[Title 29 CFR 1910.119]
[Code of Federal Regulations (annual edition) - July 1, 2002 Edition]
[Title 29 - LABOR]
[Subtitle B - Regulations Relating to Labor (Continued)]
[Chapter Xvii - OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION, DEPARTMENT]
[Part 1910 - OCCUPATIONAL SAFETY AND HEALTH STANDARDS]
[Subpart H - Hazardous Materials]
[Sec. 1910.119 - Process safety management of highly hazardous chemicals.]
[From the U.S. Government Printing Office]
29LABOR52002-07-012002-07-01falseProcess safety management of highly hazardous chemicals.1910.119Sec. 1910.119LABORRegulations Relating to Labor (Continued)OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION, DEPARTMENTOCCUPATIONAL SAFETY AND HEALTH STANDARDSHazardous Materials
Sec. 1910.119 Process safety management of highly hazardous chemicals.
Purpose. This section contains requirements for preventing or
minimizing the consequences of catastrophic releases of toxic, reactive,
flammable, or explosive chemicals. These releases may result in toxic,
fire or explosion hazards.
(a) Application. (1) This section applies to the following:
(i) A process which involves a chemical at or above the specified
threshold quantities listed in appendix A to this section;
(ii) A process which involves a flammable liquid or gas (as defined
in 1910.1200(c) of this part) on site in one location, in a quantity of
10,000 pounds (4535.9 kg) or more except for:
(A) 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;
(B) Flammable liquids stored in atmospheric tanks or transferred
which are kept below their normal boiling point without benefit of
chilling or refrigeration.
(2) This section does not apply to:
(i) Retail facilities;
(ii) Oil or gas well drilling or servicing operations; or,
(iii) Normally unoccupied remote facilities.
(b) Definitions. Atmospheric tank means a storage tank which has
been designed to operate at pressures from atmospheric through 0.5
p.s.i.g. (pounds per square inch gauge, 3.45 Kpa).
Boiling point means the boiling point of a liquid at a pressure of
14.7 pounds per square inch absolute (p.s.i.a.) (760 mm.). For the
purposes of this section, where an accurate boiling point is unavailable
for the material in question, or for mixtures which do not have a
constant boiling point, the 10 percent point of a distillation performed
in accordance with the Standard Method of Test for Distillation of
Petroleum Products, ASTM D-86-62, which is incorporated by reference as
specified in Sec. 1910.6, may be used as the boiling point of the
liquid.
Catastrophic release means a major uncontrolled emission, fire, or
explosion, involving one or more highly hazardous chemicals, that
presents serious danger to employees in the workplace.
Facility means the buildings, containers or equipment which contain
a process.
Highly hazardous chemical means a substance possessing toxic,
reactive, flammable, or explosive properties and specified by paragraph
(a)(1) of this section.
Hot work means work involving electric or gas welding, cutting,
brazing, or similar flame or spark-producing operations.
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.
Process means any activity involving a highly hazardous chemical
including any use, storage, manufacturing, handling, or the on-site
movement of such chemicals, or combination of these activities. For
purposes of this definition, any group of vessels which are
interconnected and separate vessels which are located such that a highly
hazardous chemical could be involved in a potential release shall be
considered a single process.
Replacement in kind means a replacement which satisfies the design
specification.
Trade secret means any confidential formula, pattern, process,
device, information or compilation of information that is used in an
employer's business,
[[Page 351]]
and that gives the employer an opportunity to obtain an advantage over
competitors who do not know or use it. Appendix D contained in
Sec. 1910.1200 sets out the criteria to be used in evaluating trade
secrets.
(c) Employee participation. (1) Employers shall develop a written
plan of action regarding the implementation of the employee
participation required by this paragraph.
(2) Employers shall consult with employees and their representatives
on the conduct and development of process hazards analyses and on the
development of the other elements of process safety management in this
standard.
(3) Employers shall provide to employees and their representatives
access to process hazard analyses and to all other information required
to be developed under this standard.
(d) Process safety information. In accordance with the schedule set
forth in paragraph (e)(1) of this section, the employer shall complete a
compilation of written process safety information before conducting any
process hazard analysis required by the standard. The compilation of
written process safety information is to enable the employer and the
employees involved in operating the process to identify and understand
the hazards posed by those processes involving highly hazardous
chemicals. This process safety information shall include information
pertaining to the hazards of the highly hazardous chemicals used or
produced by the process, information pertaining to the technology of the
process, and information pertaining to the equipment in the process.
(1) Information pertaining to the hazards of the highly hazardous
chemicals in the process. This information shall consist of at least the
following:
(i) Toxicity information;
(ii) Permissible exposure limits;
(iii) Physical data;
(iv) Reactivity data:
(v) Corrosivity data;
(vi) Thermal and chemical stability data; and
(vii) Hazardous effects of inadvertent mixing of different materials
that could foreseeably occur.
Note: Material Safety Data Sheets meeting the requirements of 29 CFR
1910.1200(g) may be used to comply with this requirement to the extent
they contain the information required by this subparagraph.
(2) Information pertaining to the technology of the process. (i)
Information concerning the technology of the process shall include at
least the following:
(A) A block flow diagram or simplified process flow diagram (see
appendix B to this section);
(B) Process chemistry;
(C) Maximum intended inventory;
(D) Safe upper and lower limits for such items as temperatures,
pressures, flows or compositions; and,
(E) An evaluation of the consequences of deviations, including those
affecting the safety and health of employees.
(ii) Where the original technical information no longer exists, such
information may be developed in conjunction with the process hazard
analysis in sufficient detail to support the analysis.
(3) Information pertaining to the equipment in the process. (i)
Information pertaining to the equipment in the process shall include:
(A) Materials of construction;
(B) Piping and instrument diagrams (P&ID's);
(C) Electrical classification;
(D) Relief system design and design basis;
(E) Ventilation system design;
(F) Design codes and standards employed;
(G) Material and energy balances for processes built after May 26,
1992; and,
(H) Safety systems (e.g. interlocks, detection or suppression
systems).
(ii) The employer shall document that equipment complies with
recognized and generally accepted good engineering practices.
(iii) For existing equipment designed and constructed in accordance
with codes, standards, or practices that are no longer in general use,
the employer shall determine and document that the equipment is
designed, maintained, inspected, tested, and operating in a safe manner.
(e) Process hazard analysis. (1) The employer shall perform an
initial process hazard analysis (hazard evaluation) on processes covered
by this standard.
[[Page 352]]
The process hazard analysis shall be appropriate to the complexity of
the process and shall identify, evaluate, and control the hazards
involved in the process. Employers shall determine and document the
priority order for conducting process hazard analyses based on a
rationale which includes such considerations as extent of the process
hazards, number of potentially affected employees, age of the process,
and operating history of the process. The process hazard analysis shall
be conducted as soon as possible, but not later than the following
schedule:
(i) No less than 25 percent of the initial process hazards analyses
shall be completed by May 26, 1994;
(ii) No less than 50 percent of the initial process hazards analyses
shall be completed by May 26, 1995;
(iii) No less than 75 percent of the initial process hazards
analyses shall be completed by May 26, 1996;
(iv) All initial process hazards analyses shall be completed by May
26, 1997.
(v) Process hazards analyses completed after May 26, 1987 which meet
the requirements of this paragraph are acceptable as initial process
hazards analyses. These process hazard analyses shall be updated and
revalidated, based on their completion date, in accordance with
paragraph (e)(6) of this section.
(2) The employer shall use one or more of the following
methodologies that are appropriate to determine and evaluate the hazards
of the process being analyzed.
(i) What-If;
(ii) Checklist;
(iii) What-If/Checklist;
(iv) Hazard and Operability Study (HAZOP):
(v) Failure Mode and Effects Analysis (FMEA);
(vi) Fault Tree Analysis; or
(vii) An appropriate equivalent methodology.
