logging in or signing up Sep 2004 Harry West Burnell Download Post to : URL : Related Presentations : Share Add to Flag Embed Email Send to Blogs and Networks Add to Channel Uploaded from authorPOINTLite Insert YouTube videos in PowerPont slides with aS Desktop Copy embed code: (To copy code, click on the text box) Embed: URL: Thumbnail: WordPress Embed Customize Embed The presentation is successfully added In Your Favorites. Views: 682 Category: Entertainment License: All Rights Reserved Like it (0) Dislike it (0) Added: November 08, 2007 This Presentation is Public Favorites: 0 Presentation Description No description available. Comments Posting comment... Premium member Presentation Transcript PROCESS SAFETY MANAGEMENT Recent Controversial Issues: PROCESS SAFETY MANAGEMENT Recent Controversial Issues Dr. Harry H. West, PE Mary Kay O’Connor Process Safety Center Chemical Engineering Department Texas A&M University College Station, Texas 77843-3122 hhwest@che.tamu.eduOSHA 1910.119 Process Safety Management: OSHA 1910.119 Process Safety Management Issues concerning Oil & Gas Production Jurisdiction among other regulatory agencies Oil & Gas Exemption Scope Unmanned Facilities Atmospheric Tank ExemptionRelationship of OSHA to Other Federal Agencies: Relationship of OSHA to Other Federal Agencies OSHA is precluded from regulating working conditions over which other federal agencies “exercise statutory authority to prescribe or enforce standards or regulations affecting occupational safety and health” Section 4-b-1 of OSH ActOil & Gas Pipelines: Oil & Gas Pipelines Pipeline companies under DOT OPS Contractors under OSHA What about pipelines under State jurisdiction?Oil & Gas Exemption: Oil & Gas Exemption 1910.119 section (a)(2)(ii) (a) "oil or gas well drilling or servicing operations" OSHA intended to develop a separate regulation. 1910.270 was announced in December 1983 (Wyoming OSHA) So what facilities are within OSHA PSM jurisdiction?Single Well Exemption: Single Well Exemption Letter of interpretation 26 August 1992 “ where flow from 2 or more wells come together” Retract letter in 2002 Where is boundary??"Non-heated Produced Fluids" : "Non-heated Produced Fluids" Same Letter of Interpretation 26 August 1992 PSM standard included those that are "processed by heating the fluids and physically separating the water...." ” Again … Retract letter in 2002 Where is boundary??Normally Unoccupied Remote Facilities" exemption : Normally Unoccupied Remote Facilities" exemption 1910.119(a)(2)(iii) Hours at site. Permanently stationed on site Various definitions over time Daily, for more than one second !! Less than 4 hours (1/2 ~ 8hour shift) Other time standards used Performance standard means you decide. Atmospheric Tank Exemption: Atmospheric Tank Exemption Covered by Flammable Liquids Code 1910.106 Issue: Connection to process Meer Decision; OSHRC #95-0341 Atmospheric tanks not counted in TQ Clarification of atmospheric tank exclusion taken off OSHA Regulatory agenda in 2001 Produced Water Tank Exemption: Produced Water Tank Exemption Same Letter of Interpretation 26 August 1992 “tanks used for separation and storage of produced water are not covered by the PSM standard” Again … Retract letter in 2002 Where is boundary??OSHA Interpretation Letter causes uproar! : OSHA Interpretation Letter causes uproar! Letter regarding OSHA authority to inspect homes of telecommuting workers under the ergonomic standard Caused Congress hearings, etc OSHA Guidelines / Interpretation Letters are advisory: OSHA Guidelines / Interpretation Letters are advisory Do not create new standards Do not create new employer obligations Not basis for citation 7 June 2004 memo to regional administratorsOSHA deFacto Rule making: OSHA deFacto Rule making OSHA can not change meaning of Standard through a letter of interpretation. Rule making procedure in section 6(b) of the OSH Act. PSM Criminal Case: PSM Criminal Case Willful resulting in death False info willful omission US v. Ward (Concept Sciences) Failure to do PHA, No training, No SOPs PSM Criminal Case What Happened?: PSM Criminal Case What Happened? Dismissed !! “PSM regulation itself is so ambiguous that a reasonable person in Ward’s position could not have determined whether it applied”PSM Criminal Case What Happened?: PSM Criminal Case What Happened? “the ambiguities of the PSM standard were exacerbated by OSHA’s nebulous Interpretation letters+ OSHA may not impose substantive rules without following rule making procedures.OSHA enforcement of PSM: OSHA enforcement of PSM OSHA memo to regional administrators dated 11 April 2000 OSHA will not enforce PSM standard at oil and gas facilities Economic analysis of feasibility…. 