spray, or deluge systems, monitor guns, dikes, designed drainage
systems, and other systems to control or mitigate hazardous chemi-
cals once an unwanted release occurs

The first step of | integrity program is to
p grity prog s

compile and categorize a list of process equipment and instrumenta-
tion to include in the program. This list includes pressure vessels,
storage tanks, process piping, relief and vent systems, fire protection
system components, emergency shutdown systems and alarms, and
interlocks and pumps. For the categorization of instrumentation and
the listed equipment, the employer should set priorities for which
pieces of equipment require closer scrutiny than others.

Inspection and Testing

The mean time to failure of various instrumentation and equipment
parts would be known from the manufacturer's data or the
employer's experience with the parts, which then influence inspec-
tion and testing frequency and associated procedures. Also, appli-
cable codes and standards—such as the National Board Inspection
Code, or those from the American Society for Testing and Materials,
American Petroieum institute, Nationai Fire Protection Association,
American Nationai Standards institute, American Society of Me-
chanicai Engineers, and other groups—provide information to heip
establish an effective testing and inspection frequency, as well as

The a

=
vn

»
=]
Qa
2. ©
D ><
and
ao

must be considered along with corrosion effects for piping and
valves. Where the corrosion rate is not known, a maximum inspec-
tion frequency is recommended (methods of developing the corro-
sion rate are available in the codes). Internal inspections need to
cover items such as the vessel shell, bottom and head; metallic
linings; nonmetallic linings; thickness measurements for vessels and
piping; inspection for erosion, corrosion, cracking and bulges;
internal equipment like trays, baffles, sensors and screens for
erosion, corrosion or cracking and other deficiencies. Some of these

14


OSHA Area Offices

Area Telephone
Albany, NY «+. (518) 464-6742
Albuquerque, NM .. ... (505) 766-3411
Allentown, PA ... «+. (215) 776-0592
Anchorage, AK . «+. (907) 271-5152
Appleton, Wi ... (414) 734-4521
Augusta, ME .... +++ (207) 622-8417
Austin, TX ... (512) 482-5783
Avenel, NJ.. «.- (908) 750-3270
Baltimore, MD ... (410) 962-2840
Baton Rouge, LA .. (504) 389-0474
Bayside, NY ... (718) 279-9060
Bellevue, WA ... (206) 553-7520
Billings, MT ... (406) 657-6649
Birmingham, AL .... ... (205) 731-1534
Bismarck, ND ... (701) 250-4521
.. (208) 334-1867
Bowmansville, NY .... ... (716) 684-3891
Braintree, MA ... (617) 565-6924
Bridgeport, CT ... (203) 579-5579
Calumet City, IL .... ... (708) 891-3800
Carson City, NV. (702) 885-6963
Charleston, WV .. (304) 347-5937

.. (518) 841-4132

Cincinnati, OH :

Cleveland, OH ... (216) 522-3818

Columbia, SC ... (803) 765-5904

Columbus, OH ... (614) 469-5582

Concord, NH ... (603) 225-1629

Corpus Christi, TX.... ... (512) 888-3257

Dallas, TX ... (214) 320-2400

Denver, CO..... .... (303) 844-5285
Des Plaines, Wo oo... eeeeesescceseeeseeceeeeseeeeeeeeneseneeeeeeees (708) 803-4800

38


DIRECTOR

Michigan Department of Labor
Victor Office Center

201 N. Washington Square
P.O. Box 30015

Lansing, MI 48933

(517) 373-9600

DIRECTOR
Michigan Department
of Public Health
3423 North Logan Street
Box 30195
Lansing, MI 48909
(517) 335-8022

COMMISSIONER

Minnesota Department of Labor
and Industry

443 Lafayette Road

St. Paul, MN 55155

(612) 296-2342

DIRECTOR

Nevada Department of Industrial
Relations

Capitol Complex

1370 S. Curry Street

Carson City, NV 89710

(702) 687-3032

34

SECRETARY

New Mexico Environmental
Department

Occupational Health
and Safety Bureau

1190 St. Francis Drive

P.O. Box 26110

Santa Fe, NM 87502

(505) 827-2850

COMMISSIONER
New York Department of Labor

State Office Building - Campus
12

Room 457
Albany, NY 12240
(518) 457-2741

COMMISSIONER

North Carolina Department
of Labor

4 West Edenton Street

Raleigh, NC 27601

(919) 733-0360

ADMINISTRATOR
Department of Consumer

and Business Services
Labor and Industries Building
350 Winter Street, NE, Room 430
Salem, OR 97310
(503) 378-3272


Small businesses covered by this rule often will have processes that
have less storage volume and less capacity and may be less compli-
cated than processes at a large facility. Therefore, OSHA would
anticipate that the less complex methodologies would be used to
meet the process hazard analysis criteria in the standard. These
process hazard analyses can be done in less time and with fewer
peopie being invoived. A iess compiex process generaiiy means that
less data, P&IDs, and process information are needed to perform a
process hazard analysis.

Many small businesses have processes that are not unique, such as
refrigerated warehouses or cold storage lockers or water treatment
facilities. Where employer associations have a number of members
with such facilities, a generic PHA, evolved from a checklist or what-
if questions, could be developed and effectively used by employers
to reflect their particular process; this would simplify compliance for
them.

When the employer has a number of processes that require a PHA,
the employer must set up a priority system to determine which PHAs
to conduct first. A preliminary hazard analysis may be useful in

setting oriorities for the orocesses that the emolover has determined
setting priorities for ine processes tnat ine empioyer nas ceierminea

are subject to coverage by the process safety management stan-
dard. Consideration should be given first to those processes with the
Potential of adversely affecting the largest number of employees.
This priority setting also should consider the potential severity of a
chemical release, the number of potentially affected employees, the
operating history of the process, such as the frequency of chemical
releases, the age of the process, and any other relevant factors.
Together, these factors would suggest a ranking order using either a
weighting factor system or a systematic ranking method. The use of
a preliminary hazard analysis will assist an employer in determining
which process should be of the highest priority for hazard analysis
resulting in the greatest improvement in safety at the facility occur-
ring first.

Detailed guidance on the content and application of process hazard
analysis methodologies is available from the American Institute of
Chemical Engineers’ Center for Chemical Process Safety, 345 E.
47th Street, New York, New York 10017, (212) 705-7319. Also, see
the discussion of various methods of process hazard analysis

contained in the Appendix to this publication.

Operating Procedures

Operating procedures describe tasks to be performed, data to be
recorded, operating conditions to be maintained, samples to be


CTs

Zz eanBy4

61

Notification of Process Change Checklist

Information about the Change:

Originator Date of Origination
Proposed Date of Change Area

O Permanent & Temporary From To

Description and Location of Change (Scope)
Technical Basis for Change

Nature of the Change:
Change affects: © Safety © Loss Prevention Environment C Health
Type of Change: CO Alarm © Shutdown Point © Addition or Removal of Equipment
C Piping Modification | Chemical © Process Computer Controt
© Job Procedure © Instrument © Equipment/Material Modification
GO Other.
Premodification Checklist 3

Applicable NA inifas *&~*

ay Consutt piping and equipment specfications.
“Perform reactive chemicals testing. © in process?
Add involved materiais to Toxic Substance Control Act (TSCA) inventory.
Calculate impact on F&EI and CEI.
Comply-with Engineering Practices.
Comply with Technology Center guidelines.
Comply with Dow Environmental Protection Guideline for Operations.
Comply with Safety and Loss Prevention requirements.
Consult maintenance (name)
Consult inswument and electrical technician (name)
Consult parts technician (name)
Evaluate and modify relief system (name)
Consult industrial Hygiene (name),
Consult Process Engineering (name),
Gompiete required reviews (name reviews).
ther. -

WITTE

oo000000000000000
oOo00000000000000

Postmodification Checklist (Before Startup):
Applicable N/A initals

o a Performed prestartup audit.

a a Completed or updated training program.

