Richard A. Corbett
Refining/Petrochemical Editor
Existing codes, standards, and good engineering practices, already adhered to by much of the U.S. hydrocarbon processing industry, will gain the force of federal regulation when the process plant safety standard proposed by the U.S. Occupational Safety and Health Administration (OSHA) goes into effect, possibly late this year or early next (OGJ, July 23, p. 18).
Several deadly and major accidents in the processing industry have prompted OSHA to issue a notice of proposed rulemaking (NPRM) that proposes a safety standard designed to minimize the frequency and consequences of accidents related to toxic, flammable, or explosive chemicals in the U.S. processing industry. (The complete text of the proposed standard, and OSHA's interpretation of it, can be found in the Federal Register, July 17, 1990).
Existing OSHA regulations in Section 1910-119 of Subpart H of Title 29 of the U.S. Code of Federal Regulations (29 CFR Part 1910) include processing facilities, but they do not currently address safety management procedures that, according to OSHA, could help reduce the frequency and severity of process plant accidents.
The proposed standard will replace existing Section 1910.119 of 29 CFR Part 1910. The new Section 1910.119 will be entitled, "Process safety management of highly hazardous chemicals."
The proposed standard defines requirements for the management of hazards associated with processes that use highly hazardous chemicals. Procedures are established for safety management that are designed to protect employees of process plants by preventing or minimizing the consequences of chemical accidents involving highly hazardous materials.
Although the industry already complies with a large portion of the proposed standard, and substantial documentation on process operations already exists, much more formal documentation will be required to meet the provisions of the standard. And a more structured approach will have to be taken to employee training, operating procedures, maintenance procedures, and communication of information related to safety aspects of processing operations.
Workplaces that are included in the standard are those that process highly hazardous chemicals defined in the standard. Process is defined by OSHA as any activity conducted by an employer that involves a highly hazardous chemical including any use, storage, manufacture, handling, processing, movement, or any combination of these activities. Facilities that process materials listed in the standard include chemical plants, refineries, food and beverage manufacturers, paper mills, and explosives manufacturing plants.
Industries not included: oil and gas drilling and servicing operations, because OSHA has already undertaken rulemaking with regard to these distinct activities (48 Federal Register 57202); and retail operations because they usually handle limited amounts of hazardous materials.
Exceptions are also included for facilities that use hydrocarbons solely as fuels or those that store or transport flammable liquids. OSHA states that these types of operations do not present the level of hazard as those facilities covered by the standard.
The proposed standard lists about 140 hazardous substances and the threshold quantities of them that will put a plant within the scope of the standard. The list is a mandatory part of the proposed standard.
OSHA will conduct a hearing on Nov. 27, 1990, which may continue for more than 1 day. Comments to the proposed standard and notices of intention to appear at the hearing must be received by OSHA postmarked before Oct. 15, 1990. Comments are to be submitted in quadruplicate to the OSHA Docket Officer, Docket S-026, U.S. Department of Labor, Occupational Safety and Health Administration, Room N2625, 200 Constitution Ave., N.W., Washington, D.C. 20210.
WHAT PROMPTED THE STANDARD
Several serious accidents in the process industry worldwide prompted the proposed standard. The LPG explosion in Mexico City in 1984, the methyl isocyanate release in Bhopal, India, and more recently, explosions in plants in Pasadena and Channelview, Tex., and a hydrogen fluoride release in Texas City, Tex., are examples of accidents that provided impetus for the standard.
A release of aldicarb oxime and methylene chloride in Institute, W. Va., in August 1985 prompted a demonstration program of special inspections in a small segment of the chemical industry. The program, Special Emphasis Program for the Chemical Industry (Chem SEP, 1986), consisted of inspections completed by OSHA in 40 plants, targeting one process unit contained within each plant that manufactured a specific chemical. Results showed that inspections need a comprehensive inspection approach that includes plant physical conditions and management systems.
OSHA concluded that there are sufficient data and information available upon which to base a standard that would reduce the possibility of an accident involving highly hazardous chemicals. And accident reports, particularly on some of the more recent accidents, clearly show that mandatory standards are necessary and appropriate.
A consulting firm, Kearney/Centaur, compared current practices with the provisions of the proposed rule by standard industrial classification (SIC) group using OSHA survey data and data compiled by a major chemical engineering magazine.
For all industries affected by the proposed rule, none were judged to be currently in full compliance, although compliance appears to be at or near 100% among some establishments for some specific provisions. Generally, larger firms have a higher current compliance rate than smaller firms, but for many industries, the compliance-rate differences by establishment size are not substantial, according to OSHA.
