PSM Program Review Checklist

Transcription

1 Use this checklist to help determine employer compliance with the Process Safety Management Standard issued by the Occupational Safety and Health Administration. Please note that the checklist does not include all of the standard s requirements and does not reflect all OSHA letters of interpretation or compliance directives in particular situations. There are 3 elements to a review of a PSM program: 1. Documentation review examination of the documentation of the programs required by the standard. 2. Field Inspection & Verification examination of the physical covered process; its equipment, piping, instrumentation, procedures, and operation. 3. Interviews discussions with employees and contractors to determine if the implemented program matches the program outlined in the documentation. In order to gather the information needed to audit a PSM program the following questions need to be asked for each PSM program element Who What When Where Why How Who Who is responsible for developing and implementing each of the program elements? What What are the requirements and contents of each program element? When When are the required actions for each element completed and when were they required to be completed? Where Where have actions been implemented or changed? Why Why have the implementation decisions and priorities been made as recorded in the documentation? How How is the program implemented and how is the program s effectiveness evaluated and improved? An essential part of verifying program implementation is to audit the flow of information and activities among the elements. When information in one element is changed or when action takes place in one element that affects other elements, an auditor/reviewer should examine a sample of the related elements to see if the appropriate changes and followup actions have taken place. The following example demonstrates the interrelationship among the elements: During a routine inspection of equipment (Mechanical Integrity), the maintenance worker discovers a valve that no longer meets the applicable code and must be changed. Because the type of valve is no longer made, a different type of valve must be selected and installed (Management of Change). The type of valve selected may mandate different steps for the operators (Operating Procedures) who will require training and verification in the new procedures (Training). The rationale for selecting the type of valve must be made available for review by employees and their representatives (Employee Participation). When the new valve is installed by the supplier (Contractors), a qualified and safe contractor must be selected to perform the work (Contractor Management). The work will involve shutting down part of the process (Pre-startup Safety Review) as well as brazing some of the lines (Safe Work Practices - Hot Work Permit). The employer must review the response plan (Emergency Planning) to ensure that procedures are adequate for the installation hazards. Although Management of Change provisions cover interim changes, after the new valve is in place the Process Safety Information will have to be updated before the (Process Hazard Analysis) is updated or revalidated, to account for potential hazards associated with the new equipment. Also, inspection and maintenance procedures and training will need to be updated (Mechanical Integrity). In summary, 12 PSM elements can be affected by changing one valve. A reviewer/inspector/auditor/compliance officer would check a representative number of these 11 elements to confirm that the required follow-up activities have been implemented for the new valve. Page 1 of 14

2 Application of PSM Standard to Facility (a) Does the workplace have any of the following: A process which involves a chemical at or above the specified threshold quantities listed in Appendix A of the PSM Standard (attached to checklist); or A process which involves a flammable liquid or gas [as defined in (c)] on site in one location, in a quantity of 10,000 pounds ( kg) or more. Exemptions: A threshold quantity of flammable liquids if it is stored in atmospheric tanks or transferred without the benefit of chilling or refrigeration Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort heating or gasoline for vehicle refueling.) These fuels cannot be part of a process containing other highly hazardous chemicals covered by the PSM standard. Retail facilities. Oil or gas well drilling or servicing operations. Normally unoccupied remote facilities. Note: for determining coverage by the PSM standard, the quantity of flammable liquids stored in atmospheric tanks may be excluded from the quantity in the covered process pursuant to the Meer Decision. Important interpretation: June 11, 2007 OSHA defines on-site in one location for PSM to mean that the standard applies when a threshold quantity of highly hazardous chemical (HHC) exists within an area under the control of an employer or group of affiliated employers. It also applies to any group of vessels that are interconnected, or in separate vessels that are close enough in proximity that the HHC could be involved in a potential catastrophic release. ** IF THE WORKPLACE HAS ANY OF THESE OPERATIONS OR PROCESSES, IT MUST COMPLY WITH THE PSM STANDARD. ** Examples of industries that may have highly hazardous chemicals and processes covered by the PSM standard: Industrial production of organics and inorganic materials Paints Pharmaceuticals Adhesives Sealants and Fibers Petrochemical facilities Paper Mills Food Processing with Anhydrous Ammonia over the TQ Conversion Example Gallons to lbs conversion = gallons x 8.33 x specific gravity of the liquid = lbs of liquid Example: Weight of 10,000 gallons of gasoline = 10,000 x 8.33 x = 61,559 lbs Page 2 of 14

