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Course 736 - Introduction to Process Safety Management

Safety guides and audits to make your job as a safety professional easier

Why We Have Process Safety Management

The Problem

There is a potential for an accidental release of highly hazardous chemicals any time they are not properly controlled.
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Unexpected releases of toxic, reactive, or flammable liquids and gases in processes involving highly hazardous chemicals have been reported for many years. Incidents continue to occur in various industries that use highly hazardous chemicals which may be toxic, reactive, flammable, or explosive, or may exhibit a combination of these properties.

Regardless of the industry that uses these highly hazardous chemicals, there is a potential for an accidental release any time they are not properly controlled. This, in turn, creates the possibility of disaster.

Recent major disasters include the following:

  • The 1984 Bhopal, India, incident resulting in more than 2,800 deaths.
  • The October 1989 Phillips Petroleum Company, Pasadena, TX, incident resulting in 23 deaths and 132 injuries.
  • The December 2005 Texas City Refinery explosion with 100 employees injured and 15 confirmed dead.
  • The February 2010 Connecticut power plant explosion which resulted in 27 injuries and five deaths.
  • The August 26, 2012 Amuay Oil Refinery explosion in Venezuela that wounded dozens and killed at least 39 people, including one child.

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Note: Videos and exercises in our courses are for information only and not required to view. Final exam questions will not be derived from the videos. OSHAcademy is not responsible for video content.

1. Which of the following industrial disasters was considered historically the worst of all time?

a. Amuay Refinery, 2012
b. 1984 Bhopal, India
c. Texas City Refinery, 2005
d. Connecticut Power Plant, 2010

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Hazardous chemical releases pose a significant threat to employees
Hazardous chemical releases pose a serious threat

A Disastrous Record

Several major disasters involving highly hazardous chemicals drew international attention to the potential for major catastrophes; the public record in the U.S. is replete with information concerning many other less notable releases of highly hazardous chemicals.

Hazardous chemical releases continue to pose a significant threat to employees and provide impetus, internationally and nationally, for authorities to develop or consider developing legislation and regulations to eliminate or minimize the potential for such events.

2. What caused an interest in developing OSHA's process safety management regulations?

a. Food industry spills of hazardous substances
b. Disasters involving unexpected releases of hazardous chemicals
c. Public employee union demands for improved safety
d. Disclosure of public records involving illegal use of chemicals

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Chemical Safety Board

Methyl Isocyanate Tank Rupture and Release Bhopal, India – Dec. 2-3, 1984

On the night of December 2-3, 1984, a sudden release of about 30 metric tons of methyl isocyanate (MIC) occurred at the Union Carbide pesticide plant at Bhopal, India.

The accident was a result of poor safety management practices, poor early warning systems, and the lack of community preparedness. All of these represent the root causes (management system weaknesses) for the accident, and responsible process safety management would have prevented this tragedy.

The accident led to the death of over 2,800 people (other estimates put the immediate death toll as high as 8000) living in the vicinity and caused respiratory damage and eye damage to over 20,000 others. At least 200,000 people fled Bhopal during the week after the accident. Estimates of the damage vary widely between $350 million to as high as $3 billion.

3. What would have prevented the Bhopal, India tragedy?

a. Common sense by employees
b. Responsible process safety management
c. More money to compensate for low pay
d. More technical employee training

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1989 Pasadena TX Explosion video.

Phillips 66 Houston Chemical Complex Pasadena, Texas – Oct. 23, 1989

On October 23, 1989, at approximately 1:00 p.m., an explosion and fire ripped through the Phillips 66 Company Houston Chemical Complex in Pasadena, Texas. Twenty-three workers were killed and more than 314 were injured. Property damage was nearly three-quarters of a billion dollars.

The accident resulted from a release of extremely flammable process gases that occurred during regular maintenance operations on one of the plant's polyethylene reactors. The evidence showed that more than 85,000 pounds of highly flammable gases were released through an open valve. A vapor cloud formed and traveled rapidly through the polyethylene plant. Within 90 to 120 seconds, the vapor cloud came into contact with an ignition source and exploded with the force of 2.4 tons of TNT. The conflagration, which is a large and destructive fire, took 10 hours to be controlled.

OSHA determined that the a lack of process hazard analysis (PHA), inadequate standard operating procedures (SOPs), inadequate lockout/tagout procedures were major contributing root-cause system weaknesses for the tragedy. OSHA issued 566 willful and 9 serious violations with a proposed penalty of over $5.6 million. Ultimately, after a settlement, Phillips Petroleum Company paid $4 million in fines and instituted process safety management procedures at a number of its sister facilities.

4. OSHA concluded that the major causes for the Phillips 66 1989 Texas plant explosion were due to _____.

a. uncontrollable "acts of God" causes
b. poor employee communications
c. the fault of top executives
d. system weaknesses

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PSM and RMP.

OSHA Responds

On July 17, 1990, the U.S. Dept. of Labor, OSHA issued 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals, containing requirements for the management of hazards associated with processes using highly hazardous chemicals to help assure safe and healthful workplaces.

OSHA's PSM standard emphasizes the management of hazards associated with highly hazardous chemicals and establishes a comprehensive management program that integrates technologies, procedures, and management practices.

Since the standard's publication, OSHA has published numerous Letters of Interpretation in response to public inquiries or field office inquiries regarding how some aspect of or terminology in an OSHA standard or regulation is to be interpreted and enforced by the Agency.

