a real-world introduction to psm’s 14 elements
TRANSCRIPT
My Facility is PSM-Covered – Now What?A real-world introduction to PSM’s 14 Elements
ModeratorHostSpeaker
Sajjad Gul, Dir. Business Dev.Rob Bartlett, PSM Consultant Ameyra Rosales, Brand Mangr
About 360factors, Inc.
Pareto Engineering & Management Consulting
Rob Bartlett owns Pareto Engineering & Management Consulting and.
He uses his over 20 years of experience and partners with companies
to create World Class Process Safety Systems.
3 Offices in 3 Countries
ABOUTUS
INDUSTRY FOCUSED
Oil & Gas
Utilities
Mining
Manila, Philippines
Karachi,Pakistan
Austin, TX(US HQ)
INDUSTRY FOCUSED$25M REVENUE350+ EMPLOYEES GLOBAL PRESENCE
Why is PSM Needed?
1984 – Mexico City650 fatalities. unknown injuries
Costs and Benefits of Good Safety Performance
What we see
Direct Costs of Injuries
Medical costs
Wage indemnity
Claims administration fees
What we don’t see
The Hidden Costs of Injuries
Damaged equipment, vehicles & goods
Lost production and quality
Process interruptions, yield losses
Replacement labor / Overtime
General liability costs
Litigation
Damage to customer relations & public image
Direct Cost
Indirect Cost
5X
Process Safety ManagementA real-world introduction to PSM’s 14 Elements
My Facility is PSM-Covered
Now What?
Process Safety Management
Simple* Elements
Employee Participation
Training
Hot Work
Incident Investigation
Emergency Response
Compliance Audits
Trade Secrets
*Relative to other elements
Process Safety Management
Challenging Elements
Process Safety Information
Process Hazard Analyses
Operating Procedures
Contractor Management
Pre-Startup Safety Reviews
Mechanical Integrity
Management of Change
Process Safety Management
Process Safety Information
Information pertaining to the
hazards of the highly hazardous
chemicals in the process
Toxicity information
Permissible exposure limits
Reactivity data
Corrosivity data
Information pertaining to the technology of
the process
Process Safety Information
Real World Advice
Most information exists in SDSs,
literature, & plant and process
documentation
Gather all PSI in one place – either
electronic or paper
Be sure that PSI is updated as
changes are made
Create an Action Item for annual
review of the PSI
Process Safety Management
Process Hazard Analysis
PHA shall be appropriate to the
complexity of the process and shall
identify, evaluate, and control the
hazards involved in the process
What if / What if Checklist
Hazard and Operability Study (HAZOP)
Failure Mode Effective Analysis (FMEA)
Fault Tree Analysis
Layer of Protection Analysis (LOPA)
Updated/Revalidated at least every
five years
Process Hazard Analysis
Real World Advice
Choose the right method, not every
process needs a HAZOP.
Chose the right team – experience is
the key.
PHA doesn’t end with a report -
develop a system to review and
manage PHA recommendations
Process Safety Management
Operating Procedures
Develop and implement written
operating procedures that provide
clear instructions for safety
conducting activities involved in
each covered process
Steps for each operating phase
Operating Limit
Health & Safety consideration
Safety Systems
Develop procedures for LOTO, First
Breaks, Confined Space, Facility
Control
Operating Procedures
Real World Advice
Electronic document system often
easiest to maintain.
Do not try to put all the required
information into one procedure –
combine common information into
one procedure
Be simple and direct – readability
and understandability are vital
Process Safety Management
Contractors Applies to contractors performing maintenance
or repair, turnaround, major renovation, or
specialty work on or adjacent to a covered
process
Obtain and evaluate information regarding the
contract employer's safety performance and
programs
Inform contract employers of the known
potential fire, explosion, or toxic release
hazards
Control the entrance, presence and exit of
contract employers and contract employees in
covered process areas
Contract employer has specific responsibilities
Contractor Management
Real World Advice
Develop an approval process for
contractors
Allot adequate resources to
maintaining contractor approval and
training documentation
Ensure that contractor employees
have the required training to
complete
Process Safety Management
Pre-Startup Safety Review
Perform a PSSR for new facilities
and for modified facilities when the
modification is significant enough to
require a change in PSI
Construction and equipment is in
accordance with design and specifications
Safety, operating, maintenance and
emergency procedures are in place and
adequate
PHA and MOC completed, if needed
Training employees involved in operating a
process completed
Pre-Startup Safety Reviews
Real World Advice
Involve the right people –
experience counts
Don’t rely on memory - use
checklists
Develop a system for managing
post-startup actions from PSSR
Use the PSSR as opportunity to
prove that process is safe to start –
Document everything!
Process Safety Management
Mechanical Integrity
Applies to:
Pressure Vessels and Storage Tanks
Piping Systems (including piping
components such as valves)
Relief and vent systems and devices
Emergency shut down systems
Controls (including monitoring devices,
sensors, alarms and interlocks)
Pumps
Process Safety Management
Mechanical Integrity Establish and implement written
procedures to maintain the on-going
integrity of process equipment
Train each employee involved in
maintaining the on-going integrity of
process equipment
Perform inspections and tests on process
equipment following Recognized and
Generally Accepted Good Engineering
Practices (RAGAGEP)
Document inspections and correct
deficiencies
Establish Quality Assurance procedures
Mechanical Integrity
Real World Advice RAGAGEP = 7 words = infinity of complexity
Use operations and maintenance manuals
whenever possible (have them readily
accessible)
Develop ITPM plan using CCPS MI book
Use a Computerized Maintaining System to
schedule ITPM tasks and track deficiencies
to closure
Become familiar with API, NFPA, ASME, and
other RAGAGEP
Process Safety Management
Management of Change Establish and implement written
procedures to manage changes to process
chemicals, technology, equipment, and
procedures; and, changes to facilities that
affect a covered process
Include :
Technical basis for the change
Impact of change on safety & health
Modifications to operating procedures
Necessary time period for the change
Authorizations req. for the change
Management of Change
Real World Advice
There are very few ‘Replacement in
Kind’
Be sure complete all pre- and post-
change actions
Include personnel changes
Paper is ok, but electronic is far
superior
My Facility is PSM-Covered – Now What?!?
Review OSHA 1910.119
Complete a Gap-Analysis for compliance of
existing programs
Develop programs to address gaps
Success Factors
Use as many existing processes as possible
Hot Work, PSI, Operating Procedures
Use a cross-functional team
Include operators and mechanics
Continual training and auditing
Don’t assume the processes are working
Q&A
At the end of the day, safety is all
about care, saving lives,
families, and the society we
operate in.