At the time of the methyl isocyanate release at Bhopal, I was working in the corporate offices of a Fortune 50 company. The stillness of the air in the headquarters offices and the questions on the faces of executives were quite obvious. "Could it happen here? What will be the fallout for our company? What do we need to do to make our operations safer? Will there be a regulatory response affecting our operations?" I am sure that these questions and concerns were prevalent throughout the world's chemical-producing companies.
Almost beyond belief, just months after the Bhopol incident, the unthinkable happened again a facility released methyl isocyanate into the community of Institute, W.Va., just a few miles from where I was working. There were no fatalities, but more than 135 people sought medical treatment for exposure. It now appeared certain that new regulations were coming and coming soon, and the overriding question was, "How will we implement and manage improved safety processes for our chemical operations?"
Among the regulatory responses in the years following the Bhopal incident, OSHA implemented the Process Safety Management (PSM) standard (29 CFR 1910.119). The Environmental Protection Agency (EPA) promulgated a similar regulation, Accidental Release Prevention Requirements: Risk Management Programs, under the Clean Air Act Risk Management Plan (RMP) Rule (40 CFR Chapter I, Subchapter C, Part 68). Industry now has nearly a decade of experience in implementing PSM and RMP. Herein are some of the resulting accomplishments and issues of implementation that we have seen.
Implementation and Continuous Improvement
Our PSM and RMP consulting projects and program audits have indicated that facilities, overall, are making concerted and effective efforts to implement programs and procedures to comply with applicable rules. With over a decade since the PSM and RMP rules became effective, covered facilities have the core regulatory elements in place. Efforts now are primarily for continuous quality improvement.
Some of the areas undergoing continuous quality improvements include:
- Improved communication and interaction among facility technical, operations, maintenance and management personnel teams during periodic and systematic reviews of covered processes.
- More reliable processes resulting from process hazards analysis (PHA) team problem-solving efforts.
- PSM-RMP Audit Team activities and findings are shared among facilities within the same corporations to enhance the implementation of safer equipment and procedures.
- Covered process system components are listed and tracked in greater detail.
- On-site libraries of manufacturers' manuals and design manuals are compiled to establish a core repository of technical references for system instrumentation and other components.
- Service lifetimes for piping, vessels and other components are determined by mechanical engineers, so that replacements are scheduled and replaced well-before the end of projected service life.
- Computerized preventive maintenance databases are utilized to schedule timely maintenance and replacements of system components.
- Redundant operating systems are installed, so one system is operating while another is undergoing preventive maintenance. This allows continuity in process production in one system, while a companion system is undergoing overhaul.
PSM and RMP regulations mandate periodic and systematic evaluations of covered processes containing "listed" chemicals meeting threshold quantities. The evaluations, whether in the form of PHA, audits, pre-startup safety reviews or operating procedures preparation and reviews, bring together the facility personnel engineers, operators, maintenance technicians, safety specialists, trainers, chemists, managers and, often, consultants to dynamically review and evaluate a covered chemical process. This process of periodic, systematic reviews by varied technical and managerial staff at the site-specific location is one of the strengths of PSM and RMP programs. This process forces detailed and timely consideration of all aspects of operations and maintenance to achieve safe operating performance.
Audit Teams
The PSM-RMP audit teams are being used as a positive experience by some corporations to facilitate technical and safety knowledge transfer from one facility to another. For example, the audit team may consist of two key individuals who participate in every audit for consistency. The remainder of the team is dynamic, and includes technical specialists from varied corporate processing facilities. The audit team might include personnel from an East Coast and a West Coast facility, used to audit a Gulf Coast facility. Similarly, the next audit may involve the East Coast and Gulf Coast personnel traveling to the West Coast. This shifting of audit team personnel allows them to see covered process operations from other locations, and helps them to bring knowledge for improved safety and procedures back to their home location.
The network of communications among PHA team members leads to suggestions for safety process improvements. For example, at one site, operators were concerned about the chemical containers delivered by truck to the facility. Containers sometimes had visible gouges, rust and indentations, and the operators wanted a systematic process for inspecting the containers before they entered the facility, and before acceptance by facility personnel. As a result of the operators' request, a new operating procedure was prepared based on technical information from the chemical manufacturer, the U.S. Department of Transportation and the relevant trade association. In addition, the facility operators opened up dialogues with the container maker and the trucking company to better understand and evaluate risks, liabilities and emergency planning for potential transportation accidents.
