PSM Final

What types of equipment are included in the PSM mechanical integrity requirement?

- Pressure vessels and storage tanks, piping systems, relief and vent systems and devices, emergency shutdown systems, controls, and pumps.

Contrast and compare a block flow diagram with a process flow diagram.

- Process Flow Diagram: More complex, and shows the exact steps throughout a process - Block Flow Diagram: Simple, and shows the major steps and events of a process

What is a PHA

- Process Hazard Analysis - A PHA is an organized and systematic effort to identify and analyze the significance of potential hazards associated with the processing or handling of highly hazardous chemicals

What is the purpose for having operating procedures?

- Provide clear instructions for safely conducting activities involved in each covered process

The FTA has four major advantages over other forms of system analysis. What are they?

- Provides both qualitative and quantitative analysis - Graphic representation of how a system works - Pinpoints where the failure occurred - Provides objective information for decision making

_______________ addresses construction and maintenance of process safety equipment. It ensures that process equipment is fabricated in accordance with design specifications, assembled and installed properly, and maintained at its original level of integrity.

- Quality Assurance

The goal of the hazard control function is the _____________________, but sometimes, the control function takes the form of ________________ to an acceptable level.

- Reduce the severity - Risk

It is important to analyze the problems and assess training needs before making decisions about solutions. Job aids may be all that is required or, may be needed to supplement the training materials. List three examples of job aids

- Reference Manual - Trouble-Shoot Guides - Monitoring

What are the five primary activities involved in conducting a Preliminary Hazard Analysis?

- Review safety experience - Categorize known hazards - Investigation of hazards to determine provision for control - Identify safety regulations and requirements for personnel safety - Recommendations for corrective actions

Paragraph (m) (6) of the PSM standard requires that the accident report be retained for ____ years.

- 5

Understand the EPA's definition of a Worst-case Release Scenario and what is meant by both active and passive mitigation systems and which are applicable to the worst-case release scenario.

- "Worst Case Release Scenario"- The instantaneous loss of all the regulated substance in a process, with the failure of all mitigation systems.

Where in the CFR can you find OSHA's PSM Standard?

- 29 CFR 1910.119

The EPA proposed that, within _______ of the date of publication of the final rule, all facilities register with EPA if they have regulated substances in a quantity that exceeds the threshold quantity. (Amount of time)

- 3 years

The PSM standard requires the employer to initiate the accident/incident investigation within ____ hours of the accident/incident occurring.

- 48

The off-site consequence analyses for the EPA's RMP must be updated every ________ with the RMP update, or sooner if changes at the facility or its surroundings might be expected to make the results inaccurate i.e., a substantial increase or decrease in the quantity of a regulated substance or major changes in housing or land use patterns.

- 5 years

For explosive substances the threshold quantity established by the EPA is _____________.

- 5,000lbs

Define: Catastrophic Release

- A major uncontrolled emission, fire, or explosion, involving one or more highly hazardous chemicals, that presents serious danger to employees in the workplace

What is a Hazard and Operability Study (a.k.a. Operating and Support Hazard Analysis)

- A systematic method for investigating each element at a system for which the ways are deviated from the design, assuming the design is correct

Consider the statement, "If a change to the process results in a change in the required process safety information, then ........" Now, what are the actions that would be required relative to the PSM program information?

- A written program, train employees, and documentation of completed training

How often must the employer certify that operating procedures are current and accurate.

- Annually

How often must the PHA be updated and revalidated?

- At least every 5 years

Why is a team approach considered to be the best approach to use when conducting the process hazard analysis?

- Because no one single person possesses all of the knowledge and expertise to perform a PHA effectively

The employer must ensure that any maintenance materials, spare parts, and equipment are suitable for the process application for which they will be used. You can think in terms of the fact that all replacement/modification materials must be _______ the same as the original parts.

- Better than or

One measure of the degree of a hazard is its severity. The magnitude of harm starts with a description of the immediate ___________________of the accident. The second step in describing the magnitude of accident severity is a description of the _________. The third and final step in describing the magnitude of severity is the _________ of the accident.

