29 CFR 1910.119: Process safety management of highly hazardous chemicals

Question 1

A PHA team issues several recommendations for a covered process. The plant manager wants to handle them informally: verbal agreements with supervisors, no written record, to avoid paperwork. Which part of the standard does this approach violate?

1. AThe requirement that all recommendations be implemented exactly as the team wrote them
2. BThe requirement that recommendations be resolved in a timely manner and that the resolution be documented
3. CThe requirement that recommendations be approved by a regulatory agency before action
4. DThe requirement that only recommendations rated as catastrophic be tracked

Question 2

A refinery's contractor crew is replacing valves in a process area. The contractor's safety coordinator reviews the training files and finds that each file has a sign-in sheet showing the worker's name and the date of the pre-job safety briefing. None of the files shows how the contractor confirmed that workers understood the briefing. The refinery's process safety manager says the sign-in sheets are enough because the refinery will keep its own contractor injury and illness log. What is the most accurate assessment under the PSM standard?

1. AThe files are deficient, because the contractor employer must document the means used to verify understanding in addition to worker identity and training date
2. BThe files are compliant, because a name and training date show the worker received the instruction, and verification of understanding is the host employer's duty
3. CThe files are deficient only because the refinery's process safety manager must countersign each record to make it valid
4. DThe files are compliant, because the refinery's own contractor injury and illness log replaces the need for the contractor to verify understanding

Question 3

A plant is revalidating the process hazard analysis (PHA) for its existing covered process. The team assembled consists of a chemical engineer, a mechanical engineer, a corporate operations manager from another site who has deep process-operations expertise, and a trained facilitator who is an expert in the HAZOP method being used. No one on the team has ever worked in or on this particular process. What must the PSM coordinator do to make the revalidation team compliant?

1. AAdd a second member who is knowledgeable in the HAZOP methodology
2. BReplace the team with a single licensed process engineer, since the team already covers engineering
3. CAdd at least one employee who has experience and knowledge specific to the process being evaluated
4. DMake no change, because team composition requirements apply only to the initial PHA and not to revalidations

Question 4

A chemical plant certified its operating procedures for a covered process as current and accurate eight months ago. Last month the plant replaced a feed pump with a different design and began using a new process chemical. The supervisor proposes leaving the procedures as they are until the next annual certification in four months, since they were certified within the past year. What does the standard require?

1. AUpdate only the sections that affect contractor entry, because changes to equipment and chemicals do not otherwise trigger a procedure review
2. BHold the update until the next refresher training cycle, since procedures are revisited when employees are retrained
3. CReview the procedures now and revise them to reflect the new equipment and chemical, because the review must keep pace with changes and is not tied to the annual certification date
4. DLeave the procedures unchanged until the annual certification, because certification within the past 12 months satisfies the review requirement

Question 5

A plant stores a highly hazardous chemical in three tanks. Tanks 1 and 2 sit side by side in a shared containment dike with no piping between them. The plant's own release analysis shows that a rupture of either one would put the chemical in the other at risk. Tank 3 holds the same chemical at the far end of the site, in a separate area where a release could not involve the other two tanks. How should the employer define the process(es) for applying the PSM standard?

1. ATanks 1 and 2 are separate processes unless the dike is later piped into a common drain header, and Tank 3 is a separate process
2. BTanks 1 and 2 are one process and Tank 3 is a separate process, because Tanks 1 and 2 are located so the chemical could be involved in a potential release
3. CThree separate processes, because none of the tanks is interconnected by piping
4. DAll three tanks are one process, because they hold the same chemical