Cpe 615 process safety notes unedited mo

 Example of unsafe conditions  Safety policy not defined and communicated  Responsibility, authority and accountability not assigned  Emphasis on production, rather on safety  Lack

 Safety

 The older strategy of accident prevention through the use of PPEs and

a variety of rules and regulations

 Emphasis is on the worker safety

1.1.2 Hazards versus Risk

 Deals with acute effects of hazards

 Health

 A state of physical and mental well-being

 Including the absence of disease or infirmity

 Deals with chronic effects of hazards

 Health and safety issues must be a given great emphasis starting from the design stage

bottom line, such as

 Penalties and fines

 Worker compensation

 Engineers who design the workplace and its equipment or who manage and supervise workers need to have an understanding of the safety and health regulation

1.1.5 Major Process Industry

 40 tons of Methyl Isocynate escaped from Union Carbide Plant

 Thousands more died in weeks that followed

 More than 500,000 suffered

 Chernobyl

 26 April 1986

 Chernobyl Nuclear Reactor, Ukraine

 Large area of Russia, Ukraine and Belarus was evacuated

 336,000 people resettled

 Fewer than 50 direct death, but thousands of cancer-related cases

 Severe damage to the environment

 Piper Alpha

 167 out of 229 people died

 Initial explosion followed by a fierce fire which, in turn, triggered off a further series of explosions

 Flames could be seen 100 km away

 Bright Sparkles

 1991

 Fire ignited from product testing activities

 Fire and explosion destroyed the factory completely

 23 people died and 103 other sustained injuries

 BP Texas City Refinery

 23 March 2005

 Fire and Explosion

 Killing 15 workers and injuring more than 170 others

 Deep Water Horizon Platform

 Gulf coast of United States

 Platform explosion and sinking, killed 11 workers

 Leaking of hundreds of thousands of barrels of oil into the Gulf of Mexico that is making it probably the worst industrial environmental disaster in US history

 Near miss

had the potential to do so

 Or called close call

1.2.2 Why Do Accidents Occur?

 We choose to handle dangerous processes, materials, energies

 To make a living

 To provide society with desirable products

 A potential for loss events exist

1.2.3 How Do Accidents Occurs

1) Domino theory

 From Herbert W Heinrich

 An early pioneer of accident prevention and industrial safety

 Studied 75000 reports of accidents for insurance claims and concluded

 88% caused by unsafe acts committed by workers

 10% of industrial accidents are caused by unsafe conditions

 2% of industrial accidents are unavoidable

 Injuries result from a complete series of factors

 An accident can occur as a result of unsafe act and/or unsafe conditions

 Most accidents are the result of the unsafe behaviour by people

 An unsafe act or an unsafe conditions does not immediately result in accident/injury

 The reasons why people commit unsafe acts can serve as helpful guides in selecting corrective actions

 The severity of an accident is largely fortuitous and the factors that cause it are largely preventable

 The prevention technique are analogous with the best quality and productivity techniques

 Management should assume responsibility for safety because it is in the best position to get results

 The supervisor is the key person in the prevention of industrial accidents

 In addition to the direct costs of an accident, there are also hidden or indirect cost

 5 factors in the sequence of events leading up to an accident

1 Social Environment and Ancestry

2 Fault of person (carelessness)

 Negative character traits, whether inherited or acquired are why people behave in unsafe manner and why hazardous conditions exist

3 Unsafe act or condition

 Unsafe act committed by people

 Unsafe conditions due to the presence of mechanical / physical hazards

4 Accident

5 Injury

 Injuries are caused by the action of preceding factors

 Removal of the central factor (unsafe acts/hazardous conditions) negates the action of the preceding factors and, in so doing, prevents accidents and injuries

2) Human factors theory

 Attributes accidents to a chain of events that were ultimately the result of human error

 Human factors

 Overload

the load that a person is carrying in a given state

training, state of mind, fatigue, stress and physical conditions

 Detecting hazard but not correcting it

 Removing safeguards from machines and equipment

 Ignoring safety

 Performing task without the requisite training

 Misjudging the degree of risk involved with a given task

3) Accident/Incident theory

 Developed by Dan Peterson

 Extension of the human factors theory

 Introduced such new elements as ergonomic traps, the decision to err (mistake) and system failure

