Workshop K Best Practices ... Implementation of Process Safety - - PDF document

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
• n 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?

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• 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

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?

Bordon Ice Cream 1983 Millard Ref. Services ‐ 2010 Goodyear Tire & Rubber ‐ 2008 Dixie Cold Storage 1984 Stavis Seafoods ‐ 2016 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 single process. (Appendix A of 1910.119)

• RMP List of chemicals and their

thresholds vary somewhat from PSM

Ammonia threshold for both PSM and RMP is 10,000 lbs

Process = any group of interconnected vessels and separate vessels located 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

• f 10,000 pounds and above.
• Manufacturers of explosives

and pyrotechnics

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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

• PSI
• PHA
• SOPs
• Training
• Mechanical

Integrity

• Contractors
• Employee

Participation

• Compliance Audit
• PSSR
• MOC
• Incident

Investigation

• Hot Work Permits
• Emergency Plan

OSHA PSM EPA RMP

• RMP*eSubmit
• Confidential

Information

• Hazard Assessment
• Management Programs

Regulatory Review: Overlap

• Safe Work

Practices

• Trade Secrets
• Emergency Coordination

• Incident Investigation
• Emer. Planning & Response
• Compliance Audits
• Trade Secrets

PSM/RMP Elements

• Employee Participation
• Process Safety Information
• Process Hazard Analysis
• Operating Procedures
• 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%

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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%

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All Food Manf./Cold Storage ChemNEP Citations by PSM Sub‐element FY 14 thru FY 18 Sub‐element Description % of PSM Citations 1910.119(d)(3)(ii) PSI RAGAGEP Compliance 12.1% 1910.119(j)(2) MI Written Procedures 6.9% 1910.119(j)(5) MI Equipment Deficiencies 5.3% 1910.119(d)(3)(i)(B) PSI P&IDs 5.2% 1910.119(j)(4)(iii) MI Inspection Frequency Not to RAGAGEP 4.1% 1910.119(f)(1) OP Developed & Implemented 3.7% 1910.119(n) Emergency Planning & Response 3.6% 1910.119(e)(5) PHA Findings & Recommendations 3.3% 1910.119(f)(3) OP ‐ Review 2.8% 1910.119(j)(4)(i) MI I&T Not Performed 2.8% 1910.119(l)(1) Management of Change Dev & Imp 2.8% 1910.119(j)(4)(iv) MI I&T Documentation 2.7% 1910.119(o)(4) CA Response to Findings/Deficiencies 2.3% 1910.119(j)(4)(ii) MI I&T Not to RAGAGEP 2.1%

What is this RAGAGEP you speak of?

• Recognized and Generally Accepted Good Engineering

Practices −Model Codes

• NFPA, ICC, IAPMO

−State or Local Building Codes −Consensus Industry Standards

• Ex: API, IIAR

−Manufacturer’s or Industry Association Recommendations

• Ex: Chlorine Institute

−Company Standards

29 CFR 1910.119 references RAGAGEP in 2 elements

• 1910.119(d) Process Safety Information For the design
• f all process equipment

−1910.119(d)(3)(ii): The employer shall document that equipment complies with recognized and generally accepted good engineering practices. −1910.119(d)(3)(iii): For existing equipment designed and constructed in accordance with codes, standards, or practices that are no longer in general use, the employer shall determine and document that the equipment is designed, maintained, inspected, tested, and operating in a safe manner.

• 1910.119(j) Mechanical Integrity For inspection and test

(I&T) methods and frequency for equipment covered under (j)(1)

−1910.119(j)(4)(ii) Inspection and testing procedures shall follow recognized and generally accepted good engineering practices. −1910.119(j)(4)(iii) The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior

• perating experience.

29 CFR 1910.119 references RAGAGEP in 2 elements

PSI: Design Codes/Standards: What do I need?

40 CFR 68.65(d)(1)(vi), 29 CFR 1910.119 (d)(3)(i)(F)

Model Codes State Codes Industry Standards

PSI: Design Codes/Standards: What do I need?

40 CFR 68.65(d)(1)(vi), 29 CFR 1910.119 (d)(3)(i)(F)

• My process was built in 1960. What design codes do

I need? −Those in effect at the facility location at the time

• f initial design and construction

−Those in effect when the process was modified −Evaluate updates to design codes and standards during your PHA revalidation.

