PSID: Process Safety Incident Database | CCPS

The Center for Chemical Process Safety (CCPS) developed the Process Safety Incident Database to collect, track and share important process safety incidents and experiences among project participants.

The purpose of the CCPS PSID is to pool process safety incident experience among participating companies so they can learn from the experiences of others without suffering the consequences of failures, while minimizing corporate liability. PSID includes process safety incidents with a potentially important lesson to be learned from incidents that did or could have resulted in a fire, explosion, fatality, multiple injuries, significant release of hazardous materials, or any other unique process safety incident (including near-misses).

PSID is a fully searchable incident database that is accessible on the web and includes more than 700 incidents and grows each month as PSID member companies enter new and informative incidents. It can be accessed from any computer anywhere a secure web connection can be obtained. Hardcopy print outs of incidents are also possible. PSID is designed so that all PSID member companies can grant as many employees access to PSID as they want and is a very versatile and valuable input for PHAs, incident investigations, lessons learned, and general process safety awareness. PSID requires separate dues from CCPS. PSID members do not have to belong to CCPS but get a discount if they do. PSID can be accessed by PSID member company employees. Each PSID member company has the authority to approve or deny/remove any of their employees’ access to the system.

Ref: PSID: Process Safety Incident Database | CCPS

Where to download CIMAH 1996 Regulations

The CIMAH Regulation 1996 can be downloaded from DOSH's website.

Click here.

You need to select the "02. Occupational Safety and Health Act 1994 (Act 514)" and click Save. The file is available in Portable Document Format (PDF) which can be read from common PDF reader.

Review of CIMAH Report

The review of CIMAH Industrial Activity Report to be undertaken for every 3 years or less if there is major modification that could affect the threshold quantity of the hazardous material.

For example, Plant A has stored 50 tonnes of chlorine which is more than threshold quantity (10 tonnes) in Schedule 2 of CIMAH Regulation. Therefore, Plant A is required to submit a CIMAH Industrial Activity Report to DOSH Major Hazard Division. The operations of Plant A remain unchanged for the duration of 3 years.

Another example, Plant B has stored 15 tonnes of chlorine which is more than threshold quantity in their first year. Due to market growth, Plant B has increased the quantity of chlorine to 30 tonnes on the second year by submitting the notification of JKKP  5 form to DOSH Major Hazard Division. Therefore, Plant B is required to review & update their CIMAH Industrial Activity Report due to the change of the quantity of the hazardous material in consultation with Major Hazard Competent Person.

Process Safety

Process safety focuses on preventing fires, explosions and accidental chemical releases in chemical process facilities or other facilities dealing with hazardous materials such as refineries, and oil and gas (onshore and offshore) production installations.

Ref: Wikipedia

Top 10 worst process safety incidents in history

Top 10 worst process safety incidents in history

This article discusses what the Mary Kay O’Connor Process Safety Center at Texas A&M University in College Station, Texas, consider the top 10 process safety incidents in history. The incidents were ranked based on the cumulative impact on loss of lives and economic losses, and the resulting impact on the development of what today we know as process safety.

1. Bhopal

On the early morning of December 3, 1984, at the Union Carbide plant in India, a storage tank containing methyl isocyanate (MIC) was contaminated with water leading to a runaway reaction causing the release of more than 40 tons of toxic MIC gas through a relief valve.

The incident killed more than 3,000 people and injured hundreds of thousands more. This was arguably the worst chemical industry incident in terms of people affected, however; it was just after this fatal tragedy that the chemical process industry became really conscientious of the importance of process safety and it gained complete acceptance as a standard practice.1

As a direct response to Bhopal, many regulatory initiatives were implemented worldwide. In India, this event led to the Environment Protection Act (1986), the Air Act (1987), the Hazardous Waste (Management and Handling) Rules (1989), the Public Liability Insurance Act (1991) and the Environmental Protection (Second Amendment) Rules (1992).

In the US, the Emergency Planning and Community Right-to-Know Act (EPCRA) was promulgated in 1986,2 and the Clean Air Act Amendments (CAAA) were signed into law in 1990.1

2. Chernobyl

On April 28, 1986, in a power plant in Chernobyl, Ukraine, an experiment performed in order to verify the emergency power supply of a reactor resulted in unfortunate consequences. The core of the reactor was blown out by two violent explosions causing a series of fires and the release of tons of radioactive materials.

It is considered to be the worst nuclear disaster in history. The incident directly killed 56 people and influenced the development of cancer and radiation sickness of hundreds in the subsequent years.3

Before the incident, there were no written rules for the test that led to the catastrophic consequences. This fact has made the adherence to safety-related instructions as the most highlighted lesson learned regarding to process safety.4

3. Piper Alpha

Piper Alpha was a North Sea oil production platform. On July 6, 1988, the backup condensate pump pressure safety valve was removed for routine maintenance. However, since the maintenance could not be completed within the shift, it was decided to complete the remaining work the next day. As a temporary measure, the condensate pipe was sealed with a blind flange.

Communication gaps between different shifts resulted in a catastrophe when the night shift crew unknowingly started the backup condensate pump after the failure of the primary pump. In just 22 minutes, fire broke out everywhere and the event escalated further because of design and operational flaws resulting in 167 deaths. The Piper Alpha incident was a wakeup call for the offshore industries.

Significant changes in safety practice include development and implementation of safety case regulations in UK, adherence to a permit-to-work system and realistic training for emergency response.4

4. The Macondo blowout

The Macondo exploration well located in the Gulf of Mexico (GoM) was drilled by a deep water horizontal semi-submersible rig. On April 20, 2010, a blowout caused a fire and explosion on the rig that killed 11 employees and caused a major oil spill that continued uncontrolled for 87 days.