3 YES NO Employee Participation (c)(1) Has the employer developed a written plan of action for implementation of employee participation? YES NO Employee Participation (c)(2) Has the employer consulted with employees and their representatives on the conduct and development of process hazard analyses and on the development of all other elements of the PSM standard? YES NO Employee Participation (c)(3) Do employees and their representatives have access to process hazard analyses and all other information required by the PSM standard? YES NO Hazard Information Collection (d)(1) Has the employer collected information pertaining to the hazards of the process? Toxicity PELs Physical data Reactivity Corrosivity Thermal & chemical stability Hazards of mixing chemicals MSDSs YES NO Technology of the Process Information Collection (d)(2)(i)(A) Does the employer have block diagrams or simplified process flow diagrams for each covered process? YES NO Technology of the Process Information Collection (d)(2)(i)(B-D) Does the employer have information on the technology of the covered process for the following: Process chemistry (d)(2)(i)(B). Maximum intended inventory (d)(2)(i)(C). Safe upper and lower limits for: temperature, pressures, flows, levels, compositions or other pertinent metrics for the process (d)(2)(i)(D). YES NO Technology of the Process Information Collection (d)(2)(i)(E) Has the employer performed and documented an evaluation of the consequences of deviations in the covered process, including those affecting the health and safety of employees? YES NO Equipment of the Process Information Collection (d)(3)(i)(A-H) Does the employer have information on the equipment of the covered process for the following: Materials of construction (d)(3)(i)(A). Piping and instrument diagrams (P&IDs) (d)(3)(i)(B). Electrical classification (d)(3)(i)(C). Relief system design and design basis (d)(3)(i)(D). Ventilation system design (d)(3)(i)(E). Design codes or standards used (d)(3)(i)(F). Material and energy balances for processes (d)(3)(i)(G). Safety systems (d)(3)(i)(H). Page 3 of 14

4 YES NO Equipment of the Process Information Collection (d)(3)(i)(A-H) Has the PSM documentation including all elements above been field verified and compared to the actual equipment and components in the covered process? YES NO Process Hazard Analysis (e)(1) Has the employer performed an initial process hazard analysis on the covered processes? YES NO Process Hazard Analysis (e)(2)(i-vii) Has the employer used one or more of the following methodologies to perform the process hazard analysis (PHA)? What if (e)(2)(i). Checklist (e)(2)(ii). What if/checklist (e)(2)(iii). Hazard and Operability Study (HAZOP) (e)(2)(iv). Failure mode and effects analysis (FEMA) (e)(2)(v). Fault tree analysis (e)(2)(vi). An appropriate equivalent methodology (e)(2)(vii). YES NO Process Hazard Analysis (e)(3)(i-vii) Does the PHA(s) address the following? Hazards of the process (e)(3)(i). Equipment in the process (e)(3)(i). Identification of previous incidents (e)(3)(ii). Engineering and administrative controls (e)(3)(iii). Consequences of failure for engineering or administrative controls; including consequences of deviation and steps required to correct or avoid deviation (e)(3)(iv). Facility siting (e)(3)(v). Human factors (e)(3)(vi). A qualitative evaluation of safety and health effects of failure on employees in the workplace (e)(3)(vii). YES NO Process Hazard Analysis (e)(4) Was the PHA(s) performed by a team that had the following? Expertise in engineering and process operations. At least one employee with experience and knowledge specific to the covered process. With one member of the team knowledgeable in the specific evaluation methodology used to perform the PHA. YES NO Process Hazard Analysis (e)(5) Does the employer have a system to promptly address PHA findings and recommendations? Does the system address findings and recommendations in a timely manner? Are the resolutions documented? Document actions taken? Is there a written schedule for completion of recommended actions? Has the actions taken or scheduled for resolution of recommendations been communicated to employees, contractors or other persons possible impacted by the recommendations or actions? Page 4 of 14

