Clean Air Act 112(r) Risk Management Program (RMP) SPCC/FRP EPCRA

CHEMICAL EMERGENCY PREVENTION & PLANNING Newsl

ett er

July - August 2012 US EPA Region 10

Inside This Issue Editor’s Note:

OPERATING PROCEDURES The Risk Management Program (RMP) of the EPA
requires the facility to develop and implement written operating procedures that
• Lockout/Tagout provide clear instructions for safely conducting activities involved in each covered
process consistent with the process safety information….(40 CFR 68.69.) The
• Startup Hazards following articles cover two of the required procedures:
1. Provide for the control of hazards during specific operations, such as lockout/
• RMP Training tagout [68.69(d)]
2. Startup following a turnaround, or after emergency shutdown [68.69(a)(1)(vii)]
in 2012
For more information: RMP Guidance

Know Your Lock-out

CHEMICAL EMERGENCY and Tag-out Safety
PREVENTION & PLANNING
Newsletter Procedures
US EPA Region 10,
ERU ECL-116
(CCPS Safety Alert)
1200 6th Avenue, Suite 900
Seattle, Washington 98101 Hazardous energy comes in many
forms. Electrical energy can cause
206.553.1255
Fax: 206.553.0124 electrocution and burns, provide
ignition to flammable atmospheres,
R10 RMP Webpage and activate mechanical equipment.
Newsletter Contacts:
Steam can cause burns or initiate
For RMP: Javier Morales at hazardous reactions. Nitrogen
[email protected] can cause asphyxiation. Chemical
For SPCC/FRP: AK: Matt Carr at flow can cause uncontrolled
[email protected] reaction and injury. When a piece
of equipment is being worked on,
WA OR ID: Michael Sibley at
[email protected] all sources of hazardous energy
must be securely and positively
For EPCRA: Suzanne Powers at locked out until the equipment is
[email protected]
operational.
For free Subscription:
[email protected] Untold numbers of major process
safety incidents and individual
injuries have been caused by
failure of LOTO. A prime example
is the Bhopal catastrophe, one of
the worst incidents ever to have
occurred, which was caused in part
by the failure of LOTO.
It is better to learn from the
mistakes of others rather than
to learn by painful, personal
experience. The purpose of this
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 Chemical Emergency Prevention & Planning Newsletter July - August 2012

Know Your Lock-out and Tag-out Safety Procedures

continued from page 1

featured article is to share information with you, to help you lead the implementation or improvement of LOTO in your
company. A brief overview of LOTO procedures and tools are provided, as are references to more detailed resources.
Basics of LOTO
Summarized here are the bare essentials of a good LOTO program. To have a good LOTO program:

DO: DO NOT:
1. Have a corporate-wide LOTO policy that is mandatory at all sites. 1. Remove another worker’s lock unless
2. Train affected employees in proper LOTO procedures, and retrain the worker is completely unavailable
regularly. and then only remove the lock after
a qualified supervisor has verified
3. Assign authorized employees to ensure that LOTO procedures are that it is safe to remove the lock and
faithfully and thoroughly followed. authorized the removal.
4. Identify all sources of hazardous energy potentially impacting a 2. Assume that a closing and locking a
piece of equipment and lock out all sources. valve is sufficient to prevent flow. The
5. Make sure each person working on a piece pipe must also be blinded. A cut-away
of equipment applies his personal lock to the view of one blind arrangement is shown
lockout device, as shown in Figure 1. in the figure below.
6. Apply a tag to the lockout point using a
fastener that cannot be easily or accidentally
removed. Use a tag that is not easily torn or
defaced, as shown in Figure 2.
7. Make sure that any stored energy has Figure 1
been released. This includes electrical
capacitance, pressure, residual fluids and
hazardous atmospheres, and pent up
mechanical and potential energy.
8. When maintenance activity extends
beyond the current shift, replace the
personal locks of the leaving shift
with the personal locks of the arriving 3. Assume that a piece of equipment
shift. The leaving shift should make has only one electrical source. Often,
sure the arriving shift understands the equipment has two or more – all must
maintenance process and the hazards. be locked out.
Figure 2
9. Once the locks and tags are place, try to
operate the equipment
10. Locks should not be removed until the maintenance workers and
the authorizing employee are satisfied that the equipment is ready
to be operated safely.

