For more on process safety programs and leadership, go to www.controlglobal.com/0803_ProcSaf.html.
Peter Montagna is the engineering manager at specialty chemicals manufacturer King Industries, Norwalk, Conn.
The Devilish Details
It’s not enough to show leadership. A good safety program requires specifics. The framework for a robust process safety program can be found in the Occupational Safety and Health Administration’s regulation, “Process Safety Management of Highly Hazardous Chemicals,” or PSM. The full regulation can be found in the Code of Federal Registry under 29 CFR 1910.119 and is available through OSHA website at www.osha.gov.
Recently PSM has come under scrutiny from the U.S. Chemical Safety Board for its lack of application and inadequate coverage of reactive chemical hazards. (See Item 2 in the “Leadership and Process Safety Resources” sidebar.) It’s true that the applicability section of the regulation gives very specific details on where PSM applies in a plant. As a result, companies can avoid these requirements by reducing the use of hazardous materials. However, companies can also use the regulation, without regard to applicability, to develop and implement a comprehensive process safety program—and they should. These requirements, when implemented effectively, will prevent process safety incidents, even reactive chemical hazards.
Reactive chemical hazards are an integral part of the PSM section on process safety information. If a company is serious about process safety, it will evaluate reactive chemical hazards. Accredited laboratories will perform tests, such as accelerated rate calorimetry (for evaluating heats of reaction) and differential scanning calorimetry (for evaluating thermal stability), at a reasonable price. Instructions and controls can then be put in place to prevent incidents.
A significant and often overlooked area of process safety includes equipment reliability. The requirements of the PSM section on mechanical integrity are extensive especially due to the following requirement: “1910.119(j)(4)(ii), Inspection and testing procedures shall follow recognized and generally accepted good engineering practices.”
This simple statement means that several “recognized and generally accepted good engineering practices” (RAGAGEP) apply to chemical processing. These practices are developed by agencies such as the American Petroleum Institute, the American Society of Mechanical Engineers, ISA, the American National Standards Institute and others. ( Table 1 online at www.controlglobal.com/0803_ProcSaf.html has a list of some of the more significant RAGAGEPs.)
Leadership and Process Safety Resources
- Bennis, W. G. and Bennis, W., On Becoming a Leader: The Leadership Classic—Updated and Expanded, New York, N.Y., Basic Books, 2003.
- Goleman, Daniel, Annie McKee and Richard E. Boyatzis., Primal Leadership: Realizing the Power of Emotional Intelligence, Harvard Business School Press, Boston, 2002.
- Incident Data. Reactive Hazard Investigation,” U.S.Chemical Safety Board. www.csb.gov/completed_investigations/docs/ReactiveIncidentDataReport.pdf
- Kotter, John, What Leaders Really Do, Harvard Business School Press, Boston, 1999.
29CFR1910.119 Process Safety Management of Highly Hazardous Chemicals
- Application – A process is covered if it contains one of the materials listed in Appendix A of 1910.119 above the threshold quantity, or if it contains at least 10,000 lbs of flammable materials. A detailed definition of “process” is provided in 1910.119(a) and in written clarifications available through OSHA’s web site.
- Employee Participation – Hourly employees must be involved in many areas of the program, such as development of operating procedures, process hazards analyses and incident investigations.
- Process Safety Information – The chemicals involved in the process, how those chemicals are processed and the equipment used must be thoroughly documented.
- Process Hazards Analysis – A detailed analysis of the process often accomplished through the Hazards and Operability methodology (other methodologies can be used; see 1910.119(e)). This is a proactive review of process hazards.
- Operating Procedures – Detailed instructions on how to operate process equipment. This section also requires safe work practices such as lockout/tagout, confined space entry and other maintenance-related tasks.
- Training – Specific requirements for operators are detailed, along with implied training requirements for mechanics servicing process equipment.
- Contractors – The activities of contractors working in process areas must be thoroughly reviewed and controlled to prevent them from creating a process incident and to ensure their safety should an incident take place.
- Pre-startup Safety Review – A new or significantly modified system must be thoroughly reviewed prior to the introduction of chemicals to prevent an incident during startup.
Mechanical Integrity – A comprehensive program must be developed to ensure the ongoing integrity of process equipment. This section of PSM is highly comprehensive and requires familiarity with many different “recognized and generally accepted good engineering practices” (RAGAGEP). Mechanical integrity includes requirements for:
• Engineering standards or equipment design guidelines,
• Maintenance procedures detailing equipment installation and ongoing maintenance guidelines,
• Maintenance technician qualifications,
• Inspection, testing and preventive maintenance of plant equipment,
• Quality assurance (ensuring maintenance materials used in the process area are adequate for the process demand).
- Hot Work Permits – A system must be developed and implemented to control any maintenance work in the process areas that involves a source of ignition.
- Management of Change – Any changes to materials, how those materials are processed or the equipment used in the process must be reviewed prior to the change taking effect to ensure the change will be safe.
- Incident Investigation – After an incident, a thorough review of that incident must take place that identifies root causes and recommendations to prevent that incident from occurring again (within the process area affected by the incident AND throughout the facility or company).
- Emergency Response – Procedures must be developed to ensure the health and safety of those personnel responsible for responding to any process safety incident.
- Compliance Audits – The PSM system must be thoroughly reviewed at least once every three years.
- Trade Secrets – The hazards of materials involved in a process must be communicated to all affected employees even if the specific identity of the material is kept from the employees. Visit http://www.osha.gov/ for details.