Spring PDC PSM

Spring PDC
May 1, 2014
Presented by LT Environmental, Inc.
Process Safety Management
Process Safety Management of Highly Hazardous
Chemicals (29 CFR 1910.119)
 Adopted
May 26, 1992
Process Safety Management (PSM) is the
application of management principles and
systems to the identification, understanding, and
control of process hazards to protect employees,
facility assets, and the environment.
Process Safety Management
Process Safety
Process Hazard
Operating Procedures
Employee Training
Pre-Startup Safety
Mechanical Integrity
Hot Work (Non-routine
Work Authorizations)
Management of
Incident Investigation
Emergency Planning
and Response
Compliance Audits
Application of Rule
Appendix A of 29 CFR 1910.119 contains a listing
of toxic and reactive highly hazardous chemicals
which present a potential for a catastrophic event
at or above the threshold quantities listed.
Application of Rule
The PSM regulation applies to facilities that have
processes meeting one or both of the following
criteria. The facility contains or stores:
A quantity in excess of 10,000-lb of a flammable liquid or
 Highly hazardous toxic or reactive chemicals that exceed
the established threshold quantities as listed in the
Anhydrous ammonia
 Chlorine
 Hydrogen sulfide
Threshold quantity = 10,000-lb
Threshold quantity = 1,500-lb
threshold quantity = 1,500-lb
Application of Rule
Currently Exempts
 Retail
Application of Rule
Currently Exempts
 Oil
and gas well drilling or servicing
Application of Rule
Currently Exempts
 Hydrocarbon
fuels used solely for workplace
consumption as a fuel, if such fuels are not part of a
process containing another highly hazardous chemical
covered by this standard
Application of Rule
Currently Exempts
 Flammable
liquid 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
Application of Rule
Currently Exempts
 Normally
unoccupied remote facilities
 “Normally
unoccupied remote facility” means a facility
which is operated, maintained, or serviced by employees
who visit the facility only periodically to check its operation
and to perform necessary operating or maintenance tasks.
No employees are permanently stationed at the facility.
Facilities meeting this definition are not contiguous with, and
must be geographically remote from all other buildings,
processes, or persons.
OSHA Interpretation letter = average 14 hours per week
Executive Order 13650
On August 1, 2013, President Obama signed
Executive Order 13650, entitled “Improving
Chemical Facility Safety and Security”
 Went
Executive Order 13650
9/1/2013 - OSHA
 Authorizes
enhanced information collection with the
purpose of suggesting changes to the PSM Standard
 Asked 17 Questions on Topics of Potential Rulemaking
or Policy Change
Potential Rulemaking or Policy Change
Clarifying the PSM exemption for atmospheric
storage tanks
 Original
intent to include but excluded by a judge’s
ruling in 1997.
 OSHA wants to include atmospheric storage tanks within
or connected to a process.
 Not
terminals or tank batteries, but….
Potential Rulemaking or Policy Change
Removing the oil & gas well drilling and servicing
 Original
pre-amble stated that these would be exempt
from this rule because a separate one would be
 What would be covered under the thresholds?
Potential Rulemaking or Policy Change
Removing the oil & gas production facility
 Originally
included, however an objection by API about
OSHA not completing an economic analysis on this
portion stayed enforcement.
 What about multiple well site pads?
Potential Rulemaking or Policy Change
Expanding PSM Coverage and Requirements for
Reactivity Hazards
number of the listed chemicals are highly reactive but
the list does not cover all highly reactive chemicals.
 Recommended approach takes into account not only
certain specific chemicals but also their overall
reactivity in determining the level of coverage.
Potential Rulemaking or Policy Change
Updating the List of Highly Hazardous Chemicals
The list has remained unchanged since OSHA promulgated the
PSM standard in 1992.
Current list provides specific concentrations for 11 of 137 listed
OSHA has issued interpretation considering PSM coverage to
apply if threshold quantities of such chemicals are present at
commercial grade which OSHA has interpreted as "a typical
maximum concentration of the chemical that is commercially
available and shipped." In a court case resulting from an
explosion involving hydroxylamine, a U.S. District Court dismissed
a criminal indictment based on inconsistencies in OSHA's
statements regarding coverage of hydroxylamine.
Potential Rulemaking or Policy Change
Revising the PSM Standard to Require Additional
Management-System Elements
 Adopt
management system elements from safety
standards that other federal agencies or professional
societies have promulgated since 1992
 Center
for Chemical Process Safety (CCPS) has defined a
Risk-Based Process Safety (RBPS)
 Bureau of Safety and Environmental Enforcement's Safety
and Environmental Management System (SEMS)
Potential Rulemaking or Policy Change
Require Evaluation of Updates to Applicable
recognized and generally accepted good
engineering practices (RAGAGEP)
Definition - Center for Chemical Process Safety: RAGAGEP
are the basis for engineering, operation, or maintenance
activities and are themselves based on established codes,
standards, published technical reports or recommended
practices (RP) or similar documents.
Potential Rulemaking or Policy Change
Expanding PSM Standard to Cover the Mechanical
Integrity of Any Safety-Critical Equipment
 Currently
applies to pressure vessels, storage tanks,
piping systems (including piping components such as
valves), relief and vent devices, emergency shutdown
systems, controls (including monitoring devices, sensors,
alarms, and interlocks), and pumps.
 if an employer deems additional equipment to be
critical to a particular process, the employer should
consider that equipment to be covered by MI
Potential Rulemaking or Policy Change
Clarifying PSM Standard with explicit requirement
to manage organizational changes
 The
Management of Change (MOC) element in the PSM
Standard did not include or contemplate organizational
 OSHA’s current interpretation of the PSM Standard
MOC provisions is that if changes to personnel,
budgets, etc., can affect process safety then they should
be covered by MOC.
Potential Rulemaking or Policy Change
Require Coordination of Emergency Planning with
Local Emergency-Response Authorities beyond LEPCs
 The
PSM standard requires employers to establish and
implement an emergency action plan in accordance
with other OSHA standards. However, the standard
does not require employers to coordinate emergency
planning with local emergency response authorities.
Potential Rulemaking or Policy Change
Requiring third-party compliance audits
 Current
Standard requires a facility audit every three
years, but no requirements for make up of audit team.
 Safety and Environmental Management System (SEMS)
standard from Bureau of Safety and Environmental
Enforcement (BSEE) requires the audit lead be an
independent third party, may be expanded to certified
third party.
Potential Rulemaking or Policy Change
Cover Dismantling and Disposal of Explosives,
Blasting Agents, and Pyrotechnics
 The
standard applies to the manufacture, keeping,
having, storage, sale, and transportation of explosives,
blasting agents, and pyrotechnics but it does not apply
to the sale and use of fireworks or the use of
 Dismantling and disposing of explosives are not
covered by the standard.
Potential Rulemaking or Policy Change
Address the Storage, Handling, and Management
of Ammonium Nitrate
 Not
currently covered. OSHA is seeking comments on
safe work practices for storing, handling, and
managing ammonium nitrate.
Potential Rulemaking or Policy Change
Changing Enforcement Policy of the PSM Exemption
for Retail Facilities
 The
term retail facility is not defined in the standard.
The preamble to the standard noted that chemicals in
retail facilities are generally in small packages,
containers, and allotments, and gives the example of
gasoline stations as a type of facility that typically
would qualify for the exemption.
Potential Rulemaking or Policy Change
Changing Enforcement Policy for Highly Hazardous
LT Environmental, Inc.
4600 West 60th Avenue
Arvada, Colorado 80003
Jeff Citrone, CIH, CSP, REA
[email protected]
Compliance, Remediation, Engineering

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