OCTC Ohio Chemistry Technology Council

Transcription

1 OCTC Ohio Chemistry Technology Council Process Safety Management (PSM) Requirements and Keys to Compliance Presented By: Michael Taylor Sr. PSM Consultant/Engineer EN Engineering 17-March-2016

2 Goal of this Presentation Present an overview of a site PSM program in a straight-forward manner Discuss the personnel and other resources needed to power a successful program Review major compliance issues

3 Agenda Starting from Scratch PSM Elements Resources and Support Needed Overview of Compliance Issues

4 Overview PSM Image, 14 Element Model (Some models contain up to 17 Elements)

5 PSM - Words Overview (cont d) Personnel (Six Elements) Auditing Emergency Planning and Response Management of Change Personnel (MOC-P) (MI) Incident Investigation and Reporting (MI) Contractor Safety and Performance (MI) Training and Performance (MI) Technology (Four elements) Process Technology (PSI, PTM) (MI) Operating Procedures and Safe Practices (SOP, SOC) (MI) Management of Change Technology (MOC-T) (MI) Process Hazard Analysis (PHA) (MI) Facilities (Four Elements) Management of Change Subtle (MOC-S) (MI) Mechanical Integrity (MI) A single PSM Element, but the back-door to a de-facto site audit Pre-Start-Up Safety Review (PSSR) (MI) Quality Assurance (QA) (MI)

6 Applicability of PSM Regulations (29 CFR ) At the Very Least, PSM regulations apply if: The process involves a chemical at or above the specified threshold quantities listed in Appendix A to this section. Appendix A Extract The process involves a Category 1 flammable gas (as defined in (c)) or a flammable liquid with a flashpoint below 100 F (37.8 C) on site in one location, in a quantity of 10,000 pounds ( kg) or more. Exceptions (Except for): Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling), if such fuels are not a part of a process containing another highly hazardous chemical covered by this standard; Flammable liquids with a flashpoint below 100 F (37.8 C) stored in atmospheric tanks or transferred which are kept below their normal boiling point without benefit of chilling or refrigeration.

7 Applicability of PSM Regulations (29 CFR ) Does not apply (to): Retail facilities; Oil or gas well drilling or servicing operations; or Normally unoccupied remote facilities. Interpretations Current executive order proposes changes to exemptions: Title: Executive Order Improving Chemical Facility Safety and Security Number: Date: 01-August-2013 Features Brings Ammonium Nitrate into regulation (West, TX) Elimination of atmospheric tank storage exemption (Distribution Terminals)

8 Options to PSM Applicability A facility can Manage-Out of PSM regulations, if it is wise to do so. Consciously operate at less than TQs of hazardous and flammable materials and document as such, even though traditional operation demonstrated inventory quantities greater than TQ. Sometimes, a facility receives a mandate to operate as a PSM facility (ex: Corporate oversight) even though it is not a PSM facility. In this case, application of certain PSM elements can be discretionary and can be negotiated with Corporate leadership.

9 Overview of a Site PSM Program Goal: to provide a comprehensive audit trail so government regulators may feel assured that the facility is operating Safely. Audit Trail Sampling Technology: Documented PSI; Updated PHAs; Management of Change documents. Facilities: Operating Procedures; PSSRs; MI; QA. Personnel: Site governance documents, all elements; Contractor Safety Programs; Position Qualification Training Programs and Records; Self-auditing programs and protocols; Incident Investigations, records and analysis. Employees will be interviewed during a third-party audit.

10 Assisting the Set-up of PSM Programs Assessment Checklists have been developed Assessment Checklists reflect OSHA Third-Party Audit comments from the National Emphasis Program (NEP) Checklists can be parsed and used as shift safety exercises to develop a continuing compliance metric Typical compliance level w/ existing corporate over-sight: 80% Documentation/40% administrative Time to attain adequate PSM compliance 3 Years 9 months of real time if at 80/40 36 months if no measurable compliance level Typically 1 to 3 people for the monthly time-frames Over-and-above personnel required to maintain a program

11 The Source of All Resources PSM is a Management-Driven Program Management is the hub of the wheel in the model Without management support Individual sites or areas cannot supply the resources to run the program The program will fail What does Management Support look like? Executives personally involved Managers drive the execution of excellence every day Systems embedded throughout the organization Employees have clear understandings of the expectations of senior management

12 Level of Resources Needed Approximately 1.5 dedicated persons for every $100 Million of Replacement Investment. Does not include overhead This is the long-term operating level, not the set-up level Set-up activity requires more personnel resource This person(s) can be: Direct assignee(s) per area Multiple personnel across plant-site

13 Typical Site PSM Structure Site PSM-Programs Manager Site Champions for Each Element Process Area Champions for Each Element

14 Typical Site PSM Structure Site PSM-Programs Manager Member of Site Staff Reports to Site Manager Non-staff-member PSM Managers have diminished influence Position lacks the clout needed to implement programs Sends the message that PSM is not that important

15 Typical Site PSM Structure Site Champions for Each Element 14 Elements = 14 Champions (can vary per site size) Calculate the Personnel Needed ( Moderate sized plant-site): (14 Elements) X (1 Person/2 Elements) X (0.25 Fraction of Person s Time) = 1.75 Persons as Site Champions Call it 2 People Typically Technical/Salaried Personnel Include technical and administrative requirements

