Transcript 3. Elements of Process Safety Management

Elements of Process
Safety Management
A Review of the 14 Elements
A Way of Looking at the 14 Elements of PSM
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Elements Concerned with
Evaluation of Progress
Towards Goals
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Process Hazards
Analysis
Pre-startup Safety
Review
Management of Change
Incident Investigation
Compliance Audits
Trade Secrets
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Elements Concerned with
Achieving Safety Goals
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Employee Participation
Process Safety
Information
Operating Procedures
Training
Contractors
Mechanical Integrity
Hot Work
Emergency Planning
Employee Participation
 Purpose
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One of the Most Essential Elements for a Successful
Program
People at Working Level Know Most about Operations
Serves as a Sanity Check re: Common Sense
Problems
Couples with All Other Elements and Ensures
Successful Implementation
 What is Required, Employers Must
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Have a Written Plan to Ensure Employee Participation
Involve Employees in Conduct and Implementation of
PHAs & Other Elements of PSM
Provide Access to PHAs and all other Information
Required to Be Developed by PSM Rule
Process Safety Information
 Purpose - Ensure Personnel Have Access to
Information Needed Work Safely and Efficiently
 What is Required
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HHC Hazard Information – MSDS + other Data Needed
to Comply
Info on Technology (PFDs, Process Chemistry, Max
Inventory, Safe Upper and Lower Limits, Evaluation of
Consequences of Deviations)
Info on Equipment (Materials, P&IDs, Electrical Class,
Relief System Design and, Design Codes and
Standards, Material and Energy Balances, Safety
Systems, e.g. Interlocks, etc.)
Documentation Equipment Complies with RAGAGEP
For Equipment Designed in Accordance with Codes
and Standards no Longer in Use, Must Document Is
Designed, Maintained, Inspected, Tested, and
Operating in Safe Manner
Process Hazards Analysis
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Purpose
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Identify Hazards and Provide a Preliminary Estimate as to
Seriousness
Correct Problems (Design Changes or Modifications, Adding Safety
Features, Improving Procedures and Training)
What is Required
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Process Hazard Analysis be Done Using – What If, Checklist, WhatIf/Checklist, HAZOP, FMEA, Fault Tree Analysis, etc.
PHA will Address –
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Hazards & Identification of Previous Potentially Catastrophic Incidents
Engr. and Admin. Controls Applicable, Consequences fo Failure of
Engr. and Admin. Controls
Facility Siting, Human Factors
Qualitative Evaluation Of Potential Safety and Health Effects if
Controls Fail
Team – Engr. and Process Operations, One Member Specific to
Process Evaluated, One Member Knowledgeable in PHA Process
Employer Must
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Establish System to Address Findings
Update and Revalidate Every Five Years
Operating Procedures
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Purpose is to Assure Safe and Reliable Operations
What is Required – Employer Must:
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Address Safe Actions During Initial Startup, Normal Operations,
Temporary Operations, Emergency Shutdown, Emergency
Operations, Normal Shutdown, Startup Following Turnaround or
Emergency Shutdown
Identify Operating Limits – Consequences of Deviation and
Corrective Action
Identify Safety and Health Considerations (properties and
hazards and precautions to prevent or correct problems)
Identify Safety Systems and Functions
Safe Work Practices Must be Addressed (e.g. lockout/tag-out,
confined space entry, etc.