5 YES NO Process Hazard Analysis (e)(6) Have PHAs been updated and revalidated at least every five years? YES NO Process Hazard Analysis (e)(7) Has the employer retained all documentation for PHAs, updates, revalidations, recommendations, and resolutions of recommendations? YES NO Operating Procedures (f)(1) Has the employer developed and implemented written safe operating procedures for each covered process; addressing the steps for each operating phase, the operational limits, safety and health considerations, and safety systems and their function? Steps for each operating phase: Initial startup (f)(1)(i)(A). Normal operations (f)(1)(i)(B). Temporary operations (f)(1)(i)(C). Emergency shutdown including the conditions under which emergency shutdown is required, and assignment of responsibility to qualified operators to ensure timely and safe shutdown (f)(1)(i)(D). Emergency operations (f)(1)(i)(E). Normal shutdown (f)(1)(i)(F). Startup after turnaround or emergency shutdown (f)(1)(i)(G). Operating limits: Consequences of deviation (f)(1)(ii)(A). Steps required to avoid or correct deviation (f)(1)(ii)(B). Safety and health considerations: Properties and hazards of chemicals present in the covered process (f)(1)(iii)(A). Precautions required to prevent exposure; including engineering and administrative controls, and PPE (f)(1)(iii)(B). Control measure to be taken if physical or airborne exposure occurs (f)(1)(iii)(C). Quality control of raw materials and control of hazardous chemical inventory (f)(1)(iii)(D). Any special or unique hazards (like forklifts hitting ammonia refrigeration pipes) (f)(1)(iii)(E). Safety systems and their proper operation (f)(1)(iv). Page 5 of 14

6 YES NO Employee Training (g)(1) Has the employer trained each employee involved in operating a covered process before the employee is involved in operating the process? PSM training programs MUST be developed for: Affected employees Those not directly involved in the process operation but with jobs at the facility with a covered process. Authorized employees Those directly involved in the process operation. Contractors who may perform work on a covered process. Vendors/Visitors who may visit the facility and may potentially be exposed to the covered process Primarily in emergency evacuation procedures and PPE requirements (if necessary). Training subjects should include at least the following: Lock-out/Tag-out Hot work Line & equipment opening Confined space entry (if applicable) Emergency response Operating procedures Management of Change Other Training Subjects May be Required for Authorized Employees and Contractors YES NO Employee Training (g)(2) Has refresher training been provided for employees involved in operating a covered process at least every three years or as needed? YES NO Employee Training (g)(3) Has the employer documented all training, ascertaining that employees have received and understood the training? Documentation should include the following: Identity of employee. Date of training. Means used to verify employee understanding of the training (test, interview, etc.) YES NO Contractor Management (h)(2)(i) When selecting a contractor, has the employer obtained and evaluated information regarding the contractor s safety and health performance and programs? YES NO Contractor Management (h)(2)(ii) Has the employer informed contract employer of the known potential fire, explosion or toxic release hazards related to the contractor s work and process? YES NO Contractor Management (h)(2)(iii) Has the employer explained to contractor employer the applicable provisions of the emergency action plan? YES NO Contractor Management (h)(2)(iv) Page 6 of 14

7 Has the employer developed and implemented safe work practices to control the entrance, presence and exiting of contractors in covered process areas? YES NO Contractor Management (h)(2)(v) Has the employer periodically evaluated the performance of all contractors in fulfilling their obligations in regards to training and related documentation of for contractor employees? YES NO Contractor Management (h)(2)(vi) Has the employer maintained an illness and injury log (OSHA form 300) for work performed by contract employees in the covered process area? YES NO Contractor Management (h)(3)(i-iv) Has the contractor employer done the following: Trained each contractor employee is trained in the work practices necessary to safely perform the job. Instructed each contractor employee in the known potential fire, explosion or toxic release hazards related to the job and process. Document that each contractor employee has received and understood the training required, and the documentation includes the identity of the employee, date of training, and means used to verify the contract employee understood the training. Ensure that contractor employees follow safety rules of the facility. YES NO Contractor Management (h)(2)(v) Has the contractor notified the employer of unique hazards presented by the contractor employer s work in the covered process area? YES NO Pre-Startup Safety Review (i) Did the employer perform a pre-startup review for all new facilities or modified facilities that are modified enough to require change to the process safety information? YES NO Mechanical Integrity of Process Equipment (j)(2) Does the employer have written procedures to maintain the on-going integrity of the following process equipment: Pressure vessels and storage tanks. Piping systems (including piping components such as valves.) Relief and vent systems and devices. Emergency shutdown systems. Controls (including monitoring devices and sensors, alarms, and interlocks.) Pumps. YES NO Mechanical Integrity of Process Equipment (j)(3) Does the employer have documentation of training that each employee involved in the maintaining of the on-going integrity of covered process equipment has been informed of the hazards of the process and the procedures applicable to the employee s job task and how to perform the job task in a safe manner? YES NO Mechanical Integrity of Process Equipment (j)(4) Page 7 of 14