16 Typical Site PSM Structure Process Area Champions for Each Element Typically salaried personnel Skills driven by technical needs of the element Calculation of personnel is similar Assume three (3) process areas on-site One person handles several elements in lessdemanding areas Calculate the personnel needed ( Moderate sized plant-site): (14 Elements) X (1 Person/2 Elements) X (0.1 Fraction of Person s Time) X (3 Process Areas) = 2.1 Persons as Process Area Champion Call it 2 People

17 Typical Site PSM Structure Site PSM-Programs Support Personnel Located in Works Engineering Similar title to a Reliability Engineer Calculate the personnel needed ( Moderate sized plant-site): (1 Person) X (0.25 Fraction of Person s Time) X (3 Process Areas) = 0.75 Persons as Reliability Engineer Call it 1 Person Process Area PSM-Programs Support Personnel Located in Technical Engineering Similar title to a Process Engineer Calculate the personnel needed ( Moderate sized plant-site): (1 Person) X (0.25 Fraction of Person s Time) X (3 Process Areas) = 0.75 Persons as Reliability Engineer Call it 1 Person

18 Typical Site PSM Structure Summary of Personnel Needs for PSM Programs 1 each Site Programs Manager 2 each, equivalent Site Element Champions 2 each, equivalent Process Area Element Champions 1 each, equivalent Site Engineering - Support 1 each, equivalent Process Area Engineering Support

19 Typical Site PSM Structure Impact of the Total 7 Salaried Personnel for a Moderate-Sized Plant- Site Significant portion of Technical Site Personnel Only Management has the authority to assign/hire this level of personnel to implement an additional, regulatory program. Must Have Personal Buy-in Must Embrace the PSM Premise Must Provide the Hub for the Wheel"

20 Embracing PSM Remember that Embrace means Embedding PSM philosophies in the site culture Doing what you consider to be a good job of program implementation Audit findings can be Opinion Driven on the part of the auditor A strong program allows a strong rebuttal

21 Embracing PSM Remember that Embrace also means Being proud of your work Not cutting corners Not being in a hurry Do not work under arbitrary deadlines Do not develop a Contrived Crisis to drive completion of initial programs PSM will be with us going forward - FOREVER Everyone is Behind the 8-Ball The regulations have been in effect since the 1990 s National Emphasis Programs (NEP) and Special Emphasis Programs (SEP) have shown a spotlight on industry PSM program shortcomings Currently, unfavorable outcomes of NEP/SEP are driving industry interest in the development of PSM programs

22 Embracing PSM Ask the Question What do we need to do to implement a successful PSM Program? Develop the answer from the perspective of a third party auditor Use the basics in the PSM regulations as your initial guidance Do not do more than the minimum Extra places your site's at risk (There s more to audit) An extra step in PSM may be non-compliant with other regulations Develop a Flow-Chart showing PSM program needs Start at the affected process Work backwards from the process to site staff level to better determine program requirements

23 Embracing PSM Ask the Question What do we need to do to implement a successful PSM Program? Develop the Elements Follow the basic outlines in PSM Regulations 29 CFR There are requirements listed for all 14 PSM Elements Accommodate Corporate Oversight Requirements So long as they are not counter-to requirements of PSM There may be extensive dialogue to arrive at convergence There is no Typical element Each has its specific requirements Some may appear easier to implement than others All elements take significant time and resources to initiate

24 Embracing PSM Each element requires documentation Goal: to provide a comprehensive audit trail so government regulators may feel assured that the facility is operating Safely. Support documents for PSM elements (Checklists, Governance Documents) Documentation must be retrievable Verbal recollections add no value Implement the PSM activity of the various elements as described in site governance documents Take pride in your work Safety Is Everybody s Business

25 Third Party Audit Trends NEP Audits Refinery (National Emphasis Program - for Chemical Facilities) PSM elements have accounted for 80% of the citations proposed to date. These 18 top categories - Over 50% of all citations to date: Citation Reference Description Citation Reference Description j(5) Equipment Deficiencies e(3)(v) PHA - facility siting d(3)(ii) Equipment RAGAGEP f(1) Written operating procedures e(5) PHAs Not Promptly Addressed f(3) Procedure review & certification l(1) Management Of Change Procedures o(1) Compliance audit performance d(3)(i)(b) P&IDs o(4) Compliance audit response j(2) Written MI Procedures d(3)(i)(d) Relief system design & design basis f(1)(i)(d) Procedures - Emergency Shut-Down f(1)(i)(e) Procedures - emergency operations j(4)(i) Equipment Inspection and Testing f(4) Safe work practices j(4)(iv) Inspection and Test Documentation g(1)(i) Initial training

26 Benefits of a PSM Program Regulatory Compliance Reduces Insurance Costs Lessened Liability Increased Productivity Use/Manage Resources Responsibly Maintain Product Quality Maintain Long Term Viability Good Public Relations

27 A Site PSM Program A successful Site PSM program: Allows the demonstration of on-going PSM compliance by developing data and audit trails. Improves the performance of Site Safety, especially in the Preventive Maintenance arena. Integration of the PSM Program into site overall administration never ends. Implementation of this program represents a journey toward the goal of Continuous Improvement in the application of the PSM Elements to Site Operations.

28 QUESTIONS?