 Important contribution: system failure

 Some ways that a system fails

 Management does not establish a comprehensive safety policy

 Responsibility and authority with regard to safety are not clearly defined

 Safety procedures such as measurement, inspection, correction and investigation are ignored or given sufficient attention

 Employees do not receive proper orientation

 Employees are not given sufficient safety training

 Summary

4) Sociotechnical system framework

 Every fault in an incident scenario will have been affected by root causes

 Failures in large industrial system cannot be considered solely in technical terms

 The sociotechnical system approach emphasis the individual,

performance

 Summary

1.2.4 Causes of Accidents

1) Immediate cause

 The most apparent cause

 Represent the initiators of the incidents

 The symptom

 Normally called either unsafe acts or unsafe conditions

 Example of unsafe acts

 Horseplay

 Defeating safety devices

 Failure to secure or warn

 Operating without authority

 Working on moving equipment

 Taking an unsafe position or posture

 Operating or working at an unsafe speed

 Unsafe loading, placing, mixing, combining

 Failure to use PPE

 Example of unsafe conditions

 Safety policy not defined and communicated

 Responsibility, authority and accountability not assigned

 Emphasis on production, rather on safety

 Lack of direct communication with management

 Unsafe design and selection of equipment, chemicals, process and facilities

 Inadequate safety inspection procedures

 Insufficient procedures for normal and emergency situations

 Lack of training

 Inadequate employee selection, supervision and rewards

1.2.5 The ‘Accident Weed’

1.2.6 Cost of Accidents

1) Direct cost

 Expenses incurred because of an accident

 Include medical expenses and compensation paid to an injured employee for time away from work

 Costs for repair and replacement of damaged items

2) Indirect cost of accidents

 Real expenses associated with accident

 Example

 Lost time of injured employee

 Time lost by other employees to assist injured co-workers

 Time lost by supervisor to investigate accident, prepare report and make adjustment of work arrangements

 Time spent by company first aid, medical staff

 Lost of profit

 Paper works for insurance claim

 Production losses 1.2.7 To Keep Accident from Happening?

 Design of process

 Management of process

 Operation of process

 Regulations

CHAPTER 2: SAFETY LEGISLATION AND REGULATIONS

CHAPTER 2.1: INTRODUCTION TO SAFETY LEGISLATION AND REGULATIONS 2.1.1 Legislation, Act and Regulation

 Based on the act that has been approved

 Served as a means to make the act a lot easier to follow and adhere to

 One act can have numerous regulations 2.1.2 Evolution of OSH Legislation

 In Malaysia, OSH Legislation was based on the traditional approach

 History

 Industrial revolution in Britain

 Resulted in

 Some unsafe and unhealthy working conditions

 High numbers of injury and disease

 Legislation to overcome this problem was introduced very slowly

 1844

 Specific safety provisions addressed the fencing of dangerous machinery

 Later

century extended safety provisions

to men and to other industries and hazards

 1972

 Report prepared by a committee of inquiry, chaired by Lord Robens

 Known as the Robens Report

 Major recommendations made by Robens:

 There should be a single, comprehensive Act dealing with occupational safety and health that should contain a clear statement of the basic principles of the safety responsibility of employers, employees and manufacturers, based on common law

 Act shall be supported by regulations and voluntary codes with the emphasis on the latter

2.1.3 Introduction to OSHA 1994

 Stands for Occupational Safety and Health Act 1994

 Made considering the fact that the Factory and Machinery Act 1967 only covers occupational safety and health in:

 Date of coming into operation: 25 February 1994

 Contains 15 parts , 67 sections and 3 schedules

 Main principles that had been taken as the foundation in the drafting of this Act

 Without co-operation between employers and employees, none of the occupational safety and health programmes carried out would succeed

 Transport, storage and communication

 Wholesale and Retail Trades

 Hotel and Restaurants

 Finance, Insurance Real Estate and Business services

 Public services and statutory authorities

 Not applicable to

 Work on board ships

2.1.5 Differences between FMA 1967 and OSHA 1994

2.1.6 Concept of OSHA 1994

 Accident prevention is an essential part of good management and workmanship

 Management and workers must cooperate

 Top management must take the lead

 A define and known safety and health policy

 Organization and resources to achieve policy

 Flow summary:

2.1.7 Regulations under OSHA 1994

(Exception) Regulations 1995

CIMAH

4) OSH (Classification, Packaging and Labelling of Hazardous Chemicals) Regulations 1997 – CPL

6) OSH (Use and Standards of Exposure of Chemicals Hazardous to Health)

7) OSH (Notification of Accident, Dangerous Occurrence, Occupational

2.1.8 Examples for OSHA 1994

 Examples of guideline

 Guidelines for Public Safety and Health at Construction Site Management and workers must cooperate

 Guidelines on First-Aid Facilities in the workplace

 Guidelines for Labelling of Hazardous Chemicals

 Guidelines for the Preparation of a Chemical Register

 Guidelines on the Control of Chemicals Hazardous to Health

 Guidelines on Occupational Safety and Health in Agriculture

 Examples of section

 Section 4: Object of the Act

 To secure the safety, health and welfare of persons at work against risks

 To protect persons at a place of work other than persons at work against risks

 To promote an occupational environment for persons at work which

is adapted to their physiological and psychological needs

 To provide the means whereby the associated occupational safety and health legislation may be progressively replaced by a system of regulations and approved industry codes of practice to maintain or improved the S&H standards

 Section 15: General Duties of Employer and Self-Employed

Persons

 To ensure, so far as is practicable, the safety, health and welfare at work of all his employees

 To provide and maintain plant and system of work that are, so far as

is practicable, safe and without risk to health

 To ensure safety and absence of risks to health in connection with the use or operation, handling, storage and transport of plant and substances

 To provide information, instruction, training and supervision

 To maintain any place of work under the control of the employer or self-employed person

 To provide access to and egress from it that are safe and without such risks

 To provide and maintain a working environment that is safe, without risks to health and adequate as regards facilities for their welfare at work

 Section 16: Duty to Formulate Safety and Health Policy

 It shall be the duty of every employer and every self-employed person to:

 Prepare and revise a written statement on safety and health policy

 Arrange for the time being in force in carrying out the policy

 Bring the statement and any revision of it to the notice of all of this employees

 Section 24: General Duties of an employee

 To take reasonable care for the safety and health of himself and of other persons who may be affected by his acts or omissions at work

 To cooperate with his employers or any other person

 To wear or use at all times any PPE

 To comply with any instruction or measure on OSH 2.1.9 Other Laws

 Laws of Malaysia Act 139

 Parts:

 Part 1: Preliminary

 Part 2: Safety, Health and Welfare

 Part 3: Person in Charge and Certificate of Competency

 Part 4: Notification of Accident, Dangerous Occurrence and Dangerous Diseases

 Part 5: Notice of Occupation of Factory, and Registration and Use of Machinery

 Part 6: General

2) Petroleum (Safety Measures) Act 1984

 Laws of Malaysia Act 302

 Part 2: Transportation of Petroleum by Road and Railway

 Part 3: Transportation of Petroleum by Water

 Part 4: Transportation of Petroleum by Air

 Part 5: Transportation of Petroleum by Pipelines

 Part 6: Storage and Handling of Petroleum

 Part 7: Utilization of Equipment, Gadgets, Materials, Plants, Appliances, Buildings, Structures and Installations

 Part 8: Existing equipment, Gadgets, Materials, Plants, Appliances, Buildings, Structures and Installations

 Part 9: General Powers for Rectification

 Part 10: Liability

 Par 11: General

2.1.10 Function of DOSH

 To study and review the policies and legislations of occupational safety and health

 To enforce the following legislations:

 Occupational Safety and Health Act 1994 and its regulations

 Factories and Machinery Act 1967 and its regulations

 Part of Petroleum Act 1984 (Safety Measures) and its regulations

 To conduct research and technical analysis on issues related to occupational safety and health at the workplace

 To carry out promotional and publicity programs to employers, workers and the general public to foster

 To increase the awareness of occupational safety and health

 To provide advisory service and information to government and private agencies pertaining to management and technical aspects of occupational safety and health

 To become a secretariat for the National Council regarding occupational safety and health

