Chemical Hill & Joss Ltd.

Date: March/04/2004
Project No.: CHJ-502342
Financial ID: B-2004 03

INTRODUCTION
This Program has been developed for the Ammonia Topping 4 at Chemical Hill & Joss Ltd. to meet the
requirements of OSHA Standard 29 CFR 1910.119 Process Safety Management of Highly Hazardous
Substances (PSM).

RESPONSIBILTIES

Facility Management
Assign sufficient resources and qualified operators to ensure safe operating and material
conditions are maintained.
Assign a qualified supervisor to oversee and direct Ammonia Topping 4 operations,
maintenance and training.
Involve Ammonia Topping 4 operators in the various elements of this program.
Request, as necessary, assistance from Company Engineering to execute the PSM Program
and conduct effective audits.
Ammonia Topping 4 Manager
Train all Ammonia Topping 4 operators in hazards of the Ammonia Topping 4 process, safe
operating procedures, and good engineering practices.
Assign tasks based on operators level of knowledge.
Monitor maintenance and operations activities to ensure they comply with good engineering
practice.
Ensure contractors are provided the information required by this program.
Document the information, activities, inspections, etc required by this program.

Ammonia Topping 4 Operators

Actively participate in the PSM program.
Exercise good engineering practices in the operation and maintenance of the Ammonia
Topping 4 systems.
Comply with all safety procedures.

Human Resource Manager

Provide PSM overview indoctrination training for all new employees as part of the New Hire
Safety Orientation training.

PSM ELEMENTS
The PSM Standard contains 14 Elements that must be addressed in this program.
1. Employee Participation
 2. Process Safety Information (PSI)
3. Process Hazard Analysis (PHA)
4. Operating Procedures
5. Training
6. Contractor Safety
7. Pre-Startup Safety Review
8. Mechanical Integrity
9. Hot Work Program
10. Management of Change (MOC)
11. Incident Investigation
12. Emergency Planning and Response
13. Compliance Audits
14. Trade Secrets

SECTION 1 EMPLOYEE PARTICIPATION

Requirements
The standard requires employers to:
Develop a Plan of Action for implementation of Employee Involvement.
Consult with employees on the conduct of the development of PSM Elements.
Provide access to PSM information.

SECTION 2 PROCESS SAFETY INFORMATION (PSI)

Requirements
The OSHA standard requires compiling of technical information on the process and equipment in the
Ammonia Topping 4 system. This requirement is to allow for PHA and maintaining information on the
system for Operator training and reference.

Specifically
Hazards of (type in the Chemical covered in this program) pertaining to the technology of the
Ammonia Topping 4 system.
Information pertaining to the equipment in the process.
Documentation that equipment complies with recognized and generally accepted good
engineering practices.

SECTION 3 PROCESS HAZARD ANALYSIS

Requirements
An initial process hazard analysis must be conducted by a team with expertise in engineering and process
operations, including at least one employee who has experience and knowledge on the Ammonia
Topping 4 system. Completion date for PHA was May 26, 1997.

After Initial PHA

Establish a system to promptly address the team's findings and recommendations.
Assure that the recommendations are resolved in a timely manner.
 Document resolutions.
Document what actions are to be taken.
Complete actions as soon as possible.
Develop a written schedule of when these actions are to be completed; communicate the
actions to operating, maintenance.
Engineering and administrative controls.
Detection methods for providing early warning of releases.
Consequences of failure of engineering and administrative controls.
Facility site.
Human factors.
Qualitative evaluation of a range of the possible safety and health effects of failure of controls
on employees.

SECTION 4 OPERATING PROCEDURES

Requirements
Develop and implement written operating procedures that provide clear instructions for safely
conducting operations and maintenance. Operating procedures shall be readily accessible to employees.
The operating procedures shall be reviewed as often as necessary to assure that they reflect current
operating practice. The employer shall certify annually that these operating procedures are current and
accurate.

Develop and implement safe work practices to provide for the control of hazards during operations such
as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance
into a facility by maintenance, contractor, laboratory, or other support personnel. These safe work
practices shall apply to employees and contractor employees.

Procedures Shall Include:

Initial startup.
Normal, temporary and emergency operations.
Normal shutdown.
Startup following a turnaround or after an emergency shutdown.
Operating limits.
Consequences of deviation & Steps required to correct or avoid deviation.
Safety and health considerations.
Precautions necessary to prevent exposure, including engineering controls.
Administrative controls and personal protective equipment.
Control measures to be taken if physical contact or airborne exposure occurs.
Quality control for raw materials and control of hazardous chemical inventory levels.
Safety systems and their functions.
SECTION 5 - TRAINING

Requirements

Initial training
Each operator must be trained in an overview of the process and in the operating procedures. The training
shall include emphasis on the specific safety and health hazards, emergency operations including
shutdown, and safe work practices applicable to the employee's job tasks.
For those employees already involved in operating a process on May 26, 1992, an employer may certify
in writing that the employee has the required knowledge, skills, and abilities to safely carry out the duties
and responsibilities as specified in the operating procedures.

Refresher training
Shall be provided at least every three years, and more often if necessary, to each employee involved in
operating a process to assure that the employee understands and adheres to the current operating
procedures of the process. The employer, in consultation with the employees involved in operating the
process, shall determine the appropriate frequency of refresher training.

Training documentation
The employer shall ascertain that each employee involved in operating a process has received and
understood the training required by this paragraph. The employer shall prepare a record that contains
the identity of the employee, the date of training, and the means used to verify that the employee
understood the training.

