PROCESS SAFETY MANAGEMENT
29 CFR 1910.119
The University of Akron is establishing this PSM program in order to comply with the OSHA Standard regulating the process safety management of highly hazardous chemicals, and to enable all affected researchers and staff to be able to identify and understand the hazards posed by the presence of those chemicals on our campus. The program will help prevent the occurrence of and minimize the consequences of accidental release of these chemicals.
The PSM will be reviewed regularly and updated to reflect new or modified research project tasks and procedures.
A copy of the program will be accessible to all pertinent people on the payroll of the University of Akron and to other persons in accordance with applicable OSHA requirements.
This program covers the following:
- Each research project involving a chemical listed on Table I at or above its specified threshold quantity.
- Each research project involving a flammable liquid or gas as defined in 29 CFR 1910.1200, on site in one location in a quantity of 10,000 pounds or more, except for hydrocarbon fuel used solely for workplace consumption and flammable liquids stored in atmospheric tanks.
- It does not apply to oil or gas drilling or servicing operations.
PROCESS SAFETY INFORMATION
The safety information to be made readily available to those involved in the project shall include:
- Information pertaining to hazards of the highly hazardous chemicals used in the project:
- Permissible exposure limits (PEL)
- Physical data
- Reactivity data
- Corrosivity data
- Thermal and chemical stability data
- Hazardous effects of inadvertent mixing of foreseeable different materials
- Information pertaining to the technology of the project:
- A block flow diagram or simplified process flow diagram
- Process chemistry
- Maximum intended inventory
- Safe upper and lower limits of temperature, pressure, flow rates, compositions
- Evaluation of the consequences of deviations from normal operation
- If the technical data does not exist, the Process Hazard Analysis will provide sufficient data to provide that information
- Information pertaining to the equipment in the project:
- Materials of construction
- Piping and instrument diagrams
- Electrical classification
- Relief system designs and basis
- Ventilation system design
- Design codes employed
- Material and energy balances
- Safety systems (such as interlocks, detections, and suppressions)
PROCESS HAZARD ANALYSIS
A Safety Committee involving the Lead Researcher, Experts in the field, and Safety Officers will conduct the Process Hazard Analysis.
The analysis will identify, evaluate, and control the hazards involved in the process.
The Committee will determine and document the priority order for conducting the analysis on the basis of:
- The extent of the process hazards
- Number of potentially affected employees
- Age of the process
- Operating history of the process
The process hazard analysis will be updated and revalidated at least every five years by the same or equally competent Committee.
The process hazard analysis shall utilize one or more of the following methodologies:
- Hazard and Operability Study (HAZOP)
- Failure Mode and Effects Analysis (FMEA)
- Fault Tree Analysis
- An appropriate equivalent methodology
The process hazard analysis will address the following:
- The hazards of the process
- The identification of any previous incident with likely potential for catastrophic consequences in the workplace
- Engineering and administrative controls
- Consequences of failure of engineering and administrative controls
- Facility sitting
- Human factors
- A qualitative evaluation of a range of possible safety and health effects of failure of controls on those in the area.
The University of Akron will establish a team to promptly address the finding and recommendations of the Safety Committee by doing the following:
- 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 Legal Counsel, the Provost, PFOC, and those that could be affected by the recommendations or actions
- Retain the process hazard analysis, all updates, and revalidation of each process for the life of the research project.
The Lead Researcher will develop and implement written operating procedures consistent with the Process Safety Information. The procedures will provide clear instructions for safely conducting activities and will include:
- The steps for each operating phase
- Initial startup
- Normal operation
- Temporary operations as the need arises
- Emergency operations such as emergency shutdown and who initiate these procedures
- Normal shutdown
- Startup following a turnaround or after an emergency shutdown
- Operating limits
- Consequences of deviation
- Steps required to correct and/or avoid deviation
- Safety systems and their functions
- Safety and health considerations
- Properties and hazards of the chemicals involved in the process
- Precautions to prevent exposure (Engineering, administrative controls, PPE)
- Control measures in case of physical contact or airborne exposure
- Safety procedures for opening process equipment such as pipe breaking
- Quality control for raw materials and control of hazardous chemical inventory levels
- Any special or unique hazards
- A copy of the operating procedures will be readily accessible to all those working on the project
- The University of Akron, Safety Department has developed additional safe work practices applicable to contractors as well to our employees:
- Confined space entry
- Opening process equipment or piping
- Control over entrance to a facility by maintenance, contractor, laboratory, or other support personnel
- Chemical Hygiene Plan
A. Initial Training
Each researcher and employee involved in the process or before working on the project, will be trained. The training will include emphasis on specific safety and health hazards, procedures, and safe practices.