(3) The process hazard analysis shall address:
(i) The hazards of the process;
(ii) The identification of any previous incident which had a likely
potential for catastrophic consequences in the workplace;
(iii) Engineering and administrative controls applicable to the
hazards and their interrelationships such as appropriate application of
detection methodologies to provide early warning of releases.
(Acceptable detection methods might include process monitoring and
control instrumentation with alarms, and detection hardware such as
hydrocarbon sensors.);
(iv) Consequences of failure of engineering and administrative
controls;
(v) Facility siting;
(vi) Human factors; and
(vii) A qualitative evaluation of a range of the possible safety and
health effects of failure of controls on employees in the workplace.
(4) The process hazard analysis shall be performed by a team with
expertise in engineering and process operations, and the team shall
include at least one employee who has experience and knowledge specific
to the process being evaluated. Also, one member of the team must be
knowledgeable in the specific process hazard analysis methodology being
used.
(5) The employer shall establish a system to promptly address the
team's findings and recommendations; assure that the recommendations are
resolved in a timely manner and that the resolution is documented;
document what actions are to be taken; complete actions as soon as
possible; develop a written schedule of when these actions are to be
completed; communicate the actions to operating, maintenance and other
employees whose work assignments are in the process and who may be
affected by the recommendations or actions.
(6) At least every five (5) years after the completion of the
initial process hazard analysis, the process hazard analysis shall be
updated and revalidated by a team meeting the requirements in paragraph
(e)(4) of this section, to assure that the process hazard analysis is
consistent with the current process.
(7) Employers shall retain process hazards analyses and updates or
revalidations for each process covered by this section, as well as the
documented resolution of recommendations described in paragraph (e)(5)
of this section for the life of the process.
(f) Operating procedures (1) The employer shall develop and
implement
[[Page 353]]
written operating procedures that provide clear instructions for safely
conducting activities involved in each covered process consistent with
the process safety information and shall address at least the following
elements.
(i) Steps for each operating phase:
(A) Initial startup;
(B) Normal operations;
(C) Temporary operations;
(D) Emergency shutdown including the conditions under which
emergency shutdown is required, and the assignment of shutdown
responsibility to qualified operators to ensure that emergency shutdown
is executed in a safe and timely manner.
(E) Emergency Operations;
(F) Normal shutdown; and,
(G) Startup following a turnaround, or after an emergency shutdown.
(ii) Operating limits:
(A) Consequences of deviation; and
(B) Steps required to correct or avoid deviation.
(iii) Safety and health considerations:
(A) Properties of, and hazards presented by, the chemicals used in
the process;
(B) Precautions necessary to prevent exposure, including engineering
controls, administrative controls, and personal protective equipment;
(C) Control measures to be taken if physical contact or airborne
exposure occurs;
(D) Quality control for raw materials and control of hazardous
chemical inventory levels; and,
(E) Any special or unique hazards.
(iv) Safety systems and their functions.
(2) Operating procedures shall be readily accessible to employees
who work in or maintain a process.
(3) The operating procedures shall be reviewed as often as necessary
to assure that they reflect current operating practice, including
changes that result from changes in process chemicals, technology, and
equipment, and changes to facilities. The employer shall certify
annually that these operating procedures are current and accurate.
(4) The employer shall develop and implement safe work practices to
provide for the control of hazards during operations such as lockout/
tagout; confined space entry; opening process equipment or piping; and
control over entrance into a facility by maintenance, contractor,
laboratory, or other support personnel. These safe work practices shall
apply to employees and contractor employees.
(g) Training--(1) Initial training. (i) Each employee presently
involved in operating a process, and each employee before being involved
in operating a newly assigned process, shall be trained in an overview
of the process and in the operating procedures as specified in paragraph
(f) of this section. The training shall include emphasis on the specific
safety and health hazards, emergency operations including shutdown, and
safe work practices applicable to the employee's job tasks.
(ii) In lieu of initial training for those employees already
involved in operating a process on May 26, 1992, an employer may certify
in writing that the employee has the required knowledge, skills, and
abilities to safely carry out the duties and responsibilities as
specified in the operating procedures.
(2) Refresher training. Refresher training shall be provided at
least every three years, and more often if necessary, to each employee
involved in operating a process to assure that the employee understands
and adheres to the current operating procedures of the process. The
employer, in consultation with the employees involved in operating the
process, shall determine the appropriate frequency of refresher
training.
(3) Training documentation. The employer shall ascertain that each
employee involved in operating a process has received and understood the
training required by this paragraph. The employer shall prepare a record
which contains the identity of the employee, the date of training, and
the means used to verify that the employee understood the training.
(h) Contractors--(1) Application. This paragraph applies to
contractors performing maintenance or repair, turnaround, major
renovation, or specialty work on or adjacent to a covered process. It
does not apply to contractors providing incidental services which do not
influence process safety, such as
[[Page 354]]
janitorial work, food and drink services, laundry, delivery or other
supply services.
(2) Employer responsibilities. (i) The employer, when selecting a
contractor, shall obtain and evaluate information regarding the contract
employer's safety performance and programs.
(ii) The employer shall inform contract employers of the known
potential fire, explosion, or toxic release hazards related to the
contractor's work and the process.
(iii) The employer shall explain to contract employers the
applicable provisions of the emergency action plan required by paragraph
(n) of this section.
(iv) The employer shall develop and implement safe work practices
consistent with paragraph (f)(4) of this section, to control the
entrance, presence and exit of contract employers and contract employees
in covered process areas.
(v) The employer shall periodically evaluate the performance of
contract employers in fulfilling their obligations as specified in
paragraph (h)(3) of this section.
(vi) The employer shall maintain a contract employee injury and
illness log related to the contractor's work in process areas.
(3) Contract employer responsibilities. (i) The contract employer
shall assure that each contract employee is trained in the work
practices necessary to safely perform his/her job.
(ii) The contract employer shall assure that each contract employee
is instructed in the known potential fire, explosion, or toxic release
hazards related to his/her job and the process, and the applicable
provisions of the emergency action plan.
(iii) The contract employer shall document that each contract
employee has received and understood the training required by this
paragraph. The contract employer shall prepare a record which contains
the identity of the contract employee, the date of training, and the
means used to verify that the employee understood the training.
(iv) The contract employer shall assure that each contract employee
follows the safety rules of the facility including the safe work
practices required by paragraph (f)(4) of this section.
(v) The contract employer shall advise the employer of any unique
hazards presented by the contract employer's work, or of any hazards
found by the contract employer's work.
(i) Pre-startup safety review. (1) The employer shall perform a pre-
startup safety review for new facilities and for modified facilities
when the modification is significant enough to require a change in the
process safety information.
(2) The pre-startup safety review shall confirm that prior to the
introduction of highly hazardous chemicals to a process:
(i) Construction and equipment is in accordance with design
specifications;
(ii) Safety, operating, maintenance, and emergency procedures are in
place and are adequate;
(iii) For new facilities, a process hazard analysis has been
performed and recommendations have been resolved or implemented before
startup; and modified facilities meet the requirements contained in
management of change, paragraph (l).
(iv) Training of each employee involved in operating a process has
been completed.
(j) Mechanical integrity--(1) Application. Paragraphs (j)(2) through
(j)(6) of this section apply to the following process equipment:
(i) Pressure vessels and storage tanks;
(ii) Piping systems (including piping components such as valves);
(iii) Relief and vent systems and devices;
(iv) Emergency shutdown systems;
(v) Controls (including monitoring devices and sensors, alarms, and
interlocks) and,
(vi) Pumps.
(2) Written procedures. The employer shall establish and implement
written procedures to maintain the on-going integrity of process
equipment.