Plan to attend the FREE EPA Risk Management

Training Day in your area

RISK MANAGEMENT PROGRAM (RMP) Training

Portland, Oregon: September 11, 2012
Find details on:
EPA Region 10’s RMP website – Portland Training

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 Chemical Emergency Prevention & Planning Newsletter July - August 2012

Learning from CASE HISTORIES

The case histories presented here come from companies with good LOTO programs. They are offered to give you a
better understanding of the full range of hazardous energy sources and situations where LOTO is important.

Lock-out, Tag-out, and Try-out Lock-out Requires a Lock

Pay particular attention to the last step in locking out Finally, never rely on an interlock for LOTO. Make sure
equipment – verify that the residual and stored energy you positively lock out all the sources of hazardous
has been released. Remember – Lock Out, Tag Out, energy. This operator wished he’d done it right:
and then Try Out. Make sure that you’re not surprised by
residual energy, as happened in this case: An operator needed to clean a mixer. The mixer had
an interlock limit switch that prevented the mixer from
Workers were attempting to clear a plugged line. The operating when the lid was up. For protection, the
LOTO permit was authorized and locks placed as per operator propped the lid up and entered (we assume
procedure. Unfortunately, the workers did not verify he performed the appropriate confined space entry
that all hazardous energy was removed. The residual procedure, but that is a lesson for another day). When
pressure from blowing out the line remained. As the mixer was clean, the operator started to climb
workers opened a flange just below the plug, material back out. As he reached up, his hand touched the lid.
was blown out, burning personnel in the immediate This was just enough to clear the 'lid is up' limit switch
area. and deactivate the interlock. Since he had not locked
out the power, the motor started. The motion of the
Take Care When Troubleshooting mixer caused the operator to fall back inside. When
he fell, the lid returned to full-open and the limit switch
Sometimes LOTO might seem inconvenient, for example interlocked the mixer mechanism. However, the mixer
if you need to have parts of a machine or process made a number of complete revolutions – badly injuring
energized for troubleshooting. In such cases, lock out the operator – before coming to a stop.
the process completely, determine which lock-outs need
to be removed to do the energized tests, evaluate the LOTO References
potential hazards carefully, and take the appropriate
precautions. Only then remove the lock-outs. As soon as The following references contain regulatory
the need for the equipment to be energized has passed, requirements. While different regulations may apply
the process should be locked out again. Here’s what can to your site, the OSHA standard and supporting
happen if you forget that last important step: documentation serves as a good reference to LOTO.
A worker was trying to clear a blocked pipe. The LOTO • OSHA Standard 29 CFR 1910.147: http://www.osha.
permit was authorized, and all of the required locks gov/SLTC/controlhazardousenergy/index.html
were placed according to procedure. The worker • OSHA Training for Small Businesses: http://
opened several valves in an attempt to try to blow it www.osha.gov/Publications/smallbusiness/
free. This did not work, so he re-closed the valves and small-business.html#lockout
reinstalled the lock-outs……except that he missed • NIOSH Guidelines for Lock-out Tag-
the valve on the pressurizing line. When the worker out: http://www.cdc.gov/niosh/docs/wp-
opened a flange below the plugged valve, material was solutions/2011-156/pdfs/2011-156.pdf
blown out, burning the worker.
• CCPS, “Guidelines for Process Safety
Lock-out and Tag-out Equipment that is Out-of- Documentation” pp 307-309, American
service Institute of Chemical Engineers 1995
• Oklahoma State University Lock-out Tag-out Program:
LOTO is particularly important when removing defective
http://ehs.okstate.edu/manuals/lock-tag.htm
equipment from service. Lock out and tag out defective
and unused equipment until it can be removed or
replaced. If you fail to do this, you could repeat the
following accident:
One pump of a two-parallel arrangement was out of
service but not locked out. Workers, switched to the
out of service pump as part of a routine rotation. This
resulted in a major process upset costing millions of
dollars. Luckily, no one was injured.