KEY ELEMENTS
The proposed OSHA standard is based on the Kearney/Centaur study and covers 27,775 establishments that employ about 2.2 million workers in 95 industry subgroups. Employees at risk are found throughout, but particularly in SIC 28, Chemicals and Allied Products; and SIC 29, Petroleum Refining and Related Industries.
Others also at risk are found in SIC 4221, farm-product warehousing; SICs 50 and 51, wholesale trade; SIC 131, natural gas liquids; and SIC 49, electric and water service. (It should be noted, however, that OSHA employs the term 11 establishment," which is not fully defined).
For perspective, Oil & Gas Journal surveys show roughly 200 operating refineries and about 300 operating petrochemical complexes, facilities, and plants in the U.S. that will be covered by the proposed standards. These refineries and process plants are those that process hydrocarbon materials, based on crude oil or crude oil-based feedstocks, not simply warehouses or blending and shipping facilities.
Journal surveys also show about 760 gas-processing complexes in the U.S. Many of these facilities process large enough quantities of some of the listed hazardous materials to include them in the proposed standard's scope. Although these hydrocarbon-processing plants comprise only a small percentage of OSHA's count, they are responsible for a large volume of hydrocarbon feedstock and product manufacture.
The proposed standard is designed to accomplish its goals by requiring a comprehensive management program that is a holistic approach that integrates technologies, procedures, and management practices, according to OSHA. Table 1 lists the areas that a management system must address.
SCOPE OF COVERAGE
Processes covered are those that involve chemicals in quantities above the threshold limit listed in Appendix A of the proposed standard (see Table 2) and processes which involve flammable liquids or gases, on site in one location, in quantities of 10,000 lb or more (Paragraph (b) of the standard), Exceptions are: hydrocarbon fuels used solely for workplace consumption as a fuel, such as propane or oil used for comfort heating, and flammable liquids stored or transferred which are kept below their atmospheric boiling points without the aid of chilling or refrigeration.
Normally unmanned facilities also are not covered by the standard. A facility that is remote from other facilities and operated, maintained, and serviced by employees not permanently assigned to the facility and that visit the facility only periodically to check the operation and perform necessary operating or maintenance tasks, is considered a normally unmanned facility. Toxic chemical compounds developed after the effective date of the standard will be covered if the substance hazard index (SHI) of the new chemical is greater than 5,000 or at least 500 lb of the substance is in the workplace. SHI is defined as follows (Appendix B of the standard):
SHI - EVC ERPG-3
where: EVC is the equilibrium vapor concentration at 20 C., defined as:
(substance vapor pressure at 20 C. in mm Hg) x 106 760
and: ERPG-3 (Emergency Response Planning Guidelines, Level 3) is the maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to 1 hr without experiencing or developing life-threatening health effects. ERPGs are published by the American Industrial Hygiene Association.
Required information Detailed written safety information must be compiled so that the employer and employees operating the process can identify and understand the hazards associated with the process (Paragraph (d)). This information must be communicated to all employees involved with the process. Safety information must include information on the hazards of the particular materials used in the process and detailed information on the process technologies and equipment used in the process.
OSHA states that most of the information pertaining to the hazards associated with the chemicals involved can be provided by a chemical's material safety data sheet (MSDS) already required by the hazard communication standard in 29 CFR Part 1910.1200. The MSDS would be acceptable for meeting this part of the standard.
Information on process technologies and equipment used in processes should already be available in the form of process block diagrams and piping and instrument diagrams (P & IDs).
Some key data that are required by the standard are:
- Process chemistry
- Maximum inventory of substances in the process
- Safe upper and lower limits for such items as temperatures, pressures, flows, and/or compositions
- Consequences of deviations, including those that affect the safety and health of employees. For processes that were initiated before Jan. 1, 1980, the information concerning the technology of the process may be developed from a process hazards analysis conducted in accordance with one or more of the methods shown in Table 3. Table 4 shows typical information required for equipment in the process.
APPLICABLE CODES
Equipment information (Paragraph (d)(3) of the standard) is a key area where current codes and standards will gain the force of federal regulation. Codes and standards of the American Society of Mechanical Engineers (ASME), the American National Standards Institute (ANSI), the American Society for Testing and Materials (ASTM), the National Fire Protection Association (NFPA), the American Petroleum Institute (API), and the American Institute of Chemical Engineers (AlChE) are typical of those required by the proposed standard where they are applicable to the process.
For instance, the proposed OSHA standard will require, by federal regulation, that all unfired pressure vessels in a plant be designed, constructed, operated, and maintained in accordance with Section VIII of the ASME boiler and pleasure vessel code for unfired pressure vessels. Most hydrocarbon process plants already adhere to that code because of state law or insurance requirements.