(3) Training for process maintenance activities. The employer shall
train each employee involved in maintaining the on-going integrity of
process equipment in an overview of that process and its hazards and in
the procedures
[[Page 355]]
applicable to the employee's job tasks to assure that the employee can
perform the job tasks in a safe manner.
(4) Inspection and testing. (i) Inspections and tests shall be
performed on process equipment.
(ii) Inspection and testing procedures shall follow recognized and
generally accepted good engineering practices.
(iii) The frequency of inspections and tests of process equipment
shall be consistent with applicable manufacturers' recommendations and
good engineering practices, and more frequently if determined to be
necessary by prior operating experience.
(iv) The employer shall document each inspection and test that has
been performed on process equipment. The documentation shall identify
the date of the inspection or test, the name of the person who performed
the inspection or test, the serial number or other identifier of the
equipment on which the inspection or test was performed, a description
of the inspection or test performed, and the results of the inspection
or test.
(5) Equipment deficiencies. The employer shall correct deficiencies
in equipment that are outside acceptable limits (defined by the process
safety information in paragraph (d) of this section) before further use
or in a safe and timely manner when necessary means are taken to assure
safe operation.
(6) Quality assurance. (i) In the construction of new plants and
equipment, the employer shall assure that equipment as it is fabricated
is suitable for the process application for which they will be used.
(ii) Appropriate checks and inspections shall be performed to assure
that equipment is installed properly and consistent with design
specifications and the manufacturer's instructions.
(iii) The employer shall assure that maintenance materials, spare
parts and equipment are suitable for the process application for which
they will be used.
(k) Hot work permit. (1) The employer shall issue a hot work permit
for hot work operations conducted on or near a covered process.
(2) The permit shall document that the fire prevention and
protection requirements in 29 CFR 1910.252(a) have been implemented
prior to beginning the hot work operations; it shall indicate the
date(s) authorized for hot work; and identify the object on which hot
work is to be performed. The permit shall be kept on file until
completion of the hot work operations.
(l) Management of change. (1) The employer shall establish and
implement written procedures to manage changes (except for
``replacements in kind'') to process chemicals, technology, equipment,
and procedures; and, changes to facilities that affect a covered
process.
(2) The procedures shall assure that the following considerations
are addressed prior to any change:
(i) The technical basis for the proposed change;
(ii) Impact of change on safety and health;
(iii) Modifications to operating procedures;
(iv) Necessary time period for the change; and,
(v) Authorization requirements for the proposed change.
(3) Employees involved in operating a process and maintenance and
contract employees whose job tasks will be affected by a change in the
process shall be informed of, and trained in, the change prior to start-
up of the process or affected part of the process.
(4) If a change covered by this paragraph results in a change in the
process safety information required by paragraph (d) of this section,
such information shall be updated accordingly.
(5) If a change covered by this paragraph results in a change in the
operating procedures or practices required by paragraph (f) of this
section, such procedures or practices shall be updated accordingly.
(m) Incident investigation. (1) The employer shall investigate each
incident which resulted in, or could reasonably have resulted in a
catastrophic release of highly hazardous chemical in the workplace.
(2) An incident investigation shall be initiated as promptly as
possible, but not later than 48 hours following the incident.
(3) An incident investigation team shall be established and consist
of at least one person knowledgeable in the process involved, including
a contract employee if the incident involved work
[[Page 356]]
of the contractor, and other persons with appropriate knowledge and
experience to thoroughly investigate and analyze the incident.
(4) A report shall be prepared at the conclusion of the
investigation which includes at a minimum:
(i) Date of incident;
(ii) Date investigation began;
(iii) A description of the incident;
(iv) The factors that contributed to the incident; and,
(v) Any recommendations resulting from the investigation.I11(5) The
employer shall establish a system to promptly address and resolve the
incident report findings and recommendations. Resolutions and corrective
actions shall be documented.
(6) The report shall be reviewed with all affected personnel whose
job tasks are relevant to the incident findings including contract
employees where applicable.
(7) Incident investigation reports shall be retained for five years.
(n) Emergency planning and response. The employer shall establish
and implement an emergency action plan for the entire plant in
accordance with the provisions of 29 CFR 1910.38(a). In addition, the
emergency action plan shall include procedures for handling small
releases. Employers covered under this standard may also be subject to
the hazardous waste and emergency response provisions contained in 29
CFR 1910.120 (a), (p) and (q).
(o) Compliance Audits. (1) Employers shall certify that they have
evaluated compliance with the provisions of this section at least every
three years to verify that the procedures and practices developed under
the standard are adequate and are being followed.
(2) The compliance audit shall be conducted by at least one person
knowledgeable in the process.
(3) A report of the findings of the audit shall be developed.
(4) The employer shall promptly determine and document an
appropriate response to each of the findings of the compliance audit,
and document that deficiencies have been corrected.
(5) Employers shall retain the two (2) most recent compliance audit
reports.
(p) Trade secrets. (1) Employers shall make all information
necessary to comply with the section available to those persons
responsible for compiling the process safety information (required by
paragraph (d) of this section), those assisting in the development of
the process hazard analysis (required by paragraph (e) of this section),
those responsible for developing the operating procedures (required by
paragraph (f) of this section), and those involved in incident
investigations (required by paragraph (m) of this section), emergency
planning and response (paragraph (n) of this section) and compliance
audits (paragraph (o) of this section) without regard to possible trade
secret status of such information.
(2) Nothing in this paragraph shall preclude the employer from
requiring the persons to whom the information is made available under
paragraph (p)(1) of this section to enter into confidentiality
agreements not to disclose the information as set forth in 29 CFR
1910.1200.
(3) Subject to the rules and procedures set forth in 29 CFR
1910.1200(i)(1) through 1910.1200(i)(12), employees and their designated
representatives shall have access to trade secret information contained
within the process hazard analysis and other documents required to be
developed by this standard.
Appendix A to Sec. 1910.119--List of Highly Hazardous Chemicals, Toxics
and Reactives (Mandatory)
This appendix contains a listing of toxic and reactive highly
hazardous chemicals which present a potential for a catastrophic event
at or above the threshold quantity.
------------------------------------------------------------------------
CHEMICAL name CAS* TQ**
------------------------------------------------------------------------
Acetaldehyde....................................... 75-07-0 2500
Acrolein (2-Propenal).............................. 107-02-8 150
Acrylyl Chloride................................... 814-68-6 250
Allyl Chloride..................................... 107-05-1 1000
Allylamine......................................... 107-11-9 1000
Alkylaluminums..................................... Varies 5000
Ammonia, Anhydrous................................. 7664-41-7 10000
Ammonia solutions (44% ammonia by 7664-41-7 15000
weight)...........................................
Ammonium Perchlorate............................... 7790-98-9 7500
Ammonium Permanganate.............................. 7787-36-2 7500
Arsine (also called Arsenic Hydride)............... 7784-42-1 100
Bis(Chloromethyl) Ether............................ 542-88-1 100
Boron Trichloride.................................. 10294-34-5 2500
Boron Trifluoride.................................. 7637-07-2 250
Bromine............................................ 7726-95-6 1500
Bromine Chloride................................... 13863-41-7 1500
Bromine Pentafluoride.............................. 7789-30-2 2500
Bromine Trifluoride................................ 7787-71-5 15000
[[Page 357]]
3-Bromopropyne (also called Propargyl Bromide)..... 106-96-7 100
Butyl Hydroperoxide (Tertiary)..................... 75-91-2 5000
Butyl Perbenzoate (Tertiary)....................... 614-45-9 7500
Carbonyl Chloride (see Phosgene)................... 75-44-5 100
Carbonyl Fluoride.................................. 353-50-4 2500
Cellulose Nitrate (concentration 12.6% 9004-70-0 2500
nitrogen..........................................
