Recommendations from CCPS & others

Transcription

1 Todd B. Jekel Spirit of PSSR Review of (i) 119(i) Linkage with other elements of the standard Review of OSHA-issued interpretations related to PSSRs Recommendations from CCPS & others 1

2 A comprehensive, documented review of the design & construction of new and modifications to covered processes to verify that they are acceptable and the PSM requirements are in place prior to using the process. A quality assurance process intended to assure no unintended d hazards are introduced d assure risks are properly evaluated & minimized be exercised during the life of the project & completed before changes are implemented 2

3 Regulatory [ (i)] New construction & process expansion is part of the life of most plants We cannot overlook the value of a functioning PSSR program Quality assurance check of MOC Easily is short changed in the rush of getting the project up-and-running to make & store product OSHA believes that one of the most important and necessary aspects of a process safety management program is appropriately managing changes to the process. So important that PSSR is built around monitoring the quality of the MOC process 3

4 Reference: (i) PSSR Policy ABC Foods, Inc. (1) The employer shall perform a pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information Reference: (i) 119(i) (2) The pre-startup safety review shall confirm that prior to the introduction of highly hazardous chemicals to a process: (i) Construction and equipment is in accordance with design specifications; (ii) Safety, operating, maintenance, and emergency procedures are in place and are adequate; 4

5 Reference: (i)(2) cont. (iii) For new facilities, a process hazard analysis has been performed and recommendations have been resolved or implemented before startup; and modified facilities meet the requirements contained in management of change, (l). (iv) Training of each employee involved in operating a process has been completed. Note references these other sections of the PSM Standard Process safety information (d) Operating procedures (f) PHA (e) MOC (l) Training (g) 5

6 Reference: (i) (1) The employer shall perform a pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information It seems pretty straight forward do we even need a definition of significant? require a change in process safety information Pretty broad definition. What constitutes a change? Is any addition to PSI a change? Can you think of a change that is not significant but does change PSI? MOC process Does your MOC form have a checkbox to indicate whether or not the change requires PSSR? 6

7 Chemical information Technology information Block flow & P&IDs Inventory Safe limits (pressures, temperatures, flows, ) Consequences of deviation Equipment information Materials of construction Electrical classification Safety system designs (relief, ventilation, interlocks, detection systems, emergency shutdowns, etc.) Material and energy balances The employer shall perform a pre startup The employer shall perform a pre-startup safety review for new facilities and for modified facilities when the modification is enough to require a significant change in the process safety information 7

8 Description Yes No Plant expansion in a facility that will raise inventory of chemical above TQ Adding an additional identical evaporator to an existing cold space Adding plate pairs to a plate-frame evaporator Replacing a Hansen HA4A regulator with an R/S A4A Bringing an evaporator back online after cleaning a strainer Bringing a compressor back online after changing to a different coalescing filter Recommendation: Include a number of examples of changes that are considered significant (i.e. trigger events) as-defined in your program and consistent with the requirements of

9 9 Process Hazard Analysis Operating Employee Participation Incident Investigation Design Process p g Procedures Training PSSR PSM Process MOC Process Safety Information Mechanical Integrity Contractors PSSR Compliance Audits Emergency Planning Process Safety Information Process Hazard Analysis Operating MOC Operating Procedures Training Employee Participation PSSR Compliance Audits Mechanical Integrity Contractors Incident Investigation Emergency Planning

10 Appropriate personnel should be included (team for large projects) Personnel PSM coordinator Maintenance supervisor or staff Engineering manager Safety director/representative Purchasing representative Plant manager Corporate engineer Verifies & signs off on None (ideally) Operating procedures PSI, MOC, Design/construction specifications Training Receipt of specified materials MOC PHA Note: whomever signs off is the person verifying the appropriate changes have been made Corporate or plant personnel? May depend on the size of the project Desirable characteristics for PSSR leader Is independent of the work being done, Is knowledgeable of the process, and Sees value in QA ing the project? Do you have anyone within your plant utility department s hierarchy that qualifies? Will likely require a team approach 10

11 Number of issues with startup Safety issues are more important than operability issues Number of PSSRs compared to MOCs on a yearly basis If you have short- &long long-form PSSR, monitor Short- vs. Long-form ratio Random sample short-form PSSRs to assure reasonableness of using short-form OSHA-Identified Common PSSR Problems Not done before introduction of ammonia Not done by competent personnel Construction documents not used as the basis of the Pre-Startup Safety Review P&ID s not current when the Pre-Startup Safety review is performed 11

12 Tolley 1996 What changes are significant enough to be called a new facility? a "facility" means buildings, containers and equipment which contain a process. A facility constructed on a work site where there are no other facilities is considered a new facility. PSSR standard d would be applicable to "new facilities and to modified facilities which contain a covered process", that is, a process in which (at any one point in time) there is a threshold quantity or great amount of a HHC. Identify events that should trigger PSSR Have multiple level of PSSRs (simple complex) Risk based determination of complexity Audit PSSR process to streamline future PSSRs PSSR team Broad involvement to steep PSSR into plant culture & insure employee participation i Independent of specific project or subproject 12

13 Increased Severity of Event Low Serious Catastrophic Incre eased Likelihood of Event High Medium Higher Higher Moderate Lower Medium Higher Low Lower Lower Medium Lower Risk Use short-form or simple PSSR Simple PSSR is not less important, just lower level of effort Higher Risk Use long-form PSSR Increase effort & sign-off 13

14 Project cost greater than $X Tied to corporate capital request rules New type of equipment or chemicals (first application on site) Three or more piping tie-in points New control systems or modification to controls that could affect safety controls or interlocks Fire protection system changes Reuse of used or previously mothballed equipment Could an RIK that involves the shutdown of the system or a portion of the system be subject to a PSSR? Said another way, could a PSSR be utilized for an RIK requiring shutdown? Simplified checklist to insure that t maintenance procedure is followed 14

15 Move (or extend) some aspects of review to post startup Operability issues Hearing protection Controls commissioning Functional testing of safeties & interlocks (if able) Integrate verification into MOC process Need to be able to separate MOC & PSSR for auditing, etc. Require more than simply check & sign Document list & versions reviewed, etc. Review the use of PSSR within your facilities during a compliance audit If PSSR is not consistently used, investigate why bypassed & propose changes to the process to increase use Consider additional, focused PSSRs that provide QA of maintenance & SOPs Integrated into operating procedure revalidation, OJT or supervision/review 15