20 December 1999 memo withdrawn.Additional OSHA Controversial Issues: Additional OSHA Controversial Issues Flammability PHA (HAZOP) leader training Applicability of Hazard Communication Standard 1910.1200 to production facilities. Reference to Older Voluntary Consensus StandardsFlammability: Flammability PSM uses 1910.1200 OSHA 106, flammable liquids standard (originally adopted from NFPA 30) uses different definition Flammable, if liquid is operated within 30 degrees of flash pointHAZOP : HAZOP No specific leader training OSHA can cite inadequate leader training based on interview Australian CourtOSHA Haz Comm Standard 1910.1200 : OSHA Haz Comm Standard 1910.1200 11 January 89 letter to Kansas OIL & Gas Association MSDS for crude is not required 16 Feb 96 letter to Durio CIH changes OSHA position again. MSDS is inOSHA reference to Older Consensus Standards: OSHA reference to Older Consensus Standards An example: OSHA regulation on engines and gas turbines 1910.110(b)(2) Refers to NFPA 37-1970Recent Additions to Process Safety Technology: Recent Additions to Process Safety Technology Safety Instrumented System Voluntary Consensus Standards ISA 84, ISO 61511 Merge API 14C with SIS concepts Alarm Management DOT OPS Recent Accident Experiences Purpose of Alarms: Purpose of Alarms To warn and/or advise the operator that an action is required Can we use Process Hazard Analysis to Help Alarm Management Issues?: Can we use Process Hazard Analysis to Help Alarm Management Issues? HAZOP Process Unit / Process Area Failure Mode. Consequence (sometimes risk category estimated) Detectable condition Alarm recommendation Sort by Categories Consequence (severity helps define criticality) Common failure mode Detectable condition LNG NIMBY Wars The Sequel: LNG NIMBY Wars The Sequel LNG siting battles in late 1970s FERC (land based terminals) Coast Guard (offshore terminals) DOT 193, NFPA 59A, EN 1473 States Rights! Terrorism changes the decision process Role of PSM ??? Lots of Process Safety reports !! You do not have the permission to view this presentation. In order to view it, please contact the author of the presentation.
Sep 2004 Harry West Burnell Download Post to : URL : Related Presentations : Share Add to Flag Embed Email Send to Blogs and Networks Add to Channel Uploaded from authorPOINTLite Insert YouTube videos in PowerPont slides with aS Desktop Copy embed code: (To copy code, click on the text box) Embed: URL: Thumbnail: WordPress Embed Customize Embed The presentation is successfully added In Your Favorites. Views: 682 Category: Entertainment License: All Rights Reserved Like it (0) Dislike it (0) Added: November 08, 2007 This Presentation is Public Favorites: 0 Presentation Description No description available. Comments Posting comment... Premium member Presentation Transcript PROCESS SAFETY MANAGEMENT Recent Controversial Issues: PROCESS SAFETY MANAGEMENT Recent Controversial Issues Dr. Harry H. West, PE Mary Kay O’Connor Process Safety Center Chemical Engineering Department Texas A&M University College Station, Texas 77843-3122 hhwest@che.tamu.eduOSHA 1910.119 Process Safety Management: OSHA 1910.119 Process Safety Management Issues concerning Oil & Gas Production Jurisdiction among other regulatory agencies Oil & Gas Exemption Scope Unmanned Facilities Atmospheric Tank ExemptionRelationship of OSHA to Other Federal Agencies: Relationship of OSHA to Other Federal Agencies OSHA is precluded from regulating working conditions over which other federal agencies “exercise statutory authority to prescribe or enforce standards or regulations affecting occupational safety and health” Section 4-b-1 of OSH ActOil & Gas Pipelines: Oil & Gas Pipelines Pipeline companies under DOT OPS Contractors under OSHA What about pipelines under State jurisdiction?Oil & Gas Exemption: Oil & Gas Exemption 1910.119 section (a)(2)(ii) (a) "oil or gas well drilling or servicing operations" OSHA intended to develop a separate regulation. 