psm

30Years

ofExcellence

PROCESSSAFETY

MANAGEMENTThe bookleT

March 2010

1 | PROCESS SAFETY MANAGEMENT HANDBOOK2010

our obligation to protect our employees, assets and the local community.

This booklet outlines the PSM requirements and describes GPIC’s approach to achieving those needs. We believe that only through the continuous support and dedication of our employees at every level we make GPIC one of the safest plants.

We in GPIC always strive to establish new systems and strategies to improve our practices in all aspects of our business. Safety has always been on top of our priorities and goals. The drive to implement Process Safety Management (PSM) relates back to 2001 when the initial work began to meet the OSHA requirements. In 2009, we revitalized the PSM Committee with a view to synergize the company systems to be more compliant with the PSM requirement.

GPIC’s Process Safety Management (PSM) program is designed to integrate and align under one umbrella, our plants related Engineering, Safety, Operation and Maintenance activities, with a clear objective to minimize process related risks. Through this program, we intend to achieve the main goal of fulfilling

PSMSafety Beyond Excellence

General Manager'sMessage

GPIC - 30 YEARS OF EXCELLENCE | 2


GM MESSAGE 1PSM COMMITTEE MESSAGE 4PSM ELEMENT ADMINISTRATORS 5PSM MAIN OBJECTIVES 6DEFINITION 7PSM ELEMENTS 8EMPLOYEE PARTICIPATION (EP) 9PROCESS SAFETY INFORMATION (PSI) 11PROCESS HAZARD ANALYSIS (PHA) 13OPERATING PROCEDURES (OP) 15EMPLOYEE TRAINING (ET) 17CONTRACTORS (CO) 19PRE-STARTUP SAFETY REVIEW (PSSR) 21MECHANICAL INTEGRITY (MI) 23HOTWORK PERMIT (HWP) 25MANAGEMENT OF CHANGE (MOC) 27INCIDENT INVESTIGATION (II) 29EMERGENCY PLANNING AND RESPONSE (EPR) 31COMPLIANCE AUDITS (CA) 33

Table of Contents


The Process Safety Management (PSM) of Highly Hazardous Chemicals, OSHA Standard 29CFR1910.119, is intended to prevent or minimize the consequences of the release of toxic, reactive, flammable or explosive chemicals from the adopted processes. At GPIC, we have incorporated these requirements into the Integrated Management System and decided to extend the scope of PSM to cover all process related hazards.

The PSM system facilitates the elimination of process incidents that could potentially occur as a result of failures in systems, procedures or equipment in process plants. It is a major step forward towards a safer working environment.

The PSM Committee’s role is to spearhead the establishment, maintenance, continuous evaluation and enhancement of the PSM program. In 2010, we will further enhance the program by introducing Risk Based Process Safety (RBPS).

This booklet is intended to give all our employees an overall understanding of the PSM program and how we comply the OSHA’s requirements within GPIC.

All of us play an important role in the success of the PSM program implementation.

PSMCommittee Message


Fire & Safety Suptd.

Mechanical Suptd.


Prevent or minimize the consequences of catastrophic release of toxic, reactive, flammable or explosive, Highly Hazardous Chemicals (HHC’s) from a process.

To ensure safe and Healthy workplaces and surrounding environment.

To integrate all adopted practices, system and procedures.

To improve productivity and help in minimizing operation expenses.

PSMMain Objectives


Process safety – preventing of accidental releases of hazardous substances or energy which create safety, environmental or business impact.

Process safety

ManageMent (PsM) – a set of formal management practices designed to help prevent, mitigate, respond to or recover from the effects of process plants accidents.

Why do We need Process safety?

Prevent major accidents and reduce the consequences of those that do occur

Improve employee’s health, safety and work environment

Improve equipment and process reliability

Reduce production costs

Definition


PSM ElementsgPic Process safety Management has 13 elements:

Employee Participation Process Safety Information Process Hazard Analysis Operating ProceduresEmployee Training Contractors Pre-Start up Safety Review Mechanical Integrity

Hot Work Permit Management of Change Incident Investigation Emergency Planning and

Response Compliance Audits

In the following pages, the PSM standard requirements and the GPIC compliance are highlighted.

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PSM Elements


In order to achieve a high degree of “Employee” involvement, the element directs organizations to give its employees access to Process Hazards Analysis and all its related practices and systems. This includes all types of information concerning safety of plants and personnel.

1 Employee Participation (EP)


gPic compliance Employees are consulted and are fully involved during the development and implementation of any Process Hazard Analysis study. Such involvement is demonstrated through the following methods:

• The establishment of PHA teams, committees like the SHE committee, Management Union High Council, Management Union Committees, regular meetings (Departmental, Sectional and Daily Operations).