Chlorine........................................... 7782-50-5 1500
Chlorine Dioxide................................... 10049-04-4 1000
Chlorine Pentrafluoride............................ 13637-63-3 1000
Chlorine Trifluoride............................... 7790-91-2 1000
Chlorodiethylaluminum (also called Diethylaluminum 96-10-6 5000
Chloride).........................................
1-Chloro-2,4-Dinitrobenzene........................ 97-00-7 5000
Chloromethyl Methyl Ether.......................... 107-30-2 500
Chloropicrin....................................... 76-06-2 500
Chloropicrin and Methyl Bromide mixture............ None 1500
Chloropicrin and Methyl Chloride mixture........... None 1500
Cumene Hydroperoxide............................... 80-15-9 5000
Cyanogen........................................... 460-19-5 2500
Cyanogen Chloride.................................. 506-77-4 500
Cyanuric Fluoride.................................. 675-14-9 100
Diacetyl Peroxide (Concentration 70%)... 110-22-5 5000
Diazomethane....................................... 334-88-3 500
Dibenzoyl Peroxide................................. 94-36-0 7500
Diborane........................................... 19287-45-7 100
Dibutyl Peroxide (Tertiary)........................ 110-05-4 5000
Dichloro Acetylene................................. 7572-29-4 250
Dichlorosilane..................................... 4109-96-0 2500
Diethylzinc........................................ 557-20-0 10000
Diisopropyl Peroxydicarbonate...................... 105-64-6 7500
Dilaluroyl Peroxide................................ 105-74-8 7500
Dimethyldichlorosilane............................. 75-78-5 1000
Dimethylhydrazine, 1,1-............................ 57-14-7 1000
Dimethylamine, Anhydrous........................... 124-40-3 2500
2,4-Dinitroaniline................................. 97-02-9 5000
Ethyl Methyl Ketone Peroxide (also Methyl Ethyl 1338-23-4 5000
Ketone Peroxide; concentration 60%)....
Ethyl Nitrite...................................... 109-95-5 5000
Ethylamine......................................... 75-04-7 7500
Ethylene Fluorohydrin.............................. 371-62-0 100
Ethylene Oxide..................................... 75-21-8 5000
Ethyleneimine...................................... 151-56-4 1000
Fluorine........................................... 7782-41-4 1000
Formaldehyde (Formalin)............................ 50-00-0 1000
Furan.............................................. 110-00-9 500
Hexafluoroacetone.................................. 684-16-2 5000
Hydrochloric Acid, Anhydrous....................... 7647-01-0 5000
Hydrofluoric Acid, Anhydrous....................... 7664-39-3 1000
Hydrogen Bromide................................... 10035-10-6 5000
Hydrogen Chloride.................................. 7647-01-0 5000
Hydrogen Cyanide, Anhydrous........................ 74-90-8 1000
Hydrogen Fluoride.................................. 7664-39-3 1000
Hydrogen Peroxide (52% by weight or greater)....... 7722-84-1 7500
Hydrogen Selenide.................................. 7783-07-5 150
Hydrogen Sulfide................................... 7783-06-4 1500
Hydroxylamine...................................... 7803-49-8 2500
Iron, Pentacarbonyl................................ 13463-40-6 250
Isopropylamine..................................... 75-31-0 5000
Ketene............................................. 463-51-4 100
Methacrylaldehyde.................................. 78-85-3 1000
Methacryloyl Chloride.............................. 920-46-7 150
Methacryloyloxyethyl Isocyanate.................... 30674-80-7 100
Methyl Acrylonitrile............................... 126-98-7 250
Methylamine, Anhydrous............................. 74-89-5 1000
Methyl Bromide..................................... 74-83-9 2500
Methyl Chloride.................................... 74-87-3 15000
Methyl Chloroformate............................... 79-22-1 500
Methyl Ethyl Ketone Peroxide (concentration 60%)...........................................
Methyl Fluoroacetate............................... 453-18-9 100
Methyl Fluorosulfate............................... 421-20-5 100
Methyl Hydrazine................................... 60-34-4 100
Methyl Iodide...................................... 74-88-4 7500
Methyl Isocyanate.................................. 624-83-9 250
Methyl Mercaptan................................... 74-93-1 5000
Methyl Vinyl Ketone................................ 79-84-4 100
Methyltrichlorosilane.............................. 75-79-6 500
Nickel Carbonly (Nickel Tetracarbonyl)............. 13463-39-3 150
Nitric Acid (94.5% by weight or greater)........... 7697-37-2 500
Nitric Oxide....................................... 10102-43-9 250
Nitroaniline (para Nitroaniline.................... 100-01-6 5000
Nitromethane....................................... 75-52-5 2500
Nitrogen Dioxide................................... 10102-44-0 250
Nitrogen Oxides (NO; NO2; N204; N203).............. 10102-44-0 250
Nitrogen Tetroxide (also called Nitrogen Peroxide). 10544-72-6 250
Nitrogen Trifluoride............................... 7783-54-2 5000
Nitrogen Trioxide.................................. 10544-73-7 250
Oleum (65% to 80% by weight; also called Fuming 8014-94-7 1000
Sulfuric Acid)....................................
Osmium Tetroxide................................... 20816-12-0 100
Oxygen Difluoride (Fluorine Monoxide).............. 7783-41-7 100
Ozone.............................................. 10028-15-6 100
Pentaborane........................................ 19624-22-7 100
Peracetic Acid (concentration 60% Acetic 79-21-0 1000
Acid; also called Peroxyacetic Acid)..............
Perchloric Acid (concentration 60% by 7601-90-3 5000
weight)...........................................
Perchloromethyl Mercaptan.......................... 594-42-3 150
Perchloryl Fluoride................................ 7616-94-6 5000
Peroxyacetic Acid (concentration 60% 79-21-0 1000
Acetic Acid; also called Peracetic Acid)..........
Phosgene (also called Carbonyl Chloride)........... 75-44-5 100
Phosphine (Hydrogen Phosphide)..................... 7803-51-2 100
Phosphorus Oxychloride (also called Phosphoryl 10025-87-3 1000
Chloride).........................................
Phosphorus Trichloride............................. 7719-12-2 1000
Phosphoryl Chloride (also called Phosphorus 10025-87-3 1000
Oxychloride)......................................
Propargyl Bromide.................................. 106-96-7 100
Propyl Nitrate..................................... 627-3-4 2500
Sarin.............................................. 107-44-8 100
Selenium Hexafluoride.............................. 7783-79-1 1000
Stibine (Antimony Hydride)......................... 7803-52-3 500
Sulfur Dioxide (liquid)............................ 7446-09-5 1000
Sulfur Pentafluoride............................... 5714-22-7 250
Sulfur Tetrafluoride............................... 7783-60-0 250
Sulfur Trioxide (also called Sulfuric Anhydride)... 7446-11-9 1000
Sulfuric Anhydride (also called Sulfur Trioxide)... 7446-11-9 1000
Tellurium Hexafluoride............................. 7783-80-4 250
Tetrafluoroethylene................................ 116-14-3 5000
Tetrafluorohydrazine............................... 10036-47-2 5000
Tetramethyl Lead................................... 75-74-1 1000
Thionyl Chloride................................... 7719-09-7 250
Trichloro (chloromethyl) Silane.................... 1558-25-4 100
Trichloro (dichlorophenyl) Silane.................. 27137-85-5 2500
Trichlorosilane.................................... 10025-78-2 5000
Trifluorochloroethylene............................ 79-38-9 10000
Trimethyoxysilane.................................. 2487-90-3 1500
------------------------------------------------------------------------
*Chemical Abstract Service Number.
