68 Chapter 3 Industrial Hygiene
Table 3-3 (continued)
Date Abbreviation Act
WQA OPA CAAA PPA TSCA-TI
-
NEPA HMTAA SDWA FQPA
Water Quality Act Oil Pollution Act of 1990 Clean Air Act Amendments Pollution Prevention Act of 1990
Residential Lead-Based Paint Hazard Abatement Act Federal Facility Compliance Act
National Environmental Policy Act
Hazardous Materials Transportation Act Amendments Safe Drinking Water Act Amendment
Food Quality Protection Act
lInformation from the EPA and OSHA web sites: www.epa.gov/epuhome and www.osha-slc.gov/oshsrrl-toclosha-std-toc . html.
relevant safety legislation, and Figure 3-1 shows how the amount of legislation has increased. A description of this legislation is well beyond the scope and goals of this textbook. However, it is important that chemical engineers be aware of the law to ensure that their facilities comply.
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X X
0 I I I I I I I I I
1900 1910 1920 1930 1940 1950 1960 1970 1980 1990 2000 Year
Figure 3-1 Number of federal laws relevant to chemical process safety.
process safety information is needed before training, process hazards analysis, management of change, and accident investigations.
.I,Process hazard analysis ( P H A ) must be performed by a team of experts, including engi- neers, chemists, operators, industrial hygienists, and other appropriate and experienced spe- cialists. The PHA needs to include a method that fits the complexity of the process, a hazards and operability (HAZOP) study for a complex process, and for less complex processes a less rigorous process, such as what-if scenarios, checklists, failure mode and effects analysis, or fault trees.
70 Chapter 3 Industrial Hygiene
Employers must ensure that the recommendations from the PHA are acted on in a timely manner. Every PSM process needs an updated PHA at least every five years after the initial analysis is completed.
Operating procedures that facilitate the safe operation of the plant must be documented.
These instructions need to be clearly written and consistent with the process safety information.
They need to cover, at a minimum, initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, startup after normal and emer- gency shutdowns, operating limits and consequences of deviations, safety and health consider- ations, hazardous properties of the chemicals, exposure precautions, engineering and admin- istrative controls, quality control specifications for all chemicals, special or unique hazards, and safety control systems and functions. Safe work practices also need to be documented, such as hot work, lockout/tagout, and confined space. These operating procedures are updated fre- quently, with the frequency being set by the operating personnel.
An effective training program helps employees understand the hazards associated with the tasks they perform. Maintenance and operations personnel receive initial training and re- fresher training. Operators need to understand the hazards associated with every task, includ- ing emergency shutdowns, startups, and normal operations. Refresher training is given every three years and more often if necessary; the operators decide on the frequency of the refresher
training.
..
Contractors are trained to perform their tasks safely to the same extent as employees.
Even when selecting contractors, the employees need to consider the contractors' safety per- formance in addition to their skills.
A pre-startup safety review is a special safety review that is conducted after a modification to the process or operating conditions has been made and before the startup. In this review a team of reviewers ensures that (1) the system is constructed in accordance with the design specifications, (2) the safety, maintenance, operating, and emergency procedures are in place, (3) the appropriate training is completed, and (4) the recommendations from the PHA are im- plemented or resolved.
The mechanical integrity section of the PSM standard ensures that the equipment, piping, relief systems, controls, and alarms are mechanically sound and operational. The requirements include (1) written procedures to maintain functioning systems, (2) training regarding preven- tive maintenance, (3) periodic inspections and testing based on vendor recommendations, (4) a process to correct deficiencies, and ( 5 ) a process to ensure that all equipment and spare parts are suitable.
The PSM standard ascertains that a system is in place to prepare and issue hot workper- mits before conducting hot work activities (welding, grinding, or using spark-producing equip- ment). The permit requires dates authorized for hot work, the equipment involved in the work, a system to maintain and document certification, identification of openings where sparks may drop, the types and numbers of fire extinguishers, identification of fire watches, an inspection before the work, authorization signatures, identification of flammable materials in the area,
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verification that the surrounding area is not explosive, verification that combustible materials are removed or covered appropriately, identification and closure of open vessels or ducts, and veritication that welded walls are not flammable.
Under the management of change section of the PSM standard employees are required to develop and implement documented procedures to manage changes in the process chemistry, process equipment, and operating procedures. Before a change occurs (except for replacement- in-kind), it must be reviewed to ascertain that it will not affect the safety of the operation. After the change has been made, all the affected employees are trained, and a pre-startup review is conducted.
The PSM standard mandates incident investigation. Employers must investigate all inci- dents that have or could have resulted in a major release or accident within 48 hours of the event. The regulation requires an investigation team composed of people, including operators, who are knowledgeable about the system. After the investigation, the employers are required to appropriately use the investigation recommendations.
The intent of the PSM element for emergency planning and response is to require em- ployers to respond effectively to the release of highly hazardous chemicals. Although the reg- ulation requires this activity for companies with more than 10 employees, this element should be part of a program for even the smallest organizations that handle hazardous chemicals.
Under the audits section of the PSM standard employers are required to certify that they have evaluated their compliance with the standard at least every three years. The recommen- dations from the audit must be followed. The audit reports need to be retained as long as the process exists.
The trade secrets section of the PSM standard ensures that all contractors are given all the information relevant to operating in the plant safely. Some personnel may need to sign secrecy agreements before they receive this information.