B. There will be a refresher and supplemental training for those involved in the project every three years or whenever it is necessary in order to ensure that those involved understand and adhere to the established safe operating procedures.
C. The training documentation will include:
- The identity of the employee
- The date of training
- The means and methods used to ensure that the employee understood the training
- This section of our Program 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 that do not influence process safety, such as janitorial work, food and drink services, laundry, delivery or other supply services.
- When selecting a contractor, we will obtain and evaluate information regarding the contract employer's safety performance and programs.
- Before the contractor begins work, we will do the following:
- Inform contract employers of the known potential fire, explosion, or toxic release hazards related to the contractor's work and the process;
- Explain to contract employers the applicable provisions of our emergency action plan;
- Develop and implement additional safe work practices consistent with those listed in Part VI. E. Of this Program (lockout/tagout, etc.) in order to control the entrance, presence and exit of contract employers and contract employees in covered process areas;
- Periodically evaluate the performance of contract employers in fulfilling their obligations as specified in the OSHA standard, §1910.119(h)(3), and Part VIII. D. Of this Program (below); and
- Maintain a contract employee injury and illness log for those OSHA- recordable injuries and illnesses sustained by contractor employees that are related to the contractor's work in process areas.
- We will make it a condition of each contract that the contract employer must do the following:
- Assure that each contract employee is trained in the work practices necessary to safely perform his/her job;
- 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, as well as the applicable provisions of our Emergency Action Plan;
- Document that each contract employee has received and understood the training required by the OSHA standard, and that the contract employer will 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;
- Assure that each contract employee follows our safety rules including the additional safe work practices listed in this Program (lockout/tagout, etc.); and
- Advise us of any unique hazards presented by the contract employer's work, or of any hazards found by the contract employers' work.
PRE-STARTUP SAFETY REVIEW
- Whenever we establish new projects or modify projects for which the modification necessitates a change in the process safety information, we will perform a pre-startup safety review.
- The pre-startup safety review must confirm that, prior to the introduction of highly hazardous chemicals to a process:
- Construction is in accordance with design specifications;
- Safety, operating, maintenance, and emergency procedures are in place and are adequate;
- Process hazard analysis recommendations have been addressed and actions necessary for startup have been completed; and
- Operating procedures are in place, and training of each operating employee has been completed.
- We will establish and implement written procedures in order to maintain the ongoing integrity of the following items of process equipment:
- Pressure vessels and storage tanks;
- Piping systems (including piping components such as valves);
- Relief and vent systems and devices;
- Emergency shutdown systems;
- Controls (including monitoring devices and sensors, alarms, and interlocks); and
- Each employee involved in maintaining the ongoing integrity of those items of process equipment will be trained in an overview of the process and its hazards and in the procedures applicable to the employees' job tasks in order to assure that the employee can perform the job tasks in a safe manner.
- An inspection and testing program will be established that includes the following:
- Inspections and tests shall be performed on that process equipment;
- Inspection and testing procedures shall follow applicable codes and standards, such as those published by the American Society of Mechanical Engineers, the American Petroleum Institute, the American Institute of Chemical Engineers, the American National Standards Institute, the American Society of Testing and Materials, and the National Fire Protection Association, where they exist; or, recognized and generally accepted engineering practices;
- The frequency of inspections and tests shall be consistent with applicable codes and standards, applicable manufacturers' recommendations, and good engineering practices. They will be conducted more frequently if determined necessary by prior operating experience; and
- Each such inspection and test shall be documented in order to identify:
(a) The date of the inspection or test,
(b) The name of the person who performed the inspection or test,
(c) The serial number or other identifier of the equipment on which the Inspection or test was performed,
(d) A description of the inspection or test performed, and
(e) The results of the inspection or test.
- Deficiencies in equipment that are outside acceptable limits (defined by the process safety information mentioned in Part IV of this Program and §1910.119(d) of the OSHA standard) must be corrected either before further use, or in a safe and timely manner provided necessary means are taken to assure safe operation.
