The Hard Elements of PSM/RMP. WITT O BRIEN S Process Safety Compliance Workshop Houston, Texas October 23, 2018

Transcription

1 /RMP WITT O BRIEN S Process Safety Compliance Workshop 1

2 PSM elements dependent on process size Six elements of PSM dependent on process size.119(d).119(e) 119(f).119(g).119(j).119(l) Process Safety Information Process Hazard Analysis Operating Procedures Training Mechanical Integrity Management Of Change 2 There are six elements of PSM that are difficult to implement in proportion to the size of the covered process. <click> Unfortunately, three of them process safety information, process hazard analysis, and mechanical integrity are considered the most challenging or painful to execute, regardless of how big the covered process is. 2

3 PSM elements dependent on process size Six elements of PSM dependent on process size.119(d).119(e) 119(f).119(g).119(j).119(l) Process Safety Information Process Hazard Analysis Operating Procedures Training Mechanical Integrity Management Of Change Three are the hardest PSM elements to do 3 There are six elements of PSM that are difficult to implement in proportion to the size of the covered process. <click> Unfortunately, three of them process safety information, process hazard analysis, and mechanical integrity are considered the most challenging or painful to execute, regardless of how big the covered process is. 3

4 PSI Safety Data Sheets (d)(1) Information pertaining to the hazards of the highly hazardous chemicals in the process Note: Safety Data Sheets meeting the requirements of 29 CFR (g) may be used to comply with this requirement to the extent they contain the information required by this subparagraph. 4 Have you ever reviewed an SDS and found some sections marked Not available? While SDSs can be used to provide this information, if the information in an SDS is incomplete, you still must provide it somehow. OSHA considers but it s not in our SDS right up there with my dog ate my homework. 4

5 PSI Maximum intended inventory (d)(2)(i)(c) Maximum intended inventory 5 There is nothing that limits what the maximum intended inventory is, but you must document some number. Don t pick a maximum that will be challenging to stay under. Where this requirement would have special relevance is if you use a regulated chemical, but intend to avoid being subject to the standards by staying below the threshold quantities. But then, you aren t covered and have no need to comply with the requirement at all or to produce a maximum intended inventory. 5

6 PSI Safety and Health effects (d)(2)(i)(e) An evaluation of the consequences of deviations, including those affecting the safety and health of employees. 6 In (D) you show the safe limits; you are implying that beyond those limits, it is unsafe. Unsafe how? In (E), the regulation is calling for you to spell out how exceeding the limits is unsafe. This will then show up in your operating procedures. 6

7 PSI Equipment in the process (d)(3) Information pertaining to the equipment in the process. 7 There is no limit to what OSHA considers equipment in a covered process, For instance, a blast resistant trailer has been identified as equipment covered under this paragraph as has a control room. Some people want to focus on safety critical but that distinction is never made in the regulation. 7

8 PSI Electrical classification (d)(3)(i)(c) Electrical classification 8 Electrical classification is a misnomer. It is better described as hazardous (classified) locations. This is a requirement under , Flammable Liquids and , Hazardous (classified) locations when flammable vapors are or may be present, whether the process is covered by PSM or not. 8

9 PSI Relief system design basis (d)(3)(i)(d) Relief system design and design basis 9 This is the one case where you not only have to show what the design is, but the basis for that design. First, show calculations of how much relief capacity you need (the basis) and then show calculations that your design provides at least that much capacity. 9

10 PSI RAGAGEP (d)(3)(ii) The employer shall document that equipment complies with recognized and generally accepted good engineering practices. 10 The acronym for recognized and generally accepted good engineering practices is RAGAGEP. Every piece of equipment must be designed and installed in accordance with a RAGAGEP, the RAGAGEP must be identified see (i)(f) Design codes and standard employed and the design code and standard must be identified as a RAGAGEP. Several things can be considered RAGAGEP, but national consensus standards like ASTM or ANSI codes are the easiest to defend. By the way, this is one of only three places in all of OSHA s general industry regulations that uses this term. Other two occur later in PSM, in the section on mechanical integrity. 10

