee Participation Process Safety Information Process Hazard Analysis Operating Procedures Training Contractors Pre-Startup Safety Review Mechanical Integrity Hot Works Permits Management of Change Incident Investigation Emergency Planning & Response Compliance Audits Trade Secrets

Element 1: Employee Participation Develop a written participation plan Consult with employees on PSM development Provide PSM information access to employees

Element 2: Process Safety Information Information used by employees to identify and understand hazards of Process Equipment and Chemicals. Must be compiled before a hazard analysis. Includes: – MSDS’s, Process Chemistry, and Max Intended Inventory – PFD’s/P&ID’s – Safe Operating Limits – Material and energy balances – Materials of construction and design codes employed (ie Electrical Classification, RV design, Ventilation design, safety system design)

Element 3: Process Hazard Analysis Definition: Systematic way to identify potential hazards and recommend possible solutions – Techniques: HAZOP, FMEA, What-if, Checklist Addresses: facility siting, human factors, previous incidents, control failures Relies on: Proper team and Information (PSI) Develops: Recommendations Must: Revalidate every 5 years (Ensure hazards introduced by changes are sufficiently controlled)

Element 4: Operating Procedures Written procedures for: – Startup/Shutdown – Normal operations – Temporary operations – Emergency operations Must include: – Operating Limits and Deviations – Potential Hazards and Controls (ie PPE, Safety Systems) Certified annually

Element 5: Training Must include: – Process Overview – Safety and Health Hazards – Procedures (emphasizing emergency) – Safe Work Practices Initial training w/refresher at least every 3 years Documented records and verification of qualification

Element 6: Contractors Contractor definition: – An individual performing work on or adjacent to a covered process. – Does not apply to incidental services Janitorial, Food and Drink, Mail, or Laundry service Two Different sets of responsibilities: – Employer – Contract Employer

Element 6: Employer Responsibilities Evaluate Contractor Safety Performance (prior to selection) Inform Contractor Of Known Hazards Related to: Work Being Performed and the Process Inform Contractor Of Emergency Plan Implement Safe Work Practices Covering Work Activities Lockout/Tagout, Confined Space Entry, Opening Process Equipment, and Facility Entry. Periodically evaluate Contractor Performance on Meeting OSHA Obligations (training etc) Maintain a Contractor Illness/Injury Log

Element 6: Contractor Employer Contractor Training and Documentation of Comprehension. Instruct Contractors of: – Hazards of facility/job and the Emergency Plan Ensure that Contractors follow the Facility: – Safe Work Practices – Safety Rules/Policies Notify Facility of: – Hazards of Contract Work Being Performed – Hazards found during Work

Element 6: Contractor Provisions Contractor Safety Oversight – Evaluate contractor safety program – Inform contractor of potential hazards: fire, toxic release, applicable plant safety rules – Develop and implement safe work practices – Evaluate Contractor performance Qualified Contractors – Pre-qualification process – Safety Training – Initial/annual orientation – Job specific training

Element 6: Contractor Provisions Audit Compliance – Perform Field and Bi-annual record audits on selected contractors Responsible for: – use of qualified contractors – ensuring new contractors are pre-qualified – ensuring contractor trained properly and provided required information – Ensure contractor is following rules & procedures

Element 7: Pre-Startup Safety Review Performed on New/Modified Facilities Ensures the following prior to Start-up: – Construction is in accordance with design specs – Procedures are in place – Changes have been reviewed for hazard (PHA/MOC) – Actions from hazard review have been resolved – Employee training is complete.

Element 8: Mechanical Integrity Maintenance Procedures and Training Inspection/Testing on process equipment and documentation of test. Frequency and Method per Good Engineering Practices (at minimum). Deficiencies corrected before further use Quality assurance program

Element 9: Hot Work Permits Issued for hot work ON or NEAR the process Document: – Required Fire Protection/Prevented has been implemented prior to work – Authorized for work – Equipment where hot work is to be performed.

Element 10: Management of Change Evaluates Hazards of ANY Changes to: – Chemicals, Technology, Equipment and Procedures – Before Startup – Even on temporary changes Considers the impact on the following: – Health and safety – Process safety information – Operating Procedures – Training/Inform of employees & contractors – Technical basis of the change – Time period and authorization requirements for the change

Element 11: Incident Investigation Performed on events which have or could have resulted in a catastrophic chemical release. Prompt investigation Involve employees knowledgeable in process Documentation and Report Recommendations and findings Resolutions and corrective actions

Element 12: Emergency Planning/Response Employer MUST have an emergency action plan for entire plant. Must include: – Pre-plan for catastrophe – Train and equip workers – Drills

Element 13: Compliance Audits Employer certification/internal evaluation that they comply with this OSHA 1910.119 standard. Conducted at least every 3 years. Develop a report of findings Address deficiencies.

Element 14: Trade Secrets All PSM related information MUST be made available to those developing PSM information without regard to trade secrets. – Examples: PSI, PHAs, MOCs, Investigations, Procedures, Emergency planning etc. – All PSM documents must be made available to employees regardless of trade secrets Can set Confidentiality agreements as necessary

Process Safety In the Workplace Essential to preventing incidents as a result of the release of Highly Hazardous Chemicals. Contractors play a key role by: – Knowing and following the PSM rules – Participating in the site safety culture Incident Investigations/Shared Learnings Raising concerns/Stopping work as necessary – Following the Facility Safe Work Practices – Fully understanding the hazards present and emergency action plan

Training Techniques Objectives: – Understand the adult learner – Identify techniques to enhance adult learning – Plan a training session – Assess current skills and areas for improvement – Recognize effective and ineffective training methods

Principles of Adult Education Treat learners as adults Identify learner goals Focus on the real world Emphasize how training can be applied Relate materials to their experiences Listen and respect their opinions Encourage discussion

5 Step Training Plan Review Overview Presentation Exercise Summary

Tips for Successful Presentation Be prepared Dress appropriately Be positive and show enthusiasm Speak loud enough to be heard Be flexible and accessible Make eye contact