A series of mechanical failures, lack of human judgment, faulty engineering design and improper team interaction came together to result in the largest oil spill known to mankind. The blowout was the biggest offshore incident in the US and it had a profound impact on safety regulations in the GoM.

As a direct outcome of the Macondo incident, the Drilling Safety Rule regarding wellbore reliability and well control equipment was implemented on October 14, 2010. The Modified Workplace Safety Rule was also implemented on October 15, 2010, based on the lessons learned from the Macondo blowout.5–6

5. BP Texas City

On March 23, 2005, during the startup of an isomerization unit, the safety relief valves of a distillation tower opened due to overfilling, allowing hydrocarbon liquids to flow into a disposal blowdown drum with a stack, which were also overfilled, resulting in a liquid release. The evaporation of the hydrocarbons produced a flammable vapor cloud that ignited and led to a series of fires and explosions. Fifteen workers died and about 180 were injured.7

This incident led to major investigations including the milestone Baker panel report headed by former US Secretary of State James Baker III. This incident also resulted in significantly more interest in and attention to issues such as facility siting, atmospheric venting, leading and lagging indicators and safety culture.

6. The Flixborough disaster

On June 1, 1974, in a caprolactam production plant, a temporary bypass line ruptured, resulting in the leak of almost 40 tons of cyclohexane that caused a huge vapor-cloud explosion. The tragic disaster killed 28 people including all the employees working in the control room.

There was the alarming possibility of killing more than 500 employees if it were a normal working day instead of weekend. Also, widespread damage to property within a 6-mile radius around the plant was another major consequence. The Flixborough explosion was a critical driver in moving process safety issues forward in the UK.

As a result of the Flixborough incident, at the end of 1974, the Advisory Committee on Major Hazards (ACMH) was formed. The lessons learned from this disaster highlight the importance of HAZOP analysis, blast resistant control rooms and thorough studies prior to any modification in process plants.4

7. Mexico City

On November 19, 1984, in an LPG installation in Mexico City, the failure of the safety valve of an LPG storage tank caused an overpressure inside the tank and a pipe rupture, leading to a leakage of LPG followed by an ignition and violent explosions.

Approximately 500 people were killed and more than 700 were injured.9 This incident represents the largest series of boiling liquid expanding vapor explosions (BLEVEs) in history.4 Mexico City clearly demonstrated the risk of BLEVEs in process facilities and lessons learned from this event have significantly impacted standards for design and operation.

8. Phillips

On October 23, 1989, in the Phillips 66 plant in Pasadena, Texas, the rupture of a seal on a polyethylene reactor caused the release of highly flammable ethylene and isobutene gas, forming a gas cloud and leading to a massive explosion in less than two minutes.

Twenty-three people were killed and more than 300 injured. The day before the incident, a maintenance procedure had been performed by contractor personnel. This incident underscored the importance of rigid adherence to operating procedures and the implementation of an appropriate management system for contract workers.

In response to this incident and other incidents that occurred before in the 1980s (including Bhopal, Shell Norco, Arco Channelview and Exxon Baton Rouge), the US Department of Labor, Occupational Safety and Health Administration developed the Process Safety Management (PSM) regulation.10

9. Columbia disaster

The physical cause of the Columbia shuttle disaster was separation of insulation foam that then hit the carbon–carbon reinforced panel of the left wing, thus damaging the thermal protection system. Aerodynamic pressure caused by superheated air destroyed the wing when the shuttle was reentering earth’s atmosphere at about 10,000 mph on February 1, 2003.

The tragic incident caused the death of all seven astronauts and resulted in shuttle debris being scattered over 2,000 square miles in Texas. However, the underlying causes for the disaster can be traced back to flaws in decision making at NASA.

The Columbia incident also provided important lessons for crisis communication professionals, as well. In fact, the lessons learned from the Columbia incident can be mapped to many other catastrophes such as the Piper Alpha or the Flixborough incident, covering issues such as sense of vulnerability, establishing an imperative for safety and valid on-time risk assessment.11

10. Fukushima Daiichi nuclear incident

On March 11, 2011, this incident drew the attention of the process and power industries around the world, encouraging them to incorporate natural disaster risk in any hazard analysis study. When a powerful earthquake hit the plant, the reactors shut down automatically.

However, because of the earthquake and the following tsunami, a power blackout ensued, leading to the loss of cooling, which, in turn, led to overheating of the reactors (creating serious radiation hazards). Fortunately, no one was killed because of the radiation, but there may be long-term consequences to the workers and to the neighboring communities who were exposed to radiation.

Conclusions

These tragic events and the consequences of these events have provided us with numerous lessons that help our understanding of the hazards and risks of the modern process industry and, more importantly, how design, technology, equipment, management systems, human factors and safety culture can be used to improve the safety performance of the industry.

Understanding the root causes of incidents and learning from mistakes within the company, as well as other organizations, is vital. These lessons need to be implemented both in the engineering and the management sectors.