Qa ia) Wrote and obtained approval for job procedures.

a a Updated P&IDs process flow sheets and plot plans.

a a Trained personne! on the change.

a Ss Updated critical instrument checklist.

a Q Changed computer code and documentation.
Approvals: Name Date
Originator
First Reviewer

Department Head/Superintendent

Corporate S/LP/S

February 1982

Reprinted with permission of Dow Chemical USA,
2020 Dow Center, Midland, Mi 48762.



Des Moines, IA.... .. (515) 284-4794

Englewood, CO . (303) 843-4500
Erie, PA ... (814) 833-5758
Fort Lauderdale, FL.. ... (305) 424-0242
Fort Worth, TX +. (817) 885-7025
Frankfort, KY .... .. (502) 227-7024
Harrisburg, PA (717) 782-3902
Hartford, CT .. (203) 240-3152
Hasbrouck Heights, NJ ... (201) 288-1700
Hato Rey, PR ... (809) 766-5457
Honolulu, HI .. (808) 541-2685
Houston, TX .. (713) 286-0583
Houston, TX «. (713) 591-2438
Indianapolis, IN . (317) 226-7290
Jackson, MS . (601) 965-4606

«+. (904) 232-2895
(816) 426-2756

Jacksonville, FL ...
Kansas City, MO ..

Lansing, MI .- (517) 377-1892
Little Rock, AR . ... (501) 324-6291
Lubbock, TX ... (806) 743-7681
Madison, WI .. .. (608) 264-5388
Marlton, NJ. (609) 757-5181
Methuen, MA. ... (617) 565-8110
Milwaukee, WI . (414) 297-3315
Minneapolis, MN ... ... (612) 348-1994
Mobile, AL ... (205) 441-6131

Nashville, TN . (615) 781-5423
New York, NY. .-. (212) 264-9840
Norfolk, VA ... (804) 441-3820
North Aurora, IL . ... (708) 896-8700
Oklahoma City, OK (405) 231-5351
Omaha, NE oo... cece cece cceeeseceeseseeseneeseeeeeeeeeeeeats (402) 221-3182

Parsippany, NJ... .- (201) 263-1003
Peoria, IL ... (809) 671-7033
Philadelphia, PA ...........0. cece eee seeseeeeeeeceeseeeeseneees (215) 597-4955

39



Contents

Purpose
Application.
Exceptions ....

Process Safety Information
Hazards of the Chemicals Used in the Process...
Technology of the Process ...
Equipment in the Process .
Employee Involvement

Process Hazard Analysis 2.0.0.0... cccssssseeeeeseereeeecnneneeeeeerenensees 6
Operating Procedures ..
Employee Training
Contractors
Pre-Startup Safety Review ..............

Mechanical integrity of Equipment. .
Process Defenses ..........:cceeseseees 13
Written Procedures .
Inspection and Testing
Quality Assurance ..........

Nonroutine Work Authorizations.
Managing Change
Incident Investigation
Emergency Preparedness ..

Compliance Audits
Planning .
Staffing...
Conducting the
Evaluation and Corrective Action...

Conclusion
Appendix .........002
States with Approved Plans
OSHA Consultation Project Directory .
OSHA Area Offices

Illustrations

Figure 1. Process Flow Diagram
Figure 2. Request for Change Form...
Figure 3. Incident Investigation Report



* Probability of failure;
+ Detection methods; and
+ Remarks/compensating provisions.

Multiple concurrent failures also are included in the analysis. The
last step in the analysis is to analyze the data for each component or
multiple component failure and develop a series of recommendations
appropriate to risk management.

Fault Tree Analysis. A fault tree analysis can be either a qualitative
or a quantitative model of all the undesirable outcomes, such as a
toxic gas release or explosion, that could result from a specific
initiating event. It begins with a graphic representation (using logic
symbols) of all possible sequences of events that could result in an
incident. The resulting diagram looks like a tree with many branches
listing the sequential events (failures) for different independent paths
to the top event. Probabilities (using failure rate data) are assigned
to each event and then used to calculate the probability of occur-
rence of the undesired event.

This technique is particularly useful in evaluating the effect of alter-
native actions on reducing the probability of occurrence of the
undesired event.

32


inspections may be performed by state or local government inspec-
tors under state and local statutes. However, each employer must
develop procedures to ensure that tests and inspections are con-
ducted properly and that consistency is maintained even where
different employees may be involved. Appropriate training must be
provided to maintenance personnel to ensure that they understand
the preventive maintenance program procedures, safe practices, and
the proper use and application of special equipment or unique tools
that may be required. This training is part of the overall training
program called for in the standard.

Quality Assurance

A quality assurance system helps ensure the use of proper materials
of construction, the proper fabrication and inspection procedures,
and appropriate installation procedures that recognize field installa-
tion concerns. The quality assurance program is an essential part of
the mechanical integrity program and will help maintain the primary
and secondary lines of defense designed into the process to prevent
unwanted chemical releases or to control or mitigate a release. “As
built” drawings, together with certifications of coded vessels and
other equipment and materials of construction, must be verified and
retained in the quality assurance documentation.

Equipment installation jobs need to be properly inspected in the field
for use of proper materials and procedures and to ensure that
qualified craft workers do the job. The use of appropriate gaskets,
packing, bolts, valves, lubricants and welding rods needs to be
verified in the field. Also, procedures for installing safety devices
need to be verified, such as the torque on the bolts on rupture disc
installations, uniform torque on flange bolts, and proper installation of
pump seals. If the quality of parts is a problem, it may be appropri-
ate for the employer to conduct audits of the equipment supplier's
facilities to better ensure proper purchases of required equipment
suitable for intended service. Any changes in equipment that may
become necessary will need to be reviewed for management of
change procedures.

Nonroutine Work Authorizations

Nonroutine work conducted in process areas must be controlled by
the employer in a consistent manner. The hazards identified involv-
ing the work to be accomplished must be communicated to those
doing the work and to those operating personnel whose work could
affect the safety of the process. A work authorization notice or
permit must follow a procedure that describes the steps the mainte-

15


should be selected on the basis of their training, knowledge, and
ability to contribute to a team effort to fully investigate the incident.

Employees in the process area where the incident occurred should
be consulted, interviewed or made a member of the team. Their
knowledge of the events represents a significant set of facts about
the incident that occurred. The report, its findings, and recommen-
dations should be shared with those who can benefit from the
information. The cooperation of employees is essential to an effec-
tive incident investigation. The focus of the investigation should be
to obtain facts and not to place blame. The team and the investiga-
tive process should clearly deal with all involved individuals in a fair,
open, and consistent manner.

Emergency Preparedness

Each employer must address what actions employees are to take
when there is an unwanted release of highly hazardous chemicals.
Emergency preparedness is the employer’s third line of defense that
will be relied on along with the second line of defense, which is to

nd emergency
contro! the release of chemicals. Contro! releases and emergency

preparedness will take place when the first line of defense to operate
and maintain the process and contain the chemicals fails to stop the
release. In preparing for an mergency chemical release, employers

+ Whether they want employees to handle and stop small or minor
incidental releases;

+ Whether they wish to mobilize the available resources at the plant
and have them brought to bear on a more significant release;

+ Whether employers want their employees to evacuate the danger
area and promptly escape to a preplanned safe zone area, and
then allow the local community emergency response organizations
to handle the release; or

+ Whether the employer wants to use some combination of these
actions.

Employers will need to select how many different emergency pre-

paredness or third lines of defense they plan to have, develop | the
necessary emergency plans and procedures, appropriately train
employees in their emergency duties and responsibilities, and then

imnlamen haan Hnae of dafance

implement these lines of defense.

