Process Safety Management in Performance Films Coating & Laminating Processes

Author: Anthony Porter, CPFilms Inc., a subsidiary of Eastman Chemical Company,

4210 The Great Road, Fieldale, VA 24089.
Tel 276 627 3474 E:mail tony.porter@eastman.com

Eastman Performance Films Coating and Laminating processes are not covered under OSHA
PSM regulation (29 CFR 1910.119) or EPA RMP rule (40 CFR 68); however, Performance
Films opted to treat the Coating & Laminating processes as if they fall under the PSM standards.

The Coating and Laminating process involves coating films with solvent based formulations.
Therefore this entails handling significant amounts of flammable solvents during the
manufacturing process. Flammable solvents can present significant hazards to life and property if
not properly managed. This presentation describes how Performance Films manages process
hazards in the Coating and Laminating production processes.

Proper Process Safety Management system for potential hazards in the Coating & Laminating
processes should consist of, at least, the following PSM elements: process safety information;
employee participation; proper area classification; process hazard analysis; training; management
of change; engineering controls; fire protection; mechanical integrity, grounding/bonding;
operating procedures; incident investigations, emergency planning and response; audits.

1. Process Safety Information.

Production departments that are under the PSM program are responsible for compiling and
maintaining some of the process safety information for their respective areas. This information
may include toxicity information, permissible exposure limits, physical data, thermal data,
reactivity data, stability data, corrosivity, block flow diagrams, material and energy balance,
process chemistry, upper and lower temperature and pressure ranges. Some process safety
information such as the piping and instrumentation diagrams, information pertaining to the
equipment and piping specifications, design codes, and any other information that adds to the
identification and understanding of process hazards are maintained by the Maintenance and
Engineering Department and some are kept online for employees to access.

Process safety information must be communicated to the production employees in such a way
that they can identify and understand the hazards posed by the processes including raw materials,
intermediates, products, by-products, and waste streams.

Prior to a new or existing process being analyzed for hazards, all relevant information about the
process and its components must be collected for review purposes.

2. Employee Participation
Performance Films employees are involved in the PSM program through participation in the
following programs:
1. Employee safety meetings (departmental and site safety meetings)
2. Safety training (process and personal safety trainings)
3. Operating procedures (writing and reviewing operating procedures)
4. Process Hazard Analysis
 5. Management of Change
6. Process Safety Reviews
7. Incident Investigations
8. Emergency Response
9. Safety Audits
10. Safe work permit

Employees have access to Process Safety Reviews, Incident Investigation Reports, Operating
Procedures, Compliance Audits, and Process Safety Information through the online network and
locally in their various departments.

3. Proper Area Classification

There are three types of hazardous conditions:
• Class I Hazardous Location is one in which flammable gases or vapors may be present in
the air in sufficient quantities to be explosive or ignitable. Examples: Petroleum
refineries, and gasoline storage and dispensing areas; Dry cleaning plants where vapors
from cleaning fluids can be present; Spray finishing areas; Aircraft hangars and fuel
servicing areas; and Utility gas plants, and operations involving storage and handling of
liquified petroleum gas or natural gas.
 Class II Locations." Finely pulverized material, suspended in the atmosphere, can cause
as powerful an explosion as one occurring at a petroleum refinery. Examples: Grain
elevators, flour and or feed mills, Plants that manufacture, use or store magnesium or
aluminum powders, Producers of plastics, medicines and fireworks, producers of starch
or candies, spice grinding plants, sugar plants, cocoa and coal producing plants and other
carbon handling.
 Class III hazardous locations are areas where there are easily-ignitable fibers or flyings
present, due to the types of materials being handled, stored, or processed. The fibers and
flyings are not likely to be suspended in the air, but can collect around machinery or on
lighting fixtures and where heat, a spark or hot metal can ignite them. Examples of these
types are textile mills, cotton gins, cotton seed mills, flax seed mills, plants that cut,
shape and pulverize or create saw dust flyings.

There are two kinds of hazardous conditions: Division 1 - normal, and Division 2 - abnormal.

Finally, there is the nature of the hazardous substance . . . where we find Groups A, B, C, and D
in Class I locations, and, in Class II locations: Groups E, F, and G.

4. Process Hazard Analysis

Processes Hazard Analyses (PHAs) are completed initially and revalidated and updated on a
periodic basis, at a maximum of 5 years. The PHA is conducted and managed per Eastman’s
PHA procedure. The hazard analysis team is made up of a diverse group of process experts (i.e.
electrical and instrumentation technicians, engineers, safety specialists) and at least one
individual that has intimate knowledge of the process operations (i.e., process operator or
technician).

The completed Process Hazard Analysis must be made available for review by area employees.
The team findings and corrective actions must be communicated to all appropriate employees
and addressed in a timely manner.

5. Training
A written program for training of employees (operators, mechanics, technical personnel, etc.) is
established for those persons who operate, make decisions on how it will be operated and/or
maintain the equipment associated with the PSM process. The thoroughness of the training is
specific to the responsibilities of the employees and address the operating procedures for the
process with an emphasis on the specific safety and health hazards, emergency operations
including shutdown, and safe work practices applicable to their job task as well as specific
training on how to do routine and non-routine tasks.

The written program addresses both initial training for newly assigned personnel and refresher
training in order to ensure that employees continue to understand and adhere to current operating
procedures, policies and practices. Refresher training is completed at least every 3 years.