Procedures Shall be Reviewed as Required to Accurately Reflect
Current Operations. Employer Must Certify to this Annually
Training
 Purpose is to Assure Personnel Can
Accomplish Duties Safely
 What is Required
 Initial Training with Emphasis on Safety
and Health Hazards, Emergency
Operations Including Shutdown, Safe
Work Practices
 Refresher Training at Least Every Three
Years
 Training Shall be Documented
Contractors
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Purpose is to Ensure Contract Employees Observe Same Safety
Rules and Standards as Permanent Employees
What is Required
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Applies to Contractors Performing Maintenance, Repair, T/A,
Renovation or Specialty Work In or Around a Covered Process
Employer Shall:
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When Selecting, Evaluate Contractors Safety Performance and
Programs
Inform Contract Employees of Known Hazards Related to Work to be
Done
Explain Applicable Emergency Action Plan Provisions
Expain Application of Safe Work Practices to Control Contractor
Evaluate Performance
Maintain a Log of Injuries and Illness
Contract Employer Shall
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Assure Employees Trained
Assure Employees Instructed in Known Hazards and Emergency Plan
Document Employees Receive and Understand Training
Assure Employees Follow Safety Rules of Plant
Advise Employees of any Unique Hazards Presented by Contractors
Work
Pre-Startup Safety Review
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Purpose is to Assure Initial Startups or Startups Following
Turnarounds or Abnormal Shutdowns are Carried Out
Safely
What is Required
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Review for New Facilities or Modified Facilities when The
Modification Requires a Change in the Process Safety
Information
Must Be done Prior to Introduction of HHCs
Must Confirm
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Construction and Equipment Meets Design Specifications
Safety, Operating, Maintenance, and Emergency Procedures
are Adequate
For New Facilities a PHA has Been Done and Issues Resolved
For Modified Facilities, Management of Change Procedures
Have Been Completed
Hot Work
 Purpose is to Assure Workers are Not Exposed to
Sources of High Energy, e.g. Explosive Substances,
Toxic Chemicals, Heat, Electricity, Moving Machinery,
etc.
 What is Required
 Employer Issue Hot Work Permit for Work on or
Near Covered Process
 Permit Must Document Fire Prevention and
Protection in Place
 Principles Apply to Energy Control Procedures or
Permits to Work As Well, e.g. digging near buried
cable or pipelines
Management of Change
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Purpose
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All Accidents are a Result of Uncontrolled Changes
Make Sure Changes are Properly Identified and Controlled
Before Implemented
What is Required – Employers Must
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Write Procedures to Manage Changes (Except for
Replacement in Kind) that Address
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Technical Basis for the Change
Impact of Change on Safety and Health
Modifications to Operating Procedures
Necessary Time Period for the Change
Authorization Requirements for the Change
Inform and Train Operations, Maintenance, and Contract
Employees Affected by the Change Prior to Start-up
Update Applicable Process Safety Information
Update Operating Procedures or Practices
Incident Investigation
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Purpose
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Provide Feedback for Prevention of Future Problems
Incidents are Analogous to Hazards ( Potential Problem),
Become Accidents When Someone is Harmed
After the Fact vs. Other Elements Aimed at Anticipation and
Prevention
What is Required
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Investigation of any Incident that Resulted or Could Have
Resulted in Catastrophic Release of a HHC
Prompt Initiation, Within 48 Hours
Investigation Team Formed Consisting of Knowledge of
Process Affected, Contractor if Involved, Others with
Appropriate Knowledge
Report Prepared
Employer has a System to Promptly and Effectively Address
Findings and Recommendations; and Document this
Resolution
Report is Reviewed with Affected Personnel
Reports are Retained for Five Years
Emergency Planning and Response
 Purpose is to Minimize Injuries and Damage
in Event of an Incident or Accident
 What is Required
 Establishment and Implementation of an
Emergency Action Plan
 Procedures for Handling Small Releases
 Training
Compliance Audits
 Purpose is to Compare Performance Against the
Written Standards and Procedures
 What is Required
 Employer Certify Every Three Years He Has Verified
Procedures and Practices Required by The Rule are
Adequate and Being Followed
 Audit Team Include One Person Knowledgeable in
Process and Other Knowledgeable Personnel
 Audit Report Developed
 Employer Respond to Findings and Document
Deficiencies Have Been Resolved
 Two Most Recent Audit Reports Be Retained
Trade Secrets – Only Non-Technical
Element in the Rule
 Purpose
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To Insure Employees Have Access to Information
Needed to Perform Job Safely, Regardless of Trade
Secrets
A Trade Secret is Knowledge not Patented but Gives a
Co. a Competitive Advantage
 What is Required
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Information (Regardless of Status) be Made Available
to Persons Responsible for
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Compiling Process Safety Information
Development of Process Hazard Analysis
Development of Operating Procedures
Involved in Incident Investigations, Emergency
Planning and Response, and Compliance Audits
Allows Employer’s to Require Confidentiality
Agreements of Employees
Summary
 Consistent Roadmap Through the PSM
Program
 The Elements Make Good Business Sense
to Assure Safe and Reliable Operations