- Whenever a new plant or new equipment is constructed, we will make sure that:
1. The equipment, as it is fabricated, is suitable for the process application for which it will be used;
2. Equipment as fabricated meets design specifications;
3. Appropriate checks and inspections are performed as necessary in order to assure that equipment is installed properly and is consistent with design specifications and manufacturer's instructions; and
4. Maintenance materials, and spare parts and equipment, meet design specifications.
HOT WORK PERMIT
- A permit will be required for all hot work operations (welding, burning)
- The permit must document that the fire prevention and protection requirements in 29 C.F.R. §1910.252(a), the OSHA standard that specifies the precautions for fire prevention in welding or cutting work, have been implemented prior to beginning the hot work operations.
- Each such permit 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.
MANAGEMENT OF CHANGE
- All contemplated changes to a process must be thoroughly evaluated in order to assess their potential impact upon the safety and health of employees and to determine what modifications to operating procedures may be necessary. We have therefore established written procedures to manage those changes to process chemicals, technology, equipment, procedures and facilities that affect a covered process. Those procedures will not, however, cover "replacements in kind,” as defined in Part III. I.
- Those procedures will assure that the following are addressed prior to any change:
- The technical basis for the proposed change;
- Impact of the change on safety and health;
- Modifications to operating procedures;
- Necessary time period for the change; and
- Authorization requirements for the proposed change.
- Employees involved in operating a process and those maintenance and contract employees whose job tasks will be affected by a change in the process will be informed of, and trained in, the change prior to start-up of the process or affected part of the process.
- If such a change results in a change to the process safety information covered by this Program and 29 C.F.R. §1910.119(d), that information will be appropriately updated.
- If such a change results in a change to the operating procedures or practices covered by Part VI of this Program and 29 C.F.R. §1910.119(f), those procedures and practices will be appropriately updated.
- All incidents will be investigated that have either resulted in a catastrophic release of a highly hazardous chemical in the workplace, or could reasonably have so resulted.
- Each such incident investigation will be initiated as promptly as possible, but not later than 48 hours following the incident.
- The Safety Committee will investigate and analyze each such incident.
- The investigation team must prepare a report at the conclusion of the investigation, which includes at a minimum:
- Date of the incident,
- Date investigation began,
- A description of the incident,
- The factors that contributed to the incident, and
- Any recommendations resulting from the investigation.
- We will establish a system to promptly address and resolve the incident report's findings and recommendations. All corrective actions and resolutions that are taken in response shall be documented.
- The report of the investigation team will be reviewed with all affected personnel, whose job tasks are relevant to the incident findings, including contract employees where applicable.
- All incident investigation reports shall be retained for five years.
EMERGENCY PLANNING AND RESPONSE
We have established an Emergency Action Plan for the entire campus in accordance with the provisions of 29 C.F.R. §1910.38(a), the OSHA standard that provides for the adoption of an Emergency Action Plan. Our Plan also includes procedures for handling small releases. In the event that we are covered by similar OSHA requirements (such as the OSHA hazardous waste and emergency response standard), we will establish whatever plans or programs those OSHA standards may require.
- Our process safety management system will be regularly evaluated in order to:
- Measure its effectiveness;
- Direct our attention to potential weaknesses in the system;
- Verify that the procedures and practices that we have developed under the OSHA standard are adequate; and
- Assure that all required procedures and practices are being followed
- The evaluation will be conducted at least every three years.
- It will be conducted by at least one person knowledgeable in the process.
- A report of the findings of the audit will be developed.
- We will promptly determine and document an appropriate response to each of the findings of the compliance audit, and will document that deficiencies have been corrected.
- The two most recent compliance audit reports will be retained in our records.
- Without regard to the trade secret status of such information, all information that is needed in order to comply with the OSHA standard will be made available to the members of the Safety Committee.
- Those persons provided access to information that is classified as a trade secret, however, may be required to enter into confidentiality agreements against disclosure of such information as provided in the OSHA Hazard Communication standard, 29 C.F.R. §1910.1200.
- Subject to the rules and procedures contained in that standard (see §§1910.1200(I)(1) through 1910.1200(I)(12)), employees and their designated representatives shall be permitted access to trade secret information contained within our process hazard analysis and other documents that are required to be developed by the OSHA Process Safety Management standard, 29 C.F.R. §1910.119.
ADDITIONAL PROGRAMS AND PROVISIONS
This Program is designed to be a written statement of overall University of Akron Process Safety Management rules and policies. There are a number of additional work rules, procedures, requirements, documents, reports, and separate programs that apply in particular situations or that are required by particular laws or regulations (for example: hazard communication/right-to-know). Some of them are in writing and some are not. Others will be added from time to time in the future whenever required by applicable local, state or federal law or regulation or when deemed necessary by the company.
All employees of the University must observe those rules and programs just as they are required to observe the provisions of this Program.