How to Implement Process Safety Management

Transcription

1 E-BOOK How to Implement Process Safety Management BURNET ROAD, SUITE 100, AUSTIN, TX

2 Employees working with potentially dangerous machinery and hazardous materials are arbitrarily subjected to accidents that may cause serious injuries at any given time. The safety of employees depends almost entirely on the implementation of effective and strictly regulated Process Safety Management (PSM) strategies developed by the U.S. Occupational Safety and Health Administration (OSHA). PSM also allows for the competent evolution of strategies as industrial plants experience asset upgrades and technological refurbishments. What Exactly is Process Safety Management? In addition to being a strategic method that promotes preventative actions and insights, PSM is also a regulation issued two decades ago by OSHA. It is a systematic consolidation of deliberate activities that facilitate and establish the usage, management, manufacturing, and storage of immediately hazardous materials/chemicals (HHCs). Identification of HHCs should be directed by OSHA and the Environmental Protection Agency s definition of what constitutes hazardous chemicals. Key Elements of PSM OSHA segments its PSM program into 14 different areas: 1. Training 2. Operating procedures 3. Incident investigation 4. Process hazard analysis 5. Process safety information 6. Trade secrets 7. Contractors 8. Management of change 9. Emergency response and planning 10. Employee participation 11. Mechanical integrity 12. Compliance audits 13. Hot work 14. Pre-startup safety review These elements exist as interdependent entities that must contribute consistently to maintain a successful and reliable PSM strategy. If even one element lacks integral validity, then the whole process collapses, resulting to a high probability of accidental injury. Process Safety Management does not Apply to: Retail facilities Gas / oil service operations or well drilling Facilities that are normally unoccupied Hydrocarbon fuels used as fuel (for instance, propane used as gasoline for vehicle refueling or heating), if such fuels are not part of a process 1

3 containing another highly hazardous chemical covered by this standard Flammable liquid stored or transferred in atmospheric tanks that are kept below the normal boiling point without chilling or refrigerating and are not associated with a process Process Safety Information (PSI) Correct implementation of PSM also involves assimilation of Process Safety Information (PSI), which provides comprehensive analyses of equipment and hazardous materials. To remain compliant with OSHA s PSM standards, applicable industries (and their managers) will need to include PSI data regarding hazardous chemical production and handling, as well as information about machinery used in the processing of chemicals within the framework of PSM strategies. PSI consists of, but is not limited to: Toxicity / reactivity / corrosivity data Exposure limits Chemical / thermal stability data Possible effects of accidental mixing of materials Machine construction materials Electrical classification Design standards and codes (ventilation, relief, etc.) Safety systems Implementation and Training of Process Safety Management Best Practices Establishing a PSM plan demands that any employee who is remotely or directly involved in process operations must be trained in the overview and operation of PSM. OSHA standards state that training must include procedurespecific health and safety hazards, emergency operations (shutdown, fire, etc.), and additional work practices that reinforce best safety practices. Certain employees may be exempt from training if their employee states in writing that they already possess the required abilities, skills, and knowledge to perform exemplified duties specified in the PSM strategy / flowchart. OSHA also expects employers to provide refresher training to employees when necessary or at least every three years. Employers are responsible for determining when refresher PSM training is needed for employees involved in process operations. The documentation of training must be accessible and kept by the employer. This documentation should contain employee names, dates, and verification that the employee(s) understood and completed the training. 2

4 Operating Procedures OSHA s online e-booklet provides extensive descriptions and detailed breakdowns of its PSM policy, which requires exclusive compliance from relevant industries, their employees, and managers. Important data pertaining to all operational and procedural technologies involved should include the following: A simplified process or block flow diagram Properties of process chemistry Inventory controls (intended maximum) Upper / lower safety limits for compositions, temperatures, flows, pressures, and reactivity Analysis of consequences when deviations from the norm occur (evaluation of the health and safety of employees) At least one person needs to investigate all aspects of the incident. The person, or team of people, must be knowledgeable in the process involved, including a contract employee if the incident involved the work of a contractor, and other persons with appropriate knowledge and experience to investigate and analyze the incident thoroughly. PSM investigation reports must include: Incident Investigation Identifying Why a PSM Fails Disruptions that do occur are often the consequence of human error even if PSM programs are detailed by exhaustive flowcharts, PSI is accurate and readily available, and employee training sessions appear foolproof. Identifying the chain of events leading to flaws in PSM is essential to implementing the appropriate corrective measures that greatly reduce or eliminate the chance that the same error will happen again. Investigations of all incidents contrary to PSM strategies must begin as soon as possible, preferably within 48 hours of the incident s occurrence. According to OSHA standards: Incident date / time Date / time when the investigation began Complete description of the event (what happened, materials involved, witnesses to the incident) Contributory factors precipitating the incident Recommendations OSHA defines a process safety incident as the unexpected release of flammable, reactive or toxic gases and liquids in processes involving highly hazardous chemicals. The American Institute of Chemical Engineers (AIChE) - Center for Chemical Process Safety (CCPS) publishes a widely endorsed book explaining ways to identify industrial facility hazards and how to quantify the 3

