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mikemccue.gif (8327 bytes) Mike McCue: The Process Safety Advisor
Tools to help prevent a catastrophic incident
Mike McCue is a consultant specializing in chemical process safety, plant security and environmental compliance management.  He is experienced in a variety of industries including pharmaceutical, chemical and oil refining, specialty chemicals, ammonia refrigeration, and chlorine water/wastewater treatment.  His clients have included Johnson & Johnson, Merck, Amerada Hess, Sunoco and FMC Corporation.  He has experience in governmental and regulatory affairs at both the state and federal level.  He holds a B.S. and M.S. in Chemical Engineering, a M.B.A. and a law degree.  You can reach Mike at mike.mccue@mec-ehs.com, Phone: (609) 758-6535, Fax: (609) 758-3180, or visit him on the web at http://www.mec-ehs.com.

The ABCs of Process Safety and Risk Management

The past 30 years have seen the development and maturity of Process Safety Management (PSM) and Risk Management Program (RMP) requirements. The early driving force for these concepts
and the ensuing regulations were major chemical incidents at facilities throughout the world.

 

History of PSM/RMP milestones

  • Flixborough, England 1974
    • Cyclohexane vapor cloud explosion that resulted in 29 fatalities and $232 million in property damages. One of the major contributors was a deficient Management of Change procedure. United Kingdom initiated new regulations.

  • Seveso, Italy 1976
    • Major Dioxin release resulting in extensive on-site and offsite contamination with long term effects. The Seveso Directive was issued by European Economic Community in 1982.

  • Bhopal, India 1984
    • Major Methyl Isocyanate release resulting in over 3,000 fatalities, mostly off-site

  • Institute, West Virginia 1985
    • Alicarb oxime and methyl chloride release
    • Major evacuation of Kanawha valley

  • Pasadena, Texas 1989
    • Petrochemical explosion and fire
    • 23 fatalities
    • Incident related to contractor safety

  • Channelview, Texas 1990
    • Petrochemical explosion
    • 17 fatalities

 

Recent Incidents

  • Paterson, New Jersey 1998
    • Runaway reaction, which over pressurized a 2000-gallon chemical vessel and released flammable material that ignited
    • Nine employees were injured

  • Allentown, Pennsylvania 1999
    • Several hundred pounds of hydroxylamine explosively decomposed, most likely due to high concentration and temperature
    • Five fatalities and two moderate-to-serious injuries.

  • Rosharon, Texas 2003
    • Vapor cloud fire explosion
    • Three fatalities with four other workers surviving with serious burns.

Traditional approaches to managing risk include: codes and standards, insurance carrier inspections, safety checklists/inspections and P&ID reviews. Over thirty years ago there were little organized approaches to managing safety. Processes were designed with the goal of decreasing the likelihood of accidents with increasing consequences. Higher consequence accidents are less frequent, however the possibility of observing these accidents increases with plant population and operating time. The impact of off-site consequences also increases with time and changes in surrounding demographics.

 

Based on events described earlier, process safety has evolved into regulated programs and an industry culture. Process safety is the management of facilities that handle, use, process or store extremely hazardous materials to minimize the likelihood and consequence of catastrophic incidents. Process safety is a dynamic program involving technology, materials, equipment and personnel at a facility intended to manage risk. This risk can not be eliminated, just controlled.

 

History of Regulatory Activity

  • Federal level
    • USEPA, Chemical Preparedness Program, 1985
    • Superfund Amendments and Reauthorization Act (SARA), 1986 – Title III (Emergency Planning and Community Right-to-Know)
    • Clean Air Act Amendments, 1990
      • OSHA’s PSM Regulation – Aimed at Worker Safety
        • Effective May 26, 1992
      • USEPA’s RMP Regulation – Aimed at Community Safety
        • Effective June 20, 1996

 

  • State Level
    • New Jersey, Toxic Catastrophe Prevention Act (TCPA), 1986
    • California, Risk Management and Prevention Program Regulations (RMPP), 1988
    • Delaware, Extremely Hazardous Substances Risk Management Act, 1989
    • Nevada, Chemical Catastrophes Prevention Act, 1991

 

Industry Activity

  • American Institute of Chemical Engineers (AIChE)
    • Center for Chemical Process Safety (CCPS), 1985

 

  • Chemical Manufacturers Association (CMA)
    • Community Awareness and Emergency Response Program (CAER), 1986
    • Model Program: Code of Management Practices, 1989

 

  • American Petroleum Institute (API)
    • Recommended Practice 750 (Management of Process Hazards), January 1990

PSM/RMP are management programs that are organized into subject elements. The subject elements include:

1)    Employee Participation – Documented employee involvement in PSM/RMP

 

2)    Process Safety Information – Hazards of the chemical, technology of process and equipment in the covered process

 

3)    Hazard Review (RMP only) – Offsite consequence analysis of worst case and alternate case release scenario,

 

4)    Process Hazard Analysis  - Thorough, organized, systematic approach to identifying, evaluating and controlling the hazards of covered processes

 

5)    Operating Procedures – Written instructions for safely conducting activities involved in the covered process

 

6)    Training – Employees, involved in a covered process, trained in an overview of process and the operating procedures

 

7)    Contractors – Management of contractors and contractor employees

 

8)    Pre-Startup Safety Review – Review prior to startup of new or significantly modified facilities

 

9)    Mechanical Integrity – Maintain critical process equipment to ensure proper design and that the equipment operates properly

 

10) Hot Work Permit – Requirements during hot work operations on or near a covered process

 

11) Management of Change – Manage changes (except “replacement-in-kind”) to process chemicals, technology, procedures and equipment

 

12) Incident Investigation – Investigation and documentation of incidents

 

13) Emergency Planning and Response – Written emergency action plan including provisions for training and drills

 

14) Compliance Audits – Documented periodic evaluation of compliance with program requirements

 

15) Management System (RMP only) – Administration of implementation of the RMP elements

 

Future installments will concentrate on each of these elements.

 

By: Mike McCue, Process Safety Columnist for Cheresources.com

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