Documentation is kept indicating the type of training provided, identity of the employee(s), the
date of the training and the means used to verify the employee(s) understood the training.

6. Management of Change
Any time there is a change in a process that can affect the safety and health of an employee, all
changes (i.e., physical, chemical, procedural, organizational) must be formally managed.
Formally managed change means that the changes are reviewed and analyzed for safety and
health issues along with documenting the required actions that will take place before the change
is deemed safe. A group of area specialized employees would complete this activity under the
facilitation of an MOC originator.

A written management of change program is provided to manage changes (except for

“replacement in kind”) to process chemicals, technology, equipment, the organization,
procedures (e.g., operating procedures, maintenance procedures, emergency procedures, etc.) and
changes to facilities that affect a process covered by this requirement.

This program addresses the following:

1. The documentation of the technical basis for a change and the expected result.
2. The impact of the change on safety and health.
3. When a “Process Hazards Analysis” and/or other HSE Reviews shall be conducted.
 4. The mechanisms necessary to maintain Process Safety Information and Procedures
(operating, emergency, and maintenance procedures) that are affected by the change up-
to-date and accurate.
5. Authorization by Performance Films employees who are charged with overall
responsibility for operations affected by the change.
6. The responsibilities of those persons initiating and authorizing a change.
7. The identification of temporary changes, necessary time period for these changes and
measures that should be taken to assure safe a operation.
8. Training of employees (operators, mechanics, and technical personnel) who have job
responsibilities affected by the change prior to its implementation or performing work
associated with the change.

7. Engineering controls
Engineering controls are based on the following principles:
• If feasible, design the facility, equipment, or process to remove the hazard or substitute
something that is not hazardous.
• If removal is not feasible, enclose the hazard to prevent exposure in normal operations.
• Where complete enclosure is not feasible, establish barriers or local ventilation to reduce
exposure to the hazard in normal operations.

8. Fire protection
Fire protection measures include both prevention and mitigative items.

Prevention Items:
• Static bars located in prior process areas to help prevent excessive static build
• Static Bars located at Unwind areas
• Static Bars located prior to coating, & after coating
• ESD Shoes
• Grounding & Bonding testing
• Classified areas Class1 Div 1 & Div2 type D
• LFL monitoring enclosures & mixing areas
• Conductive flooring
• Emergency extraction system

Mitigative Items:
• CO2 fire suppression
• Automated fire suppression activated by temperature rated sensor located in coater
enclosures, & dispensing areas
• Sprinkler system
• Fire link safety shut off valves
• Eyewash with alarm built in to notify someone outside the area so assistance can be given
to individual in need

9. Mechanical integrity, Grounding/Bonding

The physical make up of a hazardous process must have a high level of integrity to ensure
containment and control of the hazardous material. The site has an established Mechanical
Integrity Program that documents all of the sensitive equipment that must be assessed
periodically for integrity. The Mechanical Integrity program is managed by the Maintenance and
Engineering Department and document the test dates and limit requirements.

Grounding / Bonding is used, for example with coater heads, safety cans, reservoir for coating
mixes located in coater head areas, drums, machine grounding, mixing tanks and bonding when
pouring or transferring of liquids from one location to another. Grounding is checked a minimum
once per week, whenever a drum is replaced or whenever a ground has been removed and
reapplied.

10. Operating Procedures

Each process included in the PSM program has written procedures that provide clear instructions
for safely conducting activities and be consistent with the process safety information. These
procedures are properly labeled and indexed and accessible to allow their use during routine
operations and emergencies. Changes in operating procedures must follow the Management of
Change process in order to ensure that the operating procedures are current, accurate and
operating personnel trained on the changes that were made to the operating procedures. All
operating procedures are reviewed and certified every three years.

Operating procedures include the following:

• Steps for each of the following operating phases that apply to the process:
- Initial Startup
- Temporary Operations
- Emergency Operations
- Normal Operations
- Emergency Shutdown
- Startup Following an Emergency Shutdown

• Operating limits:
- Clearly defined safe upper and lower limits for the applicable parameters (flow,
temperature, pressure, level, pH, etc.) associated with each chemical operation
- Specific actions required by operators or others to correct or avoid exceeding a safe
upper or lower limit
- An explanation of the safety and health consequences (i.e., injuries, property
damage) associated with a deviation from a defined safe upper or lower limit.

• Safety and Health Considerations:

- Summary of the hazards presented by the chemicals used in the process.
- Precautions necessary to prevent exposure.
- Any special control measures to be taken if physical or airborne exposure occurs
- Any special procedures for the quality control of raw material and controlling the
inventory levels of hazardous materials.
- Any special or unique hazards associated with the chemicals or process.
11. Incident Investigations
All incidents must be investigated to find the Root Cause. Once the Root Cause is identified,
corrective actions must be taken to prevent reoccurrence of the incident. The investigation
should start immediately, but must start within 48 hours of the incident. The investigation team
should be comprised of employees that can bring knowledge, experience, and expertise to the
investigation.

12. Emergency Planning and Response

The site follows Emergency/Evacuation Procedures that cover fire emergencies, chemical spills,
tornados, floods, medical emergencies and biohazards.

13. Audits
At least every three years the site’s Process Safety Management Program will be audited by
Corporate HSE personnel or their designee. The site’s process safety specialist and the
departmental safety coordinators shall conduct internal audit annually to ensure that PSM system
is adequate and being followed. The audit shall be documented with follow-up for corrective
actions for non-compliant findings.