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8 views

0 - Overview of The Elements of PSM

Uploaded by

arjalili71
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Elements of Process

Safety Management

A Review of the 14 Elements


A Way of Looking at the 14 Elements of PSM

 Elements Concerned with  Elements Concerned with


Evaluation of Progress Achieving Safety Goals
Towards Goals  Employee Participation
 Process Hazards  Process Safety
Analysis Information
 Pre-startup Safety  Operating Procedures
Review  Training
 Management of Change  Contractors
 Incident Investigation  Mechanical Integrity
 Compliance Audits  Hot Work
 Trade Secrets  Emergency Planning
Employee Participation

 Purpose
 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
 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
 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

 Purpose
 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
 Process Hazard Analysis be Done Using – What If, Checklist,
What-If/Checklist, HAZOP, FMEA, Fault Tree Analysis, etc.
 PHA will Address –
 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
 Establish System to Address Findings
 Update and Revalidate Every Five Years
Operating Procedures
 Purpose is to Assure Safe and Reliable Operations
 What is Required – Employer Must:
 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
 Purpose is to Ensure Contract Employees Observe Same Safety
Rules and Standards as Permanent Employees
 What is Required
 Applies to Contractors Performing Maintenance, Repair, T/A, Renovation
or Specialty Work In or Around a Covered Process
 Employer Shall:
 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
 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

 Purpose is to Assure Initial Startups or Startups Following


Turnarounds or Abnormal Shutdowns are Carried Out
Safely
 What is Required
 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
 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
 Purpose
 All Accidents are a Result of Uncontrolled Changes
 Make Sure Changes are Properly Identified and Controlled
Before Implemented
 What is Required – Employers Must
 Write Procedures to Manage Changes (Except for
Replacement in Kind) that Address
 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
 Purpose
 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
 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
 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
 Information (Regardless of Status) be Made Available to
Persons Responsible for
 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

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