**Threshold Quantity in Pounds (Amount necessary to be covered by this
standard).
[[Page 358]]
Appendix B to Sec. 1910.119--Block Flow Diagram and Simplified Process
Flow Diagram (Nonmandatory)
[GRAPHIC] [TIFF OMITTED] TC27OC91.026
[[Page 359]]
[GRAPHIC] [TIFF OMITTED] TC27OC91.027
Appendix C to Sec. 1910.119--Compliance Guidelines and Recommendations
for Process Safety Management (Nonmandatory)
This appendix serves as a nonmandatory guideline to assist employers
and employees in complying with the requirements of this section, as
well as provides other helpful recommendations and information. Examples
presented in this appendix are not the only means of achieving the
performance goals in the standard. This appendix neither adds nor
detracts from the requirements of the standard.
1. Introduction to Process Safety Management. The major objective of
process safety management of highly hazardous chemicals is to prevent
unwanted releases of hazardous chemicals especially into locations which
could expose employees and others to serious hazards. An effective
process safety management program requires a systematic approach to
evaluating the whole process. Using this approach the process design,
process technology, operational and maintenance activities and
procedures, nonroutine activities and procedures, emergency preparedness
plans and procedures, training programs, and other elements which impact
the process are all considered in the evaluation. 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 strengthened to assure 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 result of failures in process, procedures or equipment.
The process safety management standard targets highly hazardous
chemicals that
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have the potential to cause a catastrophic incident. This 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 to the surrounding community. To control these
types of hazards, employers need to develop the necessary expertise,
experiences, judgement and proactive initiative within their workforce
to properly implement and maintain an effective process safety
management program as envisioned in the OSHA standard. This OSHA
standard is required by the Clean Air Act Amendments as is the
Environmental Protection Agency's Risk Management Plan. Employers, who
merge the two sets of requirements into their process safety management
program, will better assure full compliance with each as well as
enhancing their relationship with the local community.
While OSHA believes process safety management will have a positive
effect on the safety of employees in workplaces and also offers other
potential benefits to employers (increased productivity), smaller
businesses which may have limited resources available to them at this
time, might consider alternative avenues of decreasing the risks
associated with highly hazardous chemicals at their workplaces. One
method which might be considered is the reduction in the inventory of
the highly hazardous chemical. This reduction in inventory will result
in a reduction of the risk or potential for a catastrophic incident.
Also, employers including small employers may be able to establish more
efficient inventory control by reducing the quantities of highly
hazardous chemicals on site below the established threshold quantities.
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, then the employer
might consider dispersing inventory to several locations on site.
Dispersing storage into locations where a release in one location will
not cause a release in another location is a practical method to also
reduce the risk or portential for catastrophic incidents.
2. Employee Involvement in Process Safety Management. Section 304 of
the Clean Air Act Amendments states that employers are to consult with
their employees and their representatives regarding the employers
efforts in the development and implementation of the process safety
management program elements and hazard assessments. Section 304 also
requires employers to train and educate their employees and to inform
affected employees of the findings from incident investigations required
by the process safety management program. Many employers, under their
safety and health programs, have already established means and methods
to keep employees and their representatives informed about relevant
safety and health issues and employers may be able to adapt these
practices and procedures to meet their obligations under this standard.
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 obligations
specified by this standard. These committees can become a significant
ally in helping the employer to implement and maintain an effective
process safety managment program for all employees.
3. Process Safety Information. 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 process hazards analysis. The compiled information will
be a necessary resource to a variety of users including the team that
will perform the process hazards analysis as required under paragraph
(e); those developing the training programs and the operating
procedures; contractors whose employees will be working with the
process; those conducting the pre-startup reviews; 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 monitoring tools. Current
material safety data sheet (MSDS) information can be used to help meet
this requirement which must be supplemented with process chemistry
information including runaway reaction and over pressure hazards if
applicable.
Process technology information will be a part of the process safety
information package and it is expected that it will include diagrams of
the type shown in appendix B of this section as well as employer
established criteria for maximum inventory levels for process chemicals;
limits beyond which would be considered upset conditions; and a
qualitative estimate of the consequences or results of deviation that
could occur if operating beyond the established process limits.
Employers are encouraged to use diagrams which will help users
understand the process.
A block flow diagram is used to show the major process equipment and
interconnecting process flow lines and show 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 will show all main flow
streams including valves to enhance the understanding of
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the process, as well as pressures and temperatures on all feed and
product lines within all major vessels, in and out of headers and heat
exchangers, and points of pressure and temperature control. Also,
materials of construction information, pump capacities and pressure
heads, compressor horsepower and vessel design pressures and
temperatures are shown when necessary for clarity. In addition, major
components of control loops are usually shown along with key utilities
on process flow diagrams.
Piping and instrument diagrams (P&IDs) may be the more appropriate
type of diagrams to show some of the above details and to display the
information for the piping designer and engineering staff. The P&IDs 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 which 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 were the codes and standards relied on
to establish good engineering practice. These codes and standards are
published by such organizations as the American Society of Mechanical
Engineers, American Petroleum Institute, American National Standards
Institute, National Fire Protection Association, American Society for
Testing and Materials, National Board of Boiler and Pressure Vessel
Inspectors, National Association of Corrosion Engineers, American
Society of Exchange Manufacturers Association, and model building code
groups.
In addition, various engineering societies issue technical reports
which impact process design. For example, the American Institute of
Chemical Engineers has published technical reports on topics such as two
phase flow for venting devices. This type of technically recognized
report would constitute good engineering practice.
For existing equipment designed and constructed many years ago in
accordance with the codes and standards available at that time and no
longer in general use today, the employer must document which codes and
standards were used and that the design and construction along with the
testing, inspection and operation are still suitable for the intended
use. Where the process technology requires a design which departs from
the applicable codes and standards, the employer must document that the
design and construction is suitable for the intended purpose.
4. Process Hazard Analysis. A process hazard analysis (PHA),
sometimes called a process hazard 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 which 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 is directed toward analyzing potential causes and
consequences of fires, explosions, releases of toxic or flammable
chemicals and major spills of hazardous chemicals. The PHA focuses on
equipment, instrumentation, utilities, human actions (routine and
nonroutine), and external factors that might impact the process. These
considerations assist in determining the hazards and potential failure
points or failure modes in a process.
The selection of a PHA methodology or technique will be influenced
by many factors including the amount of existing knowledge 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 which has been
changed frequently by the inclusion of innovative features? Also, the
size and complexity of the process will influence the decision as to the
appropriate 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 the changes
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 need 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 only be a part of the team for a limited time. The team
leader needs to be fully knowledgeable in the proper implementation of
the PHA methodology that is 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, including how the work is actually
performed, alarms, emergency procedures, instrumentation, maintenance
procedures, both routine and nonroutine tasks, including how the tasks
are authorized, procurement of parts and supplies, safety and health,
and any other relevant subject as the
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need dictates. 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, and 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 example, a
process involving a series of unit operation 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
checklist PHA 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 ratios and the chemistry is documented for
the full range and ratio of batch ingredients. Another process that
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,
then 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 which has 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.
Additionally, small businesses which are covered by this rule, will
often have processes that have less storage volume, less capacity, and
less complicated 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 a few people being
involved. A less complex process generally means that less data, P&IDs,
and process information is needed to perform a process hazard analysis.
Many small businesses have processes that are not unique, such as
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 used by each employer effectively to reflect his/her particular
process; this would simplify compliance for them.
When the employer has a number of processes which require a PHA, the
employer must set up a priority system of which PHAs to conduct first. A
preliminary or gross hazard analysis may be useful in prioritizing the
processes that the employer has determined are subject to coverage by
the process safety management standard. Consideration should first be
given to those processes with the potential of adversely affecting the
largest number of employees. This prioritizing 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. These factors would suggest a ranking order and would
suggest either using a weighing factor system or a systematic ranking
method. The use of a preliminary hazard analysis would assist an
employer in determining which process should be of the highest priority
and thereby the employer would obtain the greatest improvement in safety
at the facility.