5 probability that perceptible hazards will be severe. OSHA s PSM regulations (appendix D) approves of the methods described in the book. The AIChE also publishes an online glossary containing PSM terminology and definitions to help understand and implement PSM. PSM and Trade Secrets OSHA defines trade secrets as confidential processes, information, formulas, devices or patterns that are utilized in the business operations of an employer, which provides an opportunity for the employer to hold an advantage over competitors who cannot or are unable to use it. When a hazardous chemical is implicated in trade secrets, the manufacturer / employer / importer of the chemical(s) may withhold the name / identity of the chemical from the MSDS (material safety data sheet) if: The claim that the information withheld is a trade secret can be supported Information contained in the MSDS concerning the properties and effects of the hazardous chemicals is disclosed The MSDS indicates that the specific chemical identity is being withheld as a trade secret The specific chemical identity is made available to health professionals, employees, and designated representatives in accordance with the applicable provisions of this paragraph Compliance Audits PSM audits gather substantial qualitative and quantitative information relevant to hazardous processes that verify compliance with OSHA standards. Employers are expected to select trained individuals to carefully audit a PSM program / system. Smaller plants may require only one or two people to conduct a proper audit. Compliance audits need to include: A detailed assessment of the tiered arrangement and effectiveness of the PSM system A field (physical) inspection of the health and safety conditions / employee practices to validate that an employer s PSM has been successfully implemented Use of impartial individuals who are knowledgeable about auditing techniques Other necessary elements comprising a compliance audit involve staffing, planning, the actual audit, assessing hazards, and evaluating any deficiencies found during the audit Interviews with plant personnel at all hierarchy levels Immediate implementation of corrective actions if deficiencies are found, with documented followup indicated An example of a compliance audit might involve an audit team that evaluates a PSM training program for the commensurateness of content, training frequency, and whether the program meets its objectives and goals, as outlined in the PSM. Audit teams should also determine the extent of employees awareness and knowledge of the PSM, its rules, and their duties in response to emergencies and work authorization practices. Hot Work According to (k)(1), employers shall issue a hot work permit for hot work operations conducted on or near a covered process. 4

6 Permits are expected to document fire protection and prevention requirements (indicated by 29 CFR ) that should have been established before beginning any hot work operation. Permits need to further indicate dates when hot work was authorized and name the object(s) involved in the hot work. Permits need to remain on file until the hot work task is completed ( (k)(2). Process Safety Management, Contractors, and their Employees OSHA s PSM provides special provisions for contractors and their employees who perform, repair, maintain, and renovate processes covered in a PSM or are adjacent to applicable processes. However, contractors do not have to adhere to PSM if they are performing incidental services isolated from process safety. These services include but are not limited to janitorial, laundry, food/ beverage, supply / delivery or laundry services. Management of Change OSHA s Management of Change (MOC) policy involves reviewing all proposed changes to equipment, materials, procedures, technology, and personnel before they are carried out to determine how they would affect any undetected compromises to safety. Proposed changes could generate safety vulnerabilities, which would then require the updating of applicable safety data and the retraining of employees involved in jobs that would be affected by changes. Although MOC is typically associated with permanent changes, temporary changes can also be included due to their probable role in injury-causing events. OSHA considers abnormal situations, untrained people filling in for absent trained personnel, and deviations from SOPs as temporary changes that need to be managed as if they are permanent changes. Normal process specifications, clear communication, management signoffs, and utilization of standard operating procedures are necessary. Change control forms are checklists designed to facilitate MOC procedures. Personnel who are filling out change control forms must include descriptions of the proposed change; why the change is being implemented; its environmental, health, and safety considerations; and details of any expected changes to training requirements, existing documents, safety plans or procedures. Implementation of any changes needs approval from appropriate authorities. Significant or complex changes require hazard assessment procedures, accompanied by written approvals from associated safety departments, maintenance or operations. Examples of situations that can help clarify when MOC guidelines must be implemented include: Annexation or replacement of new equipment involved in a process Minor additions and / or modifications to process equipment or critical business systems (software or procedural) Changes to control strategies involving instrumentation 5