8 Does the employer have documentation that the employer has performed inspections and tests on the covered process equipment following generally accepted engineering practices or manufacturer s recommendations on a frequency that is according to generally accepted engineering practices, manufacturer s recommendations or more frequently if determined by prior experience? The documentation should include: date, name of person performing inspection or test, description of inspection or test, and results of the inspection or test. YES NO Mechanical Integrity of Process Equipment (j)(5) Has the employer corrected deficiencies in integrity before further use or in a safe and timely manner when necessary means are taken to assure safe operation? YES NO Mechanical Integrity of Process Equipment (j)(6) Quality assurance Has the employer assured that fabricated equipment is suitable for the process application (applicable codes), has been inspected and checked for proper installation consistent with design specification and manufacturer s recommendations, and all maintenance materials and spare parts are also suitable for the process application? YES NO Hot Work (k) Has the employer issued a hot work permit for hot work operations conducted on or near a covered process? YES NO Management of Change (l)(1-2) Does the employer have written procedures to manage change in the covered process(es)? Procedures should cover the following: Technical basis for proposed change. Impact of change on safety and health. Modification to operating procedures. Necessary time period for the change. Authorization requirements for the proposed change. YES NO Management of Change (l)(3) Have affected employees and contractors been informed and trained on change in the covered process prior to start-up of the process or affected portion of the process? YES NO Management of Change (l)(4-5) Has the employer updated the following procedures, practices and/or documentation affected by the change in the process? Process information. Operation procedures or practices. Inspection and testing procedures. PHAs. Flow charts, P&IDs, equipment #s, mechanical integrity certificates, etc. YES NO Incident Investigation (m)(1) Has the employer investigated each incident, which resulted in, or could reasonably have resulted in, a catastrophic release of highly hazardous chemical in the workplace? YES NO Incident Investigation (m)(2) Page 8 of 14

9 Has an incident investigation been initiated as promptly as possible, but not later than 48 hours following the incident? YES NO Incident Investigation (m)(3) Did the investigation team(s) consist 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? YES NO Incident Investigation (m)(4) Did the investigation team issue a report at the conclusion of the investigation which included at a minimum the following: Date of incident. Date investigation begun. A description of the incident. The factors that contributed to the incident. Any recommendations resulting from the investigation. YES NO Incident Investigation (m)(5) Has the employer established a system to promptly address and resolve incident findings and recommendations, with documentation of resolutions and corrective actions? YES NO Incident Investigation (m)(6) Has the employer reviewed all incident reports with affected personnel whose job tasks are relevant to the incident findings, including contract employees? YES NO Incident Investigation (m)(7) Has the employer retained all incident reports for at least 5 years? YES NO Emergency Planning and Response (n) Has the employer developed and implemented an emergency plan for the entire plant in accordance with the provisions of 29 CFR ? YES NO Compliance Audit (o)(1-3) Has the employer performed an audit of the PSM program to certify they have evaluated compliance with the provisions of the PSM standard at least every 3 years conducted by at least one person knowledgeable in the process, and a report issued? YES NO Compliance Audit (o)(4) Has the employer promptly determined and documented appropriate response to each of the findings? YES NO Compliance Audit (o)(5) Has the employer retained the two most recent compliance audit reports? YES NO Trade Secrets (p) Has the employer made all information necessary to comply with the PSM standard available to those persons responsible for compiling the process safety information? YES NO Trade Secrets (p) Page 9 of 14

10 Have employee and their designated representatives had access to trade secret(s) information contained within process hazard analysis and other documents required to be developed by this standard? Page 10 of 14

11 Appendix A List of Highly Hazardous Chemicals, Toxics and Reactives CHEMICAL NAME CAS* TQ** Acetaldehyde Acrolein (2-Popenal) Acrylyl Chlorde Allyl Chlorid Allylamine Alkylaluminum Varies 5000 Ammonia, Anhydrous Ammonia solutions (greater than 44% ammonia by weight) Ammonium Perchlorate Ammonium Permanganate Arsine (also called Arsenic Hydride) Bis(Chloromethyl) Ether Boron Trichloride Boron Trifluoride Bromine Bromine Chloride Bromine Pentafluoride Bromine Trifluoride Bromopropyne (also called Propargyl Bromide) Butyl Hydroperoxide (Tertiary) Butyl Perbenzoate (Tertiary) Carbonyl Chloride (see Phosgene) Carbonyl Fluoride Cellulose Nitrate (concentrationgreater than 12.6% nitrogen) Chlorine Chlorine Dioxide Chlorine Pentrafluoride Chlorine Trifluoride Chlorodiethylaluminum (also called Diethylaluminum Chloride) 1-Chloro-2,4-Dinitrobenzene Chloromethyl Methyl Ether Chloropicrin Chloropicrin and Methyl Bromide mixture None 1500 Chloropicrin and Methyl Chloride mixture None 1500 Cumene Hydroperoxide Cyanogen Cyanogen Chloride Cyanuric Fluoride Diacetyl Peroxide (concentration greater than 70%) Diazomethane Dibenzoyl Peroxide Page 11 of 14

