EHS Support developed a process safety and risk management program (PSM/RMP) for the Research & Development (R&D) sector of a major chemical producer in the United States. The client’s planned project involved the delivery, storage, handling, and processing of 35,000 pounds of a highly hazardous chemical (HHC) listed in Appendix A of the Occupational Health and Safety (OSHA) General Industry Standard 1910.119 for PSM.
Due to the nature of this project and the limited duration of the project, a plan was discussed to develop a PSM/RMP program suitable for the size and scope of the project. The elements developed for the project included the following:
- Development of an employee participation program
- Modification of an employee H&S training program
- Gathering and preparation of Process Safety Information (PSI) materials, including piping and instrumentation diagrams (P&IDs)
- Implementation of Process Hazard Analysis (PHA) utilizing HazOp and What-if methodologies
- Reclassification of electrical areas as needed
- Development of a Pre-Startup Safety Review (PSSR) procedure
- Production of standard operating procedures
- Amendment to the Emergency Action and Response program, including local emergency response notification and site visit response procedures, for handling HHC incidents
- Development of mechanical Integrity procedures for the duration of the project
- Modification of the Hot Work permitting program for the project
- Modification of the Management of Change (MOC) program
- Update of contractor safety procedures
- Establishment of Off-site Consequence Analysis including worst-case release scenarios (WRS) and alternate release scenarios (ARS)
Implementation of the PSM/RMP included the following: 1) a PHA of the project under construction was conducted with action items tracked to completion of the project and verified through the PSSR; 2) all PSI materials were collected, filed, and maintained; 3) P&IDs were verified and components properly labeled; 4) employees received training on PSM/RMP and related SOPs; and 5) contractors underwent training and were updated on emergency procedures in connection with the project. Any changes to the PSM/RMP and project were documented and verified through proper channels before actual implementation of the project.
In addition, EHS Support coordinated with emergency response agencies and filed the RMP with USEPA prior to receipt of the HHC. All documentation related to the project was filed and stored, including documentation related to decommissioning of the project.