Chapter #6 Process Safety

SENG 321 & 670

Fall 2013
Dr. R.A. Mentzer
Mary Kay OConnor Process Safety Center
Chemical Engineering Department, Texas A&M University

Four still hospitalized after East Rutherford ink factory

explosion
WEDNESDAY OCTOBER 10, 2012, 5:06 PM

BY MICHAEL COPLEY
STAFF WRITER
THE RECORD
PAGES: 12> DISPLAY

ON ONE PAGE | PRINT | E-MAIL

EAST RUTHERFORD Seven plant workers were injured when a carbon compound
used to make black newspaper ink ignited a little after 1:15 p.m., causing an explosion
and a fire in ductwork at the plant. Borough Fire Chief Kevin Felten initially said the
injured workers sustained non-life-threatening first- or second-degree burns.
On Wednesday, Lynn Campbell, a spokeswoman for Sun Chemical, which owns US Ink,
said three employees are still hospitalized in the burn unit at St. Barnabas Medical
Center in Livingston, and that one other, being treated at Hackensack University
Medical Center, are in fair condition. Two injured workers were released from
Hackensack by the end of the day Tuesday and one was released Wednesday
afternoon.
The explosion and fire, which the company in a
statement said likely occurred in the plants pre-mix
room, were completely contained inside the plant
building itself. There was no danger to anyone offsite,
nor any external contamination or environmental
impact as a result.
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Questions Addressed
What significant domestic & international
incidents led to the creation of Process Safety
regulations?
What are OSHAs PSM & EPAs RMP requirements?
How does the intent of OSHA PSM differ from
EPAs RMP?
What steps might international cos. take to
ensure consistent process safety implementation
world-wide?
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Bhopal & Other Incidents Led to

Process Safety Regulations
While the 1984 Bhopal disaster had a major impact on
the field of process safety world-wide, other incidents
contributed as well:
Flixborough, England, 1974, explosion
Phillips Petroleum Plant explosion, 1989, 24 killed
and 128 injured
Piper Alpha North Sea disaster, 1989, fire &
explosion,167 killed
Additional / renewed focus on process safety following
2005 BP Texas City refinery incident, with 15 fatalities
and 180 injuries
Marsh Energy Losses Database (consultant) has 8,000
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entries from 1972 2009

Process Safety Regulations

Such major world-wide incidents in
the 1980s resulted in:
European Seveso Directive, Europe,
1982
COMAH (UKs HSE), 1984
Chemical Manufacturers Association
(CMA) Responsible Care, 1988
OSHA PSM Rule (1910.119), 1992
EPA Risk Management Plan, 1996
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Process Safety
is not only for chemical plants and
petroleum refineries.
It applies to any plant which processes or
stores a dangerous chemical in excess of a
threshold amount, for example:
- poultry processing plant employing chlorine
for refrigeration, or
- manufacturing plant (employing dangerous
acids)
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I - OSHA PROCESS SAFETY MANAGEMENT STANDARD

(PSM)
Process Safety Mgmt of Highly Hazardous Chemicals (PSM), 1992
- general requirements for managing hazardous substances; with
focus to protect on-site people
14 elements to manage chemicals, prevent major incidents, and protect
the safety of the workplace

Employee Participation
Process Hazard Analysis
Training
Pre-startup Safety Review
Hot Work Permit
Incident Investigation*
Compliance Audit
discussed in future lecture

Process Safety
Information
Operating Procedures
Contractors
Mechanical Integrity
Management of Change
Emergency Planning*
Trade Secrets

1 - Process Safety Information

The highly hazardous chemicals to be used or produced by the

process. References, in addition to MSDSs:
- Irving Sax, Dangerous Properties of Industrial Materials; Robert E.
Lenga, Sigma-Aldrich Library of Chemical Safety Data; Gessner G.
Hawley, The Condensed Chemical Dictionary; NIOSH Registry of
Toxic Effects of Chemical Substances

The technology of the process

- process flow diagrams (PFD); see page 135 of text
- process chemistry data, maximum intended inventory, and safe
upper and lower limits for temperatures, pressures, flowrates, or
compositions

The equipment to be used in the process

- materials of construction, piping and instrumentation diagrams
- safety features, such as relief system design, ventilation, safety
systems like interlocks, detection, and suppression systems
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Case Study 6.1: Hazardous Chemical

Information for Process Safety Analysis
Name of
Chemical
Toxicity info.

PEL
Physical data
Reactivity data
and so on

Phosphorus chloride (PCl3), phosphorus trichloride

Poison by inhalation. Moderately toxic by ingestion. A
corrosive irritant to skin, eyes (at 2 ppm), and
mucous membranes
Lethal dose (for 50% of population): Rats (oral) 550
mg/kg
Lethal concentrations for inhalation (for 50% of
population): Rats: 104 ppm for 4 hrs
Guinea pigs: 50 ppm for 4 hrs

OSHA PEL: 8-hr time-weighted average (TWA): 0.5ppm

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2 - Process Hazards
Analysis
What can go wrong in the process? How to deal with
these hazards?
Methods:
- what-if analysis and what-if checklists
- fault tree analysis (FTA) or failure modes and effects
analysis (FMEA)
- hazard and operability studies (HAZOP)
- learnings from past incidents
Use inherently safer design and engineering controls
Documentation of significant hazards must include
follow-up to closure, otherwise a safety issue & liability
Hazards analysis must be updated every 5 years
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3 - Operating Procedures
Process info.

