Chapter 1: Chemical Process Safety Regulations Flashcards
Regulations
Set specific rules about legality and provide the details pertinent to the related law
Regulations are created from laws by:
- Proposing a regulation in the Federal Register (FR)
- Codifying the text in the Code of Federal Regulations (CFR)
29 CFR § 1910.132 (a)
“29” = title
“CFR” = Code of Federal Regulations or how to implement the law
“USC” = describes a law
Weird symbol = symbol for section or part
1910.132 = Section #
(a) = Paragraph
What did the 1970 Occupational Safety and Health Act (OSHAct) define?
Establishing regulations, conducting investigations for compliance, developing and maintaining safety and health records
What 2 duties did OSHAct set for employers?
Furnish a place of employment free from recognized hazards causing or likely to cause death or serious harm, AND comply with occupational safety and health standards
National Institute for Occupational Safety and Health (NIOSH)
Conducts research and technical assistance programs for protection and maintenance of workers’ health
Occupational Safety and Health Administration (OSHA)
Manages, administers, and enforces responsibilities in OSHAct
OSHA published “Process Safety Management of Highly Hazardous Chemicals” in 1992. What does it contain?
Contains the requirements for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals.
Why was Process Safety Management (PSM) developed?
As a result of the Bhopal Disaster in 1984
How many sections are in the PSM standard?
14
When have the majority of US chemical plant process safety incidents occurred?
During normal operations
Why have the majority of US chemical plant process safety incidents occurred?
Top contributing factors: design, preventive maintenance, safeguards/controls/and layers of protection, emergency preparedness and response, safety culture, hazard awareness and identification, mechanical integrity, and human factors
Best Industrial Practices: Risk-Based Process Safety (RBPS) Management
- Issued by Center of Chemical Process Safety (CCPS) in 2007
- Widely-accepted industry-based standards incorporating regulatory approaches
- 20 RPBS elements
Process Safety Information
- Must be compiled and made available to all employees
- Includes toxicity, permissible exposure levels, process chemistry, safe operating limits
- detailed process design information
- consequences of deviations are also required
Employee Involvement
- Employees must be involved in developing and implementing PSM
- Written plan for active participation in all major elements of PSM as defined by employer
Process Hazards Analysis (PHA)
- Evaluation of potential causes and consequences of a safety incident
- Evaluation by a team of experts
- Uses generally accepted methodologies such as HAZOP, What-if, fault trees etc.
- PHA updated at least every 5 years
Operating Procedures
- written procedures developed, implemented, and maintained
- Covers startup, normal, temporary, and emergency operations, normal and emergency shutdown, precautions, quality specifications, control systems and functions
- safe work practices (hot work, lockout/tagout, confined space work)
Training
- Programs to train employees about hazards
- Refresher training every 3 years
Contractors
- Must have skills necessary to perform work safely
- They must be informed of all hazards related to the work and the emergency action plan
Pre-startup Safety Review
- Special safety review after modification to the process or operating conditions (before startup) to ensure equipment meets design specifications, procedures and training has been implemented, and hazard analysis recommendations have been addressed.
Mechanical Integrity
- ensure equipment, piping, relief systems, controls, and alarms are mechanically sound and operational
- written procedures for maintenance
- preventative maintenance training
- periodic inspections and testing
- procedure for corrections
- process for evaluating equipment and spares are sufficient
Hot Work
- hot work activities include: welding, grinding, using spark-producing equipment
- requires authorization dates, equipment involved, hazard analysis, signatures, etc.
Management of change (MOC)
- manage changes in process chemistry, raw material, process equipment, and operating procedures
- ensure that changes to processes are properly analyzed, documented, and communicated to employees
- ensures that changes to a process do not introduce new hazards or increase existing hazards
Incident investigation
- Each incident that resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical must be investigated
- This investigation must begin no later than 48 hours following the incident
Emergency planning and response
Required employee plan to respond effectively to the release of highly hazardous chemicals
Compliance audits
- certification of compliance required every 3 years
- address all areas of PSM
Trade secrets
Secrets must be made known to employees if this information is needed to meet PSM responsibilities, but may be protected under confidentiality agreements
Tesoro Anacortes Refinery Disaster
A heat exchanger shell failed catastrophically which resulted in 7 fatalities
EPA
Environmental Protection Agency
What does the EPA do?
- published the risk management program (RMP) in 1996, also in response to Bhopal
- designed to decrease number and magnitude of accidental releases of toxic and flammable substances
- documentation is shared with regulatory agencies and local community
What are the 3 components of EPA RMP?
Hazard assessment, prevention program, emergency response program
What is the difference in the OSHA PSM and the EPA RMP
Process safety management is designed to protect on-site individuals, whereas the risk management plan is designed to protect off-site individuals and the environment
EPA RMP: Hazard Assessment
- consequence analysis for potential releases
- includes “worst-case” scenario and more likely but significant accident scenario
- typically a risk matrix
- worst-case scenario based on releasing the entire contents of a vessel or piping system in a 10-minute period under worst-case meteorological conditions
- only consequence, not probability
EPA RMP: Prevention Program
- 12 elements
- Substantial overlap with PSM’s 14 elements
EPA RMP: Emergency Response Program
- steps to be taken by employees in response to accidental release
- procedures for notifying the community and emergency response agencies
- emergency drills required
Chemical Facility Anti-Terrorism Standards (CFATS)
- US department of Homeland Security also has regulations and standards
- Chemical facility anti-terrorism standards
What is the purpose of the CFATS?
Identify all chemical facilities of high-risk with respect to terrorism and ensure these facilities have an effective security risk management plan
- Security concerns: intentional loss of containment, theft of chemicals, contamination of product/process, degradation of the assets, acquisition of chemicals under false pretense