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 Chemical Emergency Prevention & Planning Newsletter July - August 2012

Startup Hazards Where Do I Go For More Information?

(CCPS Beacon 12-05) http://www.epa.gov/emergencies/

rmp will be updated as new
information becomes available.
A number of chemical facilities have had disastrous events occur during
startup activities. In many cases, these events point to the need for a higher EPA maintains numerous listservs to keep the
level of attention and public, state and local officials, and industry
care than that needed up to date, including several that pertain to
emergency management. You can sign up
for routine processing. for our list serve to receive periodic updates:
WHY? Startup hazards https://lists.epa.gov/read/all_forums/
are increased by subscribe?name=callcenter_oswer
inexact operating EPA Region 10 RMP Coordinator:
instructions, lack of Javier Morales 206-553-1255
experience in startup
operations, and a plant EPA Region 10 RMP Website:
http://yosemite.epa.gov/R10/
in a non-standard CLEANUP.NSF/sites/rmp
condition – for example,
feed tanks empty,
manual valves in the Superfund, TRI, EPCRA, RMP & Oil
Information Center - The Information
wrong position, new or Center can also answer questions
modified equipment. related to Clean Air Act section 112(r)
Time pressures to get and RMP reporting requirements.
(800) 424-9346 or TDD (800) 553-7672
the plant back in operation may be high, and operators may have worked (703) 412-9810 or TDD (703) 412-
long hours during the shutdown, making them less alert. Many plants 3323 in the Washington, D.C. area
require manual operation during startup. Continuous plants may startup so Normal Hours of Operation:
infrequently that plant personnel have little experience with required steps. Monday - Thursday 10:00 a.m.
- 3:00 p.m. Eastern Time
Extended Hours of Operation
Did You Know? (May, June, and July):
• Of 38 major incidents investigated by the U.S. Chemical Safety Monday - Friday 9:00 a.m. -
5:00 p.m. Eastern Time
and Hazard Investigation Board (CSB) from 1998 to 2005, three Closed Federal Holidays
occurred during startup of continuous process equipment. http://www.epa.gov/superfund/
contacts/infocenter/
• These three incidents resulted in 22 fatalities and more than 170 injuries.
• Other serious incidents occurred during startup of batch processes Risk Management Program (RMP)
or during maintenance operations that followed a power outage. Reporting Center - The Reporting
Center can answer questions about
• Startups may be rare, so refresher training may be needed. software or installation problems.
The RMP Reporting Center is available
What You Can Do from 8:00 a.m. to 4:30 p.m., Monday
through Friday, for questions on the
• Have complete and accurate written startup Risk Management Plan program.
procedures and checklists, and use them. (703) 227-7650 (phone)
[email protected] (e-mail)
• Use Management of Change reviews before
modifying any startup procedures.
This newsletter provides information on
• Ask questions and get help with startup operations the EPA Risk Management Program,
which are not familiar to you. EPCRA, SPCC/FRP and other issues
relating to Accidental Release Prevention
• Check with the responsible people that shutdown activities Requirements. The articles contained
have been completed and equipment approved for use. herein are provided for general purposes
only. EPA does not accept responsibility
• Verify equipment functionality and setup before startup, including pre- for any errors or omissions or results of
startup safety review after major maintenance or modifications. any actions based upon this information.
Please consult the applicable regulations
• Make sure all valves are in the proper position. when determining compliance. Mention of
trade names, products, or services does
• Maintain excellent communication between outside not convey, and should not be interpreted
operations and the control room! as conveying official EPA approval,
endorsement, or recommendation. The
information should be used as a reference
tool, not as a definitive source of compliance
information. Compliance regulations are
published in 40 CFR Part 68 for CAA
section 112(r) Risk Management Program,
40 CFR Part 355/370 for EPCRA, and
40 CFR Part 112.2 for SPCC/FRP.

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