Process Safety-Related Regulations and Standard

After completing this topic, students should be able to: !! Brief understanding of safety regulations:
!! Malaysia Department of Occupational Safety and Health: !! OSH Act (Occupational Safety and Health Act 1994)
!! Control of Industrial Major Accident Hazards 1996 CIMAH 1996

!! International: !! US OSHA - Process Safety Management (PSM) !! UK HSE - CIMAH, COMAH

!! Relate the standards and regulations requirements with the application of process safety fundamental to prevent losses

Many lives are lost annually due to occupational accidents !! Economic losses to families, society and the nation !! Employers loss of trained/skilled employees !! High compensation
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Statistic
Hazardous substances kill 438,000 workers annually. !! 10% of all skin cancers are attributable to workplace exposure to hazardous substances. !! 20% of all adult asthma is be attributable to workplace exposure to hazardous substances.
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Source : ILO

Occupational Death in Malaysia

Source: SOCSO, 2009

Accident Rate

Source : SOCSO,2009

Frequency of Reported Accident 2002-2008

Source : SOCSO,2009

The Rising Case for Change

1974 - Caprolactam Plant Explosion, Flixborough, UK

HAZARD: Poorly engineered temporary plant modifications Vapour cloud Vapour cloud of cyclohexane of cyclohexane "! Control building collapsed, killing 28 operators
"! Outcomes !Led to Advisory Committee on Major Hazards !HSE champions Safety Report concept !Led ultimately to CEC Seveso Directive / Safety Report Concept
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#! 1984

Bhopal, India Toxic Material Released

!! 2,500 immediate fatalities; 20,000+ total !! Many other offsite injuries

HAZARD: Highly Toxic Methyl Isocyanate

The Rising Case for Change

1989 - Plastics Manufacture Plant, Pasadena, Texas Fire following vapour cloud explosion

"! Poor Maintenance procedures, Contractor control and Management of change "! 23 Fatalities 132 Injured US$1,400 Million Damage "! Outcomes !US OSHA PSM regulations !CCPS established

HAZARD: Flammable ethylene/isobutane vapors in a 10 line

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Closer to Home Bright Sparkles (1991)

OSHAct 1994 - Regulations

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Control of Industrial Major Accident Hazard Regulations 1996 Safety and Health Committee Regulations 1996 Safety and Health Officer Regulations 1997 Classification, Packaging and Labelling of Hazardous Chemicals Regulations 1997 USECHH Regulations 2000 Safety and Health Officer Orders 1997 Prohibition of Use of Substance Order 1999 Notification Of Accidents, Dangerous Occurrences, Occupational Poisoning and Occupational Diseases 2004 (NADOPOD)

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Effective date : 01-02-1996 Key points of the regulations: These regulations are applicable to: All industrial activities except (Reg. 2): !! A nuclear installation !! An installation under armed forces !! A vehicle or vessel transporting hazardous substances to and from the site of industrial activities !! An industrial activity involved or likely to be involved with a quantity of hazardous substance(s) which is/are equal or less than 10% of the threshold quantity of the hazardous substance(s) Under these regulations, the Manufacturer shall be obliged to (Reg. 5): !! Comply with the requirements of these regulations !! Take immediate action to rectify the situation which may affect the safety of persons or the environment

Control of Industrial Major Accident Hazards Regulations (CIMAH) 1996

Control of Industrial Major Accident Hazards Regulations (CIMAH) 1996

Control of Industrial Major Accident Hazards Regulations (CIMAH) 1996

CIMAH 1996
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The Manufacturer is also responsible for identifying any industrial activity and submitting to the Director-General the Notification forms within 3 months after commencement of these regulations for existing installation or installation under construction, and within 1 month before construction of new installation (Reg. 7.1). Upon notification, it is at the Director-Generals discretion to determine whether the installation submitted is a major hazard installation or not (Reg. 7.2). For installations identified as non-major hazards, the following actions are still required to demonstrate safe operation including appropriate documentation (Reg. 10): a) Identification of major accident hazards b) Prevention of major accidents or minimization of their consequences to persons and environment c) Provision of information, training and safety equipment to workers d) Preparation of up-to-date on-site emergency plan