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 (see appendix D).
5. Operating Procedures and Practices. Operating procedures describe
tasks to be performed, data to be recorded, operating conditions to be
maintained, samples to be 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
is to be used as a resource to better assure that the operating
procedures and practices are consistent with the known hazards of the
chemicals in the process and that the operating parameters are accurate.
Operating procedures should be reviewed by engineering staff and
operating personnel to ensure that they are accurate and provide
practical instructions on how to actually carry out job duties safely.
Operating procedures will include specific instructions or details
on what steps are to be taken or followed in carrying out the stated
procedures. These operating instructions for each procedure should
include the applicable safety precautions and should contain 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
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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 normal operating parameters. Also the operating
instructions need to describe the proper method for increasing the
temperature of the unit until the normal operating temperature
parameters are achieved.
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 as a result of
the management of change procedures. 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 maintenance department (like changing a valve from
steel to brass or other subtle changes) need to be evaluated to
determine if 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 oriented to
the changes in procedures before the change is made. When the process is
shut down in order to make a change, then the operating procedures must
be updated before startup of the process.
Training in how to handle upset conditions must be accomplished as
well as what operating personnel are to do in emergencies such as when a
pump seal fails or a pipeline ruptures. Communication between operating
personnel and workers performing work within the process area, such as
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 actual tasks. When the work is
completed, operating personnel should be informed to provide closure on
the job.
6. Employee Training. All employees, including maintenance and
contractor employees, involved with highly hazardous chemicals need to
fully understand the safety and health hazards of the chemicals and
processes they work with for the protection of themselves, their fellow
employees and the citizens of nearby communities. Training conducted in
compliance with Sec. 1910.1200, the Hazard Communication standard, will
help employees to be more knowledgeable about the chemicals they work
with as well as familiarize them with reading and understanding MSDS.
However, additional training in subjects such as operating procedures
and safety work practices, emergency evacuation and response, safety
procedures, routine and nonroutine work authorization activities, and
other areas pertinent to process safety and health will need to be
covered by an employer's training program.
In establishing their training programs, employers must clearly
define the employees to be trained and what subjects are to be covered
in their training. Employers in setting up their training program will
need to clearly establish the goals and objectives they wish to achieve
with the training that they provide to their employees. 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.
Hands-on-training where employees are able to use their senses
beyond listening, 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 or panels. Upset
conditions of various types could be displayed on the simulator, 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, of course, under controlled conditions.
This realistic type of training can be very effective in teaching
employees correct procedures while allowing them to also see the
consequences of what might happen if they do not follow established
operating procedures. Other training techniques using videos or on-the-
job training can also be very effective for teaching other job tasks,
duties, or other important information. An effective training program
will allow the employee to fully participate in the training process and
to practice their skill or knowledge.
[[Page 364]]
Employers need to periodically evaluate their training programs to
see if the necessary skills, knowledge, and routines are being properly
understood and implemented by their trained employees. The means or
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 employees are not at the level
of knowledge and skill that was expected, the employer will need to
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
should also be consulted as to how best to improve the training process.
If 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 assure that employees
including maintenance and contract employees receive current and updated
training . For example, if changes are made to a process, impacted
employees must be trained in the changes and understand the effects of
the changes on their job tasks (e.g., any new operating procedures
pertinent to their tasks). Additionally, as already discussed the
evaluation of the employee's absorption of training will certainly
influence the need for training.
7. Contractors. Employers who use contractors to perform work in and
around processes that involve highly hazardous chemicals, will need to
establish a screening process so that they hire and use contractors who
accomplish the desired job tasks without compromising the safety and
health of employees at a facility. For contractors, whose safety
performance on the job is not known to the hiring employer, the employer
will need to obtain information on injury and illness rates and
experience and should obtain contractor references. Additionally, the
employer must assure that the contractor has the appropriate job skills,
knowledge and certifications (such as for pressure vessel welders).
Contractor work methods and experiences 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 illness log for contractors is another
method employers must use to track and maintain current knowledge of
work activities involving contract employees working on or adjacent to
covered processes. Injury and illness logs of both the employer's
employees and contract employees allow an employer to have full
knowledge of process injury and illness experience. This log will also
contain information which will be of use to those auditing process
safety management compliance and those involved in incident
investigations.
Contract employees must perform their work safely. Considering that
contractors often perform very specialized and potentially hazardous
tasks such as confined space entry activities and nonroutine repair
activities it is quite important that their activities be controlled
while they are working on or near a covered process. A permit system or
work authorization system for these activities would also be helpful to
all affected employers. The use of a work authorization system keeps an
employer informed of contract employee activities, and as a benefit the
employer will have 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 will
benefit all of those who work in the facility whether they be contract
employees or employees of the owner.
8. Pre-Startup Safety. 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 will be enhanced by making use of the PHA recommendations before
final installations are completed. P&IDs are to be completed along with
having the operating procedures in place and the operating staff trained
to run the process before startup. The initial startup procedures and
normal operating procedures need to be fully evaluated as part of the
pre-startup review to assure a safe transfer into the normal operating
mode for meeting the process parameters.
For existing processes that have been shutdown for turnaround, or
modification, etc., the employer must assure 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 impact
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 in light of the changes. Any incident
investigation recommendations, compliance audits or PHA recommendations
need to be reviewed as well to see what impacts they may have on the
process before beginning the startup.
9. Mechanical Integrity. Employers will need to review their
maintenance programs and schedules to see if there are areas where
``breakdown'' maintenance is used rather than an on-going mechanical
integrity program. Equipment used to process, store, or
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handle highly hazardous chemicals needs to be designed, constructed,
installed and maintained to minimize the risk of releases of such
chemicals. This requires that a mechanical integrity program be in place
to assure the continued integrity of process equipment. Elements of a
mechanical integrity program include the identification and
categorization of equipment and instrumentation, inspections and tests,
testing and inspection frequencies, development of maintenance
procedures, training of maintenance personnel, the establishment of
criteria for acceptable test results, documentation of test and
inspection results, and documentation of manufacturer recommendations as
to meantime to failure for equipment and instrumentation.
The first line of defense an employer has available is to operate
and maintain the process as designed, and to keep the chemicals
contained. This line of defense is backed up by the next line of defense
which is the controlled release of chemicals through venting to
scrubbers or flares, or to surge or overflow tanks which are designed to
receive such chemicals, etc. These lines of defense are the primary
lines of defense or means to prevent unwanted releases. The secondary
lines of defense would include fixed fire protection systems like
sprinklers, water spray, or deluge systems, monitor guns, etc., dikes,
designed drainage systems, and other systems which would control or
mitigate hazardous chemicals once an unwanted release occurs. These
primary and secondary lines of defense are what the mechanical integrity
program needs to protect and strengthen these primary and secondary
lines of defenses where appropriate.
The first step of an effective mechanical integrity program is to
compile and categorize a list of process equipment and instrumentation
for inclusion in the program. This list would include 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 would prioritize which pieces of equipment
require closer scrutiny than others. Meantime to failure of various
instrumentation and equipment parts would be known from the
manufacturers data or the employer's experience with the parts, which
would then influence the inspection and testing frequency and associated
procedures. Also, applicable codes and standards such as the National
Board Inspection Code, or those from the American Society for Testing
and Material, American Petroleum Institute, National Fire Protection
Association, American National Standards Institute, American Society of
Mechanical Engineers, and other groups, provide information to help
establish an effective testing and inspection frequency, as well as
appropriate methodologies.
