Process Safety Management involvement

Unless some discipline is imposed, engineering personnel, especially where contractors are involved, will define far more alarms than plant operations require. This situation may be addressed by simply setting the alarm hmits to values such that the alarms never occur. However, changes in alarms and alarm hmits are changes from the perspec tive of the Process Safety Management regulations. It is prudent to impose the necessary discipline to avoid an excessive number of alarms. Potential guidelines are as follows ... 

Trade Secrets When a toll involves proprietary information, a system must exist to ensure that employees have the process safety related knowledge needed to meet the intent of the process safety management system. 

Process Safety Management (PSM) A program or activity involving the application of management principles and analytical techniques to ensure the safety of chemical process facilities. Sometimes called process hazard management. Each principle is often termed an element or component of process safety. 

The "Capital Projects Design Review Procedures" element of process safety management assures that the design, the equipment and the construction are properly reviewed for all new projects. Process safety review procedures should be involved with the project from its inception. One method of illustrating the various phases of a project is shown in Figure 8.1 (Figure 5-1 from CCPS, 1989a). 

In 1990-1991, American industries involved in hazardous chemicals/materials production, shipping, storing, and usage were scrutinized from both a safety and security viewpoint, to the point where OSHA s Process Safety Management Standard (PSM) 29 CFR 1910.119 was generated to address these concerns. PSM was promulgated in 1992, to be fully complied with by May of 1997. 

Process Safety Management— A program or activity that involves the application of management principles and analytical techniques to ensure process safety in chemical facilities. The focus is on preventing major accidents rather than dealing with classic worker health and safety issues. 

Secondary prevention and mitigation, by themselves, are unable to eliminate the risk of serious or catastrophic chemical accidents, although improved process safety management can reduce their probability and severity. Most chemical production involves transformation processes, which are inherently complex and tightly coupled. Normal accidents are an unavoidable risk of systems with these characteristics [11]. However, the risk of serious, or catastrophic, consequences need not be. Specific industries use many different processes. In many cases, alternative chemical processes exist which completely or almost completely eliminate the use of highly toxic, volatile, or flammable chemicals [12]. 

On February 24, 1992, the U.S. Department of Labor, Occupational Safety and Health Administration (OSHA) promulgated a final rule, 29 CFR Part 1910.119, Process Safety Management of Highly Hazardous Chemicals. OSHA administrates regulations whose objectives are primarily involved with protecting workers. This can be regarded as inside the fence line. This is a safety issue and is addressed in this section. The rule requires employers to effectively manage the process... 

In the United States, the OSHA standard 29 CFR 1910.119 Process Safety Management of Highly Hazardous Chemicals requires that a hazard analysis must be carried out for any process involving certain listed chemicals (see Appendix A of the standard) or involving more than 10,0001b (4535.9 kg) of flammable gas or liquid. Employers must involve employees in the hazard analysis, and it must be made available to employees and updated at least every 5 years. Employees and contractors must be trained in safe work practices associated with the identified process hazards. Eull details of these and other legal requirements as well as descriptions of the information that must be included in the analysis can be found in the standard. The most recent version of this standard and all other OSHA regulations are available at www.osha.gov. 

The first major element is Employee Participation [29 CFR 1910.119 (c)]. This requires that affected employees (those who could be affected by an incident) not only have access to pertinent Process Safety Management information, but also be allowed to provide input to its development and use. It is expected that affected employees will be trained in the standard s content. Many companies not only welcome employees input, but also involve them in the development and management of the individual elements. It is expected that all employee participation in PSM implementation will be documented. ... 

In this chapter we will emphasize system upsets or abnormal situations where the loss or degradation of components or controls could allow process parameters to exceed the design intent or limit of the process or equipment, resulting in an accidental chemical release. The time factor involved in an operator s ability to assess and correct an operating deviation is discussed in more detail in CCPS Guidelines for Integrating Human Factors into Process Safety Management Systems ... 

Process Safety Management is an ongoing process, involving all managers, employees and contract workers that aims to minimize uncontrolled change from design and/or operating intent and to keep the process within its safe limits. 

It must be recognized that the Safety Lifecycle and associated Safety Instrumented Systems need to be part of an overall Process Safety Management System (PSM) for the entire plant. PSM can be defined as a program or set of activities involving the application of management principles and analyses to ensure the overall process safety of process plants. PSM, therefore, covers aU aspects of process safety, not just functional safety. 

Process Safety Management (PSM) Standard (29 CFR 1910.119) PSM is for the prevention or minimization of the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. This regulation applies to all processes that involve one or more of 137 listed chemicals (29 CFR 1910.119, Appendix A) above their threshold quantities or have 10,000 lbs. or more of a flammable liquid or gas, as defined by the U.S. OSHA HCS [29 CFR 1910.1200(c)], This includes n-hexane, hexane isomers, and all solvents listed in Table 14.10.3. 

Employee Involvement A written plan of action must be developed regarding employee participation. Employees and their representatives must be con-suiter on the conduct and development of process hazard analyses and on the development of other elements of process safety management required under the rule. Employees and their representatives should have access to process... 

Again, hot work is that type of work that involves welding, grinding, cutting, and other flame- or potential spark-producing activity that might be performed in the vicinity of processes covered by the process safety management rule. The hot work permits provide for fire safety in conjunction with that type of work and typically include written authorizations and procedures for special controls and surveillance requirements. Most important is the coordination of maintenance and operations. 

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