LITERATURE CITED
1 Mannan, M. S., et al., “The legacy of Bhopal: The impact over the last 20 years and future direction,” Journal of Loss Prevention in the Process Industries, 2005. 18(4–6): pp. 218–224.
2 Mannan, M. S., J. Makris and H. J. Overman, Process Safety and Risk Management Regulations: Impact on Process Industry, Encyclopedia of Chemical Processing and Design, ed. R. G. Anthony, Vol. 69, Supplement 1, pp. 168–193, Marcel Dekker, Inc., New York, 2002.
3 Dara, S. I. and J. C. Farmer, “Preparedness Lessons from Modern Disasters and Wars,” Critical Care Clinics, 2009. 25(1): pp. 47–65.
4 Mannan, M. S., Lees’ Loss Prevention in the Process Industries, 3rd Edition, Elsevier, 2005.
5 McAndrews, K. L., “Consequences of Macondo: A Summary of Recently Proposed and Enacted Changes to US Offshore Drilling Safety and Environmental Regulation,” Society of Petroleum Engineers Americas E&P Health, Safety, Security and Environmental Conference, Houston 2011. Available online: http://www.jsg.utexas.edu/news/files/mcandrews_spe_143718-pp.pdf, accessed on March 16, 2012.
7 Kaszniak, M. and D. Holmstrom, “Trailer siting issues: BP Texas City,” Journal of Hazardous Materials, 2008. 159(1): pp. 105-111.
8 Snorre, S., “Comparison of some selected methods for incident investigation,” Journal of Hazardous Materials, 2004. 111(1–3): pp. 29–37.
9 C.M, P., “Analysis of the LPG-disaster in Mexico City,” Journal of Hazardous Materials, 1988. 20(0): pp. 85-107.
10 Guidelines for Vapor Cloud Explosion, Pressure Vessel Burst, BLEVE, and Flash Fire Hazards, 2nd Edition, August 2010, Process Safety Progress, 2011. 30(2): p. 187.
11 American Institute of Chemical Engineers (AIChE), Lessons from the Columbia Disaster-Safety and Organizational Culture, Center for Chemical Process Safety, 2005.

MS 1722:2011 & OHSAS 18001:2007 - Occupational Health and Safety

As part of the CIMAH Industrial Activity Report contents, the manufacturer is required to describe their system of management for controlling the industrial activity. The Occupational Health and Safety Management Systems (OSHMS) is recognised in Malaysia. The full specification is MS 1722:2011 & OHSAS 18001:2007 - Occupational Health and Safety.


The Problem Led to Process Safety in US

Unexpected releases of toxic, reactive, or flammable liquids and gases in processes involving highly hazardous chemicals have been reported for many years. Incidents continue to occur in various industries that use highly hazardous chemicals which may be toxic, reactive, flammable, or explosive, or may exhibit a combination of these properties. Regardless of the industry that uses these highly hazardous chemicals, there is a potential for an accidental release any time they are not properly controlled. This, in turn, creates the possibility of disaster.

Recent major disasters include the 1984 Bhopal, India, incident resulting in more than 2,000 deaths; the October 1989 Phillips Petroleum Company, Pasadena, TX, incident resulting in 23 deaths and 132 injuries; the July 1990 BASF, Cincinnati, OH, incident resulting in 2 deaths, and the May 1991 IMC, Sterlington, LA, incident resulting in 8 deaths and 128 injuries.

Although these major disasters involving highly hazardous chemicals drew national attention to the potential for major catastrophes, the public record is replete with information concerning many other less notable releases of highly hazardous chemicals. Hazardous chemical releases continue to pose a significant threat to employees and provide impetus, internationally and nationally, for authorities to develop or consider developing legislation and regulations to eliminate or minimize the potential for such events.

On July 17, 1990, OSHA published in the Federal Register (55 FR 29150) a proposed standard, - ”Process Safety Management of Highly Hazardous Chemicals” - containing requirements for the management of hazards associated with processes using highly hazardous chemicals to help assure safe and healthful workplaces.

OSHA's proposed standard emphasized the management of hazards associated with highly hazardous chemicals and established a comprehensive management program that integrated technologies, procedures, and management practices.

The notice of proposed rulemaking invited comments on any aspect of the proposed standard for process safety management of highly hazardous chemicals and announced the scheduling of a hearing to begin on November 27, 1990, in Washington, DC.

On November 1, 1990, OSHA published a Federal Register notice (55 FR 46074) scheduling a second hearing to begin on February 26, 1991, in Houston, TX, enumerating additional issues, and extending the written comment period until January 22, 1991.

The hearings on the proposed standard were held in Washington, DC, from November 27, 1990, through December 4, 1990, and in Houston, TX, from February 26, 1991, through March 7, 1991. The Administrative Law Judge presiding at the hearings allowed participants to submit post-hearing comments until May 6, 1991, and file post-hearing briefs until June 5, 1991. OSHA received more than 175 comments in response to the notice of proposed rulemaking. In addition to these comments, the hearings resulted in almost 4,000 pages of testimony and almost 60 post-hearing comments and briefs. For readers' convenience, this publication includes, as an appendix, the full text of the final OSHA standard issued in the Federal Register on February 24, 1992, including the list of covered chemicals and threshold amounts.

State plan States, approved under section 18(b) of the Occupational Safety and Health Act of 1970 (see list on page 36) must adopt standards and enforce requirements which are at least as effective as Federal requirements. There are currently 25 State plan States; 23 covering private and public (State and local government) sectors and two covering public sector only. Plan States must adopt comparable standards to the Federal within six months of a Federal standard's promulgation.

Approximately four months after the publication of OSHA's proposed standard for process safety management of highly hazardous chemicals, the Clean Air Act Amendments (CAAA) were enacted into law (November 15, 1990). Section 304 of the CAAA requires that the Secretary of Labor, in coordination with the Administrator of the Environmental Protection Agency (EPA), promulgate, pursuant to the Occupational Safety and Heath Act of 1970, a chemical process safety standard to prevent accidental releases of chemicals that could pose a threat to employees.