Other examples are the ANSI B 31.3 standard for process piping and Section 500 of the NFPA code covering electrical equipment in areas classified as hazardous. These are already compared with by most hydrocarbon-processing facilities in the U.S. Where codes and standards are not applicable, or where no code or standard exists for a particular piece of equipment or operation, recognized and generally accepted engineering practices are allowed by the proposed standard.
And where existing equipment is designed and constructed in accordance with codes, standards, or practices that are no longer in general use, the employer must determine and document that the equipment is designed, maintained, inspected, tested, and operated in such a way that safe operation is assured.
PROCESS HAZARD ANALYSES
OSHA proposes that a process hazard analysis (Paragraph (e) of the standard) be conducted on all processes covered by the proposed standard.
The analyses can utilize one or more of the procedures listed in Table 3.
Process hazard analyses have become part of the operations of many U.S. hydrocarbon-processing plants in recent years. The proposed standard will make it mandatory for all plants to conduct hazard analyses.
The proposed standard does not specify a period of time by which the initial process hazard analysis must be completed. OSHA has received several suggestions with respect to an appropriate time period, but is seeking more information and comments before issuing a final ruling.
The hazard analysis must be performed by a team with expertise in engineering and process operations. The team must include at least one employee who has experience and knowledge specific to the process being analyzed. OSHA emphasized the requirement for a team because it states that a team approach permits varied technical points of view that lead to more thorough evaluation of possible hazardous scenarios.
The employer must also establish a system to promptly address the team's findings arid recommendations document actions taken; communicate them to operating, maintenance, and other employees whose work assignments are in the facility and who are affected by the recommendations or actions; arid assure that the recommendations are implemented in a timely manner.
The process hazard analysis must be updated and revalidated at least every 5 years. Employers must retain the two most recent analyses and/or updates for each process, as well as actions documented.
OPERATING PROCEDURES
Plants will be required by the proposed standard to develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each process consistent with the process safety information documented for the process (Paragraph (f) of the standard). Although most U.S. hydrocarbon-processing plants currently have these procedures, the proposed standard increases the depth, detail, and structure of the information required.
Written instructions must cover all phases of process operation such as:
- Initial start-up
- Normal operation
- Temporary operations as the need arises
- Emergency operations, including emergency shutdowns and those responsible for initiating the shutdowns
- Normal shutdown
- Start-up following a turnaround, or after an emergency shutdown. Consequences must be documented for operations that deviate from operating limits, and steps required to correct or avoid deviation must be provided. Operating limits must also be detailed for safety systems and their functions.
Process operating procedures must also address safety and health considerations with respect to the materials being processed, including the precautions required to prevent exposure. Information must be provided on measures to be taken if physical contact or airborne exposure occurs.
Safety procedures must be developed for opening process equipment, such as breaking process lines, removing vessel access covers, etc. Quality control for raw materials and control of hazardous chemical inventories must be part of the documented procedures, including information on special or unique hazards.
Copies of the procedures must be readily available to employees operating or maintaining the process. Procedures must be reviewed periodically to reflect current operating conditions and changes to process chemicals, technology, and equipment.
TRAINING
Employee training, already done extensively throughout the U.S. hydrocarbon-processing industry, will require more documentation and more detailed structure by the proposed standard (Paragraph (g)). The standard requires that each employee currently working in a process, and each employee before being newly assigned to a process, be trained in an overview of the process and in the operating procedures for the process. Training must include emphasis on specific safety arid health hazards, procedures, and safe practices applicable to each employee's job tasks. Refresher and supplemental training must be conducted for each employee at least once per year to assure that the employee understands and adheres to the current operating procedures for the process.
Employers must certify that each employee has completed training and refresher training in accordance with the proposed standard. A certification record is required that contains the identity of the employee, the date of training, and the signature of the person doing the training.
Requirements for contract personnel doing work on the process appear to be somewhat less stringent. The plant where contract work is being done has to inform contractors doing work on or near a process of the known potential fire, explosion, or toxic release hazards related to the contractor's work arid the process. And the process plant must ensure that contract employees are trained in the work practices necessary to safely perform their jobs.
Contractors must be informed of any applicable safety rules at the facility, and any applicable provisions of the emergency action plan required by the proposed standard. Contractor companies must assure that each of their employees follows all applicable work practices and safety rules of the facility.
PRESTART-UP SAFETY REVIEW
All new facilities, and any facilities that have been modified to the extent that the modification changes process safety information, must undergo a prestart-up safety review (Paragraph (i)). Most U.S. hydrocarbon-processing plants currently do this, but the proposed standard will make the review mandatory, and the standard specifies what the review must include.
Before hazardous materials can be introduced into new process facilities, the safety review must confirm that: construction is in accordance with design specifications; safety, operating, maintenance, and emergency procedures are in place and adequate; process hazard analysis recommendations have been addressed and actions necessary for start-up have been completed; and that operating procedures are in Place and training of each operating employee has been completed.
