Program Overview

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Introduction to the University of Akron's Process Safety Management Program

The University of Akron has established a Process Safety Management (PSM) program to comply with the OSHA Standard regulating the process safety management of highly hazardous chemicals. The program aims to enable all affected researchers and staff to identify and understand the hazards posed by the presence of these chemicals on campus.

Scope of the Program

The program covers:

• Each research project involving a chemical listed on Table I at or above its specified threshold quantity.
• Each research project involving a flammable liquid or gas as defined in 29 CFR 1910.1200, on site in one location in a quantity of 10,000 pounds or more, except for hydrocarbon fuel used solely for workplace consumption and flammable liquids stored in atmospheric tanks.
• It does not apply to oil or gas drilling or servicing operations.

Process Safety Information

The safety information to be made readily available to those involved in the project includes:

1. Information pertaining to hazards of the highly hazardous chemicals used in the project:

• Toxicity
• Permissible exposure limits (PEL)
• Physical data
• Reactivity data
• Corrosivity data
• Thermal and chemical stability data
• Hazardous effects of inadvertent mixing of foreseeable different materials

2. Information pertaining to the technology of the project:

• A block flow diagram or simplified process flow diagram
• Process chemistry
• Maximum intended inventory
• Safe upper and lower limits of temperature, pressure, flow rates, compositions
• Evaluation of the consequences of deviations from normal operation

3. Information pertaining to the equipment in the project:

• Materials of construction
• Piping and instrument diagrams
• Electrical classification
• Relief system designs and basis
• Ventilation system design
• Design codes employed
• Material and energy balances
• Safety systems (such as interlocks, detections, and suppressions)

Process Hazard Analysis

A Safety Committee involving the Lead Researcher, Experts in the field, and Safety Officers will conduct the Process Hazard Analysis. The analysis will identify, evaluate, and control the hazards involved in the process.

Operating Procedures

The Lead Researcher will develop and implement written operating procedures consistent with the Process Safety Information. The procedures will provide clear instructions for safely conducting activities and will include:

1. The steps for each operating phase

• Initial startup
• Normal operation
• Temporary operations as the need arises
• Emergency operations such as emergency shutdown and who initiate these procedures
• Normal shutdown
• Startup following a turnaround or after an emergency shutdown

2. Operating limits

• Consequences of deviation
• Steps required to correct and/or avoid deviation
• Safety systems and their functions

3. Safety and health considerations

• Properties and hazards of the chemicals involved in the process
• Precautions to prevent exposure (Engineering, administrative controls, PPE)
• Control measures in case of physical contact or airborne exposure

Training

• Initial Training: Each researcher and employee involved in the process will be trained before working on the project.
• Refresher and Supplemental Training: There will be a refresher and supplemental training for those involved in the project every three years or whenever necessary.

Contractors

This section of the Program applies to contractors performing maintenance or repair, turnaround, major renovation, or specialty work on (or adjacent to) a covered process. The University will:

1. Obtain and evaluate information regarding the contract employer's safety performance and programs.
2. Inform contract employers of the known potential fire, explosion, or toxic release hazards related to the contractor's work and the process.
3. Develop and implement additional safe work practices consistent with those listed in the Program.

Pre-Startup Safety Review

A pre-startup safety review will be performed whenever a new project is established or a modification to a project necessitates a change in the process safety information. The review will confirm that:

• Construction is in accordance with design specifications.
• Safety, operating, maintenance, and emergency procedures are in place and are adequate.
• Process hazard analysis recommendations have been addressed and actions necessary for startup have been completed.

Mechanical Integrity

The University will establish and implement written procedures to maintain the ongoing integrity of process equipment, including:

• Pressure vessels and storage tanks
• Piping systems
• Relief and vent systems and devices
• Emergency shutdown systems
• Controls

Hot Work Permit

A permit will be required for all hot work operations. The permit must document that the fire prevention and protection requirements have been implemented prior to beginning the hot work operations.

Management of Change

The University has established written procedures to manage changes to process chemicals, technology, equipment, procedures, and facilities that affect a covered process. The procedures will assure that the technical basis for the proposed change, impact of the change on safety and health, and modifications to operating procedures are addressed prior to any change.

Incident Investigation

All incidents that have resulted in a catastrophic release of a highly hazardous chemical in the workplace, or could reasonably have so resulted, will be investigated. The investigation team will prepare a report at the conclusion of the investigation, which includes at a minimum:

• Date of the incident
• Date investigation began
• A description of the incident
• The factors that contributed to the incident
• Any recommendations resulting from the investigation

Emergency Planning and Response

The University has established an Emergency Action Plan for the entire campus in accordance with the provisions of 29 C.F.R. §1910.38(a). The Plan includes procedures for handling small releases.

Compliance Audits

The University's process safety management system will be regularly evaluated to measure its effectiveness, direct attention to potential weaknesses in the system, and verify that the procedures and practices developed under the OSHA standard are adequate. The evaluation will be conducted at least every three years.

Trade Secrets

All information needed to comply with the OSHA standard will be made available to the members of the Safety Committee. Those persons provided access to information that is classified as a trade secret may be required to enter into confidentiality agreements against disclosure of such information.

Additional Programs and Provisions

This Program is designed to be a written statement of overall University of Akron Process Safety Management rules and policies. There are a number of additional work rules, procedures, requirements, documents, reports, and separate programs that apply in particular situations or that are required by particular laws or regulations.