The CAAA requires that the standard include a list of highly hazardous chemicals which includes toxic, flammable, highly reactive, and explosive substances. The CAAA also specified minimum elements that the OSHA standard must require employers to do, as follows:
(1) Develop and maintain written safety information identifying workplace chemical and process hazards, equipment used in the processes, and technology used in the processes;
(2) Perform a workplace hazard assessment, including, as appropriate, identification of potential sources of accidental releases, identification of any previous release within the facility that had a potential for catastrophic consequences in the workplace, estimation of workplace effects of a range of releases, and estimation of the health and safety effects of such a range on employees;
(3) Consult with employees and their representatives on the development and conduct of hazard assessments and the development of chemical accident prevention plans and provide access to these and other records required under the standard;
(4) Establish a system to respond to the workplace hazard assessment findings, which shall address prevention, mitigation, and emergency responses;
(5) Review periodically the workplace hazard assessment and response system;
(6) Develop and implement written operating procedures for the chemical processes, including procedures for each operating phase, operating limitations, and safety and health considerations;
(7) Provide written safety and operating information for employees and employee training in operating procedures, by emphasizing hazards and safe practices that must be developed and made available;
(8) Ensure contractors and contract employees are provided with appropriate information and training;
(9) Train and educate employees and contractors in emergency response procedures in a manner as comprehensive and effective as that required by the regulation promulgated pursuant to section 126(d) of the Superfund Amendments and Reauthorization Act;
(10) Establish a quality assurance program to ensure that initial process-related equipment, maintenance materials, and spare parts are fabricated and installed consistent with design specifications;
(11) Establish maintenance systems for critical process-related equipment, including written procedures, employee training, appropriate inspections, and testing of such equipment to ensure ongoing mechanical integrity;
(12) Conduct pre-startup safety reviews of all newly installed or modified equipment;
(13) Establish and implement written procedures managing change to process chemicals, technology, equipment and facilities; and
(14) Investigate every incident that results in or could have resulted in a major accident in the workplace, with any findings to be reviewed by operating personnel and modifications made, if appropriate.

Also the CAAA, identifies specific duties for EPA relative to the prevention of accidental releases (see section 301 (r)). Generally, EPA must develop a list of chemicals and a Risk Management Plan.

Reference: OSHA US

Emergency Planning and Response

Process Safety Requirement - Emergency Planning and Response

If, despite the best planning, an incident occurs, it is essential that emergency pre-planning and training make employees aware of, and able to execute, proper actions. For this reason, an emergency action plan for the entire plant must be developed and implemented in accordance with the provisions of other OSHA rules (29 CFR 1910.38(a)). In addition, the emergency action plan must include procedures for handling small releases of hazardous chemicals. Employers covered under PSM also may be subject to the OSHA hazardous waste and emergency response regulation (29 CFR 1910.120(a), (p), and (q). 

Trade Secrets

Process Safety Requirement - Trade Secrets

Employers must make available all information necessary to comply with PSM to those persons responsible for compiling the process safety information, those developing the process hazard analysis, those responsible for developing the operating procedures, and those performing incident investigations, emergency planning and response, and compliance audits, without regard to the possible trade secret status of such information. Nothing in PSM, however, precludes the employer from requiring those persons to enter into confidentiality agreements not to disclose the information.

Compliance Audits

Process Safety Requirement - Compliance Audits

To be certain process safety management is effective, employers must certify that they have evaluated compliance with the provisions of PSM at least every three years This will verify that the procedures and practices developed under the standard are adequate and are being followed. The compliance audit must be conducted by at least one person knowledgeable in the process and a report of the findings of the audit must be developed and documented noting deficiencies that have been corrected. The two most recent compliance audit reports must be kept on file.

Incident Investigation

Process Safety Requirement - Incident Investigation

A crucial part of the process safety management program is a thorough investigation of incidents to identify the chain of events and causes so that corrective measures can be developed and implemented. Accordingly, PSM requires the investigation of each incident that resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical in the workplace.

Such an incident investigation must be initiated as promptly as possible, but not later than 48 hours following the incident. The investigation must be by a team consisting of at least one person knowledgeable in the process involved, including a contract employee if the incident involved the work of a contractor, and other persons with appropriate knowledge and experience to investigate and analyze the incident thoroughly.

An investigation report must be prepared including at least:
  • Date of incident,
  • Date investigation began,
  • Description of the incident,
  • Factors that contributed to the incident, and
  • Recommendations resulting from the investigation. A system must be established to promptly address and resolve the incident report findings and recommendations. Resolutions and corrective actions must be documented and the report reviewed by all affected personnel whose job tasks are relevant to the incident findings (including contract employees when applicable). The employer must keep these incident investigation reports for 5 years.

Management of Change

Process Safety Requirement - Management of Change

OSHA believes that contemplated changes to a process must be thoroughly evaluated to fully assess their impact on employee safety and health and to determine needed changes to operating procedures. To this end, the standard contains a section on procedures for managing changes to processes. Written procedures to manage changes (except for “replacements in kind”) to process chemicals, technology, equipment, and procedures, and change to facilities that affect a covered process, must be established and implemented. These written procedures must ensure that the following considerations are addressed prior to any change:
  • The technical basis for the proposed change,
  • Impact of the change on employee safety and health,
  • Modifications to operating procedures,
  • Necessary time period for the change, and
  • Authorization requirements for the proposed change.
Employees who operate a process and maintenance and contract employees whose job tasks will be affected by a change in the process must be informed of, and trained in, the change prior to startup of the process or startup of the affected part of the process. If a change covered by these procedures results in a change in the required process safety information, such information also must be updated accordingly. If a change covered by these procedures changes the required operating procedures or practices, they also must be updated.