24


operating procedures and processes. Employers may wish to
develop a form or clearance sheet to facilitate the processing of
changes through the management of change procedures. A typical
change form may include a description and the purpose of the
change, the technical basis for the change, safety and health consid-
erations, documentation of changes for the operating procedures,
maintenance procedures, inspection and testing, P&IDs, electrical
classification, training and communications, pre-startup inspection,
duration (if a temporary change), approvals, and authorization.
Where the impact of the change is minor and well understood, a
check list reviewed by an authorized person, with proper communi-
cation to others who are affected, may suffice. (See Figure 2 fora
sample request for change form that can be helpful in guiding this
procedure.)

For a more complex or significant design change, however, a hazard
evaluation procedure with approvals by operations, maintenance,
and safety departments may be appropriate. Changes in documents
such as P&lDs, raw materials, operating procedures, mechanical
integrity programs, and electrical classifications should be noted so
that these revisions can be made permanent when the drawings and
procedure manuals are updated. Copies of process changes must
be kept in an accessible location to ensure that design changes are
available to operating personnel as well as to PHA team members
when a PHA is being prepared or being updated.

Incident Investigation

Incident investigation is the process of identifying the underlying
causes of incidents and implementing steps to prevent similar events
from occurring. The intent of an incident investigation is for employ-
ers to learn from past experiences and thus avoid repeating past
mistakes. The incidents OSHA expects employers to recognize and
to investigate are the types of events that resulted in or could rea-
sonably have resulted in a catastrophic release. These events are
sometimes referred to as “near misses,” meaning that a serious
consequence did not occur, but could have. (See Figure 3 for
sample incident investigation report form.)

Employers must develop in-house capability to investigate incidents
that occur in their facilities. A team should be assembled by the
employer and trained in the techniques of investigation including how
to conduct interviews of witnesses, assemble needed documenta-
tion, and write reports. A multi-disciplinary team is better able to
gather the facts of the event and to analyze them and develop
plausible scenarios as to what happened, and why. Team members

17


States with Approved Plans

COMMISSIONER

Alaska Department of Labor
1111 West 8th Street

Room 306

Juneau, AK 99801

(907) 465-2700

DIRECTOR

industrial Commission of Arizona
800 W. Washington

Phoenix, AZ 85007

(602) 542-5795

DIRECTOR
California Department

of Industrial Relations
455 Golden Gate Avenue
4th Floor
San Francisco, CA 94102
(415) 703-4590

COMMISSIONER

Connecticut Department of Labor
200 Folly Brook Boulevard
Wethersfield, CT 06109

(203) 566-5123

DIRECTOR

Hawaii Department of Labor
and Industrial Relations

830 Punchbowl Street

Honolulu, Hi 96813

(808) 586-8844

COMMISSIONER

Indiana Department of Labor
State Office Building

402 West Washington Street
Room W195

Indianapolis, IN 46204

(317) 232-2378

COMMISSIONER

lowa Division of Labor Services
1000 E. Grand Avenue

Des Moines, 1A 50319

(515) 281-3447

SECRETARY

Kentucky Labor Cabinet

1049 U.S. Highway, 127 South
Frankfort, KY 40601

(502) 564-3070

COMMISSIONER
Maryland Division of Labor
and Industry
Department of Licensing
and Regulation
501 St. Paul Place, 2nd Floor
Baltimore, MD 21202-2272
(410) 333-4179

33


Contractors

Employers who use contractors to perform work in and around
processes that involve highly hazardous chemicals have to establish
a screening process so that they hire and use only contractors who
accomplish the desired job tasks without compromising the safety
and health of any employees at a facility. For contractors whose
safety performance on the job is not known to the hiring employer,
the employer must obtain information on injury and illness rates and
experience and should obtain contractor references. In addition, the
employer must ensure that the contractor has the appropriate job
skills, knowledge, and certifications (e.g., for pressure vessel weld-
ers). Contractor work methods and experience should be evaluated.
For example, does the contractor conducting demolition work swing
loads over operating processes or does the contractor avoid such
hazards?

Maintaining a site injury and iliness iog for contractors is another
method employers must use to track and maintain current knowledge
of activities involving contract employees working on or adjacent to

processes covered by POM. injury and iliness logs of both ‘the
empioyer's s employees and contre

log contains information useful to those  auching process safet ety

management compliar ice and those involved in incident investiga-

wn

oy
Nv

oO
an
i)

3
ae

Contract employees must perform their wor afely. Considering

that contrac nd potentially
hazardous t e entry activities and
nonroutine 1 ust be controlled while they
are on or near a process covered y PS . r

authorization system for these ac

ployer has better coordination and more management control over
the work being performed in the process area. A well-run and well-
maintained process, where employee safety is fully recognized,
benefits all of those who work in the facility whether they are employ-
ees of the employer or the contractor.

Pre-Startup Safety Review

For new processes, the employer will find a PHA helpful in improving
the design and construction of the process from a reliability and
quality point of view. The safe operation of the new process is
enhanced by making use of the PHA recommendations before finai

12


Solvent
Storage

A\

Raw
Material
Storage

cws

os

Vent System

CONDENSER — CWR

REACTOR

Catalyst
(Drum Stock)

Condensate,
cwR

CWR

PACKED

|<t— CWS

COLUMN

REFLUX
CONDENSER

Soivent

Reclamation

System

Vacuum System

VACUUM.
RECEIVER

SOLVENT
STRIPPER

RO, Water
System

Wastewater
Treatment
System

WASH
VESSEL

Product
Storage

Process Flow

ABC Diagram
Chemical,
inc. No. Rev.

L eanbig


Appendix - Methods of Process Hazards Analysis

On July 17, 1990, OSHA issued a proposed rule for the management
of hazards associated with processes using highly hazardous
chemicals. This rule, called the Process Safety Management
standard, was finalized on February 24, 1992.

In an appendix to the proposed rule, OSHA discussed several
methods of process hazard analysis. That discussion, which may be
helpful for those doing job hazard analyses, follows:

What-if. For relatively uncomplicated processes, review the process
from raw materials to product. At each handling or processing step,
“what if” questions are formulated and answered, to evaluate the
effects of component failures or procedural errors on the process.

Checklist. For more compiex processes, the “what if” study can be
best organized through the use of a “checkiist,” and assigning certain
aspects of the process to the committee members having the
greatest experience or skill in evaluating those aspects. Operator
practices and job knowledge are audited in the field, the suitability of
equipment and materials of construction is studied, the chemistry of
the process and the control systems are reviewed, and the operating
and maintenance records are audited. Generally, a checklist evalua-
tion of a process precedes use of the more sophisticated methods
described below, unless the process has been operated safely for
many years and has been subjected to periodic and thorough safety
inspections and audits.

What-If/Checklist. The what-if/checklist is a broadly based hazard
assessment technique that combines the creative thinking of a
selected team of specialists with the methodical focus of a prepared
checklist. The result is a comprehensive hazard analysis that is
extremely useful in training operating personne! on the hazards of
the particular operation.

The review team is selected to represent a wide range of production,
mechanical, technical, and safety disciplines. Each person is given a
basic information package regarding the operation to be studied.
This package typically includes information on hazards of materials,
process technology, procedures, equipment design, instrumentation
control, incident experience, and previous hazards reviews. A field
tour of the operation also is conducted at this time.

The review team methodically examines the operation from receipt of
raw materials to delivery of the finished product to the customer's
site. At each step, the group collectively generates a listing of “what-
if questions regarding the hazards and safety of the operation.

30


Compliance Audits

An audit is a technique used to gather sufficient facts and informa-
tion, including statistical information, to verify compliance with
standards. Employers must select a trained individual or assemble a
trained team to audit the process safety management system and
program. A small process or plant may need only one knowledge-
able person to conduct an audit. The audit includes an evaluation of
the design and effectiveness of the process safety management
system and a field inspection of the safety and health conditions and
practices to verify that the employer's systems are effectively imple-
mented. The audit should be conducted or led by a person knowl-
edgeable in audit techniques who is impartial towards the facility or
area being audited. The essential elements of an audit program
include planning, staffing, conducting the audit, evaluating hazards
and deficiences and taking corrective action, performing a follow-up
and documenting actions taken.