- Consequence - Loss - Cost

The hazard control function will manifest itself in only two fundamental ways. What are they?

- Degree of Exposure - Degree of Severity

Using the elements of practice and repetition, this method of instruction is valuable for developing worker skill in fundamental tasks and for performing under pressure. Workers required to perform in crisis situations should be trained under conditions that resemble the crisis as closely as possible. The trainer/employer should therefore consider using the ____________ method of training.

- Drill method

Know how legitimate confidential business information is treated under CAA section 114(c) when developing a RMPs.

- EPA believes that the RMP's should not include info that facilities can legitimately claim as confidential business information.

What type of accident does the PSM standard require you to investigate?

- Each incident that resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical in the workplace

Once an operating procedure is firmly established and personnel are trained so that procedure and field practice are consistent, no change in technology, facilities or procedures should be permitted. What is the exception to this, and what are three things that need to be done if operating procedures are to be changed?

- Employees affected by change must be notified and trained prior to start-up - If change in Process Safety Information, it must be updated accordingly - If changes in Operating Procedures, it must be updated accordingly

What does the abbreviation ECP stand for and briefly describe what it is

- Engineering Change Proposal: Management tool to purpose a configuration change

How often does the PSM standard require compliance auditing?

- Every 3 years

How often is Refresher Training required?

- Every 3 years

Where do the hazards delineated in a Preliminary Hazard Analysis come from?

- Experience and knowledge of a safety professional

The PSM standard refers to secondary lines of defense. What are some examples of secondary lines of defense?

- Fixed fire protection systems like sprinklers, water spray or deluge systems, monitor guns, dikes, designed drainage systems, and other systems which would control or mitigate hazardous chemicals once an unwanted release occurs.

When should an employer consider using the "What-If " method for a process hazard analysis?

- For uncomplicated processes to evaluate the effects of component failure

In order to fully understand the safety and health hazards of the chemicals they work with, employees are to receive training that is conducted in compliance with

- HAZCOM 29 CFR 1910.1200

What are the two distinct areas that hazard analysis is concerned with?

- Identify Hazard - Understand Hazard

The employer must document that each employee involved in operating a process has received and understood the training required by the PSM standard. What three items does OSHA insist be included in this documentation?

- Identify employee - Date of training - Verify employee understood training

What are the four primary benefits of training?

- Improved performance - Fewer incidents - Reduced costs - Reinforcement of operational goals

Employers are required to compile written process safety information before conducting mandatory Process Hazard Analyses. The compilation of data is necessary so that they can first identify and then understand the hazards. What are the three main categories of information that are required?

- Information on the hazards of the highly hazardous chemicals used or produced by the process - Information on the technology of the process - Information on the equipment in the process

List five items that should be included in a set of operating procedures

- Initial start-up - Normal operations - Normal shut-down - Emergency shut-down - Precautions necessary to prevent exposure

What is the purpose of the Preliminary Hazard Analysis?

- It effectively evaluates and controls hazards associated with the process facility

What is the preferred source for obtaining the information necessary to determine the hazards of the chemicals used in a process?

- MSDS (Material Safety Data Sheet)

When evaluating the reliability of a particular system or piece of equipment, engineers often refer to the operational time between failures as the ________ both are sometimes represented with the Greek character ________.

- MTBF or Mean Time Between Failure - λ

Inspection and testing must be performed on process equipment, using procedures that follow recognized and generally accepted good engineering practices. The frequency of inspections and tests of process equipment must conform to ________ and good ___________.

- Manufactures' Recommendations - Engineering Practices

When did the list of substances and threshold quantities for the EPA's RMP become effective?

- March 2nd 1994

With regards to the EPA's concerns, what is meant by a "primary line of defense"?

- Means to prevent unwanted releases.

Assurance of __________ provides the opportunity to improve the reliability of emergency control and process equipment.

