Biodiesel Process Safety Management

As biodiesel grows, expect increased scrutiny of safety compliance
By Wayne Lee and John Hardy | March 09, 2011

A segment of our practice as the nation’s largest biodiesel consulting firm is devoted to safety. We have a safety trainer for plant personnel training, and our legal counsel, co-author here, leads our Process Safety Management practice. This article should not be relied upon as a legal opinion, nor should it be considered exhaustive. It is a but a starting point from which those in the biodiesel industry can better understand the topic as it applies to biodiesel plants.


Process Safety Management is a regulation promulgated by the U.S. Occupational Safety and Health Administration. OSHA specifically notes in its introduction that unexpected releases of toxic, reactive, or flammable liquids and gases in processes involving highly hazardous chemicals have been reported for many years in various industries that use chemicals with such properties and regardless of the industry that uses them, there is always potential for accidental release when not properly controlled. These standards attempt to prevent these releases and ultimately prevent disasters. 


The OSHA standards specifically require that facilities that use more than 10,000 pounds (about 1,500 gallons) of certain flammable liquids or gas implement specific safety standards. In the biodiesel industry, these flammable components are most often methanol, ethanol, potassium methylate and sodium methylate, and the product that producers refer to as being “in process” (i.e., the feedstock in the processor that is mixed with one or more of these components).  When a producer speaks of product in process, he is normally not referring to reaction agents and catalysts stored in separate tanks. However, OSHA’s definition of a process includes any activity that involves a highly hazardous chemical, including “any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or combination of these activities.” The OSHA definition specifically notes that any group of vessels that are interconnected, and separate vessels that are located such that a highly hazardous chemical could be involved in a potential release, are considered to be part of this process.


These definitions make it clear that the flammable catalysts and reaction agents used or stored at biodiesel plants are part of the process. Commercial biodiesel plants fit within the definitions and must have process safety management.  What must a biodiesel plant do to comply?


The starting point is that management must have a commitment—one that includes employees and encompasses all facets of process safety management.  Ongoing safety trainings, done by most plants, are certainly an integral part but simply conducting these trainings is not compliance. Plants must gather (and keep) process safety information, conduct safety reviews, analyze potential hazards, ascertain the mechanical integrity of equipment and be ready to manage change as it occurs. They must incorporate good operating procedures, fire prevention, equipment training, and procedures for investigating and reporting accidents, and auditing of these procedures. Plants must be compliant and owners must ensure outside companies are educated and operate safely in their plants.


Here is a cursory review of the 13 major elements of Process Safety Management standards. Process Safety Information: This involves organizing and understanding all the written information concerning the chemicals, technology and equipment used at the plant, including Material Safety Data Sheet information, block flow diagrams, process flow diagrams, and piping and instrument diagrams.Employee Involvement: Employers must consult with employees in developing safety programs and hazard assessments. Training and education is required. Process Hazard Analysis: This is an organized, systematic effort to identify and analyze the significance of potential hazards associated with the processing or handling of hazardous chemicals. Operating Procedures: This is a detailed summary of the plant’s standard operating procedures, which need to be technically accurate yet understandable to employees. They must be revised periodically to ensure that they reflect current operations. Employee Training: This is a clearly defined training program that ensures that employees know how to safely handle hazardous chemicals. Contractors: A screening process must be established to ensure and document that any contractors and their employees are qualified and trained in safe work practices.  Contractors should be advised of the plant’s PSM plan and prohibited from making unilateral changes to the physical plant. Pre-Startup Safety Review: For new and existing plants that have been shut down for any reason. Mechanical Integrity of Equipment: A detailed mechanical integrity program should be developed that routinely reviews the plant’s maintenance programs and ensures the reliability of the plant’s equipment. Nonroutine Work Authorizations: A consistent procedure for any work that would not be considered part of the regular routine, including identification of all hazards related to that work, must be established. Safely Manage Change: Employers must establish means and methods to detect both technical and mechanical changes, and develop a change form that includes such things as a description and purpose of the change, the technical basis for the change, inspection and testing, approvals, and authorization. Incident Investigation: A procedure must be developed for identifying the underlying causes of incidents and implementing steps to prevent similar events from occurring. Plants should be learning from near misses, and should have a team to do the investigation. Emergency Planning: A procedure must be established to inform employees of their responsibilities if there is an unwanted release of hazardous chemicals. It should involve different sets of plans for different emergencies and local authorities should be involved. Employers must have an emergency action plan, activated by an alarm system that will facilitate the prompt evacuation of employees to a safe zone. Compliance Audits: The process safety management system must periodically be audited by a trained individual or team. The audit should be thoroughly documented and any necessary corrective action identified.


Although OSHA provides guidelines, developing a PSM program is likely to be a daunting task for most biodiesel plant owners. Assembling and organizing the vast amounts of chemical, process and equipment information, and developing a cohesive program is undoubtedly burdensome, but it’s something that must be done. Noncompliance is recipe for disaster. Although OSHA has the ability to assess huge penalties for noncompliance, and has done so in appropriate cases, the agency historically has not “scoured the countryside” looking for potential problems at biodiesel plants. However, as the industry grows, expect increased scrutiny. If there is a serious accident, particularly one with injuries, the plant should expect its Process Safety Management program to be reviewed. If the plant is found to be noncompliant, potential fines are large enough to put the plant out of business.


It’s important to note that OSHA is very helpful for those who desire to comply. In addition to hiring experts, plants can request OSHA personnel to conduct onsite visits without citation books in hand, designed to assist in identifying potential problems and to give guidance on rectifying. The idea is to help those who are trying to help themselves. 


We’re at a time when many biodiesel plants seek funding. Lenders and investors have a justified skepticism of our industry in light of the difficulties of the past few years. But as the industry moves forward, government and private funding will expand accordingly. The lenders will continue to demand evidence that an operation is of the highest caliber—proven technology, reliable feedstock sources, and ongoing process safety management programs.


In the final analysis, process safety management is nothing more than a system of identifying, evaluating and preventing disasters in the workplace. While a PSM program does not have to be a doctoral thesis, it does need to be a complete compilation of properly organized documents. It must involve employees having a clear understanding of what these documents mean and how to use them. Electing not to have a good process safety management program is much like deciding not to have insurance. It’s not worth the risk.

Authors: Wayne Lee, John Hardy
CEO, Attorney, Lee Enterprises Consulting Inc.
(501) 833-8511
wlee52@lee-enterprises.com

 

 
 
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