• Incident Reports, Suggestion Improvement Program, Shift Talks, etc.

controlling documents SOP-PSM-00-01, Process Safety Management

of Hazardous Chemicals PSM Electronic Database


The element requires that all the Process Safety Information shall be made available in order to carry out a successful Process Hazard Analysis. This information shall help in identifying and understanding the hazards posed by those processes involving highly hazardous chemicals.

2 ProcessSafety Information (PSI)


gPic compliance Information related to Material Safety Data Sheet (MSDS) of chemicals, codes and standards used, equipment details, Process & Instrumentation Diagrams (P&IDs) and Process Flow Diagrams (PFDs) is captured through the Technical Data Books (TDB), Maintenance Data Books (MDB), Operation Manuals and Basic Engineering Documents. The documents are available at six locations (i.e. controlled libraries) within GPIC Complex. There is an established system that ensures controlling, maintaining and updating of all Process Safety Information documents in those libraries.

controlling documents SOP-ENG-02-11, Management of Change (MOC) SI-TEC-01, Material Safety Data Sheet Technical

Data Book (TDB Volume 112) SOP-ENG-02-04, Updating Technical Documents SOP-ENG-01-13 Process Hazard Assessment

(PHA) Procedure


The element requires that Process Hazard Analysis (PHA) should be carried out for all the processes handling Highly Hazardous Chemicals. This shall help in identifying the hazards in the process. All such PHAs should be revalidated at least once every five years.

3 ProcessHazard Analysis (PHA)


gPic compliance Process Hazard Analysis (PHA) for all the plants has been completed and documented. The PHA studies have been revalidated in year 2009. The next revalidation of all the plants is scheduled to be after 5 years. Furthermore, in GPIC, process hazard analysis review is carried out on each and every change during the Management of Change (MOC) cycle.

controlling documents SOP-ENG-01-13, Process Hazard Assessment

(PHA) Procedure SOP-ENG-02-11, Management of Change (MOC)


The element requires that there should be clear documented operating procedures to safely carry out activities concerning normal start-ups and shutdowns, emergency shutdowns, operations of temporary nature, handling and exposure to hazardous chemicals, etc.

Operating4 Operating Procedures (OP)


gPic complianceGPIC’s existing Standard Operating Procedures and Standing Instructions include:

• Normal start ups and shutdowns • Emergency shutdowns considering various

scenarios and plant upsets.• Simplified trip logic diagrams, catalyst

manual

controlling documents Standard operating procedures (Plant SOPs) Standing Instructions (Plant SIs) Plant Trip Logic Diagrams SHE-SAF-07, Permit to Work System SHE-SAF-05, Complex Emergency Material Safety Data Sheets (TDB Vol. 112) Relevant P&IDs Relevant Vendor Manuals


The element requires that each employee operating a process is imparted the relevant training. Thus, each employee before being involved in operating a newly assigned process requires to be adequately trained. Also, refresher training in operating such processes needs to be provided to the employees periodically. The training shall emphasise on the specific safety and health hazards.

Employee5 Employee Training (ET)


gPic compliance A structured training program is provided to employees (including operators, technicians, supervisors and engineers) prior to the assignment of any new responsibility. Refresher training program is also put in place and is designed to update the knowledge, skills and awareness of safety, environment and health hazards. Besides acquiring training on the details of plant configuration, the program also aims at updating the employees with “lessons learned” on the process incidents and accidents that have taken place in other similar plants. Further, training needs of all employees are identified and courses are organized accordingly. controlling documents SOP-TRN-00-01, Training and Development

Program for Graduate Supervisors & Engineers SOP-TRN-00-03, Cross Training & Development

Procedure for Plant Operators SOP-TRN-00-11, New Operators Training

Program SI-TRN-00-08, New Employee(s)


The element requires that contractors performing maintenance, repair, turnaround, major renovation work or specialty work on the process or adjacent to the process shall be well trained in carrying out the intended work and shall be informed about the known potential hazards related to the work and/or the process involved.

6 Contractors (CO)


gPic compliance GPIC's direct hire and /or lump sum contractors go through a selection process that starts from contractor prequalification assessment, trade testing, equipment verification, safety induction training, on the job assessment, weekly contractor safety meetings and post service evaluation. Contractors performing maintenance within the process areas are apprised about the hazards during Safety induction training.

controlling documents FR-PLN-70-02, Contractor Prequalification

Requirements SOP-PLN-70-01, Contracator Services

Management FR-MTR-01-09, Contractor / Vendor Performance

Evaluation Form GL-S&S-01-08, Safety Checking of Contractors

Equipment SOP-S&S-02-02, GPIC Complex Access

& Egress (Induction to contractors by SHE Department)

FR-PLN-70-10, Technical Evaluation- Manpower Supply Services.

FR-PLN-70-09, Technical Evaluation- Package Contract Services.

FR-MTR-01-13, Supplier Pre-qualification Form.


The element requires that a pre-startup safety review to be carried out for new facilities and modifications in the process area.