Planning

Planning is essential to the success of the auditing process. During
planning, auditors should select a sufficient number of processes to
give a high degree of confidence that the audit reflects the overail
ievel of compliance with the standard. Each empioyer must establish
the format, staffing, scheduling, and verification methods before
conducting the audit. The format should be designed to provide the
lead auditor with a procedure or checklist that details the require-
ments of each section of the standard. The names of the audit team
members should be listed as part of the format as well. The check-
list, if properly designed, could serve as the verification sheet that
provides the auditor with the necessary information to expedite the
review of the program and ensure that all requirements of the
standard are met. This verification sheet format could also identify
those elements that will require an evaluation or a response to
correct deficiencies. This sheet also could be used for developing
the follow-up and documentation requirements.

Staffing

The selection of effective audit team members is critical to the
success of the program. Team members should be chosen for their
experience, knowledge, and training and should be familiar with the
processes and auditing techniques, practices, and procedures. The
size of the team will vary depending on the size and complexity of
the process under consideration. For a large, complex, highly
instrumented plant, it may be desirable to have team members with
expertise in process engineering and design; process chemistry;
instrumentation and computer controls; electrical hazards and

27


Purpose

The major objective of process safety management (PSM) of highly
hazardous chemicals is to prevent unwanted releases of hazardous
chemicals especially into locations that could expose employees and
others to serious hazards. An effective process safety management
program requires a systematic approach to evaluating the whole
chemical process. Using this approach, the process design, process
technology, process changes, operational and maintenance activities
and procedures, nonroutine activities and procedures, emergency
preparedness plans and procedures, training programs, and other
elements that affect the process are all considered in the evaluation.

Application

The various lines of defense that have been incorporated into the
design and operation of the process to prevent or mitigate the
release of hazardous chemicals need to be evaluated and strength-
ened to ensure their effectiveness at each level. Process safety
management is the proactive identification, evaluation and mitigation
or prevention of chemical releases that could occur as a resuit of
failures in processes, procedures, or equipment.

The process safety management standard targets highly hazardous
chemicals that have the potential to cause a catastrophic incident.
The purpose of the standard as a whole is to aid employers in their
efforts to prevent or mitigate episodic chemical releases that could
lead to a catastrophe in the workplace and possibly in the surround-
ing community.

To control these types of hazards, employers need to develop the
necessary expertise, experience, judgement, and initiative within
their work force to properly implement and maintain an effective
process safety management program as envisioned in the Occupa-
tional Safety and Health Administration (OSHA) standard.

The OSHA standard is required by the Clean Air Act Amendments,
as is the Environmental Protection Agency’s Risk Management Plan,
which will be proposed in 1992. Employers who merge the two sets
of requirements into their process safety management program will
better assure full compliance with each as well as enhance their
relationship with the local community.

Although OSHA believes process safety management will have a
positive effect on the safety of employees and will offer other poten-
tial benefits to employers, such as increased productivity, smaller
businesses that may have limited resources available to them at this




ing procedures put in place, and the operating staff trained to run the
be’

process, before startup. The initial startup procedures and normal
operating procedures must be fully evaluat ted as part of the pre-
p ure a safe transfer into the normal oper: ating

For existing processes that have been shutdown for turnaround or
modification, the employer must ensure that any changes other than
“replacement in kind” made to the process during shutdown go
through the management of change procedures. P&IDs will need to
be updated, as necessary, as well as operating procedures and
instructions. If the changes made to the process during shutdown
are significant and affect the training program, then operating
personnel as well as employees engaged in routine and nonroutine
work in the process area may need some refresher or additional
training. Any incident investigation recommendations, compliance
audits, or PHA recommendations need to be reviewed to see what
affect they may have on the process before beginning the startup.

Mechanical Integrity of Equipment

Employers musi review their maintenance programs and schedules

to see if there are areas where “breakdown” maintenance is used
rather than the more preferable on-going mechanical integrity

Process Defenses

The first line of defense an employer has is to operate and maintain
the process as designed and to contain the chemicals. This is
backed up by the second line of defense which is to control the
release of chemicals through venting to scrubbers or flares, or to
surge or overflow tanks designed to receive such chemicals. This
also would include fixed fire protection systems like sprinklers, water


training programs and the operating procedures; contractors whose
employees will be working with the process; those conducting the
pre-startup reviews; as well as local emergency preparedness
planners, and insurance and enforcement officials.

The information to be compiled about the chemicals, including
process intermediates, needs to be comprehensive enough for an
accurate assessment of the fire and explosion characteristics,
reactivity hazards, the safety and health hazards to workers, and the
corrosion and erosion effects on the process equipment and monitor-
ing tools. Current material safety data sheet (MSDS) information can
be used to help meet this requirement but must be supplemented
with process chemistry information, including runaway reaction and
over-pressure hazards, if applicabie.

Technology of the Process

Process technology information will be a part of the process safety
information package and should include employer-established
criteria for maximum inventory levels for process chemicals; limits
beyond which would be considered upset conditions; and a qualita-
tive estimate of the consequences or results of deviation that could
occur if operating beyond the established process limits. Employers
are encouraged to use diagrams that will help users understand the
process.

A block flow diagram is used to show the major process equipment
and interconnecting process flow lines and flow rates, stream
composition, temperatures, and pressures when necessary for
clarity. The block flow diagram is a simplified diagram.

Process flow diagrams are more complex and show all main flow
streams including valves to enhance the understanding of the
process as well as pressures and temperatures on all feed and
product lines within all major vessels and in and out of headers and
heat exchangers, and points of pressure and temperature control
(see Figure 1 for a sample process flow diagram). Also, information
on construction materials, pump capacities and pressure heads,
compressor horsepower, and vessel design pressures and tempera-
tures are shown when necessary for clarity. In addition, process flow
diagrams usually show major components of control loops along with
key utilities.


02

te

National Safety Council

ACCIDENT INVESTIGATION REPORT

‘ADDRESS

COMPANY
DEPARTMENT

LOCATION (it citterent from mating address)

1. NAME of INJURED

2. SOCIAL SECURITY NUMBER | 3. SEX
cm oF

4-AGE | 5. DATE of ACCIDENT

6. HOME ADDRESS

7 EMPLOYEE'S USUAL OCCUPATION

8. OCCUPATION at TIME of ACCIDENT

11, EMPLOYMENT CATEGORY
C Regular, tulktime C2 Temporary Cl Nonemployee

9. LENGTH of EMPLOYMENT
‘DLess than 1 mo. (16 mos. to 5 yrs.

215 mos.

‘Di More than 5 yrs.

10. TIME in OCCUP. at TIME of ACCIDENT
C Less tnan 1 mo, 6 mos. to 5 yrs

O15 mos. More than 5 yrs

Ci Regular, part-ume 2 Seasonal

13, NATURE of INJURY and PART of BODY

12. CASE NUMBERS and NAMES of OTHERS INJURED in SAME ACCIDENT

V4. NAME and ADDRESS of PHYSICIAN

15. NAME and ADDRESS of HOSPITAL

pr ote ot shi

16. TIME of INJURY

AM
APM,

> B Time within shit

Ae _

17. SEVERITY of INJURY

CO Fatality
CO Lost workdays—days away from work
C Lost workdays—days of restricted activity

D Medical treatment
OFirst aia

COther, soecity

18. SPECIFIC LOCATION of ACCIDENT

‘ON EMPLOYER'S PREMISES? Yes No

19, PHASE, OF EMPLOVEE's WORKDAY at TIME of INJURY

si
eras) ‘During rest ped
"2.5 our mat os
© Wong over,
een og

C Entering or leaving plant
Oi Pertorming work duties
Somer

20. DESCRIBE HOW the ACCIDENT OCCURRED

21. ACCIDENT SEQUENCE. Descnbe in reverse order of occurrence events preceding the injury and accident. Staring
‘with the injury and moving backward m time, reconstruct the sequence of events that led to the injury

‘A. Injury Event

B. Accisent Event

C. Prereaing Event #1

D. Preceding Event #2, #3, etc

€ einByy

ns


Compliance

U.S. Department of Labor



Employers who have not implemented an occupational safety and
health program may wish to form a safety and health committee of
employees and management representatives to help the employer
meet the PSM obligations. Such a committee can be a significant
ally in helping the employer implement and maintain an effective
process safety management program for all employees.