Hot Work Permit

Process Safety Requirement - Hot Work Permit

A permit must be issued for hot work operations conducted on or near a covered process. The permit must document that the fire prevention and protection requirements in OSHA regulations (1910.252(a)) have been implemented prior to beginning the hot work operations; it must indicate the date(s) authorized for hot work; and identify the object on which hot work is to be performed. The permit must be kept on file until completion of the hot work.

Mechanical Integrity

Process Safety Requirement - Mechanical Integrity

OSHA believes it is important to maintain the mechanical integrity of critical process equipment to ensure it is designed and installed correctly and operates properly. PSM mechanical integrity requirements apply to the following equipment:

  • Pressure vessels and storage tanks;
  • Piping systems (including piping components such as valves);
  • Relief and vent systems and devices;
  • Emergency shutdown systems;
  • Controls (including monitoring devices and sensors, alarms, and interlocks); and
  • Pumps.
The employer must establish and implement written procedures to maintain the ongoing integrity of process equipment. Employees involved in maintaining the ongoing integrity of process equipment must be trained in an overview of that process and its hazards and trained in the procedures applicable to the employees's job tasks.

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 with manufacturers' recommendations and good engineering practices, or more frequently if determined to be necessary by prior operating experience. Each inspection and test on process equipment must be documented, identifying the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test.

Equipment deficiencies outside the acceptable limits defined by the process safety information must be corrected before further use. In some cases, it may not be necessary that deficiencies be corrected before further use, as long as deficiencies are corrected in a safe and timely manner, when other necessary steps are taken to ensure safe operation.

In constructing new plants and equipment, the employer must ensure that equipment as it is fabricated is suitable for the process application for which it will be used. Appropriate checks and inspections must be performed to ensure that equipment is installed properly and is consistent with design specifications and the manufacturer's instructions.

The employer also must ensure that maintenance materials, spare parts, and equipment are suitable for the process application for which they will be used.

Pre-Startup Safety Review

Process Safety Requirement - Pre-Startup Safety Review

It is important that a safety review takes place before any highly hazardous chemical is introduced into a process. PSM, therefore, requires the employer to perform a pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information. Prior to the introduction of a highly hazardous chemical to a process, the pre-startup safety review must confirm that the following:
  • Construction and equipment are in accordance with design specifications;
  • Safety, operating, maintenance, and emergency procedures are in place and are adequate;
  • A process hazard analysis has been performed for new facilities and recommendations have been resolved or implemented before startup, and modified facilities meet the management of change requirements; and
  • Training of each employee involved in operating a process has been completed.

Contractors

Process Safety Requirement - Contractors

Application
Many categories of contract labor may be present at a jobsite; such workers may actually operate the facility or do only a particular aspect of a job because they have specialized knowledge or skill. Others work only for short periods when there is need for increased staff quickly, such as in turnaround operations. PSM includes special provisions for contractors and their employees to emphasize the importance of everyone taking care that they do nothing to endanger those working nearby who may work for another employer.

PSM, therefore, applies to contractors performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process. It does not apply, however, to contractors providing incidental services that do not influence process safety, such as janitorial, food and drink, laundry, delivery, or other supply services.

Employer Responsibilities
When selecting a contractor, the employer must obtain and evaluate information regarding the contract employer's safety performance and programs. The employer also must inform contract employers of the known potential fire, explosion, or toxic release hazards related to the contractor's work and the process; explain to contract employers the applicable provisions of the emergency action plan; develop and implement safe work practices to control the presence, entrance, and exit of contract employers and contract employees in covered process areas; evaluate periodically the performance of contract employers in fulfilling their obligations; and maintain a contract employee injury and illness log related to the contractor's work in the process areas.

Contract Employer Responsibilities
The contract employer must:
  • Ensure that contract employees are trained in the work practices necessary to perform their job safely;
  • Ensure that contract employees are instructed in the known potential fire, explosion, or toxic release hazards related to their job and the process, and in the applicable provisions of the emergency action plan;
  • Document that each contract employee has received and understood the training required by the standard by preparing a record that contains the identity of the contract employee, the date of training, and the means used to verify that the employee understood the training;
  • Ensure that each contract employee follows the safety rules of the facility including the required safe work practices required in the operating procedures section of the standard; and
  • Advise the employer of any unique hazards presented by the contract employer's work.

Training

Process Safety Requirement - Training

Initial Training
OSHA believes that the implementation of an effective training program is one of the most important steps that an employer can take to enhance employee safety. Accordingly, PSM requires that each employee presently involved in operating a process or a newly assigned process must be trained in an overview of the process and in its operating procedures. The training must include emphasis on the specific safety and health hazards of the process, emergency operations including shutdown, and other safe work practices that apply to the employee's job tasks. Those employees already involved in operating a process on the PSM effective date do not necessarily need to be given initial training. Instead, the employer may certify in writing that the employees have the required knowledge, skills, and abilities to safely carry out the duties and responsibilities specified in the operating procedures.

Refresher Training
Refresher training must be provided at least every three years, or more often if necessary, to each employee involved in operating a process to ensure that the employee understands and adheres to the current operating procedures of the process. The employer, in consultation with the employees involved in operating the process, must determine the appropriate frequency of refresher training.

Training Documentation
The employer must determine whether each employee operating a process has received and understood the training required by PSM. A record must be kept containing the identity of the employee, the date of training, and how the employer verified that the employee understood the training.

Employee Participation

Process Safety Requirement - Employee Participation

Employers must develop a written plan of action to implement the employee participation required by PSM. Under PSM, employers must consult with employees and their representatives on the conduct and development of process hazard analyses and on the development of the other elements of process management, and they must provide to employees and their representatives access to process hazard analyses and to all other information required to be developed by the standard.