The review shall confirm that the changes are as per the design and specifications, that the safety, operating, maintenance and emergency procedures are adequate, and that sufficient training has been given to the employees for operating the new process or change.

Pre-Startup7 Pre-Startup Safety Review (PSSR)


gPic complianceA formal Standard Operating Procedure has been put in place to ensure that any newly installed facility or modification, before being commissioned, has been executed as per:

• Relevant design codes, specifications, and engineering drawings

• Relevant operating, safety and emergency procedures

• HAZOP recommendations • Relevant training

controlling documents SOP-OPR-01, Pre Startup Safety Review (PSSR)

Procedure FR-PSM-01 to 10, PSSR Checklists


The element requires that written procedures should be available to maintain:•Pressure vessels, storage tanks, piping

systems, pumps. •Relief and venting systems, emergency

shutdown systems, and controls (like alarms, trip interlocks, etc.)

The standard also, requires quality assurance during the fabrication and installation of plant equipment.

8 Mechanical Integrity (MI)


gPic compliance At GPIC, a comprehensive inspection schedule in line with the process licensor(s) guidelines is being followed. A Risk Based Inspection technique is also employed to strengthen the inspection program. Furthermore, the following activities are carried out during turnarounds:

• Internal examination of major equipment. • Safety Relief valves, emergency shutdown

systems and interlocks are checked and tested. When new equipment is being procured it is ascertained that the fabrication, construction and installation is as per the specifications laid down in the technical enquiry and it adheres to the applicable codes and standards. Furthermore, a comprehensive critical equipment list has been developed at GPIC identifying process equipment which have impact on production, safety, health and environment.

controlling documents SOP-PLN-30-05, Preventive Maintenance

Management SOP-MCH-01-42, Mechanical Integrity SOP-ISP-00-14, Risk Based Inspection (RBI) Critical Equipment List

The element requires that a hot work permit is to be issued for any hot work operation conducted on or near a process area.


9 HotWork Permit (HWP)


gPic compliance GPIC Permit To Work (PTW) comprehensively covers the hot work permit system. Authorization to receive or issue permit to work is only granted to those who pass both a written exam and an interview to ensure that they fully understand the requirement and the essence of the (PTW). Appraisal is done every two years to revalidate this authorization. GPIC PTW procedure is regularly audited and reviewed.

controlling documents SHE-SAF-07, Permit to Work System


PHA

RaiseRFC

Archive Updating of PSI FAC PSSR

Screening & Processing

Engineering& Approval Implementation

The element requires that written procedures should be established and implemented to manage changes to process, chemicals, technology, equipment and procedures that are not “Replacement in kind”.

Employees or contract employees whose job will be affected by the change should be informed and trained about the change prior to its commissioning and start-up.

Management10 Management of Change (MOC)


gPic compliance Changes in any of GPIC facilities, including process related changes, are covered under the Management of Change (MOC) Procedure. The Management of Change system ensures that all requirements; such as HAZOP, environmental impact, training, and operating procedure changes are considered before implementing the change.

controlling documents SOP-ENG-02-11, Management of Change (MOC)


The element requires that each process incident which resulted in, or could reasonably have resulted in catastrophic release of highly hazardous chemicals should be investigated.

The standard further requires that the findings and recommendations arising from the investigation should be resolved and documented.

11 Incident Investigation (II)


gPic compliance Process Incident and near misses in GPIC can be reported by any person. The incident, investigation findings, recommendations and actions are recorded and saved in the company’s main database. The investigations of any “lost time” incidents are investigated by a dedicated team and the recommendations are reported to the Executive Management.

controlling documents SHE-SAF-13, Accident and Near Miss Reporting Lotus Notes, Plant Operations Incident Databank

(derived from SHE-SAF-13) SOP-OPR-02, GPIC Plant Operation Incident Data

Bank


The element requires that an emergency action plan for the entire complex be available. The plan should be designed to handle small releases also.

12 EmergencyPlanning and Response (EPR)

gPic complianceA comprehensive emergency response plan is established to cater to any emergencies within the Complex. The plan details the emergency warning alarms, control centers, assembly points, and job roles of the personnel during emergencies. The plan is reviewed and tested periodically.

controlling documents SHE-SAF-05, Complex Emergency Procedure SHE-SAF-06, Generic Emergency Procedure SHE-SAF-08, GPIC Emergency Planning Guide Procedure Mock drills procedure (part of SHE-SAF-08)



The element requires that the Process Safety Management (PSM) processes are evaluated through a compliance audit by at least one person knowledgeable in the process once every three years. The standard also requires that an appropriate response to each of the findings is reported and that all the deficiencies are corrected.

13 Compliance Audits (CA)


gPic compliance There is an established procedure to carryout internal audits of Process Safety Management system as part of the internal audits of Integrated Management Systems in GPIC. External audits shall be carried out once every three years.

controlling documents SOP-IMS-00-01, Internal Audit Procedure

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