The applicable codes and standards provide criteria for external
inspections for such items as foundation and supports, anchor bolts,
concrete or steel supports, guy wires, nozzles and sprinklers, pipe
hangers, grounding connections, protective coatings and insulation, and
external metal surfaces of piping and vessels, etc. These codes and
standards also provide information on methodologies for internal
inspection, and a frequency formula based on the corrosion rate of the
materials of construction. Also, erosion both internal and external
needs to be considered along with corrosion effects for piping and
valves. Where the corrosion rate is not known, a maximum inspection
frequency is recommended, and methods of developing the corrosion rate
are available in the codes. Internal inspections need to cover items
such as 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 inspections may be performed by state
of local government inspectors under state and local statutes. However,
each employer needs to develop procedures to ensure that tests and
inspections are conducted properly and that consistency is maintained
even where different employees may be involved. Appropriate training is
to be provided to maintenance personnel to ensure that they understand
the preventive maintenance program procedures, safe practices, and the
proper use amd 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.
A quality assurance system is needed to help ensure that the proper
materials of construction are used, that fabrication and inspection
procedures are proper, and that installation procedures recognize field
installation concerns. The quality assurance program is an essential
part of the mechanical integrity program and will help to maintain the
primary and secondary lines of defense that have been designed into the
process to prevent unwanted chemical releases or those which control or
mitigate a release. ``As built'' drawings, together with certifications
of coded vessels and other equipment, and materials of construction need
to 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 assure that qualified
craftsmen are used to do the job. The use of appropriate gaskets,
packing, bolts, valves, lubricants and welding rods need to be verified
in the field. Also
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procedures for installation of safety devices need to be verified, such
as the torque on the bolts on ruptured disc installations, uniform
torque on flange bolts, proper installation of pump seals, etc. If the
quality of parts is a problem, it may be appropriate to conduct audits
of the equipment supplier's facilities to better assure proper purchases
of required equipment which is suitable for its intended service. Any
changes in equipment that may become necessary will need to go through
the management of change procedures.
10. Nonroutine Work Authorizations. Nonroutine work which is
conducted in process areas needs to be controlled by the employer in a
consistent manner. The hazards identified involving the work that is to
be accomplished must be communicated to those doing the work, but also
to those operating personnel whose work could affect the safety of the
process. A work authorization notice or permit must have a procedure
that describes the steps the maintenance supervisor, contractor
representative or other person needs to follow to obtain the necessary
clearance to get the job started. The work authorization procedures need
to reference and coordinate, as applicable, lockout/tagout procedures,
line breaking procedures, confined space entry procedures and hot work
authorizations. This procedure also needs to provide clear steps to
follow once the job is completed in order to provide closure for those
that need to know the job is now completed and equipment can be returned
to normal.
11. Managing Change. To properly manage changes to process
chemicals, technology, equipment and facilities, one must define what is
meant by change. In this process safety management standard, change
includes all modifications to equipment, procedures, raw materials and
processing conditions other than ``replacement in kind''. These changes
need to be properly managed by identifying and reviewing them prior to
implementation of the change. 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 covers such as changes in process technology
and changes to equipment and instrumentation. Changes in process
technology can result from changes in production rates, raw materials,
experimentation, equipment unavailability, new equipment, new product
development, change in catalyst and changes in operating conditions to
improve yield or quality. Equipment changes include among others change
in materials of construction, equipment specifications, piping pre-
arrangements, experimental equipment, computer program revisions and
changes in alarms and interlocks. Employers need to establish means and
methods to detect both technical changes and mechanical changes.
Temporary changes have caused a number of catastrophes over the
years, and employers need to establish ways to detect temporary changes
as well as those that are permanent. It is important that a time limit
for temporary changes be established and monitored since, 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 insure 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 is invaluable in assuring that the safety and health
considerations are being incorporated into the operating procedures and
the process.
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 considerations, 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 communication to
others who are affected may be sufficient. However, for a more complex
or significant design change, a hazard evaluation procedure with
approvals by operations, maintenance, and safety departments may be
appropriate. Changes in documents such as P&IDs, raw materials,
operating procedures, mechanical integrity programs, electrical
classifications, etc., need to be noted so that these revisions can be
made permanent when the drawings and procedure manuals are updated.
Copies of process changes need to 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 done or one is being updated.
12. Investigation of Incidents. 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 employers to learn from past
experiences and thus avoid repeating past
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mistakes. The incidents for whicn OSHA expects employers to become aware
and to investigate are the types of events which result in or could
reasonably have resulted in a catastrophic release. Some of the events
are sometimes referred to as ``near misses,'' meaning that a serious
consequence did not occur, but could have.
Employers need to develop in-house capability to investigate
incidents that occur in their facilities. A team needs to be assembled
by the employer and trained in the techniques of investigation including
how to conduct interviews of witnesses, needed documentation and report
writing. 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 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 form a significant set of facts
about the incident which occurred. The report, its findings and
recommendations are to be shared with those who can benefit from the
information. The cooperation of employees is essential to an effective
incident investigation. The focus of the investigation should be to
obtain facts, and not to place blame. The team and the investigation
process should clearly deal with all involved individuals in a fair,
open and consistent manner.
13. Emergency Preparedness. Each employer must address what actions
employees are to take when there is an unwanted release of highly
hazardous chemicals. Emergency preparedness or the employer's tertiary
(third) lines of defense are those that will be relied on along with the
secondary lines of defense when the primary lines of defense which are
used to prevent an unwanted release fail to stop the release. Employers
will need to decide if 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. Or whether employers want their employees to
evacuate the danger area and promptly escape to a preplanned safe zone
area, and 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 preparedness or tertiary lines of defense they plan
to have and then develop the necessary plans and procedures, and
appropriately train employees in their emergency duties and
responsibilities and then implement these lines of defense.
Employers at a minimum must have an emergency action plan which will
facilitate the prompt evacuation of employees due to an unwanted release
of a highly hazardous chemical. This means that the employer will have a
plan that will be activated by an alarm system to alert employees when
to evacuate and, that employees who are physically impaired, will have
the necessary support and assistance to get them to the safe zone as
well. The intent of these requirements is to alert and move employees to
a safe zone quickly. Delaying alarms or confusing alarms are to be
avoided. The use of process control centers or similar process buildings
in the process area as safe areas is discouraged. Recent catastrophes
have shown that a large life loss has occurred in these structures
because of where they have been sited and because they are not
necessarily designed to withstand over-pressures from shockwaves
resulting from explosions in the process area.
Unwanted incidental releases of highly hazardous chemicals in the
process area must be addressed by the employer as to what actions
employees are to take. If the employer wants employees to evacuate the
area, then the emergency action plan will be activated. For outdoor
processes where wind direction is important for selecting the safe route
to a refuge area, the employer should place a wind direction indicator
such as a wind sock or pennant at the highest point that can be seen
throughout the process area. Employees can move in the direction of
cross wind to upwind to gain safe access to the refuge area by knowing
the wind direction.
If the employer wants specific employees in the release area to
control or stop the minor emergency or incidental release, these actions
must be planned for in advance and procedures developed and implemented.
Preplanning for handling incidental releases for minor emergencies in
the process area needs to be done, appropriate equipment for the hazards
must be provided, and training conducted for those employees who will
perform the emergency work before they respond to handle an actual
release. The employer's training program, including the Hazard
Communication standard training is to address the training needs for
employees who are expected to handle incidental or minor releases.
Preplanning for releases that are more serious than incidental
releases is another important line of defense to be used by the
employer. 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
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plan. If the employer wishes to use plant personnel such as a fire
brigade, spill control team, a hazardous materials team, or use
employees to render aid to those in the immediate release area and
control or mitigate the incident, these actions are covered by
Sec. 1910.120, the Hazardous Waste Operations and Emergency Response
(HAZWOPER) standard. If outside assistance is necessary, such as through
mutual aid agreements between employers or local government emergency
response organizations, these emergency responders are also covered by
HAZWOPER. The safety and health protections required for emergency
responders are the responsibility of their employers and of the on-scene
incident commander.