CHAPTER 2.2: REGULATIONS UNDER OSHA 1994

 Apply to all industrial activities except:

 A nuclear installation

 An installation under the armed forces

 A vehicle or vessel transporting hazardous substance to or from the site

of an industrial activity

 An industrial activity where quantity of hazardous substance equal or less than 10% of threshold quantity of hazardous substances

 Definition

explosion resulting from uncontrolled development in the course of an industrial activity, which leads to serious danger to persons, whether immediate or delayed, inside or outside an installation, or to the environment, and involving one or more hazardous substance

Major hazard installation

An industrial activity which produces, processes, handles, uses, disposes of or stores, permanently or temporarily, one or more hazardous substances equal

or exceed the threshold quantity

 Obligations of Manufacturer an Employee

 Every manufacturer who undertakes an industrial activity shall

 Comply with the requirements of these Regulations

 As soon as he becomes aware of an imminent danger, take immediate action

 To rectify the situation

 Establish and maintain a good management system for controlling any major accident

 Identification and notification of industrial activity

 Every manufacturer needs to identify an industrial activity within his control and submit to the Director General the notification of industrial activity form specified in Schedule 5

 The authority will determine whether the installation

 Is a major hazard installation even though quantity of hazardous substance less than threshold quantity, if the authority feels that installation may cause a major accident

 Is not a major hazard installation even though equal or exceed threshold quantity, if the authority feels that installation is incapable of causing a major accident

 Any change of the status of installation shall be notified to the authority

 Hazard Installation

 Non major hazard installation

 Identify possible major accident hazards

 Show adequate steps taken to

 Prevent any major accident or minimize its consequences to people and the environment

 Provide people working on site with information, training and equipment necessary to ensure their safety

 Prepare and keep up to date an adequate on-site emergency plan

 The authority may request additional information or whatever

 Major hazard installation

 Require preparation of safety report by competent person

 Competent person is an employee or person appointed by the manufacturer and who has been approved by the Director General

to prepare a written report

 Modification

 Any modification to the industrial activity to which the report relates which can materially affect the particulars in the report

 A competent person must prepare a further written report and has sent

a copy of the Report to the Director General who will review it and direct the manufacturer to submit further information within such time as he may specify

 The manufacturer shall be entitled to take urgent and remedial action with respect to an industrial activity in order to put an end to or prevent imminent danger to life or property

 Emergency plan

 Required to submit an on-site and off-site emergency plan

 On-site emergency plan

 The manufacturer shall prepare and keep an up-to-date and adequate on-site emergency plan and include the name of the person who is responsible for safety and the names of those who are authorized to take action in the event of an emergency

 The manufacturer shall ensure that the on-site emergency plan prepared is constantly updated and that every person on the site who is affected by the plan is informed of its relevant provisions

 The manufacturer shall prepare and submit the on-site emergency to the Director General at least three months before the commencement of the industrial activity or within three months from the date of the determination for an industrial activity which has been determined as a major hazard installation

 Updating and review

 Where the manufacturer has prepared an on-site emergency plan and the industrial activity concerned is continuing, the manufacturer shall update the on-site emergency plan as part of the report

 The Director General may review the on-site emergency plan submitted to him, and shall, if he is of satisfactory, direct the manufacturer in writing to improve the emergency plan within such time as he may specify

 Off-site emergency plan

 The manufacturer shall inform the local authority or port authority of that area that his industrial activity is considered is capable of producing major accident hazard and of the need for the preparation

of an off-site emergency plan for the area surrounding his site\

 The manufacturer shall

 Inform the authorities within three months of the commencement

or within three months of the date of the determination for an industrial activity which has been determined as a major hazard installation

 Provide the authorities with the information relating to the industrial activity under his control, and afford to the local or port authority upon request all reasonable facilities needed

 Inform the public

 The manufacturer has to ensure that persons outside the site who are likely to be affected by a major accident occurring at the site, are supplied with at least the information specified in Schedule 3

 The manufacturer shall endeavour to enter into an agreement with the authorities to disseminate the information specified in Schedule 3 to the persons concerned but the manufacturer shall remain responsible for the accuracy, completeness and form of the information supplied

