2/1/2005 Letter of Interpretation to Mr.

Roygene Harmon

Appendix Example Application of 1910.119(e)(3)(vii) Below are excerpts from two different PHA methodologies [What-If Checklist (Figure 1) and HAZOP (Figure 2)]. Each PHA excerpt identifies one hazard/deviation as well as its corresponding engineering and administrative controls, safeguards, recommendation/actions and a quantitative description of consequence, likelihood and the risk priority for the identified hazard. An example (e.g. ) of the application of the specific OSHA 1910.119(e)(3) consequence requirements are identified on the example PHA worksheets. After the PHA worksheet examples, other examples are provided to illustrate how some employers utilize a risk matrix to comply with the qualitative evaluation requirement (1910.119(e)(3)(vii)). As noted earlier, PSM is performance standard, and that these examples may or may not be applicable to your specific situation. The following is an example of the development and use of a risk matrix. First, a qualitative description of consequence and likelihood/frequency of the hazard based on a failure of engineering and/or administrative controls is established. Figure 3 is the Consequence Table. It is a qualitative description of the range of degrees of consequences related to the identified hazard and its associated failure of controls. These consequences range from 1 4, with 4 being the most severe Consequence Class. Figure 4 is the Likelihood Table, it is a qualitative description of the range of likelihood/frequency that an identified engineering or administrative control might fail. The likelihood ranges from 1 4, with 4 being the most likely to fail. Using the Consequence and Likelihood Class numbers a Risk Priority Matrix (Figure 5) can be constructed. The Risk Priority Matrix is used to identify the Risk Class. Once the Risk Class (e.g. C) is determined from the Risk Priority Matrix, the Risk Class can be correlated to the Risk Priority Legend (Figure 6) which prioritizes the hazard as identified by the PHA team. In this case, the PHA team enters the evaluated Consequence Class, Likelihood Class, and Risk Class on the PHA worksheets, Figures 1 and 2. In the following example PHA worksheets the abbreviations and symbols mean: C = Consequences Class L = Likelihood Class R = Risk Priority Class

- 1910.119(e)(3)(i): - 1910.119(e)(3)(iii): - 1910.119(e)(3)(iv): - 1910.119(e)(3)(vii):

address the hazards of the process address engineering and administrative controls applicable to the hazards address consequence of failure of engineering and administrative controls address a qualitative evaluation of a range of possible safety and health effects of failure of controls

2/1/2005 Letter of Interpretation to Mr. Roygene Harmon

Figure 1 - Example Worksheet Excerpt from What If/Checklist PHA Methodology C= Consequence Class, L= Likelihood Class, R = Risk Class What If Consequences/ Safeguards C L R Recommendations/ Hazard Action Emergency Shutdown Valve 23 (ESD - 23) fails to close when needed? (This can occur due to extremely cold weather, reliability due to inspection/ testing/maintenance or design problems) Release of highly flammable materials in the operating area. Potential for fire/explosion with employee injuries/fatalities 1. Specific Inspection/testing/ maintenance program for ESDs 2. Valve actuator sizing 3. ESD-23 is fail closed design 4 2 B 1. Due to cold weather modify MI procedures to increase ESD valve testing to 1/2wks. 2. Inspection records for ESD 23 not in file, follow-up to assure ESD-23 inspected as required by MI procedures 3. No equipment data sheet was found for actuator for ESD-23, follow-up with engineering to assure design is correct. 4. Consider over sizing valve actuator Figure 2 - Example Excerpt from HAZOP PHA Methodology C= Consequence Class, L= Likelihood Class, R = Risk Class Causes Consequences Safeguards Recommendations/ C L R Actions Agitator Un-reacted HHC in HHC detector 1. Consider adding 4 2 B motor fails the reactor carried and alarm alarm/shutdown of the over to Storage Tank system for loss of Electrical 3 (ST-3) and is agitation to the utility lost released to the reactor enclosed work area. Agitator Probable injuries or 2. Ensure adequate mechanical fatalities to workers ventilation exists for linkage fails due to highly acute enclosed work area toxic material hazard and/or use an Operator enclosed ST-3 fails to activate 3. Update PSI file and agitator Op. Procedure HHC-39 to include consequence of deviation, engineering controls including safety system information, e.g. SIS and emergency ventilation

Deviation Loss of Agitation

2/1/2005 Letter of Interpretation to Mr. Roygene Harmon

Consequence Class 1 2 3 4

Figure 3 - Consequence Table Qualitative Employee Safety Consequence Criteria No employee injuries One Loss Time Injury or Illness Multiple Lost Time Injuries or Illnesses Multiple Lost Time Injuries or Illnesses w/one or more fatalities Figure 4 - Likelihood Table Qualitative Likelihood Criteria Not expected to occur during the lifetime of the process. Examples Simultaneous failures of two or more independent instrument or mechanical systems Expected to occur only a few times during the life of the process. Examples Rupture of product piping, trained employees w/procedures injured during LOTO operation Expected to occur several times during the life of the process. Examples hose rupture, pipe leaks, pump seal failure Expected to occur yearly. Examples - instrument component failures, valve failure, human error, hose leaks

Likelihood Class 1

Figure 5 - Example Risk Priority Matrix

Consequences

4 3 2 1

C C D D 1

B B C D 2

A B B C 3

A A B C 4

Likelihood

Priority

Risk Class A

Figure 6 - Example Risk Priority Legend Explanation of Risk Risk intolerable - needs to be mitigated within 2 weeks to at least a Class C, if that cannot be accomplished, process needs to be shutdown Risk undesirable - needs to be mitigated within 6 months to at least a Class C Risk tolerable with controls (engineering and administrative) Risk acceptable no further action required

B C D