11 PSI Existing equipment (d)(3)(iii) For existing equipment designed and constructed in accordance with codes, standards, or practices that are no longer in general use, the employer shall determine and document that the equipment is designed, maintained, inspected, tested, and operating in a safe manner. API 579-1/ASME FFS-1, Fitness For Service 11 For equipment that has no evidence of being designed and constructed to a RAGAGEP, you must either reverse engineer it to a RAGAGEP, or worse, remove it and replace it with something that has been designed and constructed to a RAGAGEP. This single requirement is the most compelling reason to make sure that the boundaries of your process are not too expansive. <click> A reference document that many find useful in determine and document that their equipment is designed, maintained, inspected, tested, and operating in a safe manner is API 579 1/ASME FFS 1, Fitness For Service. 11

12 PHA Methodologies (e)(2) The employer shall use one or more of the following methodologies that are appropriate to determine and evaluate the hazards of the process being analyzed. 12 OSHA has some opinions about which methodologies are appropriate in which cases, but aren t nearly as rigid about it as most consultants are. That said, the HazOp methodology is so commonly used that for many, the terms HazOp and PHA are interchangeable. 12

13 PHA Hazards (e)(3)(i) The process hazard analysis shall address the hazards of the process 13 If you fail to address a hazard that OSHA considers obvious, e.g. exposure to chlorine during a leak, they will cite you for not addressing the hazards of the process. 13

14 PHA Previous incidents (e)(3)(ii) The identification of any previous incident which had a likely potential for catastrophic consequences in the workplace 14 You will look at your incident reports for this. The incident reports that are relevant, however, are those that involve catastrophic consequences or the potential for catastrophic consequences with regulated highly hazardous chemicals. Best practice is to also look at previous incidents in similar processes and across the industry. 14

15 PHA Facility siting (e)(3)(v) Facility siting 15 OSHA does not define facility siting, anywhere in the standard, but they expect it to be addressed. Despite a layperson s interpretation of the term, facility siting does not refer to where a facility is sited. Instead, it refers to the physical arrangement of process equipment in relation to other equipment. The vent discharge location from a relief valve, for instance, is a facility siting issue. 15

16 PHA Human factors (e)(3)(vi) Human factors 16 Likewise, OSHA does not define human factors, but they too must be addressed. Usually, this boils down to questions about how personnel interact with the process, be it reading a screen in a control room, being physically in the plant, or while taking a sample. Image By Steag, Germany Steag, Germany, CC BY SA 3.0, 16

17 PHA Team (e)(4) The process hazard analysis shall be performed by a team with expertise in engineering and process operations, and the team shall include at least one employee who has experience and knowledge specific to the process being evaluated. 17 There must be at least two people on the team. There are three roles defined: someone who knows how the process is supposed to be run, someone who knows how the process is actually run 17

18 PHA Team (e)(4) Also, one member of the team must be knowledgeable in the specific process hazard analysis methodology being used. 18 and a facilitator. This is usually a third person, but could be one of the first two, as long as the role of facilitating is not compromised. 18

19 PHA Findings and Recommendations (e)(5) The employer shall establish a system to promptly address the team's findings and recommendations 19 Any recommendation coming out of a PHA must be addressed. One way to address a recommendation is to implement it. Another way is to do something else or to determine that no action is required. In these later instances, however, there needs to a documented analysis to show why the recommended action wasn t taken and why the course of action taken instead was all right. EVERY RECOMMENDATION MEANS SOMEONE HAS WORK TO DO, so don t make recommendations lightly. 19

20 PHA Resolving recommendations (e)(5) Assure that the recommendations are resolved in a timely manner and that the resolution is documented 20 Resolution does not necessarily mean implementation. 20

21 PHA Revalidation (e)(6) At least every five (5) years after the completion of the initial process hazard analysis, the process hazard analysis shall be updated and revalidated 21 Typically, this is executed as a fresh PHA, then five years later a review of that PHA, then five years later (ten years after the fresh PHA) another fresh PHA, and so on. 21

