Process Safety Management (PSM) and Risk Management Plan (RMP): - - PowerPoint PPT Presentation

Identifying the Likelihood of Hazardous Events in Your Facility

Conan Reed, GSP Nick Foreman, CSP

November 19, 2020

Process Safety Management (PSM) and Risk Management Plan (RMP):

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• Safety & IH Services Project

Manager

• BS in Occupational Safety and

Health, Murray State University

• 19 Years of Consulting

CONAN REED, GSP

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NICK FOREMAN, CSP

• Safety & IH Services Group Manager
• B.S. in Biology, Texas A&M University
• Master of Public Health, Texas A&M

University

• 14 Years of consulting

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PSM/RMP WHAT ARE THEY?

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• Intended to be mirror programs but it didn’t happen that way.
• PSM – OSHA’s program to protect workers
• RMP – EPA’s program to protect the environment and the

community

Goals of PSM and RMP

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PROCESS SAFETY MANAGEMENT – APPLICABILITY & EXEMPTIONS

Who is covered and what is required?

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• A process which involves a chemical at or above the

specified threshold quantities listed in Appendix A of CFR 1910.119;

• A process which involves a Category 1 flammable or a

flammable liquid with a flashpoint below 100 degrees Fahrenheit on site in one location, in a quantity of 10,000 pounds or more.

Applicability of the PSM Standard?

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Some Example Appendix A Chemicals & Thresholds

USE THE CAS NUMBERS!!!!

Chemical OSHA PSM Threshold Chlorine 1,500 lbs. Anhydrous Ammonia 10,000 lbs. Formaldehyde 1,000 lbs. Toluene Diisocyanate (TDI) Not Listed Hydrogen Fluoride 1,000 lbs. Phosgene 100 lbs.

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Businesses with potential PSM-covered processes

Asphalt Paving/Roofing Materials (NAICS 32412) Chemical and Allied Products (NAICS 4246) Chemical Products- Misc (NAICS 42469) Drugs (NAICS 4242) Fabricated Metal (NAICS 332) Fabricated Rubber Products (NAICS 32521) Food and Kindred Products (NAICS 31199) Industrial Organic Chemicals (NAICS 32519) Inorganic Chemical Manufacturing (NAICS 32518) Lumber, Wood Products (NAICS 321) Natural Gas Liquids (NAICS 2212) Paints, Varnishes, Enamels (NAICS 3255) Paper and Allied Products (NAICS 32229) Plastics Products- Miscellaneous (NAICS 3261) Plastics, Rubber, Cellulosics (NAICS 325211) Petroleum & Coal Products-Misc (NAICS 32419) Petroleum Refining (NAICS 32411) Primary Metals Industries (NAICS 331) Stone, Glass & Concrete (NAICS 21232, 3272, 3273) Textile Mill Products (NAICS 3131) Wholesale Trade (NAICS 42)

PSM 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 with a flashpoint below 100 °F stored in atmospheric tanks or transferred which are kept below their normal boiling point without benefit of chilling or refrigeration. (Note: Atmospheric tanks are storage tanks designed to

• perate at pressures from atmospheric through 0.5 psig)

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Who is not covered by PSM?

Retail facilities Oil or gas well drilling

• r servicing operations

Normally unoccupied remote facilities

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It’s applicable, now what?

Then develop your PSM program

PSI PHA Operating Procedures Employee Participation Training Contractors Pre-Startup Safety Reviews Mechanical Integrity Hot Work Permitting MOC Incident Investigation Emergency Planning and Response Compliance Audits Trade Secrets

Then perform a process hazard analysis (PHA) Start by compiling your existing written process safety information (PSI)

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• Process Hazards
• Previous Incidents
• Engineering and

administrative controls

• Consequences of a

failure of controls

• Facility siting
• Human Factors

What does a PHA cover?

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Example PHA Methodologies

What If/Checklist Hazard and Operability Study (HAZOP) Failure Mode and Effects Analysis (FMEA) Fault Tree Analysis

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HAZOP Method

Setup the HAZOP Study

• Identify and Select Nodes
• Divide system into parts, use

P&IDs or process flow diagrams

• Identify Guidewords

Identify Deviations using guidewords Identify causes or concequences Identify Safety Measures Assign Risks Provide Recommendations

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HAZOP Guidewords

Parameter Guideword Deviation Flow None, Less, More, Reverse, Other, Also, Misdirected No flow, Less Flow, More Flow, Reverse Flow, Other, Contamination, Misdirected Flow Pressure More, Less (High, Low) More Pressure, Less Pressure Temperature (Product and Ambient) More, Less (High, Low) Higher Temperature, Lower Temperature Viscosity More, Less More Viscosity, Less Viscosity Reaction None, Less, More No Reaction Reaction Incomplete Intense Reaction

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Don’t try to do this on your own! The PHA Team should consist of the following:

• Experts in the engineering and process operations
• Employees who have specific knowledge of the process
• A member that is knowledgeable in the specific PHA

methodology being used (typically 3rd party)

PHA Team

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How often must I audit and perform PHA updates?

