Introduction - hdbk11010017

DOE-HDBK-1101-96

1.0 Introduction

1.1 Purpose

The purpose of this document is to assist U.S. Department of Energy (DOE) contractors who work

with threshold quantities of highly hazardous chemicals (HHCs), flammable liquids or gases, or

explosives in successfully implementing the requirements of the Occupational Safety and Health

Administration (OSHA) OSHA Rule for Process Safety Management of Highly Hazardous

Chemicals (29 CFR 1910.119), hereafter referred to as the PSM Rule. Successful implementation

requires each contractor to study existing and required chemical process safety management (PSM)

systems to determine that a comprehensive program is in place.

Process safety management requires an ongoing effort to prevent catastrophic accidents involving

hazardous process materials and energies. It applies management principles and analytic techniques

to reduce risks to processes during the onsite manufacture, use, handling, storage, and movement of

chemicals. Its focus is on hazards related to the materials and energies present in chemical process

facilities.

The purpose of the PSM Rule is to prevent releases of HHCs (listed in Appendix A) that have the

potential to cause catastrophic fires, explosions, or toxic exposures. This objective is achieved by

first building safety into a process, and then keeping the facility operating safely throughout its life

cycle, by identifying process hazards and providing necessary controls over the life of the process

[Q36, Q47]. PSM integrates 14 elements to manage facilities, technology, and personnel, as

summarized in Table 1.1. The elements of the PSM system are employee participation, process

safety information (PSI), process hazard analysis (PrHA), operating procedures, training,

subcontractor safety, pre-startup safety review, mechanical integrity, nonroutine work authoriza-

tions, management of change (MOC), incident investigation, emergency management, compliance

audits and trade secrets.

Other DOE Orders and OSHA rules address general industrial hazards, industrial hygiene, and

radiation protection. Thus, PSM is just one program in a comprehensive safety management system.

Figure 1.1 shows how PSM and other OSHA chemical safety programs apply to the accident

consequence continuum.

The following example shows how the PSM elements are integrated in actual practice. Pilot studies

indicate that higher yields can be obtained by maintaining higher temperatures in a reaction vessel.

A change in operating temperature must be approved by all technical and support functions (MOC).

The impact of this change is assessed though revision of the process hazard analysis (PrHA), which

results in a recommendation to modify the pressure relief system. The modifications in temperature

and pressure relief system mandate new steps for process operators (Operating Procedures), who

require training and verification in the new procedures (Training). The modifications to the pressure

relief system are made by the supplier (Contractor Safety) and require that a portion of the process

be shut down for this work. The work includes a brazing operation requiring a Hot Work Permit

(Nonroutine Work Authorization). Potential impacts on the process require a review of emergency

response plans (Emergency Planning). The new pressure relief system must be inspected and tested,