Process Safety Management of Highly Hazardous & Explosive ChemicalsOperating Procedures, Safety Procedures & Training

Now that the PHAs Are Competed or UnderwayOperating Procedures & Safety Programs Must Be Developed

PHA Information Can Be Used

Operating Procedures1910.119(f)

Operating Procedures & Safety Programs Must Consider:Initial start-upNormal operationsTemporary operationsEmergency shutdownEmergency operationsNormal shutdown Start-up following turnaroundConsequences of deviationSteps required to correct or avoid deviation

Operating Procedures or Standard Operating Procedures (SOPs)Where Did This Methodology Come From?

Answer: The Military

Definition: A standard operating procedure is a set of instructions having the force of a directive, covering those features of operations that lend themselves to a definite or standardized procedure without loss of effectiveness. Standard Operating Policies and Procedures can be effective catalysts to drive performance improvement and improving organizational results. Every good quality system is based on its standard operating procedures (SOPs).

*Readily accessible to employeesOperating ProceduresDevelop and implement written operating procedures* consistent with the process safety information and addresses at least the following elements:Initial start-up, normal and temporary operationsNormal and emergency shut-down proceduresOperating limits and consequences of deviationHazards presented by the process

Operating ProceduresThe operating procedures addressing operating parameters will contain operating instructions about:pressure limitstemperature rangesflow ratesand what to do when an upset condition occurswhat alarms and instruments are pertinent if an upset condition occurs, and other subjects.

Operating Procedures - Start UpWe Must

Describe normal SOP's

Describe start-up SOP's

Describe Shut-down SOPs

Operating Procedures - Start UpWe MustInclude Sections such as:ObjectivesPurposeConcernsProceduresDepartmentOperatorEquipment InvolvedLocationRelated Documents

Lets Look at An Example

Process Safety Management Procedure - Revision HPR-1 Revision Date: 1-9-2009 by: SWD

ObjectiveThis procedure is designed to describe the Technical Operating Specifications (TOS), and to set down the Standard Operating Procedures for the safe operation of Ammonia High Pressure Receiver 1 (HPR-1)Purpose:The purpose of the TOS is to provide a description of the High Pressure Receiver, to define the function of the receiver, its operating conditions and limits, and consequences of deviation from these limits; To describe controls and instrumentation and safety systems, and set operating alignments. The purpose of the Standard Operating Procedure (SOP) is to set down the proper steps for starting, monitoring normal operation, and stopping and restarting the Receiver under normal and emergency conditionsConcerns: Very Careful attention to valve positions, temperature, and pressure levels is extremely important to the successful completion of these procedures. Deviations from normal operating limits could cause personal injury or death, small to catastrophic release of ammonia or environmental damage, or evacuation of, or injury to, members of the public. We seek to prevent incidents such as: Injury to operators and others in the area. Damage to the High Pressure Receiver. Release of any quantity of Anhydrous Ammonia refrigerant. The company Lockout/Tagout program shall be followed when taking the receiver out of service, while maintaining the receiver, and while returning it to service. If Line-Breaking is required, all Line-Breaking precautions described in the company Line-Break Policy shall be observed. Additionally, proper PPE shall be immediately available, or worn in response to the threat level posed by the work and circumstances.

Department: Refrigeration Operator: Qualified Refrigeration Operator(s) Equipment: Ammonia High Pressure Receiver, HPR-1 outside the south compressor room. Data from U-1-A: Vertical Receiver, Serial Number 124011, National Board Number 8664, built in 1998, by E.L. Nickell Company. MAWP: 250 psig @ 240F Location: Related Documents: Initial Date of 4/1998 Development: Authorized By: Previous Revision: 4/1/1998 Annual Review By, 9/2001 plant engineer, utilities supervisor, two operators, the Process and Date: Safety Management (PSM) coordinator, and an outside consultant

Operating ProceduresMust be Developed for Each Equipment Operation in the Covered ProcessRefer to Block DiagramsRefer to P&IDMust Cover Normal Operating Conditions, Normal Operating Parameters, i.e.. Pressure/Flow/Current/ etc.Must Follow Procedures & Recommendations in PHAsMust Follow Form

Operating Procedures For Shut-down ProceduresRemember:Most operations must be shut down in a specific order!Failure to follow these shut down procedures could results in a catastrophic release or system failure

Ammonia Plant Explosion Caused by Improper Shut-down of Engine Room

Operating Procedures Operating LimitsOperating Limits Must be UnderstoodPressuresFlowsElectrical PotentialTolerances

Operating Procedures - Hazards of the ProcessOperating Procedures Must Identify the Hazards of the Process in All Phases:Start UpNormal Operating ConditionsTemporary Operating ConditionEmergency Shut-down

Now That Weve Completed the Operating ProceduresWe Must Develop Safety Work Practices, Programs & Procedures for Covered Processes

Safe Work Practices1910.119(f)(1)

Develop and implement safe work practices* to provide for the control of hazards during operations such as: Lockout/tagout; Confined space entry; Line Opening process equipment or piping; and Control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel

Safe Work Practices*These safe work practices apply to contractor employees as well

Safe Work Practices

Safe Work Practices, Programs & Procedures must:Be specific to the Covered ProcessFollow Procedures & Recommendations in the PHAsFollow Procedures in the Operating ProceduresMust be Able to be TrackedFollow Form

Lockout Tagout - One of the Most Important Procedures in PSMMust be Written Carefully & Follow all Procedures (PHAs, Operating Procedures)Must be Followed to the Letter!