7 Modification to critical process constants (operating limits) that move past pivotal ranges indicated in SOPs Alterations to shutdown procedures, fire suppression, interlocks, and other safety systems Changes in sourcing / component specifications of raw materials Implementation of new connections or alterations to steam, gas, electrical, air or water utility systems Changes to critical test devices and quality assessment procedures OSHA s Hazardous Waste and Emergency Response Regulation (29 CFR (a), (p), and (q). Based on (b) oral and written emergency action plans must be in writing and available in the workplace. Plans need to be available to employees at any given time for proper review. Employers with less than 10 employees on the payroll are allowed to communicate emergency action plans orally to employees. At least, emergency action plans are expected to include the following: Procedures for reporting any type of emergency (fire, spill, equipment malfunction) Emergency evacuation procedures, including exit routes and types of evacuation Procedures defining methods of accounting for all employees following a complete evacuation Special procedures that must be followed by personnel who are considered critical to plant operations before an evacuation ( (c)(3)) Recognizable alarm system for employees alarm systems must have unique signals indicating the implementation of specific actions by employees, and signals must comply with requirements ( (d) ) Emergency Response and Planning Emergency response plans must be implemented according to provisions described in OSHA rules (29 CFR (a)). Plans must also include guidelines for managing small hazardous chemical accidents. Moreover, employers covered under a process management system strategy may be required to follow Another critical component of a PSM Emergency Response and Planning (ERP) program is emergency preparedness, which covers the immediate preparation for an unexpected chemical release. In developing an ERP, employers must decide: If employees or other designated personnel should manage incidental releases If available resources can be adequately mobilized 6

8 to assist in an emergency preparedness plan If employees need to evacuate to safe zones in order to facilitate entrance and assistance of ERP teams OSHA discourages the use of buildings or process control centers as safe areas. According to their guidelines: recent catastrophes indicate that lives are lost in these structures because of their location and because they are not necessarily designed to withstand overpressures from shock waves resulting from explosions in the process area. OSHA s Hazardous Waste Operations and Emergency Response (HAZWOPER) standard must also be followed if employers want to utilize plant personnel (spill control teams, fire brigades, HAZMAT) to assist people involved in the release and control the incident. When outside assistance is required, emergency responders are covered by OSHA s HAZWOPER standards. Mechanical Integrity OSHA s primary mechanical integrity requirements of critical process equipment involve their correct design, installation, and implementation in the PSM. Employers must establish written procedures that fully describe the maintenance of the ongoing integrity of all process machines and their components. Training of employees involved in maintaining process equipment is mandatory. Regular testing and inspection on process equipment must be done. Procedures recognized as good engineering practices must also be followed. Inspection frequency must adhere to the recommendations of the equipment s manufacturer. However, if prior experiences with the equipment necessitate more frequent inspections, this practice should be included in the PSM strategy. Individual inspections must be properly documented including the inspection date, name of the employee performing the test / inspection, and the equipment s identifying serial number. Correction of equipment deficiencies must be implemented before resuming operations, except in cases where the deficiency is deemed not applicable to process stoppage as long as deficiencies are corrected in a safe and timely manner. Pre-Startup Safety Assessment Requirement Before the introduction of any hazardous chemicals or materials, PSM guidelines require employers to perform pre-startup safety reviews for new and modified facilities if the change is considerable enough to necessitate updates to PSI. Prior to including hazardous chemicals to a process, prestartup safety reviews must verify that: Equipment and construction conform to design specifications Emergency, safety, maintenance, and operating procedures have been established and deemed applicable to their respective circumstances New facilities have sustained and passed a comprehensive process hazard analysis this includes the implementation and / or resolution of any pre-startup recommendations Mechanical integrity points identified in PSM strategies have been identified and validated mechanical integrity applies to storage tanks, pressure vessels, pipe and vent systems, emergency shutdown controls, alarms / sensors / interlocks, and pumps. 7

9 Distinguished Professor of Engineering Kaoru Ishikawa has deemed the flowchart as a fundamental quality control tool that is more effective and pragmatic than Pareto charts, scatter diagrams or histograms. The building blocks of flowcharts not only empower the efficacy of a process management system to achieve compliance with OSHA standards, but also accelerate the implementation of PSM so that employers minimize or eliminate risks associated with underestimating vulnerabilities obscured within a process. General types of flowcharts include document, data, system, and program flowcharts (with emphasis on control types instead of the exclusive flow itself advancing the holistic purpose of the flow chart). Necessity of Flowcharts in Process Safety Management Flowcharts visually simplify all components of a PSM plan by condensing them into a clearly defined sequence of actions or materials that enter (input) or leave (output) the PSM. Flowcharts also incorporate services, decisions, personnel, and time needed to complete each step and applicable measurements. Implementing a flowchart to facilitate PSM strategies reinforces an employer s ability to: Develop a systematic understanding of process finalization Examine each stage of a process to determine whether there is room for improvement Facilitate and expedite communication to others regarding the performance of a process Thoroughly document the process with analytical precision Mitigate difficulties with initiating a PSM plan 8

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