MAINTENANCE PROCEDURES
Process plants will have to pay close attention to maintenance of equipment and processes because OSHA's proposed standard mandates specific maintenance procedures necessary to maintain equipment integrity (Paragraph (j)).
Maintenance of process equipment has always been an important activity in hydrocarbon processing plants. But because maintenance will be governed by federal regulation as a result of the proposed standard, plant operators may have to step up the frequency and level of process maintenance.
Process equipment that will be subject to the standard's maintenance provisions are: pressure vessels and storage tanks, piping systems (including piping components, such as valves), relief and vent systems and devices, emergency shutdown systems, and controls (including monitoring devices and sensors), alarms, and interlocks.
Written procedures must be established and implemented to maintain on-going integrity of the process equipment. And each employee involved in maintaining the integrity of the equipment must be trained in the procedures applicable to the employee's job tasks.
Inspection and test procedures must follow applicable codes and standards, such as ASME, AlChE, API, ANSI, ASTM, and NFPA. Where no code or standard applies, recognized and generally accepted engineering practices must be followed. Equipment found to be deficient or outside of acceptable limits will have to be corrected before the equipment can continue to be used.
Frequency of testing is to be in accordance with applicable codes, or more frequently where prior operating experience dictates. Each inspection or test must have a certification record showing that each inspection and test was performed in accordance with the proposed standard.
Certification must identify the date of inspection and test, the name of the person conducting the inspection and test, and the serial number or other identifier of the equipment. The proposed standard also requires that equipment be checked for proper installation, proper design specifications, and that spare parts are in accordance with design specifications.
HOT WORK PERMITS
Hot work permits (permits to allow cutting, welding, grinding, etc. where hazardous materials may be present) that certify that fire prevention and protection requirements of 29 CFR Part 1910.252 (a) have been implemented, must be issued for all hot work. Exceptions are where an employer or employer's representative, designated as responsible for authorizing hot-work operations, is present while the hot work is being performed, and in welding shops authorized by the employer.
The permit must indicate the date(s) authorized for the hot work, and it must identify the equipment or facility on which hot work is to be done. It must be kept on file until completion of the hot work.
CHANGES IN FACILITIES
The proposed standard requires written procedures to cover changes (except for replacements in kind) in process chemicals, technology, and equipment, and changes in facilities (Paragraph (1)). The technical basis for the change, the affect of the change on safety and health, the modifications to operating procedures, the necessary time period for the changes, and the authorization requirements for proposed changes all must be addressed.
INCIDENT INVESTIGATIONS
In order to gain trend information that might avoid serious accidents, or at least mitigate the consequences of an accident, OSHA's proposed standard will require investigation of every incident which results in, or could reasonably have resulted in, a major accident in the workplace (Paragraph (m)). Appendix E of the proposed standard gives guidelines for conducting incident investigations. (Appendix E is not a mandatory part of the standard.)
The proposed standard calls for a team investigation as soon as possible after, but no later than 48 hr following, the incident. The investigation team is to consist of persons knowledgeable in the process involved in the incident, and other specialties as necessary.
A report must be prepared at the conclusion of the investigation that includes the date of the incident, the date the investigation began, a description of the incident, the factors that contributed to the incident, and any recommendations resulting from the investigation. Reports must be kept on file for 5 years.
All operating, maintenance, and other personnel whose work assignments are within the facility where the incident occurred, must review the report. And a system to promptly address the report findings and recommendations, and to implement report recommendations, must be established.
EMERGENCY PLANNING AND SAFETY AUDITS
An emergency action plan must be established and implemented in accordance with the provisions of 29 CFR Part 1910.38(a). Also, 29 CFR Part 1910.120(a), (p), and (q) may be applicable. Most hydrocarbon-processing plants already meet this requirement.
Safety audits are to be conducted at least every 3 years. The audits must certify that processors are complying with provisions of the proposed standards. Audits are to be conducted by a team that consists of at least one person knowledgeable in the process. A report of the findings of the audit is required.
It is necessary for the employer to promptly determine and document an appropriate response to each of the findings of the audit, and to certify that deficiencies have been corrected. The two most recent audits, along with documented actions taken as a result of the audit, must be retained.
Most U.S. refineries, petrochemical, and gas processing plants should already be close to compliance with the proposed standard. But as with any new federal regulations, the proposed OSHA standard will require substantially more documentation and more structured procedures for most facilities.
Suppliers to the U.S. hydrocarbon processing industry will also have to provide clear, written procedures governing the installation, start-up, operation, and maintenance of process technology, chemicals, and equipment. The proposed OSHA standard will, no doubt, become part of all engineering specifications for equipment, processes, and chemicals.
Copyright 1990 Oil & Gas Journal. All Rights Reserved.