Biodiesel producers and process safety management compliance

By Nathan Vander Griend | April 25, 2012

Most biodiesel producers have heard about the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) citing a Wisconsin biodiesel facility, Midwest Biofuel LLC, with 15 health and safety violations, and the $46,200 in fines proposed by the governmental agency. Is this an isolated case, or is OSHA starting to closely scrutinize the biodiesel industry? As the vice president of client services for the largest safety and risk management group in the biofuels industry, my educated guess would be the latter, since this is a fairly standard pattern.

As any industry evolves, more accidents occur and the regulatory agencies get more involved. For biodiesel, this should come as no surprise. More than a year ago, Lee Enterprises Consulting, the largest alternative fuels consulting group, published an article warning the biodiesel industry to stay abreast on what was required by OSHA and to stay compliant. The consulting group saw that biodiesel producers were headed to the forefront of OSHA activity.

The consulting group also sought out a strategic partner that could fully assist their biodiesel plant clients with safety, U.S. EPA/OSHA compliance, with a strong focus on risk management planning and process safety management. In February, Lee Enterprises Consulting selected our company, ERI Solutions Inc., as that strategic alliance.

We have been extremely active in the environmental, health and safety arena in the ethanol industry for several years, and we have assisted more than 90 plants. While the biodiesel and ethanol processes are different, the basics of process safety management (PSM) are virtually identical. Just as we saw in ethanol several years ago, the biodiesel industry currently has a handful of producers with somewhat sound PSM programs, but there seems to be a lack of overall knowledge as to what is required. Since biodiesel plants are now in the crosshairs of OSHA from a PSM compliance standpoint, it is time for producers to be proactive.   

The goal of a PSM program is to ensure that process facilities that have hazardous chemicals on site are operated safely. PSM programs focus on major process-related events such as fires, explosions and the release of toxic chemicals. PSM programs are divided into 14 separate elements as follows:

1) Employee Participation - Employers must develop a written plan of action for employee involvement as it relates to development and management of the PSM program.

2) Process Safety Information (PSI) - Employers must develop a compilation of written process safety information including hazard information on HHCs as well as technology and equipment information on the applicable processes.

3) Process Hazards Analysis (PHA) – Employers must develop a set of organized and systematic assessments of the potential hazards associated with the process to assist managers and employees in making decisions for improving safety and reduce the consequences of unwanted or unplanned releases of hazardous chemicals.

4) Operating Procedures – Operating procedures consistent with the process safety information must be developed and followed for all scenarios.

5) Training - Documented initial training on the process and all PSM elements along with refresher training every three years.

6) Contractors - Employers develop and implement a contractor management program for all contractors that perform maintenance or repair on, in, or near plant areas that contain highly hazardous chemicals.

7) Pre-Startup Safety Review (PSSR) - Review of the safety of a new or modified process prior to introduction of a highly hazardous chemical.

8) Mechanical Integrity (MI) – Establishing documented maintenance activities on PSM covered equipment to ensure integrity throughout the life of each system and component.

9) Hot Work – A permit system must be in place and used when any hot work is going to be performed on or near any PSM covered system or equipment.

10) Management of Change (MOC) – Changes must be thoroughly evaluated to assess their impact on employee safety and health and determine needed changes to operating procedures.

11) Incident Investigation – Investigations of incidents to identify the chain of events and causes so corrective action can be developed and implemented.

12) Emergency Planning and Response – If, despite best planning, an incident occurs, it is essential that emergency preplanning is in place.

13) Compliance Audits – Employers must certify that they have evaluated PSM compliance every three years.

14) Trade Secrets – All information necessary to comply with PSM must be made available to persons compiling process safety information.

While developing PSM programs for clients, Jay Beckel, our vice president of safety and health, is charged with leading a group of API-certified engineers making certain that these elements all link with one another and run efficiently. For example, suppose an engineer wishes to change operating conditions. According to protocol, the engineer must find out the current operating limits per No. 2 above. Then the proposed change must be put through the management of change system per No. 10 and this may require that a process hazard analysis be performed per No. 3. Then operating information (No. 2), operating procedures (No. 4) and training programs (No. 5) must be updated. Before making these changes in the field, a pre-startup safety review (No. 7) needs to be performed. Finally, when the change is complete, the updated program must be audited per No. 13.

So, where should the biodiesel plant begin? The first step for any plant is to do a complete safety audit and employee training. This is relatively inexpensive and will let the plant know exactly where it stands and what needs to be done, and will insure that the employees know the basics of staying safe in a hazardous environment. After the audit, the auditors should sit down with the owners and plant managers to go over their findings. This will give everyone a much better understanding of what needs to be done, and who is going to take responsibility for making sure it is accomplished. OSHA requires that biodiesel plants have a written safety program, new employee orientation, and a number of other safety manuals onsite and ready for review should they stop in. Plants need written PSM documents, including process hazards analysis, operating procedures, mechanical integrity and emergency planning. PSM and risk management plan compliance audits are required every three years, and tests and inspections are required every five to 10 years.

While all of this can certainly appear to be an overwhelming and daunting maze of government paperwork, it is what companies like ours do. We have checklists, forms, manuals, and the trained staff necessary to insure that our clients have the right tools to be compliant. If biodiesel plants are like other industries, we will find that some take the initiative and get their plants ready, while others will take a dangerous path of noncompliance until OSHA shows up. As Lee Enterprises Consulting’s CEO Wayne Lee wrote more than a year ago, “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.”

 At ERI Solutions Inc., we currently work with almost 100 biofuels plants, and 40 agribusiness facilities. As we tell our clients, it is not a matter of “if OSHA shows up,” but rather “doing the right things for the right reasons.” If you are prepared, an OSHA visit is nothing to fear. More importantly, these regulations are in place to make your workplace safe and protect lives and property. That is OSHA’s goal, and it should be the primary concern of every biofuel plant.

 
 
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