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Administering CHRA

Activities Effectively –

A PETRONAS Case Study

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CHRA Case Study

ContentsPresentation Objective

Background

PFK’s CHRA

Information on PFK

PFK CHRA Introduction

CHRA Process Flow

Operationalising CHRA

Expectation on CHRA exercise

Findings

Challenges

Advantages / Disadvantages

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CHRA Case Study

Presentation Objective

To share the experience of PETRONAS in

administering / carrying out CHRA in one of the

PETRONAS plant

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CHRA Case Study

All of PETRONAS OPUs have carried out CHRA to a certain extent either by:

PETRONAS in-house resources

Consultants

The OPUs compliance to the USECHH Regulations 2000, in particular, CHRA was assessed through:

• CHSE Noise & USECHH Legal Compliance Assessment carried out in 2002 – 2003

• CHSE Tier-3 HSE Assurance

One of the main findings was quality of CHRA reports varied fromone OPU to another (some was incomplete/insufficient)

Background

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CHRA Case Study

Background

What Are the Common Issues ?

Mistakes in categorizing work unit

Incorrect Hazard Rating for mixture of chemicals

Imprecise description of tasks

Selection of Duration Rating (DR)/ Frequency Rating (FR)

Subjective assessment of Magnitude Rating (MR)

Poor assessment on the adequacy of existing control

Recommendations (e.g. LEV, PPE, Chemical Exposure Monitoring, Health Surveillance) are too general

Variation in the format of CHRA Report

No mechanism to amend or updating the CHRA report

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CHRA Case Study

Background

What Has Been Done by PETRONAS ?

PETRONAS Industrial Hygienists have reviewed existing CHRA reports from various Operating Units (OPUs)

Debated and compiled the strengths and weaknesses of the finding

Developed common methodology and approach to carry out CHRA to ensure high quality of CHRA across PETRONAS

Identified one OPU (PFK SB) as a pilot project to implement PETRONAS CHRA common methodology and approach

Conducted CHRA Enhancement Training to all PETRONAS CHRA assessor/ focal person

Implemented CHRA standardization across the group

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CHRA Case Study

PF(K)SB’s CHRA

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CHRA Case Study

Information on PFK

PETRONAS Fertilizer (Kedah) Sdn. Bhd. is a wholly owned subsidiary of PETRONAS

It is the second PETRONAS fertilizer complex, Commercial operation started in 1999 in Gurun, Kedah

The daily production capacity of the complex is:

Urea - 2000 MT

Ammonia - 1125 MT

Methanol - 200 MT

Formaldehyde - 17 MT

Supporting facilities include:• Steam distribution and generation system

• Cooling water

• Instrument air

• Nitrogen

• Waste water treatment plant

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CHRA Case Study

PFK Plant

Urea & Ammonia Plant Urea Export Terminal

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CHRA Case Study

PFK CHRA Introduction

CHRA was carried out and reviewed between October –November 2004

Basic hazards and risk identification data was available prior to CHRA

It was carried out by PETRONAS in-house resources, utilizing PFK staff with assistance from Corporate HSE

CHSE apply standardize methodology to carry out CHRA in ensuring high quality CHRA reports are established in PETRONAS

The methodology used is as per the “Assessment of the Health Risks Arising from the Use of Hazardous Chemicals in the Workplace Manual” (DOSH, 2000)

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CHRA Case Study

Awareness on the USECHH requirement

Staff attended the 1st CHRA training organized by CHSE

Appointment of CHRA Task Force members,

endorsed by HSE Steering Committee

Some of CHRA Task Force members

attended NIOSH CHRA Training

Conducted a series of CHRA Awareness training to staff

Task Force members carry out CHRA

Briefing to PFK MC on CHRA Plan

Review of CHRA findings and CHRA exercise

Presentation of CHRA findings to PFK Management

Submission of CHRA Report to DOSH

Final preparation of CHRA Report

HSE

HSE

HSE

HSE SC

CHRA Task Force

HSE

CHRA Task Force

CHSE/CHRA Task Force

HSE/CHSE

HSE/CHSE

HSE

CHRA Process Flow

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CHRA Case Study

Operationalising CHRA

Members of the task force were selected from areas where

chemicals are used/stored in PFK; and from specific discipline

Task Force

Custodian

CHRA assessor

Urea

Utility

OHD

AmmoniaLab Warehouse

Engineering

Hygiene Tech.

Co-ordinator

Facilitator

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CHRA Case Study

Expectation on CHRA Exercise

CHRA to cover the whole company

Task force members to meet weekly on Friday

To collect data from:

Available CSDS and from suppliers

Hazard register and hazard rating

Chemical spills incident report

Accident reports

Health complaints/surveys

Job safety analysis

Timely report submission to DOSH

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CHRA Case Study

Findings

Clear direction and advice from CHSE made Task Force members more committed

A comprehensive assessment on the use of chemicals in the Laboratory

280 chemicals were assessed

The interactions between chemicals were also considered

Detailed description of tasks were developed, enabling the assessor to identify steps that require special attention

Two options used to fill up Form C (Workplace Assessment):

By “chemical” – traditional method

By “task” – new method

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CHRA Case Study

Findings

Non-routine tasks were assessed through table top exercises, staff feedback and actual site survey

Shutdown activities were covered during the exercise, eg.:

Catalyst change-out

Chemical cleaning

Critical plant activities (non-routine jobs) were identified and evaluated during the exercise:

Breakdown of syngas compressors

Welding activities on a life ammonia reactor

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CHRA Case Study

Findings

Monitoring of chemical exposure were specified based on the exposure and adequacy of control measures as well as the availability of monitoring and analysis protocol:

• Welding fume exposure

• IAQ in laboratory

Thorough review of CHRA findings by ROHA enabled specific tests/ methods to carry out Health Surveillance, Medical Surveillance and Biological Monitoring were proposed:

• Eg. Visual assessment (fundoscopy) was proposed for Lab technicians performing Methanol product sampling

• Eg. Spirometry and chest x-ray was specified for MIG/TIG welders

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CHRA Case Study

Findings

Format of “Summary Report of CHRA” (for DOSH submission) were modified:

• Expanding “Recommendation” column to specifically to PPE, Exposure Monitoring, Health Surveillance, and Biological Monitoring

• This will allow various sections to pick up actions required by their sides to close the CHRA gaps identified

Format of “Final CHRA Report” were proposed and has been accepted by PETRONAS to be standard format to be used across PETRONAS OPUs

The integration of CHRA with the Hazard and Effect Register as per the HEMP (Hazard and Effect Management Process) Procedure

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CHRA Case Study

Challenges

Availability of task force members:

Most of the team members were line people, whose core functions are non-HSE

CHRA was not included as part of their KPI

Transfer of trained assessor(s) from PFK

Lack of training/experience of team members; Some has not attended CHRA training

Poor planning which delayed the CHRA report submission to DOSH

Incomplete information (eg. CSDS to determine hazard rating)

To carry out table top exercise for non-routine jobs

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CHRA Case Study

Advantages and Disadvantages of Using Internal

Resources

The advantages were:Cost savings

Better understanding of work processes

Ownership

Hands on experience on conducting CHRA

The disadvantages were:Time consuming, resulted in delayed project

Limited expertise to conduct CHRA

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CHRA Case Study