 Notification of major accidents

 Where a major accident occurs on a site, the manufacturer shall notify the nearest occupational safety and health office of the accident quickly shall provide

 The following information relating to the accident as soon as it becomes available

 The circumstances of the accident

 The hazardous substances involved

 The date available for assessing the effects of the accident on persons and the environment

 The emergency measures taken

 A statement of the steps envisaged to alleviate medium or long term effects of the accident and prevent the recurrence of such an accident

2.2.2 CPL 1997: Classification, Packaging and Labelling Hazardous Chemicals Regulations

 Application

 To a supplier of hazardous chemicals for use at work except hazardous chemicals which are

 A radioactive material under the Atomic Energy Licensing Act 1984

 A pesticide under the Pesticides Act 1974

 Poisons in the Poisons List Order 1993, except for chemicals which are classified therein as industrial and laboratory poisons

 A drug under the Sales of Drugs Act 1952

 Scheduled wastes in the First Schedule of the Environmental Quality (Schedule Wastes) Regulation 1989

 Foodstuff

 Shall not apply to

 The transportation of hazardous chemicals by rail, inland waterway, sea

or air

 Hazardous chemicals in transit which are stored at a bonded warehouse

 Duty of supplier to classify

 It shall be the duty of a supplier to classify hazardous chemicals according to the specified nature of the risk involved based on the categories of hazards in Schedule `

 Chemicals which fall within more than one category of hazard in parts A and B of schedule I shall be classified under the category which poses the greatest degree of hazard in each part

 The materials constituting the packaging and the fastening are not susceptible to adverse attack by the contents therein or liable to form harmful or dangerous compounds with the contents

 The packaging and fastening are strong and solid throughout to ensure that they will not come loose and will safely meet the normal stress and strain of handling

 Containers fitted with replaceable fastening device are so designed that the packaging can be repeatedly designed that the packaging can be repeatedly without the contents escaping

 A supplier shall ensure that packages are initially closed with a seal

in such a way that once the packages are opened, the seal are broken and could not be repaired

 The name, address and telephone number of the supplier

 The danger symbol and indication of danger as specified in Schedule II

 The nature of the special risk associated with the use of the chemical as specified in Schedule III

 The safety precautionary measures as specified in Schedule IV

 Duty of supplier to furnish Chemical Safety Data Sheet

 A supplier shall furnish an up-to-date Chemical Safety Data Sheet for each hazardous chemical supplied

 The Chemical Safety Data Sheet shall contain the following information:

 The chemical product itself including the trade or common name of the chemical and the company identification with the details of the supplier

 The composition of the ingredients that clear identifies the hazardous chemical for the purpose of conducting a hazard evaluation

 The toxicological information (including the potential routes of entry into the body and the possibility of synergism with other chemicals or hazards encountered at work)

 The exposure controls and personal protection (including the possible methods of monitoring workplace exposure)

 The hazard identification

 The first aid measures

 The fire fighting measures

 The accidental release measures

 The handling storage

 The physical and chemical properties

 The stability and reactivity

 The ecological information

 The disposal information

 The transport information

 The date of preparation of the Chemical Safety Data Sheet

2.2.3 Safety and Health Officer Order 1997

 Application of the Law

 The employer of the following class or description of industries shall employ a safety and health officer

 Any building operation where the total contract price of the project exceeds RM 20 million

 Any work of engineering construction where the total contract price of the project exceeds RM 20 million

 Any ship building employing at the peak of the work more than 100 employees

 Any gas processing activity or petrochemical industries employing more than 100 employees

 Any chemical and allied industry employing more than 100 employees

 Any boiler and pressure vessel manufacturing activity employing more than 100 employees

 Any metal industry where there is canning or stamping or blanking or shearing or bending operations and employing more than 100 employees

 Any wood working industry where there is cutting or sawing or planning

or moulding or sanding or peeling or any combination of the above, and employing more than 100 employees

 Any cement manufacturing activity employing more than 100 employees

 Any other manufacturing activity other than the manufacturing activity specified, employing more than 500 employees

CHAPTER 3: HAZARDS IDENTIFICATION CHAPTER 3.1 INTRODUCTION TO HAZARDS IDENTIFICATION 3.1.1 Categories of Hazards

 Act of God and natural causes

 Abnormal environment extremes

 External interference

 Instability of structures

 External releases of energy or

 Should be viewed as an integral part of securing the long term profitable development of the business

 To identify

 The hazards that will exist

 The consequences that may occur due to these hazards

 The likelihood that these events may take place

 The likelihood that safety system and emergency system will function properly

 The requirement is a key element of OSHA 1994

 What makes people want to look for hazards?