- Mechanical Integrity

Computer-Assisted Training allows the workers to receive information by reading or watching a video presentation and then respond to situations and questions. List four reasons (advantages) that computer assisted training has over other methods and for each item, list at least one requirement of the regulation that it can help an employer fulfill.

- Name and date on computer - Training program on computer - Electronic signature - Correct answer before moving to next question

What would the EPA call a mishap that did not result in a release because of employee actions or luck?

- Near miss

Are employers forbidden by OSHA to hire contractors whose safety records are less than perfect?

- No

Once an employer begins the process safety analysis task, must they use the same analysis methodologies throughout the entire task?

- No, they can use different methods to maximize their results

With regards to 40 CFR, do maintenance employees need to be trained in process operating procedures to the same extent as those employees who are actually involved in operating the process?

- Not to the same extent, but to where they are knowledgeable enough to understand the dangers of the hazard present.

What is OSHA's position relative to the type of analysis employers must use to complete the process safety hazard analysis?

- OSHA recommends PHA to be performed by a team with expertise in engineering, and process operations

The training that employees receive relative to the hazards of the chemicals used in the process is only part of the training that the PSM standard requires. What are three other areas where training is mandatory?

- Operating process - Emergency evacuation and response - Safe work practice

What are the recognized types of accident investigation and analysis discussed in the text and in class?

- Operators mistake poor training, inappropriate SOP's, poor design of control systems, equipment failures from improper maintenance, misuse of equipment.

Consider the Preliminary Hazard Analysis and the HAZOP, how are they different and how does this affect the application of their use?

- PHA: Useful in prioritizing - HAZOP: Involves each element of a system for any different parameters

What method did OSHA specify for employers to use to ensure that the employees understood the training they were given?

- Performance Based Training

What are the civil penalties associated with violation of the EPA's Part 68 of 40 CFR?

- Persons in violation of the requirements may be subject to civil penalties of not more than $25k per day per violation as well as criminal penalties.

A hazard may be defined as ____________, while risk is _______________.

- Potential harm - The probability and severity

The __________ confirms that the equipment is in accordance with design specifications, appropriate procedures are in place, and necessary training has been given.

- Pre-Startup Safety Review

A _________ must be conducted for new facilities, restart of suspended operations, and extensive modifications that required shutdown of existing facilities, modification and restart.

- Pre-startup Safety Review

A variation OJT is known as job instruction training (JIT) also referred to as the four-point method. What are the four points in JIT?

- Preparation - Presentation - Performance - Follow-up

What is the advantage of using a FEMA?

- Prepared plan for Emergency Management and response - Potential loss is reduced - Fast operation recovery

What are four things that a process owner intent on hiring a contractor with a less-than-perfect safety record, should do to help prevent safety problems on the job?

- Safety orientation - Promote safety requirements in contract - Pre-Award - Punishment and permits regulated

List three sources of objective information that employers can use to evaluate the safety performance of outside contractors.

- Safety program - EMR - OSHA IR

What would the EPA call a release that occurred, but did not affect the public or the environment because of favorable weather conditions at the time of the release to be?

- Significant Accidental Release

A ____________ release is any accidental release of a regulated substance that has caused or has the potential to cause off-site consequences such as death, injury, or adverse effects to human health or the environment or to cause the public to seek shelter or be evacuated to avoid such consequences.

- Significant accidental

What are OSHA's primary concerns for requiring an accident investigation to begin within the 48 hour time frame?

- So events can be recounted as clearly as possible - To preserve crucial evidence - There is less likelihood that the scene could have been disturbed

Investigation of major PSM accidents concluded that most of the incidents were caused by one or more of four key factors. What are they?

- Technology - Human error - Management systems - External events

Understand the relationship between the Clean Air Act (CAA), the PSM Standard, and the RMP relative to facilities that have more than the threshold quantity of a regulated substance based on the final list promulgated by EPA.

- The CAA states that facilities covered by the risk management program regulations are those that have more than a threshold quantity of a regulated substance based on the final list promulgated by the EPA.