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A written report on industrial activities is to be prepared and submitted by appointed (registered) Competent Person (CP) within 12 months after existing activity is determined as Major Hazard Installation, or within 3 months before commencement of the new activity (Reg. 13 & 14). Manufacturer to immediately notify the Director-General for any changes in the quantity of hazardous substance kept at site, or in the pipeline, or cessation of industrial activity, by resubmitting the Notification Forms (Reg. 8). Director-General can request for evidence to show that the manufacturer is applying risk assessment in their industrial activities (Reg. 10 & 11). Director-Generals approval is required before any further modification can be carried out, with a written report submitted by CP at least 3 months in advance (reg. 15). Reports are required to be reviewed every 3 years, and to be resubmitted not later than a month after expiry (Reg. 16).

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Competent Person is also responsible to maintain and keep an up-to-date emergency response plan, which must be constantly updated; and people affected informed (Reg. 18). Manufacturer is responsible for informing local/port authority within 3 months of determination (Reg. 21): !! of activity capable of producing a major accident hazard !! of the need for the preparation of emergency response plan Information to the public should be given voluntarily via the local authority and within 6 months of being determined as a major hazard installation (Reg. 22). Nearest DOSH office should be immediately notified should a major accident occur. Details of the accident report to include remedial actions (Reg. 23).

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Objective: prevent unwanted releases of hazardous chemicals especially into locations that could expose employees and others to serious hazards Makes employers responsible for providing safe and healthy working conditions for employees Highlights of OSHAs enforcement rights:
!! Employers must admit OSHA compliance officers into their plant sites for safety inspections with no advanced notice. A search warrant may be required to show probable cause !! OSHAs right of inspection includes safety and health records !! Criminal penalties can be invoked !! OSHA officers finding conditions of imminent danger may request plant shutdowns

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Aim: to improve effectiveness of CIMAH Main changes from CIMAH:

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Changes implemented in COMAH:

!! CIMAH emphasized technical safety but management error is responsible for 90% of major accidents !! COMAH emphasizes management errors !! Major Accident Prevention Plan (MAPP) introduced in COMAH must include:
!! aims of processing activities !! principles of hazard control !! description safety management systems (SMS)

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Changes implemented in COMAH (continued):

!! Safety reports emphasized:
!! Must fully address potential hazards !! Must be submitted to competent authority (i.e., HSE in UK) !! Management and organizational issues must be considered

!! Site and installation: provisions apply to whole site as well as individual installations (plants) !! Domino effects: effects of an incident on surrounding plants must be considered !! Emergency plans must be included

The accident pyramid

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Accident and Loss Statistics

"! OSHA incidence rate is based on cases per 100 workers years. "! A worker year is assumed to contain 2000 hours (50 work weeks x 40 hours/week) $! The OSHA incidence rate is based on 200,000 hours exposure to a hazard OSHA incidence rate (based on injuries and illness) = Number of injuries and illnesses x 200000 Total hours worked by all employees during period covered.

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Accident and Loss Statistics

OSHA incidence rate (based on lost workdays) =

Number of Lost workdays x 200,000 Total hours worked by all employees during period covered.

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!"#$%&'() (
Use your OSHA incidence rate to compare your company's safety performance with state and national averages and other business in your industry. Number of reportable injuries/illnesses: 5 Total number of hours worked by all employees: 50

Incident Rate Per Year: 20,000

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http://www.hse.gov.uk/comah/index.htm !! http://www.osha.gov/ !! http://yosemite.epa.gov/oswer/ Ceppoweb.nsf/content/RMPoverview.htm !! www.hse.gov.uk/research/rrpdf/rr343.pdf !! http://dosh.mohr.gov.my/koperat/LAW/ Occupational Safety and Health Act 1994 (Act514)/a0514.pdf
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