Process Safety Information (PSI)

Process Safety Requirement - Process Safety Information

Employers must complete a compilation of written process safety information before conducting any process hazard analysis required by the standard. The compilation of written process safety information, completed under the same schedule required for process hazard analyses, will help the employer and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals. Process safety information must include information on the hazards of the highly hazardous chemicals used or produced by the process, information on the technology of the process, and information on the equipment in the process. Information on the hazards of the highly hazardous chemicals in the process shall consist of at least the following:1

  • Toxicity,
  • Permissible exposure limits,
  • Physical data,
  • Reactivity data,
  • Corrosivity data, and
  • Thermal and chemical stability data, and hazardous effects of inadvertent mixing of different materials.

Information on the technology of the process must include at least the following:

  • A block flow diagram or simplified process flow diagram,
  • Process chemistry,
  • Maximum intended inventory,
  • Safe upper and lower limits for such items as temperatures, pressures, flows or compositions, and
  • An evaluation of the consequences of deviations, including those affecting the safety and health of employees.

Where the original technical information no longer exists, such information may be developed in conjunction with the process hazard analysis in sufficient detail to support the analysis.

1Note: Material Safety Data Sheets (MSDSs) meeting the requirements of the Hazard Communication Standard (20 CFR 1910.1200) may be used to comply with this requirement to the extent they contain the required information.

Information on the equipment in the process must include the following:
  • Materials of construction,
  • Piping and instrument diagrams (P&IDs),
  • Electrical classification,
  • Relief system design and design basis,
  • Ventilation system design,
  • Design codes and standards employed,
  • Material and energy balances for processes built after May 26, 1992, and
  • Safety systems (e.g., interlocks, detection, or suppression systems).

The employer shall document that equipment complies with recognized and generally accepted good engineering practices. For existing equipment designed and constructed in accordance with codes, standards, or practices that are no longer in general use, the employer shall determine and document that the equipment is designed, maintained, inspected, tested, and operated in a safe manner.

The compilation of the above described process safety information provides the basis for identifying and understanding the hazards of a process and is necessary in developing the process hazard analysis and may be necessary for complying with other provisions of PSM such as management of change and incident investigations.

Process Hazard Analysis

Process Safety Requirement - Process Hazard Analysis

The process hazard analysis is a thorough, orderly, systematic approach for identifying, evaluating, and controlling the hazards of processes involving highly hazardous chemicals. The employer must perform an initial process hazard analysis (hazard evaluation) on all processes covered by this standard. The process hazard analysis methodology selected must be appropriate to the complexity of the process and must identify, evaluate, and control the hazards involved in the process.

First, employers must determine and document the priority order for conducting process hazard analyses based on a rationale that includes such considerations as the extent of the process hazards, the number of potentially affected employees, the age of the process, and the operating history of the process. All initial process hazard analyses should be conducted as soon as possible, but at a minimum, the employer must complete no fewer than 25 percent by May 26, 1994; 50 percent by May 26, 1995; 75 percent by May 26, 1996; and all initial process hazard analyses by May 26, 1997. Where there is only one process in a workplace, the analysis must be completed by May 26, 1994.

Process hazard analyses completed after May 26, 1987, that meet the requirements of the PSM standard are acceptable as initial process hazard analyses. All process hazard analyses must be updated and revalidated, based on their completion date, at least every five years.

The employer must use one or more of the following methods, as appropriate, to determine and evaluate the hazards of the process being analysed:

  • What-if, Checklist,
  • What-if/checklist,
  • Hazard and operability study (HAZOP),
  • Failure mode and effects analysis (FMEA),
  • Fault tree analysis, or
  • An appropriate equivalent methodology.

A discussion of these methods of analysis is contained in the companion publication, OSHA 3133, Process Safety Management Guidelines for Compliance. Whichever method(s) are used, the process hazard analysis must address the following:

  • The hazards of the process;
  • The identification of any previous incident that had a potential for catastrophic consequences in the workplace;
  • Engineering and administrative controls applicable to the hazards and their interrelationships, such as appropriate application of detection methodologies to provide early warning of releases. Acceptable detection methods might include process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors;
  • Consequences of failure of engineering and administrative controls;
  • Facility siting;
  • Human factors; and
  • A qualitative evaluation of a range of the possible safety and health effects on employees in the workplace if there is a failure of controls.

OSHA believes that the process hazard analysis is best performed by a team with expertise in engineering and process operations, and that the team should include at least one employee who has experience with and knowledge of the process being evaluated. Also, one member of the team must be knowledgeable in the specific analysis methods being used.

The employer must establish a system to address promptly the team's findings and recommendations; ensure that the recommendations are resolved in a timely manner and that the resolutions are documented; document what actions are to be taken; develop a written schedule of when these actions are to be completed; complete actions as soon as possible; and communicate the actions to operating, maintenance, and other employees whose work assignments are in the process and who may be affected by the recommendations or actions.

At least every five years after the completion of the initial process hazard analysis, the process hazard analysis must be updated and revalidated by a team meeting the standard's requirements to ensure that the hazard analysis is consistent with the current process.

Employers must keep on file and make available to OSHA, on request, process hazard analyses and updates or revalidation for each process covered by PSM, as well as the documented resolution of recommendations, for the life of the process.

Operating Procedures

Process Safety Requirement - Operating Procedures

The employer must develop and implement written operating procedures, consistent with the process safety information, that provide clear instructions for safely conducting activities involved in each covered process. OSHA believes that tasks and procedures related to the covered process must be appropriate, clear, consistent, and most importantly, well communicated to employees. The procedures must address at least the following elements:

Steps for each operating phase:
  • Initial startup;
  • Normal operations;
  • Temporary operations;
  • Emergency shutdown, including the conditions under which emergency shutdown is required, and the assignment of shut down responsibility to qualified operators to ensure that emer gency shutdown is executed in a safe and timely manner;
  • Emergency operations;
  • Normal shutdown; and
  • Startup following a turnaround, or after an emergency shut down.