1910.270 was announced in December 1983 (Wyoming OSHA) So what facilities are within OSHA PSM jurisdiction?Single Well Exemption: Single Well Exemption Letter of interpretation 26 August 1992 “ where flow from 2 or more wells come together” Retract letter in 2002 Where is boundary??"Non-heated Produced Fluids" : "Non-heated Produced Fluids" Same Letter of Interpretation 26 August 1992 PSM standard included those that are "processed by heating the fluids and physically separating the water...." ” Again … Retract letter in 2002 Where is boundary??Normally Unoccupied Remote Facilities" exemption : Normally Unoccupied Remote Facilities" exemption 1910.119(a)(2)(iii) Hours at site. Permanently stationed on site Various definitions over time Daily, for more than one second !! Less than 4 hours (1/2 ~ 8hour shift) Other time standards used Performance standard means you decide. Atmospheric Tank Exemption: Atmospheric Tank Exemption Covered by Flammable Liquids Code 1910.106 Issue: Connection to process Meer Decision; OSHRC #95-0341 Atmospheric tanks not counted in TQ Clarification of atmospheric tank exclusion taken off OSHA Regulatory agenda in 2001 Produced Water Tank Exemption: Produced Water Tank Exemption Same Letter of Interpretation 26 August 1992 “tanks used for separation and storage of produced water are not covered by the PSM standard” Again … Retract letter in 2002 Where is boundary??OSHA Interpretation Letter causes uproar! : OSHA Interpretation Letter causes uproar! Letter regarding OSHA authority to inspect homes of telecommuting workers under the ergonomic standard Caused Congress hearings, etc OSHA Guidelines / Interpretation Letters are advisory: OSHA Guidelines / Interpretation Letters are advisory Do not create new standards Do not create new employer obligations Not basis for citation 7 June 2004 memo to regional administratorsOSHA deFacto Rule making: OSHA deFacto Rule making OSHA can not change meaning of Standard through a letter of interpretation. Rule making procedure in section 6(b) of the OSH Act. PSM Criminal Case: PSM Criminal Case Willful resulting in death False info willful omission US v. Ward (Concept Sciences) Failure to do PHA, No training, No SOPs PSM Criminal Case What Happened?: PSM Criminal Case What Happened? Dismissed !! “PSM regulation itself is so ambiguous that a reasonable person in Ward’s position could not have determined whether it applied”PSM Criminal Case What Happened?: PSM Criminal Case What Happened? “the ambiguities of the PSM standard were exacerbated by OSHA’s nebulous Interpretation letters+ OSHA may not impose substantive rules without following rule making procedures.OSHA enforcement of PSM: OSHA enforcement of PSM OSHA memo to regional administrators dated 11 April 2000 OSHA will not enforce PSM standard at oil and gas facilities Economic analysis of feasibility…. 20 December 1999 memo withdrawn.Additional OSHA Controversial Issues: Additional OSHA Controversial Issues Flammability PHA (HAZOP) leader training Applicability of Hazard Communication Standard 1910.1200 to production facilities. Reference to Older Voluntary Consensus StandardsFlammability: Flammability PSM uses 1910.1200 OSHA 106, flammable liquids standard (originally adopted from NFPA 30) uses different definition Flammable, if liquid is operated within 30 degrees of flash pointHAZOP : HAZOP No specific leader training OSHA can cite inadequate leader training based on interview Australian CourtOSHA Haz Comm Standard 1910.1200 : OSHA Haz Comm Standard 1910.1200 11 January 89 letter to Kansas OIL & Gas Association MSDS for crude is not required 16 Feb 96 letter to Durio CIH changes OSHA position again. MSDS is inOSHA reference to Older Consensus Standards: OSHA reference to Older Consensus Standards An example: OSHA regulation on engines and gas turbines 1910.110(b)(2) Refers to NFPA 37-1970Recent Additions to Process Safety Technology: Recent Additions to Process Safety Technology Safety Instrumented System Voluntary Consensus Standards ISA 84, ISO 61511 Merge API 14C with SIS concepts Alarm Management DOT OPS Recent Accident Experiences Purpose of Alarms: Purpose of Alarms To warn and/or advise the operator that an action is required Can we use Process Hazard Analysis to Help Alarm Management Issues?: Can we use Process Hazard Analysis to Help Alarm Management Issues? HAZOP Process Unit / Process Area Failure Mode. Consequence (sometimes risk category estimated) Detectable condition Alarm recommendation Sort by Categories Consequence (severity helps define criticality) Common failure mode Detectable condition LNG NIMBY Wars The Sequel: LNG NIMBY Wars The Sequel LNG siting battles in late 1970s FERC (land based terminals) Coast Guard (offshore terminals) DOT 193, NFPA 59A, EN 1473 States Rights! Terrorism changes the decision process Role of PSM ??? Lots of Process Safety reports !!