Process Hazard Analysis

A process hazard analysis (PHA), or evaluation, is one of the most
important elements of the process safety management program. A
PHA is an organized and systematic effort to identify and analyze the
significance of potential hazards associated with the processing or
handling of highly hazardous chemicals. A PHA provides information
that will assist employers and employees in making decisions for
improving safety and reducing the consequences of unwanted or
unplanned releases of hazardous chemicals.

A PHA analyzes potential causes and consequences of fires, explo-
sions, releases of toxic or flammable chemicals, and major spills of
hazardous chemicals. The PHA focuses on equipment, instrumenta-
tion, utilities, human actions (routine and nonroutine), and external
factors that might affect the process.

The selection of a PHA methodology or technique will be influenced
by many factors including how much is known about the process. Is
it a process that has been operated for a long period of time with little
or no innovation and extensive experience has been generated with
its use? Or, is it a new process or one that has been changed
frequently by the inclusion of innovation features? Also, the size and
complexity of the process will influence the decision as to the appro-
priate PHA methodology to use. All PHA methodologies are subject
to certain limitations. For example, the checklist methodology works
well when the process is very stable and no changes are made, but it
is not as effective when the process has undergone extensive
change. The checklist may miss the most recent changes and
consequently they would not be evaluated. Another limitation to be
considered concerns the assumptions made by the team or analyst.
The PHA is dependent on good judgement and the assumptions
made during the study need to be documented and understood by
the team and reviewer and kept for a future PHA.

The team conducting the PHA needs to understand the methodology
that is going to be used. A PHA team can vary in size from two
people to a number of people with varied operational and technical
backgrounds. Some team members may be part of the team for only


Equipment in the Process

Piping and instrument diagrams (P&lDs) may be the more appropri-
ate type diagrams to show some of the above details as well as
display the information for the piping designer and engineering staff.
The P&lDs are to be used to describe the relationships between
equipment and instrumentation as well as other relevant information
that will enhance clarity. Computer software programs that do P&IDs
or other diagrams useful to the information package may be used to
help meet this requirement.

The information pertaining to process equipment design must be
documented. In other words, what codes and standards were relied
on to establish good engineering practice? These codes and
standards are published by such organizations as the American
Society of Mechanical Engineers, the American Petroleum Institute,
American National Standards institute, National Fire Protection
Association, American Society for Testing and Materiais, The
National Board of Boiler and Pressure Vessel inspectors, Nationai
Association of Corrosion Engineers, American Society of Exchange
Manufacturers Association, and Modei Buiiding Code groups.

For existing equipment designed and constructed many years ago in
accordance with the codes and standards availabie at that time and
no longer in generai use today, the empioyer must document which

ds S h in and consiructio

Cartign 29, at Am

Section 30: ct Am

eratg cone: pac

are to cons: ees

ing th: ndi

ing th 1d

mana ca ard

mana Sa ard

204 2 to tra ed

304 al to trai edi

and to i ees of the findi

investig rocess safet

Many empl. existina safety

Many empl existing safety

already hay methods to keep e
resenta it relevant saf

oe


Related Publications

OSHA-2056 All About OSHA

OSHA-3084 Chemical Hazard Communication
OSHA-3047 Consultation Services for the Employer
OSHA-3088 How to Prepare for Workplace Emergencies
OSHA-2098 OSHA Inspections

OSHA-3021 OSHA: Employee Workplace Rights
OSHA-3077 Personal Protective Equipment

OSHA-3132 Process Safety Management

OSHA-3079 Respiratory Protection

Hazard Communication Standard, Title 29, Code of Federal
Regulations (CFR) Part 1910.1200.

Process Safety Management of Highly Hazardous Chemicals
Standard, Title 29, Code of Federal Regulations (CFR) Part
1910.119 FR 57, P. 6356. This contains the actual text of the PSM
tule.

(A single free copy of the above materials can be obtained from
OSHA Publications Office, Room N3101, Washington, DC 20210,
(202) 523-9667).

OSHA-3104 Hazard Communication - A Compliance Kit
(A reference guide to step-by-step requirements for compliance
with the OSHA standard.)

OSHA-3071 Job Hazard Analysis

(OSHA 3104 and OSHA 3071 are available from the Superintendent
of Documents, U.S. Government Printing Office, Washington, DC
20402, (202) 783-3238. OSHA 3104 - GPO Order No. 929-022-
000009, $18-domestic; $22.50-foreign. OSHA 3071 - GPO Order No.
029-016-00142-5, $1.00.)

U.S. GOVERNMENT PRINTING OFFICE : 1994 O - 154-969 : QL 3


require engineering studies or more detailed review of actual proce-
dures and practices. There may be instances where no action is
necessary; this is a valid response to an audit finding. All actions
taken, including an explanation when no action is taken on a finding,
need to be documented.

The employer must assure that each deficiency identified is ad-
dressed, the corrective action to be taken is noted, and the respon-
sible audit person or team is properly documented. To control the
corrective action process, the employer should consider the use of a
tracking system. This tracking system might include periodic status
reports shared with affected levels of management, specific reports
such as completion of an engineering study, and a final implementa-
tion report to provide closure for audit findings that have been
through management of change, if appropriate, and then shared with
affected employees and management. This type of tracking system
provides the employer with the status of the corrective action. It also
provides the documentation required to verify that appropriate
corrective actions were taken on deficiencies identified in the audit.

Conciusion
OSHA believes the preceding discussion of PSM should help small
employers to comply more easily with the new requirements the

standard imposes. The end result can only be safer more healthful
workplace for all employees—a goal we all share.

29


classifications; safety and health disciplines; maintenance; emer-
gency preparedness; warehousing or shipping; and process safety
auditing. The team may use part-time members to provide the
expertise required and to compare what is actually done or followed
with the written PSM program.

Conducting the Audit

An effective audit includes a review of the relevant documentation
and process safety information, inspection of the physical facilities,
and interviews with all levels of plant personnel. Utilizing the audit
procedure and checklist developed in the preplanning stage, the
audit team can systematically analyze compliance with the provi-
sions of the standard and any other corporate policies that are
relevant. For example, the audit team will review aii aspects of the
training program as part of the overall audit. The team will review
the written training program for adequacy of content, frequency of
training, effectiveness of training in terms of its goals and objectives
as well as to how it fits into meeting the standard’s requirements.
Through interviews, the team can determine employees’ knowledge
and awareness of the safety procedures, duties, rules, and emer-
gency response assignments. During the inspection, the team can
observe actual practices such as safety and health policies, proce-
dures, and work authorization practices. This approach enables the
team to identify deficiencies and determine where corrective actions
or improvements are necessary.

Evaluation and Corrective Action

The audit team, through its systematic analysis, should document
areas that require corrective action as well as where the process
safety management system is effective. This provides a record of
the audit procedures and findings and serves as a baseline of
operation data for future audits. It will assist in determining changes
or trends in future audits.

Corrective action is one of the most important parts of the audit and
includes identifying deficiencies, and planning, following-up, and
documenting the corrections. The corrective action process normally
begins with a management review of the audit findings. The purpose
of this review is to determine what actions are appropriate, and to
establish priorities, timetables, resource allocations and require-
ments, and responsibilities. In some cases, corrective action may
involve a simple change in procedures or a minor maintenance effort
to remedy the problem. Management of change procedures need to
be used, as appropriate, even for a seemingly minor change. Many
of the deficiencies can be acted on promptly, while some may

28


time, might consider alternative avenues of decreasing the risks
associated with highly hazardous chemicals at their workplaces.
One method that might be considered is reducing inventory of the
highly hazardous chemical. This reduction in inventory will result in
reducing the risk or potential for a catastrophic incident. Also,
employers, including small employers, may establish more efficient
inventory control by reducing, to below the established threshold, the
quantities of highly hazardous chemicals onsite. This reduction can
be accomplished by ordering smaller shipments and maintaining the
minimum inventory necessary for efficient and safe operation. When
reduced inventory is not feasible, the employer might consider
dispersing inventory to several locations onsite. Dispersing storage

into locations so that a release in one loc tion will not cause a

e in another |

ay to reduce the risk

The PSM standard does not apply to the following:

¢ Retail facilities;

Oil or gas well drilling or servicing operations;

.