At another site, maintenance technicians relied on local apprenticeship craft training for maintenance of electronic sensors and alarms, and for replacement of component parts in flow regulators and valves. Implementation of a mechanical integrity program, including identification and listing of specific component parts by manufacturers and model numbers, led to requests by the maintenance technicians to assemble the specific maintenance manuals and technical information sheets for all components, however small, into a facility library. This was no insignificant feat, as some manuals had to be collected for components that had been in use for two decades or more. An interest in receiving the very latest technical information on component parts led to another facility inviting the manufacturer's technical representative on an annual basis to directly train the maintenance technicians. This now has evolved into a training process in which the manufacturer's representative brings in over a ton of demonstration equipment onto the site for annual hands-on training.
Periodic reviews of covered process components has led some teams to question and ask for validation of the service lifetimes of system components and materials. Often, the components of system instruments, valves, rate controllers and related devices are overhauled or replaced on a schedule based on manufacturer's recommendations. However, what is the decision factor used by a manufacturer for replacement of component parts? Is it based on erosion or corrosion of the parts? Does the manufacturer's recommendation adequately compensate for fluctuations or upsets in the covered process? What factors or range of conditions in the covered process might cause the manufacturer's recommendations to no longer be valid?
Some facilities are employing mechanical engineers to evaluate the service lifetimes of covered process components to schedule replacements before the material fails. For example, what is the projected lifetime of piping conveying the regulated chemical, and should it be replaced every few years? Most facilities have preventive maintenance (PM) software that is well-suited to track the maintenance and replacement history of even the smallest of system components. The biggest challenge, though, is not the scheduling with the software, but the identification and evaluation of each and every individual system component, no matter how small or seemingly insignificant. Piping gaskets, washers in gauges, inch-long sections of polymer tubing, springs in valves and flow regulator diaphragms are examples of system components that may be included in the PM software.
Site Challenges
Some issues are still presenting challenges for the most effective implementation. Since OSHA's PSM and EPA's RMP are performance-based standards, there are not exacting requirements dictating how to implement the provisions of these regulations. In particular, management and control of contractors can be a challenge. Some facilities struggle with the means to track and control access of contractors into covered processes. Locked doors of buildings housing covered processes and locked gates of fences surrounding covered processes are obvious physical means to restrict contractor access, but how "near a covered process" (29 CFR 1910.119[h][1]) must a contractor be until PSM rules are triggered for that contractor?
Sept. 11 introduced the terrorism factor into deliberations of PHA teams. To what extent should a facility go to ensure security of a covered process? One obvious factor is the surrounding community. If densely populated, this may justify tighter security to prevent a terrorist's sabotage of hazardous chemical processes, as opposed to a facility that is isolated well -away from residential, suburban or urban communities.
An issue sometimes grossly underestimated by site management is the time needed to perform site PSM and RMP administrative requirements. There is voluminous documentation including training, operating procedures preparation and updates, hot work permits, RMP regulatory filings, process hazard analysis reports, audit reports and filing of archives. It often requires substantial time on the part of a dedicated PSM and RMP site coordinator, and significant time on the parts of multiple site staff, to document, file and archive the records required to document regulatory compliance.
Partly because of the extensive recordkeeping requirements, some site managers are investigating means to replace covered processes with systems not regulated under PSM and RMP. This may be an ultimate, but understated, achievement of PSM and RMP rules that is, replacement of a hazardous process with one that is less hazardous. Often, if a covered process can be eliminated at a facility, the resulting process is one that is less hazardous for the workers and the surrounding community and may be less costly to the facility in terms of chemical inventory and regulatory and administrative burden.
Ron Hill, CIH, CSP, is manager of Occupational Health and Safety for Clayton Group Services' Denver regional office. He has 30 years of experience in the field of EHS and industrial hygiene, including regulatory compliance, medical surveillance management and health and safety training. Hill has advised clients in hazardous chemical emergency response, the control of toxic chemical exposures, worker health protection policies and programs, environmental assessment, indoor air contamination and workers' compensation.