5. OSHA's Process Safety Management standard emphasizes the management of hazards associated with _____.

a. uncontrollable releases of hazardous chemicals
b. highly hazardous chemicals
c. problematic hazardous chemical equipment
d. safety processes within the energy industry

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The Clean Air Act Amendments and the PSM Standard

Transverse motion

Shortly after the publication of OSHA's proposed PSM standard, Congress enacted the Clean Air Act Amendments (CAAA) which contained revisions to the Clean Air Act of 1990.

Section 304 of the CAAA requires that the Secretary of Labor, in coordination with the Administrator of the Environmental Protection Agency (EPA), promulgate a PSM standard to prevent accidental releases of chemicals that could pose a threat to employees.

The CAAA also requires that the PSM standard include a list of highly hazardous chemicals which includes toxic, flammable, highly reactive, and explosive substances.

CAAA Requirements for the PSM Standard

The CAAA requires that the standard include a list of highly hazardous chemicals which includes toxic, flammable, highly reactive, and explosive substances. These requirements have become widely known as the “14 PSM Program Elements."

6. The Clean Air Acts Amendment (CAAA) requires that the PSM standard include _____.

a. 14 PSM Program Elements
b. a prioritized list of chemicals
c. comprehensive list of all chemicals
d. list of exception of exempted chemicals

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OSHA's PSM Standard

OSHA's PSM standard, CFR 29 1910.119, emphasizes the management of hazards associated with highly hazardous chemicals and establishes a comprehensive management program that integrates technologies, procedures, and management practices.

The standard requires the employer to incorporate each of the 14 key elements in a formal PSM program. The key provision of final PSM standard is process hazard analysis (PHA) - a careful review of what could go wrong and what safeguards must be implemented to prevent releases of hazardous chemicals. Employers must identify those processes that pose the greatest risks and begin evaluating those first.

PSM clarifies the responsibilities of employers and contractors involved in work that affects or takes place near hazardous processes to ensure that the safety of both plant and contractor employees is considered.

Click on the button below to see a summary of the 14 Key Elements of the PSM program.

The 14 PSM Key Elements

  1. Employee participation 1910.119(c). The employer must develop a written plan of action implementing employee participation. Employers must 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.
  2. Process safety information 1910.119(d). The employer must compile written process safety information before conducting any process hazard analysis required by the standard. Process safety information must include information on the hazards of the highly hazardous chemicals used or produced by the process, information on the technology of the process, and information on the equipment in the process.
  3. Process hazard analysis. 1910.119(e). The employer must perform an initial process hazard analysis appropriate to the complexity of the process and identify, evaluate, and control the process hazards.
  4. Operating procedures 1910.119(f). The employer must develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information.
  5. Training 1910.119(g). Each new and current employee involved in operating a process must be trained in an overview of the process and in the operating procedures. The training must include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks.
  6. Contractors 1910.119(h). Employers, when selecting contractors performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process must obtain and evaluate information regarding the contract employer's safety performance and programs.
  7. Pre-startup review 1910.119(i). The employer must 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.
  8. Mechanical integrity 1910.119(j). The employer must establish and implement written procedures to maintain the on-going integrity of process equipment.
  9. Hot work permit 1910.119(k). The employer must issue a hot work permit for hot work operations conducted on or near a covered process.
  10. Management of change 1910.119(l). The employer must 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.
  11. Incident Investigation 1910.119(m). The employer must investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemical in the workplace.
  12. Emergency planning and response 1910.119(n). The employer must establish and implement an emergency action plan for the entire plant. The emergency action plan must include procedures for handling small releases. Covered employers may also be subject to the hazardous waste and emergency response provisions contained in 29 CFR 1910.120, Hazardous waste operations and emergency response.
  13. Compliance audits 1910.119(o). Employers must certify that they have evaluated compliance with OSHA 1910.119 at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed.
  14. Trade secrets 1910.119(p). Employers must make all information necessary to comply with the standard available to those persons responsible for compiling the process safety information, those assisting in the development of the process hazard analysis, those responsible for developing the operating procedures, and those involved in incident investigations, emergency planning and response, and compliance audits without regard to possible trade secret status of such information.

We will review each of the 14 Elements contained within the PSM standard throughout the remaining modules in this course.

7. The key provision of CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals, is _____.

a. to emphasize the management of hazards
b. to clarify management responsibilities
c. integrating technologies
d. the process hazard analysis (PHA)

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Benefits of an Effective PSM Program

Effective PSM helps ensure the proper development of plant systems and procedures to prevent unwanted releases which may ignite and cause toxic impacts, local fires, or explosions in plants and installations.

PSM can also improve:

  • the operability, productivity, stability, and quality of the outputs of hazardous chemical processes; and
  • the design and specification of safeguards against undesirable events.

Tangible benefits. Effective PSM results in tangible benefits such as fewer hazards and reduced OSHA citations, lawsuits, liability claims, and workers' compensation insurance premiums.

Intangible benefits. Intangible benefits include higher employee morale, increased trust between labor and management, and an improved relations with the local community as a responsible corporate citizen.

8. Which of the following is a tangible benefit of an effective PSM program?

a. Improved corporate citizenship
b. Higher employee morale
c. Improved inspection results
d. Increased employee-employer trust

Check your Work

Read the material in each section to find the correct answer to each quiz question. After answering all the questions, click on the "Check Quiz Answers" button to grade your quiz and see your score. You will receive a message if you forgot to answer one of the questions. After clicking the button, the questions you missed will be listed below. You can correct any missed questions and check your answers again.



CSB safety video detailing key lessons from investigation into 2016 chemical release at MGPI processing facility in Atchison, Kansas.

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