Responders may be working under very hazardous conditions and
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 emergency response planners and
responder organizations is one means to obtain better preparedness. This
close cooperation and coordination between plant and local community
emergency preparedness managers will also aid the employer in complying
with the Environmental Protection Agency's Risk Management Plan
criteria.
One effective way for medium to large facilities to enhance
coordination and communication during emergencies for on plant
operations and with local community organizations is for employers to
establish and equip an emergency control center. The emergency control
center would be sited in a safe zone area so that it could be occupied
throughout the duration of an emergency. The center would serve as the
major ccommunication link between the on-scene incident commander and
plant or corporate management as well as with the local community
officials. The communication 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
communication network in case of power failure or one communication
means fails. The center should also be equipped with the plant layout
and community maps, utility drawings including fire water, emergency
lighting, appropriate reference materials such as a government agency
notification list, company personnel phone list, SARA Title III reports
and material safety data sheets, emergency plans and procedures manual,
a listing with the location of emergency response equipment, mutual aid
information, and access to meteorological or weather condition data and
any dispersion modeling data.
14. Compliance Audits. Employers need to select a trained individual
or assemble a trained team of people to audit the process safety
management system and program. A small process or plant may need only
one knowledgeable person to conduct an audit. The audit is to include 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 implemented. The audit should be conducted or lead by a
person knowledgeable in audit techniques and who is impartial towards
the facility or area being audited. The essential elements of an audit
program include planning, staffing, conduting the audit, evaluation and
corrective action, follow-up and documentation.
Planning in advance is essential to the success of the auditing
process. Each employer needs to establish the format, staffing,
scheduling and verification methods prior to conducting the audit. The
format should be designed to provide the lead auditor with a procedure
or checklist which details the requirements of each section of the
standard. The names of the audit team members should be listed as part
of the format as well. The checklist, if properly designed, could serve
as the verification sheet which provides the auditor with the necessary
information to expedite the review and assure that no requirements of
the standard are omitted. This verification sheet format could also
identify those elements that will require evaluation or a response to
correct deficiencies. This sheet could also be used for developing the
follow-up and documentation requirements.
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 with 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 classifications, safety and
health disciplines, maintenance, emergency preparedness, warehousing or
shipping, and process safety auditing. The team may use part-time
members to provide for the depth of expertise required as well as for
what is actually done or followed, compared to what is written.
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
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preplanning stage, the audit team can systematically analyze compliance
with the provisions of the standard and any other corporate policies
that are relevant. For example, the audit team will review all 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, documentation, etc. Through interviews, the team can
determine the employee's knowledge and awareness of the safety
procedures, duties, rules, emergency response assignments, etc. During
the inspection, the team can observe actual practices such as safety and
health policies, procedures, and work authorization practices. This
approach enables the team to identify deficiencies and determine where
corrective actions or improvements are necessary.
An audit is a technique used to gather sufficient facts and
information, including statistical information, to verify compliance
with standards. Auditors should select as part of their preplanning a
sample size sufficient to give a degree of confidence that the audit
reflects the level of compliance with the standard. The audit team,
through this systematic analysis, should document areas which require
corrective action as well as those areas where the process safety
management system is effective and working in an effective manner. This
provides a record of the audit procedures and findings, and serves as a
baseline of operation data for future audits. It will assist future
auditors in determining changes or trends from previous audits.
Corrective action is one of the most important parts of the audit.
It includes not only addressing the identified deficiencies, but also
planning, followup, and documentation. 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
requirements and responsibilities. In some cases, corrective action may
involve a simple change in procedure or minor maintenance effort to
remedy the concern. Management of change procedures need to be used, as
appropriate, even for what may seem to be a minor change. Many of the
deficiencies can be acted on promptly, while some may require
engineering studies or indepth review of actual procedures and
practices. There may be instances where no action is necessary and this
is a valid response to an audit finding. All actions taken, including an
explanation where no action is taken on a finding, needs to be
documented as to what was done and why.
It is important to assure that each deficiency identified is
addressed, the corrective action to be taken noted, and the audit person
or team responsible be properly documented by the employer. 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 implementation 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.
Appendix D to Sec. 1910.119--Sources of Further Information
(Nonmandatory)
1. Center for Chemical Process Safety, American Institute of
Chemical Engineers, 345 East 47th Street, New York, NY 10017, (212) 705-
7319.
2. ``Guidelines for Hazard Evaluation Procedures,'' American
Institute of Chemical Engineers; 345 East 47th Street, New York, NY
10017.
3. ``Guidelines for Technical Management of Chemical Process
Safety,'' Center for Chemical Process Safety of the American Institute
of Chemical Engineers; 345 East 47th Street, New York, NY 10017.
4. ``Evaluating Process Safety in the Chemical Industry,'' Chemical
Manufacturers Association; 2501 M Street NW, Washington, DC 20037.
5. ``Safe Warehousing of Chemicals,'' Chemical Manufacturers
Association; 2501 M Street NW, Washington, DC 20037.
6. ``Management of Process Hazards,'' American Petroleum Institute
(API Recommended Practice 750); 1220 L Street, N.W., Washington, D.C.
20005.
7. ``Improving Owner and Contractor Safety Performance,'' American
Petroleum Institute (API Recommended Practice 2220); API, 1220 L Street
N.W., Washington, D.C. 20005.
8. Chemical Manufacturers Association (CMA's Manager Guide), First
Edition, September 1991; CMA, 2501 M Street, N.W., Washington, D.C.
20037.
9. ``Improving Construction Safety Performance,'' Report A-3, The
Business Roundtable; The Business Roundtable, 200 Park Avenue, New York,
NY 10166. (Report includes criteria to evaluate contractor safety
performance and criteria to enhance contractor safety performance).
10. ``Recommended Guidelines for Contractor Safety and Health,''
Texas Chemical Council; Texas Chemical Council, 1402 Nueces Street,
Austin, TX 78701-1534.
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11. ``Loss Prevention in the Process Industries,'' Volumes I and II;
Frank P. Lees, Butterworth; London 1983.
12. ``Safety and Health Program Management Guidelines,'' 1989; U.S.
Department of Labor, Occupational Safety and Health Administration.
13. ``Safety and Health Guide for the Chemical Industry,'' 1986,
(OSHA 3091); U.S. Department of Labor, Occupational Safety and Health
Administration; 200 Constitution Avenue, N.W., Washington, D.C. 20210.
14. ``Review of Emergency Systems,'' June 1988; U.S. Environmental
Protection Agency (EPA), Office of Solid Waste and Emergency Response,
Washington, DC 20460.
15. ``Technical Guidance for Hazards Analysis, Emergency Planning
for Extremely Hazardous Substances,'' December 1987; U.S. Environmental
Protection Agency (EPA), Federal Emergency Management Administration
(FEMA) and U.S. Department of Transportation (DOT), Washington, DC
20460.
16. ``Accident Investigation * * * A New Approach,'' 1983, National
Safety Council; 444 North Michigan Avenue, Chicago, IL 60611-3991.
17. ``Fire & Explosion Index Hazard Classification Guide,'' 6th
Edition, May 1987, Dow Chemical Company; Midland, Michigan 48674.
18. ``Chemical Exposure Index,'' May 1988, Dow Chemical Company;
Midland, Michigan 48674.
[57 FR 6403, Feb. 24, 1992; 57 FR 7847, Mar. 4, 1992, as amended at 61
FR 9238, Mar. 7, 1996]