22 PHA Record retention (e)(7) Employers shall retain process hazards analyses and updates or revalidations for each process covered by this section, as well as the documented resolution of recommendations described in paragraph (e)(5) of this section for the life of the process. 22 Keep everything that has to do with hazard analysis. If a PHA is accidently destroyed or lost, there is nothing to be done for it, but be able to explain. Typically, a lost PHA will be cited no more than once, if at all, but it will depend on whether your record retention is in good faith. OSHA inspectors are instructed to accept any previous PHA as the initial PHA. 22

23 MI Mechanical Integrity (j) Mechanical integrity 23 This is one of the toughest of all the PSM elements. Not only does the equipment have to be designed and constructed according to RAGAGEP, it has to be maintained according to RAGAGEP at frequencies consistent with RAGAGEP. 23

24 MI Types of process equipment (j)(1) Application. Paragraphs (j)(2) through (j)(6) of this section apply to the following process equipment: 24 While the requirements for equipment specs in PSI apply to all equipment, the MI requirements apply to six specific categories of equipment. OSHA expects you to apply to other types of equipment if you have determined them to be critical, although OSHA has not defined critical and the requirement is not explicitly stated anywhere in the standard. 24

25 MI Vessels and tanks (j)(1)(i) Pressure vessels and storage tanks 25 Sometimes people forget that pressure vessel also applies to the shells on shell and tube heat exchangers, to filter housings, and other equipment designed to contain pressure. Also, OSHA interprets storage tank pretty broadly. 25

26 MI Piping components (j)(1)(ii) Piping systems (including piping components such as valves ) 26 Valves and other fittings like strainers, steam traps, check valves, samplers, sometimes get overlooked. 26

27 MI Written procedures (j)(2) Written procedures. The employer shall establish and implement written procedures to maintain the on-going integrity of process equipment. 27 If maintenance does it, there has to be a written procedures and training on how to do the procedure. If third parties do the maintenance, there still must be written procedures. 27

28 MI RAGAGEP for inspection and testing (j)(4)(ii) Inspection and testing procedures shall follow recognized and generally accepted good engineering practices. 28 RAGAGEP this is second of three appearances of this dreadful term. 28

29 MI Inspection and testing frequency (j)(4)(iii) The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience. 29 RAGAGEP the third and final appearance of this idea, this clause says that not only must the inspection and testing procedures be according to RAGAGEP, but the frequency must be according to RAGAGEP. 29

30 MI Documenting inspections and testing 30 (j)(4)(iv) The employer shall document each inspection and test that has been performed on process equipment. The documentation shall identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test. Not only must inspections and tests be done, and done at the frequency required, they must be documented: Date, by whom (name, not initials), specific piece of equipment, test performed, as found and as left. Retain these records at least long enough to document that the inspections and tests are being conducted often enough. 30

31 MI Correcting deficiencies (j)(5) Equipment deficiencies. The employer shall correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information in paragraph (d) of this section) before further use or in a safe and timely manner when necessary means are taken to assure safe operation. 31 If something is broken, fix it. If operators tell an inspector about the time they had to limp along, there is likely to be a citation. 31

32 MI Quality assurance (j)(6) Quality assurance 32 The requirement for quality assurance in maintenance frequently catches people off guard. How do you show that you are not only doing the maintenance correctly and frequently enough, but with the correct parts? No mix up on gasket materials? SS304 instead of SS316L? No counterfeit parts from China? 32

33 It is our attitude at the beginning of a difficult task which, more than anything else, will affect its successful outcome. William James 33 If you conclude that you have a process that is covered under the process safety regulations, you will need to implement all of the elements of process safety. These three process safety information, process hazard analysis, and mechanical integrity will be the hardest and take the most time. They will frustrate you. You can do it, however. Others have. But remember that in addition to these three elements of PSM, there are 11 others that should be easier to implement, but that will still need your attention. 33