12 CHEMICAL NAME CAS* TQ** Diborane Dibutyl Peroxide (Tertiary) Dichloro Acetylene Dichlorosilane Diethylzinc Diisopropyl Peroxydicarbonate Dilauroyl Peroxide Dimethyldichlorosilane Dimethylhydrazine, 1, Dimethylamine, Anhydrous ,4-Dinitroaniline Ethyl Methyl Ketone Peroxide (also Methyl Ethyl Ketone Peroxide; concentration greater than 60%) Ethyl Nitrite Ethylamine Ethylene Fluorohydrin Ethylene Oxide Ethyleneimine Fluorine Formaldehyde (Formalin) Furan Hexafluoroacetone Hydrochloric Acid, Anhydrous Hydrofluoric Acid, Anhydrous Hydrogen Bromide Hydrogen Chloride Hydrogen Cyanide, Anhydrous Hydrogen Fluoride Hydrogen Peroxide (52% by weight or greater) Hydrogen Selenide Hydrogen Sulfide Hydroxylamine Iron, Pentacarbonyl Isopropylamine Ketene Methacrylaldehyde Methacryloyl Chloride Methacryloyloxyethyl Isocyanate Methyl Acrylonitrile Methylamine, Anhydrous Methyl Bromide Methyl Chloride Methyl Chloroformate Page 12 of 14

13 CHEMICAL NAME CAS* TQ** Methyl Ethyl Ketone Peroxide (concentration greater than 60%) Methyl Fluoroacetate Methyl Fluorosulfate Methyl Hydrazine Methyl Iodide Methyl Isocyanate Methyl Mercaptan Methyl Vinyl Ketone Methyltrichlorosilane Nickel Carbonly (Nickel Tetracarbonyl) Nitric Acid (94.5% by weight or greater) Nitric Oxide Nitroaniline (para Nitroaniline) Nitromethane Nitrogen Dioxide Nitrogen Oxides (NO; NO(2); N2O4; N2O3) Nitrogen Tetroxide (also called Nitrogen Peroxide) Nitrogen Trifluoride Nitrogen Trioxide Oleum (65% to 80% by weight; also called Fuming Sulfuric Acid) Osmium Tetroxide Oxygen Difluoride (Fluorine Monoxide) Ozone Pentaborane Peracetic Acid (concentration greater 60% Acetic Acid; also called Peroxyacetic Acid) Perchloric Acid (concentration greater than 60% by weight) Perchloromethyl Mercaptan Perchloryl Fluoride Peroxyacetic Acid (concentration greater than 60% Acetic Acid; also called Peracetic Acid) Phosgene (also called Carbonyl Chloride) Phosphine (Hydrogen Phosphide) Phosphorus Oxychloride (also called Phosphoryl Chloride) Phosphorus Trichloride Phosphoryl Chloride (also called Phosphorus Oxychloride) Propargyl Bromide Propyl Nitrate Sarin Selenium Hexafluoride Stibine (Antimony Hydride) Sulfur Dioxide (liquid) Sulfur Pentafluoride Page 13 of 14

14 CHEMICAL NAME CAS* TQ** Sulfur Tetrafluoride Sulfur Trioxide (also called Sulfuric Anhydride) Sulfuric Anhydride (also called Sulfur Trioxide) Tellurium Hexafluoride Tetrafluoroethylene Tetrafluorohydrazine Tetramethyl Lead Thionyl Chloride Trichloro (chloromethyl) Silane Trichloro (dichlorophenyl) Silane Trichlorosilane Trifluorochloroethylene Trimethyoxysilane Footnote* Chemical Abstract Service Number Footnote** Threshold Quantity in Pounds (Amount necessary to be covered by this standard.) Page 14 of 14