SECTION 6 - CONTRACTORS

Requirements
Obtain and evaluate information regarding the contract employer's safety performance and
programs.
Contract employers of the known potential fire, explosion, or toxic release hazards related to
the contractor's work and the process to contract employers the applicable provisions of the
emergency action plan.
Develop and implement safe work practices to control the entrance, presence and exit of
contract personnel.
Evaluate the performance of contract employers in fulfilling their obligations.
A contract employee injury and illness log related to the contractor's work in process areas.

SECTION 7 PRE-STARTUP SAFETY REVIEW

Requirements
Perform a pre-startup safety review for new facilities and for modified facilities when the modification is
significant enough to require a change in the process safety information. The purpose of the Pre-Startup
Review is to confirm that, prior to the introduction of highly hazardous chemicals to a process:
Construction and equipment is in accordance with design specifications.
Safety, operating, maintenance, and emergency procedures are in place and are adequate.
 Modified facilities meet the requirements contained in Management of Change.
Training of each employee involved in operating a process has been completed.

SECTION 8 MECHANICAL INTEGRITY

Requirements
Establish and implement written procedures to maintain the on-going integrity of Ammonia Topping 4
equipment. This includes:
Test & Inspections (T&Is) on equipment following recognized and generally accepted good
engineering practices, manufacturers recommendations and operating experience for the
conduct and frequency.
Documentation of T&Is, identifying:
o Date
o Name of the person performing T&I.
o Serial number or other identifier.
o Description of the inspection or test performed.
o Results
Equipment deficiencies - Correct deficiencies in equipment that are outside acceptable limits
before further use or in a safe and timely manner when necessary means are taken to assure
safe operation.
New Equipment - Assure that equipment as it is fabricated is suitable for the process
application for which they will be used. Additionally, conduct appropriate checks and
inspections to assure that equipment is installed properly and consistent with design
specifications and the manufacturer's instructions.
Material Control - Assure that maintenance materials, spare parts and equipment are suitable
for the process application for which they will be used.

SECTION 9 HOT WORK

Requirements
The employer shall issue a hot work permit for hot work operations conducted on or near a covered
process. The permit shall document that the fire prevention and protection requirements in 29 CFR
1910.252(a) have been implemented prior to beginning the hot work operations; it shall indicate the
date(s) authorized for hot work; and identify the object on which hot work is to be performed. The permit
shall be kept on file until completion of the hot work operations.

SECTION 10 MANAGEMENT OF CHANGE (MOC)

Requirements
Establish and implement written procedures to manage changes (except for "replacements in kind") to
process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a
covered process. Prior to the change, address the following considerations:
The technical basis for the proposed change.
Impact of change on safety and health.
Modifications to operating procedures.
 Necessary time period for the change.
Authorization requirements for the proposed change.
Train affected employees and contract employees in the change prior to start-up of the
process or affected part of the process.
Up-date PSI, PHA and Operating Procedures.

SECTION 11 INCIDENT INVESTIGATION

Requirements
Investigate each incident that resulted in, or could reasonably have resulted in a catastrophic
release of highly hazardous chemical in the workplace. An incident investigation shall be
initiated as promptly as possible, but not later than 48 hours following the incident.
Establish an incident investigation team which consists of at least one person knowledgeable
in the process involved, including a contract employee if the incident involved work of the
contractor, and other persons with appropriate knowledge and experience to thoroughly
investigate and analyze the incident.
Incident Reports - A report shall be prepared at the conclusion of the investigation that
includes at a minimum:
o Date of incident.
o Date investigation began.
o Description of the incident.
o Factors that contributed to the incident.
o Recommendations resulting from the investigation.
Corrective Actions - Establish a system to promptly address and resolve the incident report
findings and recommendations. Resolutions and corrective actions shall be documented.
Report Review - The report shall be reviewed with all affected personnel whose job tasks are
relevant to the incident findings including contract employees where applicable. Incident
investigation reports shall be retained for five years.

SECTION 12 EMERGENCY PLANNING AND RESPONSE

Requirements
Establish and implement an emergency action plan for the entire plant in accordance with the provisions
of 29 CFR 1910.38(a), 29 CFR 1910.120(a), (p) and (q). In addition, the emergency action plan shall
include procedures for handling small releases.

SECTION 13 COMPLIANCE AUDITS

Requirements
Certify compliance with the provisions of the PSM Standard at least every three years to verify that the
procedures and practices developed under the standard are adequate and are being followed.
The compliance audit shall be conducted by at least one person knowledgeable in the process.
A report of the findings of the audit shall be developed.
Promptly determine and document an appropriate response to each of the findings of the
compliance audit, and document that deficiencies have been corrected.
 Retain the two (2) most recent compliance audit reports.

SECTION 14 TRADE SECRETS

Requirements
Make all information necessary to comply with the section available to those persons responsible for
compiling the process safety information, those assisting in the development of the process hazard
analysis, those responsible for developing the operating procedures, and those involved in incident
investigations, emergency planning and response and compliance audits without regard to possible trade
secret status of such information.

There is no restriction in the OSHA Standard 1910.119 which prevents the company from requiring any
persons to whom the information is made available to enter into confidentiality agreements not to
disclose the information.

Rules and procedures set forth in OSHA Standard 1910.1200, employees and their designated
representatives shall have access to trade secret information contained within the process hazard
analysis and other documents required to be developed by this standard.