Normally unoccupied remote facilities;

* 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; or

¢ Flammable liquids stored in atmospheric tanks or transferred,
which are kept below their normal boiling point without benefit of
chilling or refrigerating and are not connected to a process.

Process Safety Information
Hazards of the Chemicals Used in the Process

Complete and accurate written information concerning process
chemicals, process technology, and process equipment is essential
to an effective process safety management program and to a pro-
cess hazard analysis. The compiled information will be a necessary
resource to a variety of users including the team performing the
process hazard analysis as required by PSM; those developing the


nance supervisor, contractor representative, or other person needs
to follow to obtain the necessary clearance to start the job. The work
authorization procedures must reference and coordinate, as appli-
cable, lockout/tagout procedures, line breaking procedures, confined
space entry procedures, and hot work authorizations. This proce-
dure also must provide clear steps to follow once the job is com-
pleted to provide closure for those that need to know the job is now
completed and that equipment can be returned to normal.

Managing Change

To properly manage changes to process chemicals, technology,
equipment and facilities, one must define what is meant by change.
In the process safety management standard, change includes all
modifications to equipment, procedures, raw materials, and process-
ing conditions other than “replacement in kind.” These changes
must be properly managed by identifying and reviewing them prior to
implementing them. For example, the operating procedures contain
the operating parameters (pressure limits, temperature ranges, flow
rates, etc.) and the importance of operating within these limits. While
the operator must have the flexibility to maintain safe operation
within the established parameters, any operation outside of these
parameters requires review and approval by a written management
of change procedure. Management of change also covers changes
in process technology and changes to equipment and instrumenta-
tion. Changes in process technology can result from changes in
production rates, raw materials, experimentation, equipment unavail-
ability, new equipment, new product development, change in cata-
lysts, and changes in operating conditions to improve yield or quality.
Equipment changes can be in materials of construction, equipment
specifications, piping pre-arrangements, experimental equipment,
computer program revisions, and alarms and interlocks. Employers
must establish means and methods to detect both technical and
mechanical changes.

Temporary changes have caused a number of catastrophes over the
years, and employers must establish ways to detect both temporary,
and permanent changes. It is important that a time limit for temporary
changes be established and monitored since otherwise, without
control, these changes may tend to become permanent. Temporary
changes are subject to the management of change provisions. In
addition, the management of change procedures are used to ensure
that the equipment and procedures are returned to their original or
designed conditions at the end of the temporary change. Proper
documentation and review of these changes are invaluable in
ensuring that safety and health considerations are incorporated into

16


OSHA Consultation Project Directory

State Telephone
Alabama .... (205) 348-3033
. (907) 269-4939
. (602) 542-5795
. (501) 682-4522
w+. (415) 7038-4441
w+. (303) 491-6151
«+. (203) 566-4550
... (302) 577-3908
.... (202) 576-6339
s+. (904) 488-3044
«+ (404) 894-8274
.. (671) 647-4202
«+. (808) 586-9116
+. (208) 385-3283

. (312) 814-2337

District of Columbia
Florida ....
Georgia ..

Illinois...
Indiana .. (317) 232-2688
lowa .... «+. (515) 281-5352
Kansas s+ (913) 296-4386
Kentucky ... ... (502) 564-6895
Louisiana ... w+. (504) 342-9601
«+ (207) 624-6460
Maryland .... (410) 333-4218
Massachusetts ..........0.:cccccceseeseseeeteseeeeseseseseteteneeeeseee (617) 969-7177
MICHIGAN 0.0... coe ccc ecceeeeeeseneeeeteeseeeseeeseesesensenees (517) 322-8250(H)
(517) 322-1809(S)
Minnesota (612) 297-2393
Mississippi . . (601) 987-3981
MiSSOUFE oo... ececeeeeeeceeeeseeseseeseseeatsecscsecseseesseseeees (314) 751-3403
Montana ..... ss (406) 444-6418
Nebraska .... ws. (402) 471-4717

36


LN CN (o - ESES (702) 486-5016
New Hampshire 00.2.0... eee eeeceeeceesseceeceseseseseseesesseeeeaee (603) 271-2024

New Jersey .. .. (609) 292-3923
New Mexico (505) 827-2877
(518) 457-2481
North Carolina.. (919) 733-2360
North Dakota ... (701) 221-5188
(614) 644-2631
(405) 528-1500
(503) 378-3272
Pennsylvania ... (412) 357-2396
Puerto Rico (809) 754-2171
Rhode Island ... (401) 277-2438
South Carolina . (803) 734-9599
South Dakota... (605) 688-4101

Tennessee . .. (615) 741-7036

(512) 440-3834

(801) 530-6868

(802) 828-2765

Virginia (804) 786-8707

Virgin Islands... (809) 772-1315

Washington (206) 956-5443

West Virginia ... (304) 558-7890

WISCONSIN .......cceece ee eeee cee eeeceeceeeceeeseeeeeeeeseeseeeeaees (608) 266-8579(H)

(608) 266-1818(S)

WYOMING 00... cceceececceececsecececeececseeesscseseceesesseesseeees (307) 777-7786
(H) - Health
(S) - Safety

37


Emp! n, t have an emergency a
will facilitate the prompt evacuation of employees when there is an
unwanted release of a highly hazardous chemical. This means that
the employer's plan will be activated by an alarm system to alert
employees when to evacuate, and that employees who are physi-
cally impaired will have the necessary support and assistance to get
them to a safe zone. The intent of these requirements is to alert and
move employees quickly to a safe zone. Delaying alarms or confus-
ing alarms are to be avoided. The use of process control centers or
buildings as safe areas is discouraged. Recent catastrophes indi-
cate that lives are lost in these structures because of their location
and because they are not necessarily designed to withstand over-
pressures from shock waves resulting from explosions in the process
area.

n plan that
p

When there are unwanted incidental releases of highly hazardous
chemicals in the process area, the employer must inform employees
of the actions/procedures to take. if the employer wants employees
to evacuate the area, then the emergency action plan will be acti-
vated. For outdoor processes, where wind direction is important for
selecting the safe route to a refuge area, the empioyers shouid piace
a wind direction indicator, such as a wind sock or pennant, at the
highest point visible throughout the process area. Employees can
wind of the sé to gain safe access to a refuge area by
iowing the wind direction.

z

If area to

CO those

co , these

a eloped and
im mergencies in
the proce: ppropri

ref
ne}
omy

aso oO

ear The employer's gpr
ing the Hazard Communication standard training, is to address,
identify, and meet the training needs for employees who are ex-
pected to handle incidental or minor releases.

Preplanning for more serious releases is an important element in the
employer's line of defense. When a serious release of a highly
hazardous chemical occurs, the employer, through preplanning, will
have determined in advance what actions employees are to take.
The evacuation of the immediate release area and other areas, as
necessary, would be accomplished under the emergency action
plan. If the employer wishes to use plant personnel—such as a fire
brigade, spill control team, a hazardous materials team—or employ-
ees to render aid to those in the immediate release area and to
control or mitigate the incident, refer to OSHA’s Hazardous Waste

nN
co)


4


Occupational Safety and Health Administration

Regional Offices

Region I

433: Portland Street

4ct FI

Region VI

525 Griffin Street

Room602.