Process analysis

E.G., initial startup, normal

operations, normal shutdown,
Operating procedures
emergency operations &
shutdown, etc

Important that operators be trained in breath of Operating

Procedures
Written Operating Procedures need to be specific to the
person or persons (positions) for each of the facility's
operating areas

The capability to recognize when something has gone wrong

- a process needs to have preset limits for the variables under
control
- for example, a centrifugal pump on a pipeline
1) a minimum suction pressure at inlet
2) maximum discharge pressure

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4 Training & Certification

Four ingredients for an effective training plan:
1. initial training for new operators or new processes
2. refresher training at prescribed intervals, and at
least every three years
3. verification or testing to prove that employees
understand the process and safe procedures; addl
training as needed
4. documentation to confirm that the training and
testing have been carried out

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5 - Contract Personnel
Companies frequently use outside contractors .
The OSHA process safety standard requires that primary
employers assess the safety record of prospective
contractor firms before contracting / using.
Responsibilities:
- primary employer
1) communicate process hazards information to
contractors
2) perform periodic evaluations
3) maintain an injury and illness log of contract employees
- contract employer
1) provide safe and healthful workplace, including training
2) assure employees follow prime employers safety rules
3) maintain incident log of employees
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5 - Contract Personnel
contd
Many
facets to this area:
ensuring consistency of employer & contractor safety metrics
who pays for training and how much is needed? How to ensure
competency?
is work site at contractors yard or employers property; dont
monitor former
Contractor safety statistics are generally worse than those for
employers employees. Why?
Are contractors given more hazardous work?
Are contractors more driven by schedule and costs, with less focus on
safety?
Safety culture of contractor may not match that of employer
Managing contractors can be challenging:
Foreign government may require use of a national contractor,
regardless of safety record
In international locations, will contractor have made arrangements for
medical support, as well as security for their personnel; generally
required per contract
Sr. Mgmt of Employer may need to meet with Sr. Mgmt of contractor to
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ensure alignment on safety expectations

6 - Mechanical Integrity
Establish and implement written procedures to maintain the
Mechanical Integrity of:
- Pressure Vessels and Storage Tanks
- Piping Systems
- Relief and Vent Systems
- Emergency Shutdown (ESD) Systems
- Controls, Alarms, and Interlocks
Includes:
corrosion program,
preventative maintenance program, schedule for inspections /
testing, process to correct deficiencies, and
process to ensure equipment & spare parts are being maintained.

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7 - Management of Change
Establish and Implement Written Management of
Change Procedures for changes in process chemistry,
equipment or operating procedures. MOC addresses:

Technical Basis (except for in-kind replacement)

Impact on Safety and Health
Modifications to Operating Procedures
Training and Pre-startup Review
Necessary Time Period for the Change
Authorization Requirements

Handling of personnel changes temporary & permanent?

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II - EPA, RMP Rule

Risk Management Program for Chemical Accident
Release Prevention (RMP), 1996
Focus to protect off-site people & environment
Reduce the risk of releases of toxic, flammable,
and reactive substances
List of 140 regulated chemicals with a threshold
amount of each to determine requirements at a
site
Requires hazard assessment & review of various
release scenarios, prevention program,
Emergency Response plan and on-site
documentation
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Implementation of RMP
1. Hazard assessment
- Five year accident history
- Worst case release scenario involving flammable or
toxic onsite materials; E.G., 10 minute release of
largest quantity of
regulated chemical
- Alternative release scenarios ... more likely to occur than
worst case
- Off-site consequence analysis; many aspects, dispersion
modeling, etc
2. Prevention program; requirements similar to OSHA PSM
3. Emergency response plan; similar to PSM
4. On-site documentation
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RMP & PSM Comparison

RMP: 11 elements
Regulates off-site
people &
environment
Risk Assessment:
release
consequences
Info to community
ERP: notification of
community,
responders

PSM: 14
comprehensive
elements
Regulates workplace
Employee
participation
Contractors
addressed
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Safety & Environmental Mgmt System

SEMS required for all US Offshore Continental Shelf
(OCS) operations by Nov, 2011
Similar elements as OSHA PSM
Focuses on process safety with some occupational
safety, and additional requirements added to
American Petroleum Institute (API) RP 75
Operators held responsible for overall safety of
facility, operation and contractors
Applies to all offshore drilling & operating phases
SEMS II addresses workplace authority (operator vs.
contractor), external auditors, etc
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Industrial Compliance with OSHA PSM

- ExxonMobils Operations Integrity Mgmt System (OIMS) for all
operations world-wide
- Many other companies have similar systems

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23

HW6a due Thurs, Oct 10

6.2
6.4
6.6
6.8
6.9
6.19
6.21 what system might one put in place to
manage information beyond the road map?
6.24

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