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Chapter 13Regulatory Overview OSHA,

PSM, and EPA

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Occupational Safety and Health Act

• The purpose of the Occupational Safety and Health Act is to (1) remove know hazards from the workplace that could lead to serious injury or death, and (2) ensure safe and healthful working conditions for American workers.

• Applies to agriculture, construction, general industry, and the maritime industry.

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Figure 13-1 OSHA

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Process Safety Management

• The PSM standard was implemented because of disasters like Bhopal, Phillips, and ARCO.

• PSM Final Rule was implemented in 1992 rewriting the process technician job description.

• PSM has lead to the creation of a standardized college curriculum.

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Figure 13-2 The PSM Standard

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Employee Participation

The employee participation section has four important parts:

• How to identify hazards• How to gather crucial process and hazard

information• How to communicate crucial process and

hazard information• The written procedure and how employees will

access it

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Process Safety Information

• Includes information on the accidental mixing of chemicals and the products they produce, potential hazards, and safe handling procedures.

• A simplified flow diagram of the process should be included so a new person can easily see the various steps of the process.

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Process Hazard Analysis• Designed to identify the causes and

consequences of fires, vapor releases, and explosions. All of the hazards on a unit need to be identified.

• The following detective work is required:• List what can go wrong

• Identify the consequences

• Explain how it could arise again

• Select the contributing factors

• Determine the frequency of the hazard

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Operating Procedures

• Standard operating procedures apply to technicians and must reflect current work practices, process properties, hazards, process change of chemicals, and startup and shutdown procedures.

• Maintenance procedures apply to maintenance employees.

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Employee Training

OHSA and the EPA believe the key to preventing catastrophic emergencies inside the CPI is to provide adequate employee training.

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The employee training aspect of the PSM standard includes seven sections:

1. Process overview

2. Training records and method used to administer training (You must document attendance and competency achieved)

3. Chemicals used in the process

4. Description of how access to and from the process unit is controlled

5. Training materials that reflect current work practices.

6. Refresher training provided

7. Contractors must inform and train their employees and document the training.

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Pre-Startup Safety Review

It is during this this phase that operational and safety procedures are written and tested.

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Mechanical Integrity

Mechanical integrity is a term that applies to the soundness of a plant process.

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Management of Change

The PSM standard requires that a formal system be in place that makes deviation from standard operational procedures be structured with layers of approval required.

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Incident Investigation

Incident investigation is a procedure that takes place when a near-catastrophic or catastrophic event occurs. There are three parts:

• Assemble incident investigation team within 48 hours.

• Address all of the findings.• Correct all the action items identified

during the investigation.

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Emergency Planning and Response

• The first level deals with emergency plans that impact plant employees

• The next level deals with people who are responding to the emergency.

• The final level deals with the community, the plant, and the emergency.

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Environmental Protection Agency

• The EPA is most noted for its management of the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (Superfund)

• The creation of the EPA has brought 15 federal programs under one umbrella.

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• Today the government has passed over 12 environmental laws that impact air, water, and land. These laws span cradle-to-grave.