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Management Systems, Process Safety Management, and RMP Jeffrey J. Wanko, PE, CSP Directorate of Enforcement Programs Office of Chemical Process Safety
Management Systems,
Process Safety Management,
and RMP
Jeffrey J. Wanko, PE, CSP
Directorate of Enforcement Programs
Office of Chemical Process Safety
• Management Systems
• Process Safety Management History
• Process Safety Management Elements
• Ammonia Distribution
• PSM-RMP Comparison
• PSM Future
• How to Get Help
Safety Management System
Strengths
• Management systems (such as PSM and
Injury and Illness Prevention Programs)
work because they provide for:1. System design
2. System execution
3. System evaluation
4. System correction
5. (repeat)
Also called Plan-Do-Check-Act
Safety Management System Core
Elements
• Six core elements:
– Management leadership
– Worker participation
– Hazard identification and assessment
– Hazard prevention and control
– Education and training
– Program evaluation and improvement
History of Process Safety
Management
• PSM became effective in 1992
• Stakeholders consensus regarding the
performance-based model
• A single prescriptive regulation could not
cover all facilities
History of Process Safety
Management
• PSM sets a management framework for
preventing catastrophic releases of highly
hazardous chemicals or minimizing
consequences
• PSM incorporates the philosophy and
strengths of safety management systems
Process Safety Management
Elements• Employee participation
• Process safety
information
• Process hazard
analysis
• Operating procedures
• Training
• Contractor safety
• Pre-start up safety
review
• Mechanical integrity
• Hot work permit
• Management of change
• Incident investigation
• Emergency response
• Compliance audits
Benefits of the Process Safety
Management System Framework
• Flexible
• Comprehensive
• Adaptive
• Creative
The PSM Elements
• Employee Participation*– Workers are most likely exposed to the hazards of the
process
– Workers are most knowledgeable in how the process
operates daily
– Written plan of action to involve employees in the
program
– Consult with employees on the conduct of the
process hazards analysis (PHA)
– Communicate PHA findings to employees
The PSM Elements
• Process Safety Information (PSI)
– Information about the process, process,
design, equipment design, etc.
– The information necessary to conduct a PHA
and to operate the process over time
– Process chemicals
– Process technology
– Process equipment
The PSM Elements
• Process Hazards Analysis (PHA)– Systematic evaluation of the hazards of a process
– What could go wrong (how often and how badly)
– Evaluation of the administrative and engineering
systems that keep the process safe (not limited to
those items dedicated to safety)
– Group effort - process operator involvement not
required but encouraged
The PSM Elements
• Operating Procedures (OP)– Clear instructions on how to operate the process
– All phases of operation
– Written
– Reviewed annually to ensure they reflect current and
actual operating practice
– Includes safe work practices (lockout, confined space
entry, personnel entry, etc)
The PSM Elements
• Training
– Initial training to ensure process operators
can safely operate all phases of the process
in accordance with the operating procedures
– Refresher training as necessary but no less
than every three years
The PSM Elements
• Contractors*– Contractors who work on the process or could affect
the process
– Employer (host) responsibilities
• Evaluate
• Recordkeeping
• Communication
– Employer (contractor) responsibilities
• Communication
• Instruction in safety procedures
The PSM Elements
• Pre-Startup Safety Review (PSSR)*
– Required for new facilities or facilities having
gone through a significant change (change to
PSI)
– Ensure that everything is complete prior to
introduction of the highly hazardous chemical
• PSI update
• PHA
• OPs
• Training, etc…
The PSM Elements
• Mechanical Integrity (MI)– Maintaining the integrity of process equipment
• Vessel
• Piping/Hoses
• Pump
• Valves
• Safety systems
• Controls
– Written procedures
– Training for personnel performance maintenance
activities
The PSM Elements
• Hot Work*
– Administrative control of welding, cutting,
brazing and other spark-producing activities
– Permit
The PSM Elements
• Management of Change (MOC)*
– Changes to chemicals, process, equipment,
procedures, etc.
• Other than in-kind changes
– Establish a written program
– Inform employees affected by the change
The PSM Elements
• Incident Investigation
– Investigate incidents that resulted in or could
have resulted in a catastrophic release of
highly hazardous chemical(s)
– No later than 48 hours after the incident
– Prepare a report
The PSM Elements
• Emergency Planning and Response
– Establish a program for response during
emergencies
– One of the following:
• Emergency action plan (1910.38)
• Emergency response plan (1910.120)
The PSM Elements
• Compliance Audits
– Every three years conduct an audit of
compliance with the standard
– Prepare a report of findings
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How Do the Elements Interact? –
An Example
• I store 100,000 pounds of anhydrous
ammonia for filling nurse tanks
• My raw materials are
– Anhydrous ammonia delivered in OTR tanker
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What Do I Need to Do This
Safely?