Operating limits:
  • Consequences of deviation, and
  • Steps required to correct or avoid deviation.
  • Safety and health considerations:
  • Properties of, and hazards presented by, the chemicals used in the process;
  • Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment;
  • Control measures to be taken if physical contact or airborne exposure occurs;
  • Quality control for raw materials and control of hazardous chemical inventory levels; and
  • Any special or unique hazards.
  • Safety systems (e.g., interlocks, detection or suppression systems) and their functions.

To ensure that a ready and up-to-date reference is available, and to form a foundation for needed employee training, operating procedures must be readily accessible to employees who work in or maintain a process. The operating procedures must be reviewed as often as necessary to ensure that they reflect current operating practices, including changes in process chemicals, technology, and equipment, and facilities. To guard against outdated or inaccurate operating procedures, the employer must certify annually that these operating procedures are current and accurate.

The employer must develop and implement safe work practices to provide for the control of hazards during work activities such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. These safe work practices must apply both to employees and to contractor employees.

Process Safety Management

The Problem

Unexpected releases of toxic, reactive, or flammable liquids and gases in processes involving highly hazardous chemicals have been reported for many years. Incidents continue to occur in various industries that use highly hazardous chemicals which may be toxic, reactive, flammable, or explosive, or may exhibit a combination of these properties. Regardless of the industry that uses these highly hazardous chemicals, there is a potential for an accidental release any time they are not properly controlled. This, in turn, creates the possibility of disaster.

Recent major disasters include the 1984 Bhopal, India, incident resulting in more than 2,000 deaths; the October 1989 Phillips Petroleum Company, Pasadena, TX, incident resulting in 23 deaths and 132 injuries; the July 1990 BASF, Cincinnati, OH, incident resulting in 2 deaths, and the May 1991 IMC, Sterlington, LA, incident resulting in 8 deaths and 128 injuries.

Although these major disasters involving highly hazardous chemicals drew national attention to the potential for major catastrophes, the public record is replete with information concerning many other less notable releases of highly hazardous chemicals. Hazardous chemical releases continue to pose a significant threat to employees and provide impetus, internationally and nationally, for authorities to develop or consider developing legislation and regulations to eliminate or minimize the potential for such events.

On July 17, 1990, OSHA published in the Federal Register (55 FR 29150) a proposed standard, - ”Process Safety Management of Highly Hazardous Chemicals” - containing requirements for the management of hazards associated with processes using highly hazardous chemicals to help assure safe and healthful workplaces.

OSHA's proposed standard emphasized the management of hazards associated with highly hazardous chemicals and established a comprehensive management program that integrated technologies, procedures, and management practices.

The notice of proposed rulemaking invited comments on any aspect of the proposed standard for process safety management of highly hazardous chemicals and announced the scheduling of a hearing to begin on November 27, 1990, in Washington, DC.

On November 1, 1990, OSHA published a Federal Register notice (55 FR 46074) scheduling a second hearing to begin on February 26, 1991, in Houston, TX, enumerating additional issues, and extending the written comment period until January 22, 1991.

The hearings on the proposed standard were held in Washington, DC, from November 27, 1990, through December 4, 1990, and in Houston, TX, from February 26, 1991, through March 7, 1991. The Administrative Law Judge presiding at the hearings allowed participants to submit post-hearing comments until May 6, 1991, and file post-hearing briefs until June 5, 1991. OSHA received more than 175 comments in response to the notice of proposed rulemaking. In addition to these comments, the hearings resulted in almost 4,000 pages of testimony and almost 60 post-hearing comments and briefs. For readers' convenience, this publication includes, as an appendix, the full text of the final OSHA standard issued in the Federal Register on February 24, 1992, including the list of covered chemicals and threshold amounts.

State plan States, approved under section 18(b) of the Occupational Safety and Health Act of 1970 (see list on page 36) must adopt standards and enforce requirements which are at least as effective as Federal requirements. There are currently 25 State plan States; 23 covering private and public (State and local government) sectors and two covering public sector only. Plan States must adopt comparable standards to the Federal within six months of a Federal standard's promulgation.

Approximately four months after the publication of OSHA's proposed standard for process safety management of highly hazardous chemicals, the Clean Air Act Amendments (CAAA) were enacted into law (November 15, 1990). Section 304 of the CAAA requires that the Secretary of Labor, in coordination with the Administrator of the Environmental Protection Agency (EPA), promulgate, pursuant to the Occupational Safety and Heath Act of 1970, a chemical process safety standard to prevent accidental releases of chemicals that could pose a threat to employees.

The CAAA requires that the standard include a list of highly hazardous chemicals which includes toxic, flammable, highly reactive, and explosive substances. The CAAA also specified minimum elements that the OSHA standard must require employers to do, as follows:

  1. Develop and maintain written safety information identifying workplace chemical and process hazards, equipment used in the processes, and technology used in the processes;
  2. Perform a workplace hazard assessment, including, as appropriate, identification of potential sources of accidental releases, identification of any previous release within the facility that had a potential for catastrophic consequences in the workplace, estimation of workplace effects of a range of releases, and estimation of the health and safety effects of such a range on employees;
  3. Consult with employees and their representatives on the development and conduct of hazard assessments and the development of chemical accident prevention plans and provide access to these and other records required under the standard;
  4. Establish a system to respond to the workplace hazard assessment findings, which shall address prevention, mitigation, and emergency responses;
  5. Review periodically the workplace hazard assessment and response system;
  6. Develop and implement written operating procedures for the chemical processes, including procedures for each operating phase, operating limitations, and safety and health considerations;
  7. Provide written safety and operating information for employees and employee training in operating procedures, by emphasizing hazards and safe practices that must be developed and made available;
  8. Ensure contractors and contract employees are provided with appropriate information and training;
  9. Train and educate employees and contractors in emergency response procedures in a manner as comprehensive and effective as that required by the regulation promulgated pursuant to section 126(d) of the Superfund Amendments and Reauthorization Act;
  10. Establish a quality assurance program to ensure that initial process-related equipment, maintenance materials, and spare parts are fabricated and installed consistent with design specifications;
  11. Establish maintenance systems for critical process-related equipment, including written procedures, employee training, appropriate inspections, and testing of such equipment to ensure ongoing mechanical integrity;
  12. Conduct pre-startup safety reviews of all newly installed or modified equipment;
  13. Establish and implement written procedures managing change to process chemicals, technology, equipment and facilities; and
  14. Investigate every incident that results in or could have resulted in a major accident in the workplace, with any findings to be reviewed by operating personnel and modifications made, if appropriate.


CIMAH Regulations Enforcer - DOSH

The Department of Occupational Safety and Health (DOSH) is a department under the Ministry of Human Resources. This department is responsible for ensuring the safety, health and welfare of people at work as well as protecting other people from the safety and health hazards arising from the activities sectors which include:

  • Manufacturing
  • Mining and Quarrying
  • Construction 
  • Hotels and Restaurant
  • Agriculture, Forestry and Fishing
  • Transport, Storage and Communication
  • Public Services and Statutory Authorities
  • Utilities - Gas, Electricity, Water and Sanitary Services 
  • Finance, Insurance, Real Estate and Business Services
  • Wholesale and Retail Trades

As a government agency, the department is responsible for the administration and enforcement of legislations related to occupational safety and health of the country, with a vision of becoming an organisation which leads the nation in creating a safe and healthy work culture that contributes towards enhancing the quality of working life.

Reference: DOSH

Safety and Health Legislation in Malaysia

Safety and Health legislation in Malaysia hierarchy as below:

  1. Acts (link)
  2. Regulations (link)
  3. Order (link)
  4. Code of Practice (link)
  5. Guidelines (link)

Major Hazard Competent Person Responsibilities

Competent Person Major Hazard is registered under the provisions of Regulation 13, Occupational Safety and Health (The Control of Industrial Major Accident Hazards) Regulations, 1996.

Duties of a Competent Person

To provide consultations to the manufacturer in major hazard control especially in the following areas:
In the preparation of a written report (new report) containing the information specified under the Schedule 6 of the Regulations for submission to the Director General.

  • In the preparation of a further report (modification report) to take account of those changes make in any modification works for submission to the Director General.
  • In the preparation of a further report (updating report) which shall have regard in particular to new technical knowledge which materially affects the particulars in the previous report relating to safety and development in the knowledge of hazard assessment for submission to the Director General.
  • In the preparation and keeping up to date an adequate on site emergency plan for submission to the Director General.
Reference: DOSH

Link to Major Hazard Competent Person Qualifications

List of Major Hazard Competent Person

"Competent Person" means an employee or any other person who is appointed by the manufacturer and approved in writing by the Director General to prepare a written report pursuant to the requirements of Part IV.

The list of Major Hazard Competent Person can be found in the DOSH's website here.

CIMAH Industrial Activity Report Contents

The report on industrial activity under subregulations 14(1) and 15(1) shall contain the following information:

  • Information relating to every hazardous substances involved in the industrial activity and its relevant quantity as listed in Schedule 2
  • Information relating to the installation
  • Information relating to the management for controlling the industrial activity
  • Information relating to a potential major accident in the form of risk assessment

CIMAH Regulations 1996

CIMAH regulations apply to all industrial activities except:
- A nuclear installation
- An installation under armed forces
- A vehicle or vessel transporting hazardous substances to/from the site of an industrial activity
- An industrial activity involved with quantity of hazardous substances less than 10% of threshold quantity

Part I Preliminary
Reg.  1 - Citation and commencement
Reg.  2 - Application
Reg.  3 - Interpretation
Reg.  4 - Limitation of power of officer
Reg.  5 - Obligations of manufacturer and employee

Part II - Identification and Notification of an Industrial Activity
Reg.  6 - Application
Reg.  7 - Identification and notification
Reg.  8 - Notification of Change

Part III DOSO for Non-Major Hazard Installation
Reg. 9 - Application
Reg. 10 - DOSO
Reg. 11 - Review of DOSO

Part IV Report on Industrial Activity & ERP for Major Hazard Installation
Reg. 12 - Application
Reg. 13 - Registration of Competent Person
Reg. 14 - CIMAH Report
Reg. 15 - Modification
Reg. 16 - Updating CIMAH Report
Reg. 17 - Review of CIMAH Report

Reg. 18 - On-site Emergency Plan
Reg. 19 - Updating On-site Emergency Plan
Reg. 20 - Review of On-site Emergency Plan
Reg. 21 - Off-site Emergency Plan

Reg. 22 - Information to Public

Part V Notification of Major Accident
Reg. 23 - Notification of Major Accident

Part VI Penalty
Reg. 24 - Penalty (RM50,000 or 2 years imprison)

Sch. 1 - Indicative criteria
Sch. 2 - List of substances & quantity
Sch. 3 - Information to public
Sch. 4 - Industrial installations
Sch. 5 - Notification form (JKKP 5)
Sch. 6 - Information in industrial activity report