(80d) Implementation of Process Safety Standards in an R&D Environment

In 1992, OSHA issued the Process Safety Management standard (29 CFR 1910.119) to reduce the risk to employees from potential incidents. The standard was phased in during the mid 1990's. Currently, the PSM standard is applied only to installations containing more than a threshold amount or either flammable or toxic chemicals; the threshold is typically 10,000 pounds of flammables, usually somewhat fewer pounds of toxic chemicals. The Process Safety Standard has 14 separate requirements as outlined below:

1. Employee Involvement in Process Safety Management. 2. Process Safety Information. 3. Process Hazard Analysis. 4. Operating Procedures. 5. Training. 6. Contractors. 7. Pre-Startup Safety Review. 8. Mechanical Integrity. 9. Nonroutine Work Authorizations. 10. Management of Change. 11. Incident Investigation. 12. Emergency Planning and Response. 13. Compliance Audits. 14. Trade Secrets.

(1910.119 Appendix C - Compliance Guidelines and Recommendations for Process Safety Management)

Most of the time, installations used in process development activities fall below the thresholds outlined in the PSM standard, so legally, strict adherence is not required. Although the quantities of materials may be smaller than the OSHA thresholds, most process development activities have the potential for serious injury or fatality, even if the extreme numbers envisioned when the PSM standard was crafted are not possible. Given this, most engineers would agree that some systematic approach to safety during the design and operation of all process development installations is prudent.

The PSM standard can provide a pre-built template for a systematic approach to the safe design and operation of smaller processes. There are several advantages to using the 14-point outline provided by OSHA:

? The engineer doesn't have to reinvent the wheel, independently deciding the scope of adequate safety design. The engineer will be less likely to completely ignore an essential issue. ? The engineer can use the same software tools (PHA for example) used for PSM implementation at large facilities. ? The engineer will speak the same language as his colleagues in commercial plants as well as any safety professionals he consults with. ? There is a wealth of information on the internet and in safety publications, and engineering periodicals referring to PSM issues.

For each requirement of the PSM standard, the engineer can decide the level of implementation that is appropriate, documenting the reasons for the implementation level, as well as the actions taken.

This paper will focus on our migration to applying the PSM standard at our R&D facility in Elkton MD. The site had been and still is primarily focused on customer applications development and analytical testing, using small extruders, molding machines, and analytical labs during regular business hours. In 1995, as PSM implementation was well underway in the chemical industry, we designed and installed a continuous pilot plant at Elkton. As we worked on the design and installation, it became obvious that we would have to re-write many of our R&D safety polices, adjusting for the realities of continuous operation. In 2003, we installed several small batch polymerization reactors, essentially following all 14 sections of the standard. Several issues will be addressed in the presentation:

? Which standards to implement first, and why. ? What are the costs and benefits of meeting each of 14 requirements of the PSM ? What are the difficulties of following through into the operation of the equipment, specifically management of change, training requirements, and mechanical integrity plans at a smaller site with far fewer specially trained technicians and engineers. ? What are the difficulties associated with a multi-use site (pilot plants, analytical labs, operating floor)

The authors believe that a systematic approach to process safety should be applied whatever the quantities of materials or scope of the operation: lab glassware or commercial plant. We also believe that using the 14 requirements of the PSM standard is the best starting point for this systematic approach. For a small experiment in a laboratory, a systematic approach might take a few man-hours. But the benefits in improved safety and operation are well worth the investment.