Safe Work Practices

Lockout/Tagout in PSMWhy not Use Digital Imaging in Your Procedures to Identify Critical Lockout /Tagout Positions

Safe Work Practices

Safe Work PracticesLine Opening PermitsIdentify Procedures for Opening any Process Line in a Covered ProcessMust Include Hazards of the Line OpeningPPE Required

Safe Work PracticesLine & Equipment OpeningA Hazard Review Must Completed for All Line/Equipment Hazards Including:

HAZARDOUS MATERIALS IN SYSTEMPOTENTIAL PHYSICAL HAZARDSBARRICADING AS REQUIRED FIRST AID IF EXPOSEDLOCATION OF SAFETY EQUIPMENTPPE REQUIRED FOR LINE OPENING

Safe Work Practices-Hot WorkA Program Must be Developed for the Covered Process That Requires:A Hot Work Permit be Issued for ALL Hot Work Performed in the Plant by Employees or ContractorsA Permit must be Posted at the Location of the Hot WorkA Fire Watch Is RequiredA Fire Extinguisher or Other Appropriate Fire Fighting Equipment Must Be Present, Fire Watch must be Trained in its use

Paper Mill Explosion & Fire Caused by Failure to Follow Hot Work Procedures

Safe Work Practices

Must be Specific for the Covered ProcessMay Require Additional Program other than Lockout Tagout, Line Opening & Hot Worksuch as Confined Space, Electrical Safe Work Practices, Combustible Dust

Now That Weve Developed Safe Work PracticesWe Have to Train

Training1910.119(g)

PSM 29CFR1910.119(g) Requires(G) Training (Initial, Refresher, and Documentation) (paragraphs (g)(1), (g)(2), and (g)(3)).

Paragraph (g)(1) requires employers to train employees operating dangerous process. Paragraph (g)(2) requires that the employer provide refresher training at least every three years. Paragraph (g)(3) requires the employer to prepare a record that contains the name of employee, the date of training, and the means used to verify that the employee understood the training

PSM TrainingPSM Training Programs Must be Developed for:Affected Employees - Those not Directly Involved in the Process OperationAuthorized Employees - Those Directly Involved in the Process OperationContractors Who May Perform Work on a Covered ProcessVendors/Visitors who May Visit the Facility and May Potentially be Exposed to the Covered Process

PSM TrainingTraining Must Be Performed as Follows:Initial trainingPrior to work assignmentWaved for those already in a processRefresher trainingEvery three yearsAll Training Must be Documented

PSM TrainingTraining Subjects Must Include at Least:Lockout TagoutHot WorkLine & Equipment OpeningConfined Space (if applicable)Emergency Response

Examples of Training PSM training example including the means used to verify that the employee understood the training.

Lets Use Hot Work Procedures

Safe Work Practices Hot Work Program

EXAMPLES OF HOT WORK

Safe Work Practices Hot Work Burning, Welding, GrindingOur Program RequiresA Hot Work Permit be Issued for ALL Hot work Performed in the Plant by Employees or ContractorsPermit must be Posted at the Location of the Hot WorkFire Watch Is RequiredFire Extinguisher Must Be Present, Fire Watch must be Trained in its use

Safe Work PracticesHOT WORKPERMIT MUST BE COMPLETED PRIOR TO BEGINNING WORK INVOLVIING ANY HOT WORKPERMIT SHALL BE DISPLAYED AT THE LOCATION OF THE ACTUAL HOT WORK OPERATION

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VERIFICATION OF UNDERSTANDING WORKSHEETHOT WORKCIRCLE THE CORRECT ANSWER1. A HOT WORK permit must be obtained prior to beginning HOT.work by welders and contractors before beginning a job. TRUE2. A HOT WORK permit is not necessary if just burning and grinding is being done on a job. FALSE3. Contractors are not required to obtain HOT WORK permits. FALSE4. The employee or contractor will obtain a HOT WORK permit from his supervisor and must determine if conditions are safe and have a fire watch if necessary. TRUE

5. HOT WORK is permitted in explosive atmospheres, around hazardous tanks and equipment. FALSE6. The following protective measures can be used: damp sand on floors, protective shields, or fire resistant coverings while Hot Work is taking place.TRUE7. 35 feet is a good safe distance for covered combustibles to be away from HOT WORK.TRUE8. Fully charged and operable fire extinguishers and/or hose lines shall be available and ready.TRUE 9. The HOT WORK permit shall be posted at the job site, and the supervisor shall retain the permits for three (3) days.TRUE10. The fire watch does not have to be trained in fire extinguishing and is not responsible for sounding an alarm in the event of a fire. FALSE

PSM Operating Procedures SummaryYou Must Develop and implement written operating procedures consistent with the process safety information and addresses at least the following elements:Initial start-up, normal and temporary operationsNormal and emergency shut-down proceduresOperating limits and consequences of deviationHazards presented by the process

PSM Safe Work PracticesSummarySafe Work Practices, Programs & Procedures must:Be specific to the Covered Process(s)Follow Procedures & Recommendations in the PHAsFollow Procedures in the Operating ProceduresMust be Able to be TrackedFollow Form

PSM Training SummaryPSM Training Programs Must be Developed for All Necessary Workers and ContractorsVerification of Understanding is RequiredTraining Must Be Performed as Follows:Initial trainingPrior to work assignmentWaved for those already in a processRefresher trainingEvery three yearsAll Training Must be Documented

Whats Next?

In the Last Session, we will Cover Contractor Pre-Qualification, Emergency Planning & Response Audits, and EPA Risk Management Plans (RMP)

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