TSUTIOor

Boston, MA 02144

Room 602

Dallas, TX 75202

Region Il
(NJ, NY,* PR,* VI)

Region Vil

201 Varick Street
Room 670

(IA,* KS, MO, NE)
914 Walnut Street, Room 406
Kansas Gity, MO-64106

New York, NY 10014
Telephone: (212) 337-2378

Telephone: “(81 6) 426-5861

Region Vill

Region Ill
(DC, DE, MD,* PA, VA,* WV)

(CO, MT, ND, SD, UT,* WY*)

Gateway Building, Suite 2100
3535 Market Street

Federal Building, Room 1576

41961-Stout Street
Denver,CO.80294

Philadelphia, PA 19104
Telephone: (215) 596-1201

Telephone: (303) 844-3061

Region IX

Region IV
(AL, FL, GA, KY,* MS, NC,

Telephone: (404) 347-3573

(American Samoa, AZ,* CA,*

San Francisco, CA 04105

Telephone: Nat 5). 744-6670

RegionV

Region X

(it, IN,* MI,* MN,* OH, wi)

Telephone: (31 2)-353-2220

(AK," ID, OR," WA")

Telephone: (206) 553-5930

*These states and territories operate their own OSHA-approved job safety
bli



collected, and safety and health precautions to be taken. The
procedures need to be technically accurate, understandable to
employees, and revised periodically to ensure that they reflect
current operations. The process safety information package helps to
ensure that the operating procedures and practices are consistent
with the known hazards of the chemicals in the process and that the
operating parameters are correct. Operating procedures should be
reviewed by engineering staff and operating personnel to ensure
their accuracy and that they provide practical instructions on how to
actually carry out job duties safely. Also the employer must certify
annually that the operating procedures are current and accurate.

Operating procedures provide specific instructions or details on what
steps are to be taken or followed in carrying out the stated proce-
dures. The specific instructions should include the applicable safety
precautions and appropriate information on safety implications. For
example, the operating procedures addressing operating parameters
will contain operating instructions about pressure limits, temperature
ranges, flow rates, what to do when an upset condition occurs, what
alarms and instruments are pertinent if an upset condition occurs,
and other subjects. Another example of using operating instructions
to properly implement operating procedures is in starting up or
shutting down the process. In these cases, different parameters will
be required from those of normal operation. These operating
instructions need to clearly indicate the distinctions between startup
and normal operations, such as the appropriate allowances for
heating up a unit to reach the normai operating parameters. Also,
the operating instructions need to describe the proper method for
increasing the temperature of the unit until the normal operating
temperatures are reached.

Computerized process control systems add complexity to operating
instructions. These operating instructions need to describe the logic
of the software as well as the relationship between the equipment
and the control system; otherwise, it may not be apparent to the
operator.

Operating procedures and instructions are important for training
operating personnel. The operating procedures are often viewed as
the standard operating practices (SOPs) for operations. Control
room personnel and operating staff, in general, need to have a full
understanding of operating procedures. If workers are not fluent in
English, then procedures and instructions need to be prepared in a
second language understood by the workers. In addition, operating
procedures need to be changed when there is a change in the
process. The consequences of operating procedure changes need
to be fully evaluated and the information conveyed to the personnel.
For example, mechanical changes to the process made by the


Hands-on training, where employees actually apply lessons learned
in simulated or real situations, will enhance learning. For example,
operating personnel, who will work in a control room or at control
panels, would benefit by being trained at a simulated control panel.
Upset conditions of various types could be displayed on the simula-
tor, and then the employee could go through the proper operating
procedures to bring the simulator panel back to the normal operating
parameters. A training environment could be created to help the
trainee feel the full reality of the situation but under controlled
conditions. This type of realistic training can be very effective in
teaching employees correct procedures while allowing them also to
see the consequences of what might happen if they do not follow
established operating procedures. Other training techniques using
videos or training also can be very effective for teaching other job
tasks, duties, or imparting other important information. An effective
training program will allow employees to fully participate in the
training process and to practice their skills or knowledge.

Employers need to evaluate periodically their training programs to
see if the necessary skills, knowledge, and routines are being
properly understood and impiemented by their trained employees.
The methods for evaluating the training should be developed along
with the training program goals and objectives. Training program
evaluation will help employers to determine the amount of training
their employees understood and whether the desired results were
obtained. If, after the evaluation, it appears that the trained employ-
ees are not at the level of knowledge and skill that was expected, the
employer should revise the training program, provide retraining, or
provide more frequent refresher training sessions until the deficiency
is resolved. Those who conducted the training and those who
received the training also should be consulted as to how best to
improve the training process. !f there is a language barrier, the
language known to the trainees should be used to reinforce the
training messages and information.

Careful consideration must be given to ensure that employees,
including maintenance and contract employees, receive current and
updated training. For example, if changes are made to a process,
affected employees must be trained in the changes and understand
the effects of the changes on their job tasks. Additionally, as already
discussed, the evaluation of the employee’s absorption of training
will certainly determine the need for further training.

11


Process Safety
Management
Guidelines for
Compliance

U.S. Department of Labor
Robert B. Reich, Secretary

Occupational Safety and Health Administration
Joseph A. Dear, Assistant Secretary

OSHA 3133
4994 (Reprinted)


SECRETARY
Puerto Rico Department of Labor
and Human Resources

Prudencio Rivera Martinez
Building

505 Munoz Rivera Avenue
Hato Rey, PR 00918
(809) 754-2119

COMMISSIONER

South Carolina Department
of Labor

3600 Forest Drive

P.O. Box 11329

Columbia, SC 29211-1329

(803) 734-9594

COMMISSIONER

Tennessee Department of Labor
710 James Robertson Parkway
Suite “A” - 2nd Floor

Nashville, TN 37243-0659

(615) 741-2582

COMMISSIONER

industrial Commission of Utah
P.O. Box 146600

Salt Lake City, UT 84110-6600
(801) 530-6898

COMMISSIONER

Vermont Department of Labor
and Industry

120 State Street

Montpelier, VT 05620

(802) 828-2288

COMMISSIONER

Virgin |slands Department
of Labor

2131 Hospital Street

Christiansted

St. Croix, VI 00840-4666

(809) 773-1994

COMMISSIONER

Virginia Department of Labor
and Industry

Powers- Taylor Building

13 South 13th Street

Richmond, VA 23219

(804) 786-2377

DIRECTOR

Washington Department of Labor
and Industries

General Administration Building

P.O. Box 44001

Olympia, WA 98504-4001

(206) 956-4213

ADMINISTRATOR
Occupational Safety and Heaith
Administration

Herschier Building, 2nd Floor
East

122 West 25th Street
Cheyenne, WY 82002
(307) 777-7672

35


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4

2. TASK and ACTIVITY at TIME of ACCIDENT 73. POSTURE of EMPLOYEE

‘A. General type of task

8. Specific actrnty

24. SUPERVISION at TIME of ACCIDENT
©. Employee was working:

‘A Directy supervised C Not supervised
Clone Ci with crew or fellow warker Omer, specity

Ci Indirectly suoervsed 5 Supervsion not feasibie

25. CAUSAL FACTORS. Events and conaitons that contnbuted to the accident. Include those
‘identified by use at the Guide for Identifying Causal Factors and Corrective Actions,

aA
(26. CORRECTIVE ACTIONS. Those that nave Deen, or will De, taken to prevent Tecur
indentified by use of the Guide for identifying Causal Factors and Corrective Actions.

PREPARED BY APPROVED
TmeE TITLE DATE
DEPARTMENT. DATE APPROVED

Reprinted with permission from the Nationa! tme DATE
‘Satety Council, 1121 Spnng Lake Dnve,

itasca, IL 60143-3201

(panujuog) ¢ aanBy4


This informational booklet provides a generic,
non-exhaustive overview of OSHA standards-
related topics. This publication does not itself
alter or determine compliance responsibilities,
which are set forth in OSHA standards them-
selves and the Occupational Safety and Health
Act. Moreover, because interpretations and
enforcement policy may change over time, for
additional guidance on OSHA compliance
requirements, the reader should consult current
administrative interpretations and decisions by
the Occupational Safety and Health Review

Commission and the courts.