What are some of the sources you can use to obtain reliable and accurate information regarding inspection methodologies for process equipment?

- The National Board of Inspection Code, the American Society for Testing and Material, American Petroleum Institute, National Fire Protection Association, American National Standards Institute, and American Society of Mechanical Engineers.

How much detail is required, or how much information should one compile in preparation for conducting the process hazard analysis?

- The amount of information necessary to cover a process from production to disposal phase

Describe what is meant by "exposure" relative to hazard assessment and how it might affect the probability of occurrence for a given hazard.

- The amount, and number of times an employee is exposed to a certain hazard

If you are the contractor employer, do you still have to fill out the OSHA 300 log even though the host employer is required by OSHA to maintain a log on your employees? Please explain your answer

- The contract employer is required to log down incidents and illnesses if the contractor is supervising day to day operations. If supervision is by the host employer, they are responsible for recording the injury or illness.

With regards to obtaining information on the equipment used in the process, list three sources from which you could obtain reliable data.

- The manufacturer of the equipment - Operation manual of the equipment - An extensive literature review

A hazard possesses two properties - probability of occurrence and severity. Together, these two properties measure the magnitude of a hazard and provide the proper measure of its control priority. What is meant by the term "control priority" in the previous sentence?

- The priority control is meant to be used with the RAC (Risk Assessment Code) - The RAC gives the priority of which hazards need to be mitigated first

OJT is widely used because it allows the worker to produce during the training period. However, what are the three things the training manager must ensure?

- The trainer must be good at training - Allow for adequate training time - Consistent training program

Why are retail facilities exempt from 29 CFR 1910.119?

- They don't have enough of each chemical to present a critical risk

What is the purpose of including previous incidents when conducting the process hazard analysis?

- To make sure the JHA adequately shows a wide enough range of concerns

True or False: If either of the two properties of a hazard has no value, the hazard is intrinsically safe or is simply not a hazard.

- True

What are the characteristics of the team that is assembled to develop a written management of change program?

- Under the proposed rule, the owner or operator of a facility would be required to evaluate every exchange of equipment, processes, chemicals, or procedures to ensure that the technical basis of the change is documented and that the changes do not create new hazards.

When should an employer consider using the "Checklist" method for a process hazard analysis and when should they not use it?

- Use a checklist when it has been proven effective for the process - Do not use a checklist when the process is unknown or complicated

In addition to the worst-case release scenarios, EPA would require facilities to analyze other more likely significant accidental release scenarios for each process in which the regulated substance is used above the threshold quantity. In doing these analyses, what are the assumptions that can be made relative to passive mitigation systems and active mitigation systems?

- When examining these potential release scenarios, facilities would be allowed to assume that passive mitigation systems, such as contaminant dikes, functioned properly. Active mitigation systems, such as excessive flow valves, fail-safe systems, flares, deluge systems, and water curtains, would be assumed to fail.

When is it best to use FMEA?

- When studying an item of equipment to provide a methodical approach to failure modes

Under what circumstances would all of the provisions of the PSM standard apply to a contract employer?

- When the contract employees will be performing work on, or adjacent to processes covered by PSM standard

A ____________ release means the loss of all of the regulated substance from the process in an accidental release that leads to the worst off-site consequences.

- Worst-case

Are employers allowed to keep training records on computer if they so desire?

- Yes

Does the PSM standard mandate that the employer document the resolutions and corrective actions that result from the required accident investigations?

- Yes

The PHA is dependent on good judgment and the assumptions made during the study need to be documented and understood by the team and reviewer and kept for a future PHA. What advantage would you have by documenting and retaining files that included the team's assumptions?

- You would only have to change the PHA for what has changed since the last assessment

What types of items are covered under the management of change requirements in the PSM standard?

1. The technical basis for the proposed change 2. Impact of change on safety and health 3. Modifications to operating procedures 4. Necessary time period for the change 5. Authorization requirements for the proposed change.