• Process Safety Information
– Properties of the anhydrous ammonia
• Conditions under which is a gas or liquid
• Is it corrosive?
– To what?
• How does ammonia act at different pressures and
temperatures
• Toxicity
• Molecular weight
• Flammability/combustibility
• Other hazards?
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What Do I Need to Do This
Safely?
• Process Safety Information
– The process and equipment
• How much do I need?
– Raw materials (inventory)
– Energy
– Safe upper and lower limits (temp, pressure)
• What should the equipment be made of to reduce
problems?– To what standards is the equipment designed and
constructed?
– Vessel construction
– Piping and hose construction
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Looking for Possible Problems
• Systematically review the process and
analyze for hazards (PHA)• Analyze the potential ways in which problems
could arise– Overpressure
– Vehicular impact
– Design requirements (CGA K61.1 and G2.1)
– Overfilling
– Drive away
• May have to find answers to questions which arise
• Human factors
• Facility siting
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What About Designing, Building,
and Operating?• Is my process designed correctly?
– K61.1 or G2.1
• Is my process built correctly?– Proper materials for valves, pipes, vessels, etc.– Control systems designed and installed correctly?– Do my relief valves relieve to safe locations?
• How do you show that the process is built correctly and in compliance with codes and standards
• Procedures– Operating– Startup– Shutdown & Emergency shutdown
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What About Designing, Building,
and Operating?
• Are operators, maintenance, contractors properly
trained?– Unloading and loading operations
– Daily inspections (vessel, hose, piping)
• How do I know if my equipment is lasting as long as it
should?– Testing
– Frequency of tests
– Trained people to do testing
• How do I handle contractors working on or around my
workplace?– Can they adversely affect the process?
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Will Things Always Stay the
Same?
• What if I make changes in materials,
pressures, equipment, procedures, etc?– How will the changes affect other items
• Procedures
• Training
• PSI
• Testing
• Emergency procedures
• etc.
– Was the change significant? (PSSR)• New hose material
• New pump seal material
• New vessel
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Preventing Fires & Dealing with
Releases
• Do I have a program to ensure safe hot
work?
• How do I handle releases of ammonia?– Planning – is response necessary?
• If I do have a release or some incident,
what then?– Investigations
– Improvements
– What about if I “almost” have a release?
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Regular Program Review
• How do I make sure that year after year
my programs are working?– Who should do the audits?
– What should be audited?
– How is an audit conducted?
– What happens if the auditors find problems?
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PSI
Physical
& More
Running it
Dealing
with
Change
What could go
Wrong?
PHA Maintaining
it
RMP 2 and PSM Comparison
• RMP 2
– Eight program
elements:
• Safety Information
• Hazard Review
• Operating procedures
• Training
• Maintenance
• Incident Investigation
• Compliance audit
• Emergency response
• PSM
– Eight RMP 2 elements
plus
• Employee Participation
• Management of
Change
• Prestart-up safety
review
• Contractor safety
• Hot work program
RMP 2 and PSM Comparison
• RMP 2
– Safety information
• Safety data sheet
• Safe upper and lower
limits
• Equipment
specifications
• Codes and standards
used for design
• PSM
– Process Safety
Information
• Chemicals
• Technology
• Equipment
RMP 2 and PSM Comparison
• RMP 2
– Hazard review
• Identify hazards
• No required
methodology
• Can be completed by
an individual
• PSM
– Process Hazards
Analysis
• More in-depth study
• Requires personnel
involved in the process
• Requires human factors
analysis
• Requires facility siting
analysis
• Evaluate failure of
controls
RMP 2 and PSM Comparison
• RMP 2
– Maintenance
• Perform maintenance
• No other requirement
• PSM
– Mechanical Integrity• Six classes of equipment
including safety-critical
• Written procedures
• Procedures, inspections,
and testing must:
– Follow manufacturers
instructions
– Recognized and
generally accepted
good engineering
practice
RMP 2 and PSM Comparison
• RMP 2
– Emergency Response
• Coordinate with
responders
• PSM
– Emergency Response
• Must follow:
– 1910.38 – emergency
action plans or
– 1910.120 -
HAZWOPER
PSM Future
• Executive Order 13650 (8/1/13)
• OSHA PSM Request-for-Information
(12/9/13)
– Addresses many gaps identified since
promulgation
– Addresses modernizations necessary to align
with EPA and current industry practice
How to Get Assistance
• OSHA Compliance Assistance Program
– OSHA On-Site Consultation
– See the Web site for information on the office
closest to you
– 1-800-321-6742
• Jeffrey Wanko
– 202-693-2137