Material contained in this publication is in the
public domain and may be reproduced, fully or
partially, without permission of the Federal
Government. Source credit is requested but not
required.

This information will be made available to
sensory impaired individuals upon request.
Voice phone: (202) 219-8045;
Telecommunications Device for the Deaf (TDD)
message referral phone: 1-800-326-2577


When the review team has completed listing its spontaneously
generated questions, it systematically goes through a prepared
checklist to stimulate additional questions.

Subsequently, answers are developed for each question. The
review team then works to achieve a consensus on each question
and answer. From these answers, a listing of recommendations is
developed specifying the need for additional action or study. The
recommendations, along with the list of questions and answers,
become the key elements of the hazard assessment report.

Hazard and Operability Study (HAZOP). HAZOP is a formally
structured method of systematically investigating each element of a
system for all of the ways in which important parameters can deviate
from the intended design conditions to create hazards and operability
problems. The hazard and operability problems are typically deter-
mined by a study of the piping and instrument diagrams (or plant
model) by a team of personnel who critically analyze effects of
potential problems arising in each pipeline and each vessel of the
operation.

Pertinent parameters are selected, for example, flow, temperature,
pressure, and time. Then the effect of deviations from design
conditions of each parameter is examined. A list of key words, for
example, “more of,” “less of,” “part of,” are selected for use in de-
scribing each potential deviation.

The system is evaluated as designed and with deviations noted. All
causes of failure are identified. Existing safeguards and protection
are identified. An assessment is made weighing the consequences,
causes, and protection requirements involved.

Failure Mode and Effect Analysis (FMEA). The FMEA is a methodi-
cal study of component failures. This review starts with a diagram of
the operation, and includes all components that could fail and
conceivably affect the safety of the operation. Typical examples are
instrument transmitters, controllers, valves, pumps, rotometers, etc.
These components are listed on a data tabulation sheet and individu-
ally analyzed for the following:

+ Potential mode of failure, (i.e., open, closed, on, off, leaks, etc);

* Consequence of the failure; effect on other components and
effects on whole system;

+ Hazard class, (i.e., high, moderate, low);

31


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Springfield, MA ... (413) 785-0123

... (314) 425-4249
. (815) 451-0808

St. Louis, MO ...
Syracuse, NY ...

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40


Operations and Emergency Response (HAZWOPER) standard (Title
29 CFR Part 1910.120). If outside assistance is necessary, such as
through mutual aid agreements between employers and local
government emergency response organizations, these emergency
responders are also covered by HAZWOPER. The safety and health
protection required for emergency responders is the responsibility of
their employers and of the on-scene incident commander.

Responders may be working under very hazardous conditions;
therefore, the objective is to have them competently led by an on-
scene incident commander and the commander's staff, properly
equipped to do their assigned work safely, and fully trained to carry
out their duties safely before they respond to an emergency. Drills,
training exercises, or simulations with the local community emer-
gency response planners and responder organizations is one means
to obtain better preparedness. This close cooperation and coordina-
tion between plant and local community emergency preparedness
managers also will aid the employer in complying with the Environ-
mental Protection Agency’s Risk Management Plan criteria.1

An effective way for medium to large facilities to enhance coordina-
tion and communication during emergencies within the plant and with
local community organizations is by establishing and equipping an
emergency control center. The emergency control center should be
located in a safe zone so that it could be occupied throughout the
duration of an emergency. The center should serve as the major
communications link between the on-scene incident commander and
plant or corporate management as well as with local community
officials. The communications equipment in the emergency control
center should include a network to receive and transmit information
by telephone, radio, or other means. It is important to have a backup
communications network in case of power failure or if one communi-
cation means fails. The center also should be equipped with the
plant layout; community maps; utility drawings, including water for
fire extinguishing; emergency lighting; appropriate reference materi-
als such as a government agency notification list, company person-
nel phone list, SARA Title Ill reports and material safety data sheets,
emergency plans and procedures manual; a listing with the location
of emergency response equipment and mutual aid information; and
access to meteorological data and any dispersion modeling data.

‘EPA is required by the Clean Air Act Amendments of 1990 to develop regulations that
will require companies to make available to the public information on the way the
companies manage the risks of the chemicals they handle. These regulations will be
developed in 1992. The OSHA PSM standard, which meets similar Clean Air
Amendment requirements and the forthcoming EPA rules, will apply only to specified
chemicals in listed quantities. OSHA and EPA's lists will not necessarily be identical.

26


a limited time. The team leader needs to be fully knowledgeable in
the proper implementation of the PHA methodology to be used and
should be impartial in the evaluation. The other full or part-time team
members need to provide the team with expertise in areas such as
process technology; process design; operating procedures and
practices; alarms; emergency procedures; instrumentation; mainte-
nance procedures, both routine and nonroutine tasks, including how
the tasks are authorized; procurement of parts and supplies; safety
and health; and any other relevant subjects. At least one team
member must be familiar with the process.

The ideal team will have an intimate knowledge of the standards,
codes, specifications, and regulations applicable to the process
being studied. The selected team members need to be compatible
and the team leader needs to be able to manage the team and the
PHA study. The team needs to be able to work together while
benefiting from the expertise of others on the team or outside the
team to resolve issues ard to forge a consensus on the findings of
the study and recommendations.

The application of a PHA to a process may involve the use of
different methodologies for various parts of the process. For ex-
ample, a process involving a series of unit operations of varying
sizes, complexities, and ages may use different methodologies and
team members for each operation. Then the conclusions can be
integrated into one final study and evaluation.

A more specific example is the use of a PHA checklist for a standard
boiler or heat exchanger and the use of a Hazard and Operability
PHA for the overall process. Also, for batch-type processes like
custom batch operations, a generic PHA of a representative batch
may be used where there are only small changes of monomer or
other ingredient ratio and the chemistry is documented for the full
range and ratio of batch ingredients. Another process where the
employer might consider using a generic type of PHA is a gas plant.
Often these plants are simply moved from site to site, and therefore,
a generic PHA may be used for these movable plants. Also, when
an employer has several similar size gas plants and no sour gas is
being processed at the site, a generic PHA is feasible as long as the
variations of the individual sites are accounted for in the PHA.

Finally, when an employer has a large continuous process with
several control rooms for different portions of the process, such as
for a distillation tower and a blending operation, the employer may
wish to do each segment separately and then integrate the final
results.


maintenance department (like changing a valve from steel to brass
or other subtle changes) need to be evaluated to determine whether
operating procedures and practices also need to be changed. All
management of change actions must be coordinated and integrated
with current operating procedures, and operating personnel must be
alerted to the changes in procedures before the change is made.
When the process is shut down to make a change, then the operat-
ing procedures must be updated before re-starting the process.

Training must include instruction on how to handle upset conditions
as well as what operating personnel are to do in emergencies such
as pump seal failures or pipeline ruptures. Communication among
operating personnel and workers within the process area performing
nonroutine tasks also must be maintained. The hazards of the tasks
are to be conveyed to operating personnel in accordance with
established procedures and to those performing the actuai tasks.
When the work is compieted, operating personnei shouid be in-
formed to provide closure on the job.

with reading and un
training in subjects such as operating procedures and safe work

S$ suCcN as OD ig procedures

practices, emergency evacuation and response, safety procedures,

routine and nonroutine work authorization activities, and other areas
pertinent to process safety and health need to be covered by the
employer's training program.

In establishing their training programs, employers must clearly
identify the employees to be trained, the subjects to be covered, and
the goals and objectives they wish to achieve. The learning goals or
objectives should be written in clear measurable terms before the
training begins. These goals and objectives need to be tailored to
each of the specific training modules or segments. Employers
should describe the important actions and conditions under which
the employee will demonstrate competence or knowledge as well as
what is acceptable performance.

10