 The fear of getting hurt when the risk of doing a job is not minimized by mitigating the hazards

 The pressure applied by the Company to identify hazards or else a negative performance review

 The desire to meet behavioural expectations

 Personal integrity or the personal pride that one has in doing the right job

 Objectives

 To improve the safety reliability and operability of a project by recognising and eliminating or reducing potential hazards at the design stage as well as through the whole project lifecycle

 To avoid endangering the health and safety of the plant employees and nearby public

 To avoid loss of properties which will cause serious financial and economic loss

 When to carry out hazard identification

 Introduction of new plant, equipment, process, materials

 Alteration to the plant, equipment, workplace

 Change to the way the plant, equipment and area is used

 Change to the work system

 Change in location of the plant, equipment or people

 After an incident, accident or workplace illness

 The process of hazard identification can also assist in

 Revealing hazards which were overlooked in the original design and installation of plant, equipment, operating procedures and setting up of associated work systems

 Detecting hazards which have developed after the plant, equipment or work system has been established

 Highlighting any ergonomics problems associated with the plant, equipment, operating procedures

 Indicating any environmental factors

 Determining methods for on-going monitoring to achieve optimum OHS standards

 Highlighting any training requirements 3.1.4 Basic Approach to Hazard Identification and Risk Assessment

consequences

Arising from this hazard (to people, the environment, financial impact or any combination of these)

control and mitigation measures in place

To limit the consequences and / or reduce the likelihood

are adequate and reduce the risk

To as low as reasonably practicable (ALARP)

3.1.5 Components of Hazard Identification

1) Develop a register for all hazardous items

 Must list all items with details on the location and usage

 One person must be given responsibility for maintaining the register in each area

2) Analyse available information about the potential hazards associated with each item and work system

 Check accident / incident reports

 Check breakdown / maintenance records

 Check recommended training information, instructions

 Check codes of practice / standards

3) Inspect the workplace to identify hazards Analyse

 The environment

 The system of work

 The piece of plant, equipment, chemicals or other item itself

4) Record the hazard identification on

 Hazard identification checklist

 Hazard identification worksheet

 Register

3.1.6 Hazard Control Hierarchy

so that it is not there

hazardous one

Place a barrier or similar between the hazard and people within the workplace (example: a fence surrounding the hazard)

controls

Install or using additional machinery (example: ventilation system, guarding on machinery, sensor system)

controls

Safety briefings, safety trainings, work procedure, safety awareness signage

above measures have failed

 Figure:

3.1.7 Layers of Protection in Process Plant

 Layer 1: Basic process control

 Maintain variables at set point

 Layers 2: Alarms

 Alert operators

 Layer 3: Safety Interlock System

 Automatic action usually stops part of plant operation to achieve safe conditions

 Relies on the chemistry than on control systems, interlocks etc

 Major approach to inherently safer process design

1) Intensification / Minimise

 Change from large batch reactor to a smaller continuous reactor

 Reduce storage inventory of raw materials

 Improve control to reduce inventory of hazardous intermediate chemicals

 Reduce process hold-up

2) Substitution

 Use safer materials in place of the hazardous ones

 Use solvent that is less toxic

 Use mechanical gauges versus mercury

 Use water as a heat transfer fluid instead of hot oil

3) Moderate (Attenuation and limitation of effects)

 Reduce process temperatures and pressure

 Refrigerate storage vessels

 Dissolve hazardous material in safe solvent

 Operate at conditions where reactor runaway is not possible

 Place control room away from operations

 Separate pump rooms from other rooms

4) Simplification / error tolerance

 Keep piping systems neat and visually easy to follow

 Design control panels that are easy to comprehend

 Design plants for easy and safe maintenance

 Pick equipment that requires less maintenance

 Label vessels and controls to enhance understanding