An audit should be performed every 3 years to ensure compliance and that the procedures and practices put into remain adequate. The PHA should be updated/revalidated every 5 years after the initial assessment.

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Large Manufacturer of AC Units Large Propane tank 10,000 lbs. as a reserve in case natural gas was not available. Natural gas used for heating and for brazing

• perations. Propane was used as backup.

Is the propane tank exempt?

PSM Applicability Scenario

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• OSHA currently has nine

Active NEPs

• Process Safety

Management

• Combustible Dust
• Hazardous Machinery
• Hexavalent Chromium
• Lead
• Primary Metal Industries
• Shipbreaking
• Silica
• Trenching & Excavation

National Emphasis Program (NEP)?

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RISK MANAGEMENT PROGRAMS – APPLICABILITY & EXEMPTIONS

40 CFR Part 68

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Stationary facilities holding more than a threshold quantity of a regulated substance in a process are required to comply with EPA’s Risk Management Program regulations.

Who falls under the RMP Standard?

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Is your facility a stationary source? Yes Do you have a regulated substance above a threshold quantity in a process? Yes You are subject to the rule! Assign Program levels to covered processes. No STOP! You are not covered by the rule. No STOP! You are not covered by the rule.

RMP Applicability Flow Chart

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• Ammonia: when held by a farmer for use on a farm as a
• fertilizer. It does not apply to agricultural suppliers or the

fertilizer manufacturer. It does not apply to farm cooperatives or to groups of farmers who buy, use, and sell ammonia.

• In the event that a farmer stores one or more other regulated

substance above threshold quantities, that storage would be covered.

RMP Exemptions: Ammonia

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• Flammable Fuels: Flammable substances listed in § 68.130

are excluded from coverage under part 68 when they are used as a fuel or held for sale as a fuel at a retail facility.

• A retail facility is defined as a stationary source at which more than

half of the income is obtained from direct sales to end users or at which more than one-half of the fuel sold, by volume, is sold through a cylinder exchange program.

RMP Exemptions: Flammable Fuels

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• Transportation Activities: The rule applies only to stationary
• sources. It does not apply to transportation, including

storage incident to transportation.

• Transportation includes, but is not limited to:
• transportation subject to oversight or regulation under 49 CFR parts 192

(Federal safety standards for transportation of natural and other gas by pipeline), 193 (Federal safety standards for liquefied natural gas facilities), or 195 (Federal safety standards for transportation of hazardous liquids by pipeline), or a state natural gas or hazardous liquid program for which the state has in effect a certification to DOT under 49 U.S.C. 60105.

RMP Exemptions: Transportation Activities

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• West, Texas
• Fertilizer Plant
• >50,000 lbs of

Ammonium Nitrate

• Large explosion
• Covered by RMP???

RMP Applicability Scenario?

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Some Example Listed Chemicals & Thresholds

USE THE CAS NUMBERS!!!! Chemical OSHA PSM Threshold EPA RMP Threshold Chlorine 1,500 lbs. 2,500 lbs. Anhydrous Ammonia 10,000 lbs. 10,000 lbs. Formaldehyde 1,000 lbs. 15,000 lbs. Toluene Diisocyanate (TDI) Not Listed 10,000 lbs. Hydrogen Fluoride 1,000 lbs. Anhydrous 1,000 lbs. Phosgene 100 lbs. 500 lbs.

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Each facility's program should address three areas:

• Hazard assessment
• Prevention program
• Emergency response program

What does the RMP require?

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• Program 1: Processes which would not affect the public in the case
• f a worst-case release and with no accidents with specific offsite

consequences within the past five years are eligible for Program 1.

• Limited hazard assessment requirements and minimal prevention and

emergency response requirements.

• Program 3: Processes not eligible for Program 1 and either subject

to OSHA's PSM standard under federal or state OSHA programs or classified in one of ten specified NAICS codes

• Imposes OSHA’s PSM standard as the prevention program as well as

additional hazard assessment, management, and ER requirements.

RMP Program Levels

32211, 32411, 32511, 325181, 325188, 325192, 325199, 325211, 325311, or 32532.

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• Program 2: Processes not

eligible for Program 1 or subject to Program 3 are placed in Program 2

• imposes streamlined

prevention program requirements, as well as additional hazard assessment, management, and emergency response requirements.

RMP Program Levels

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• Know your applicability
• Know your exemptions
• Can be in RMP and PSM
• Can be in one and not the
• ther
• Both are time intensive and

not a one-time event/expense

• Plenty of Guidance

Be Careful...

• Flammable Liquids Definitions are

different

• OSHA uses flashpoint (<100)
• EPA uses NFPA Category 4 (essentially

flammable gases)

• Unless your flammable is a listed

chemical you probably won't fall under RMP.

• Check concentrations for

hydrochloric acid, Hydrofluoric Acid, Nitric Acid, and Ammonia

Conclusions

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Conan Reed, GSP Nick Foreman, CSP

Project Manager Group Manager 972.509.9616 972.509.9609 CReed@BraunIntertec.com NForeman@BraunIntertec.com

CONTACT INFORMATION

Lance French

Business Development Manager 972.509.9612 LFrench@BraunIntertec.com

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