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DOE-HDBK-1101-2004; Process Safety Management for Highly

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DOE-HDBK-1101-2004; Process Safety Management for Highly NOT MEASUREMENT SENSITIVE DOE-HDBK-1101-2004 August 2004 Superseding DOE-HDBK-1101-96 February 1996 DOE HANDBOOK PROCESS SAFETY MANAGEMENT FOR HIGHLY HAZARDOUS CHEMICALS U.S. Department of Energy AREA SAFT Washington, D.C. 20585 DISTRIBUTION STATEMENT A. Approved for public release; distribution is unlimited. DOE-HDBK-1101-2004 This document has been reproduced directly from the best available copy. Available to DOE and DOE contractors from the ES&H Technical Information Services, U.S. Department of Energy, (800) 473-4375, fax: (301) 903-9823. Available to the public from the U.S. Department of Commerce, Technology Administration, National Technical Information Service, Springfield, VA 22161; (703) 605-6000. ii DOE-HDBK-1101-2004 ACKNOWLEDGEMENTS The U.S. Department of Energy (DOE) wishes to thank several organizations for their support in developing this handbook. The Occupational Safety and Health Administration (OSHA) staff provided assistance. Mobil Chemical, General Electric, and Dow Chemical graciously shared their process safety management experience and program materials. JBF Associates shared sample programs and responses by an OSHA/industry panel to process safety management questions. Mr. John Piatt of Pacific Northwest National Laboratories (PNNL) managed the preparation of this standard by Battelle Memorial Institute staff at PNNL and the Battelle Columbus Division. iii DOE-HDBK-1101-2004 FOREWORD The Office of Health (EH-5) under the Assistant Secretary for Environment, Safety and Health of the U.S. Department of Energy (DOE) has published two handbooks for use by DOE contractors managing facilities and processes covered by the Occupational Safety and Health Administration (OSHA) Rule for Process Safety Management of Highly Hazardous Chemicals (29 CFR 1910.119), herein referred to as the PSM Rule. The PSM Rule contains an integrated set of chemical process safety management elements designed to prevent chemical releases that can lead to catastrophic fires, explosions, or toxic exposures. The purpose of the two handbooks, "Process Safety Management for Highly Hazardous Chemicals" and "Chemical Process Hazards Analysis," is to facilitate implementation of the provisions of the PSM Rule within the DOE. This handbook provides information necessary to determine if a chemical process is covered by the PSM Rule and provides an interpretation of the 14 elements of the PSM Rule. An overview of these elements is given in Table 1.1. This handbook also describes DOE programs that may, with or without modification, satisfy the requirements of this Rule. Questions and answers, based on OSHA's responses to questions from industry and labor, are provided at the end of most sections. Applicable question numbers are referenced in the text in brackets. Sample programs are included that may be used to satisfy provisions of the PSM Rule. These sample programs are adapted from industry and are not mandatory, even though some contain directive language (e.g., will, shall, should). Appendix D lists additional sources of detailed PSM information. For specific guidance on the Process Hazards Analysis element, the reader is referred to the handbook, "Chemical Process Hazards Analysis" (DOE-HDBK-1100-2004). OSHA's performance-based Rule permits great latitude in how its requirements are implemented, so long as the objectives of each element are met. This handbook recognizes this latitude, but attempts to guide DOE contractors toward efficient and effective options, given existing DOE Orders and requirements. These handbooks describe PSM Rule implementation in terms of industry practices and do not supercede any DOE Orders or requirements. Promulgation of the PSM Rule has heightened the awareness of chemical safety management issues within the DOE. Contractors whose chemical processes are not covered by the PSM Rule may use these handbooks as a basis for good safety management practices. Implementation of PSM programs is expected to be a dynamic process. Further information and interpretations may be issued as necessary to clarify the Rule. DOE has an OSHA interpretation phone line at 1-800-292-8061 where DOE contractors can direct questions not covered in this handbook. iv DOE-HDBK-1101-2004 TABLE OF CONTENTS ACKNOWLEDGEMENTS ........................................................................................................ i FOREWORD............................................................................................................................... iv LISTS OF FIGURES, TABLES, AND EXHIBITS.................................................................... vii ACRONYMS ............................................................................................................................. vii GLOSSARY................................................................................................................................ x REFERENCES ........................................................................................................................... xiv 1.0 INTRODUCTION ................................................................................................................ 1 1.1 Purpose ............................................................................................................................ 1 1.2 Background ..................................................................................................................... 5 1.3 Application...................................................................................................................... 5 2.0 PROCESS SAFETY MANAGEMENT ELEMENTS.......................................................... 15 2.1 Employee Participation ................................................................................................... 16 2.2 Process Safety Information ............................................................................................. 21 2.3 Process Hazard Analysis ................................................................................................. 27 2.4 Operating Procedures ...................................................................................................... 35 2.5 Training ........................................................................................................................... 40 2.6 Subcontractor Safety ....................................................................................................... 44 2.7 Pre-Startup Safety Review .............................................................................................. 63 2.8 Mechanical Integrity ....................................................................................................... 71 2.9 Nonroutine Work Authorizations (Hot Work Permits)................................................... 76 2.10 Management of Change .................................................................................................. 79 2.11 Incident Investigation...................................................................................................... 85 2.12 Emergency Planning and Response ................................................................................ 88 2.13 Compliance Audits.......................................................................................................... 90 2.14 Trade Secrets................................................................................................................... 113 3.0 PSM PROGRAM DEVELOPMENT.................................................................................... 115 3.1 Defining Process Safety Management Policy, Goals, and Objectives............................ 115 3.2 Process Safety Management Planning ............................................................................ 115 3.3 Program Leadership and Implementation ....................................................................... 117 v DOE-HDBK-1101-2004 APPENDICES APPENDIX A OSHA and EPA Lists of Highly Hazardous Substances and Threshold Quantities (TQ) for Accidental Release Prevention .................... A1 APPENDIX B The Process Safety Management Rule.......................................................... B1 APPENDIX C Comparison of the EPA Risk Management Program with OSHA's Process Safety Management Program..................................... C1 APPENDIX D Sources of Information.................................................................................. D1 vi DOE-HDBK-1101-2004 LIST OF FIGURES Figure 1.1 Chemical Safety Programs Related to Accident Consequence ................................. 4 Figure 1.2 Applicability of the PSM Rule................................................................................... 7 Figure 2.1 The Process Safety Management System .................................................................. 15 LIST OF TABLES Table 1.1 Overview of PSM Elements........................................................................................ 2 LIST OF EXHIBITS Exhibit 2.1 Sample Employee Participation Plan ....................................................................... 18 Exhibit 2.6.1 Sample Subcontractor Safety Program.................................................................. 48 Exhibit 2.6.2 Sample Subcontractor Safety Questionnaire......................................................... 54 Exhibit 2.6.3 Sample Subcontractor Safety Program Evaluation and Criteria ........................... 57 Exhibit 2.7 Sample Prestartup Safety Review ...........................................................................
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