PSI: Design Codes/Standards: What do I need?

40 CFR 68.65(d)(1)(vi), 29 CFR 1910.119 (d)(3)(i)(F)

PSI: Design Codes/Standards: What do I need?

40 CFR 68.65(d)(1)(vi), 29 CFR 1910.119 (d)(3)(i)(F)

• How about Manufacturer’s Specifications?

Internal Standards – Why should we use them?

• Translating RAGAGEP into detailed facility

implementation of program or procedure

• Unique equipment or no RAGAGEP exists
• Supplement inadequately addressed equipment
• Controls hazards more effectively
• Other RAGAGEP are outdated or no longer good

engineering practices

Revised RA Memo – “Shall” Language in RAGAGEP

• “Shall” is a mandatory minimum requirement

−Failure to follow presumed violative

• Example: Chlorine Pamphlet 1‐ 13.8.5 Connections: A

chlorine compatible flexible connection must be used between the container and a pressurized piping

• system. If a chlorine covered process does not include a

Cl2 compatible connection as stipulated, a violation of 119(d)(3)(ii) is presumed.

Revised RA Memo – “Should” Language in RAGAGEP

• Focus on control of the hazard
• Substitution of administrative controls for engineering

controls is a red flag – these are unlikely to be deemed RAGAGEP

• The employer does not have to justify deviation from

“should” statements, but still must document compliance with RAGAGEP

Revised RA Memo – “Should” Language in RAGAGEP

• Identifies an acceptable and preferred approach to

controlling hazards

• If applicable to the employer’s process & equipment,

compliance is acceptable to OSHA

• Alternate approaches may be acceptable if they are

RAGAGEP

Enforcement Considerations

• Employers choose their RAGAGEP (not OSHA)
• No OSHA list of acceptable/required RAGAGEP
• Multiple standards ‐ if protective either is acceptable

Example API 520/521 and ISO 4196 for pressure relief system design & installation, or IIAR2 for pressure relief system design for ammonia refrigeration systems

Enforcement Considerations

• Do not need to comply with provision that is not

applicable to specific worksite conditions −Document, Document, Document

• Stay inside intended area of application

−Don’t use ammonia inspection for refinery process −Don’t use API or NBIC internal inspection standards in an ammonia refrigeration process.

Enforcement Considerations

• Adopt RAGAGEP(s) that control all hazards in covered

process

• Selected RAGAGEP might not control all hazards
• Must adopt another RAGAGEP to address remaining

hazards

• Inadequate control of hazards by mixing and matching

provisions

Enforcement Considerations

• Frequency of testing consistent with applicable

Manufacturer’s recommendations

• More frequent if necessary by prior experience
• Employer must meet own internal requirements

Enforcement Considerations

• Mechanical Integrity

−correct deficiencies before further use −or interim means to assure safe

• peration

−Timely scheduling permanent correction

• Older covered equipment RAGAGEP

may not exist at time constructed

• Must document operating and

maintaining in a safe manner

Enforcement Considerations

• Establish and document age & installation date of

equipment, modifications & RAGAGEP selected including addition & publication date

• Updated RAGAGEP ‐More protective but not explicitly

retroactive −Not have to upgrade equipment etc. −But must document is operating in safe manner.

• Notify OSHA if RAGAGEP changed to be less protective

• Steps to improve

compliance

−Take the time to identify all parts of the covered process

• What are your

boundaries?

Process Safety Information

40 CFR 68.65(d), 29 CFR 1910.119 (d)

• Steps to improve

compliance

−Take the time to research the appropriate technical

• perating specifications for

the equipment Process Safety Information

40 CFR 68.65(d), 29 CFR 1910.119 (d)

• Steps to improve compliance

−If the technical operating specifications are not available, then make note of the equipment for which the information is lacking and discuss those in detail at the first opportunity using proper PHA techniques Process Safety Information

40 CFR 68.65(d), 29 CFR 1910.119 (d)

• Steps to improve compliance

−Verify current RAGAGEP with every Management of Change Process Safety Information

40 CFR 68.65(d), 29 CFR 1910.119 (d)

• Steps to improve compliance

−Evaluate RAGAGEP updates as part of your PHA revalidation Process Safety Information

40 CFR 68.65(d), 29 CFR 1910.119 (d)