EHS Specialist, SW Hub Manager, EHS VP & General Manager REVISION HISTORY

Transcription

1 No.: BCF Page: Page 1 of 12 REVISION HISTORY Date Rev. # Revision Details 2/ Removal of reference to safety awareness talks. Minor typographical revisions. 10/ added RMP-specific information, including Sections 3.15 and /21/ in Sections and 4.7, removed term 95% Safety Reviews to be consistent with BCF /15/ in Section 3.5.1, removed a reference to an optional, no obsolete training evaluation form 04/23/ This standard is being revised to bring it into compliance with the template and formatting of the Corporate Safety Procedures. No major changes have been made. The reference for Contractor DOT members has been changed to Contractor Employees Who Are involved in PSM covered processes for Operations or Loading/Unloading activities. There are also minor Word revisions to accommodate the format.

2 No.: BCF Page: Page 2 of PURPOSE This written plan of action is established to ensure that employees and contractors (contractor employees who are involved in PSM or RMP covered processes for operations or loading/unloading activities) participation and responsibilities are communicated. 2. SCOPE This procedure applies to all production units that fall under OSHA PROCESS SAFETY MANAGEMENT or EPA 40 CFR RISK MANAGEMENT PLAN. 3. DEFINITIONS 3.1. BASF Employee Participation (General Responsibilities) All employees are responsible to participate in site safety by: actively participating in safety meetings by giving safety suggestions, conducting meetings, giving input for topics, training others on special topics, identifying close calls for others to avoid, etc. rotating membership of unit safety teams (UST) when requested assuring one s self of the safe nature of each job before starting being alert for unsafe conditions and acts: correcting and/or reporting promptly making safety suggestions to improve the overall progress participating in inspections of safety and emergency equipment carrying out work in a safe manner, using good judgment, and observing all applicable safety rules and procedures ensuring that areas of work are kept clean, picked up, and free of trash and unnecessary equipment reviewing proposed site standards through the UST, where assigned, and continual review of standards for adequacy as used in daily tasks

3 No.: BCF Page: Page 3 of Process Safety Information Keeping safety information updated by identifying changes to the proper personnel and assisting in the updating as requested, i.e., P&IDs, TJAs, instrumentation documentation, block flow diagrams, checklists, process manuals, etc. 3.3 PHA Employees, when requested, participate on PHA teams Employees have access to the results of PHAs to review for accuracy, review corrective actions, give input on hazards of the process for creating prioritization, and share information about PHAs and the design concepts Operating Procedures Employees participate by: using their knowledge, experience, and skills to help develop, update, review, and approve written operation procedures when needed giving input on procedures to avoid hazards and use PPE per procedures and safe practices following all operating limits set by procedures and identifying and correcting (or reporting to correct) inadequate procedures following all safe work practices and correcting or reporting inadequacies 3.5. Training Employees participate by: assisting in development or reviewing training materials and programs when requested training others on processes, safe work practices, and procedures attending training sessions and providing feedback on the adequacy of the training frequency

4 No.: BCF Page: Page 4 of Contractors Employees participate by: reviewing contractors work to ensure that they are following safe work practices and adhering to safe work permits and procedures including contractors in incident investigations when they are affected by or are involved in the incidents ensuring that equipment, processes, and areas are prepared for contractors work reviewing contractors accidents/incidents in safety meetings, when appropriate, to understand contractors requirements 3.7. Pre-Startup Safety Reviews Employees participate by: attending pre-startup reviews as assigned to ensure changes to facilities are properly installed, maintained, or replaced reviewing punch list items and ensuring that items are corrected before startup, as agreed in team meetings, when requested 3.8. Mechanical Integrity Assigned employees participate by: helping establish MI programs scheduling and inspecting equipment keeping files updated of equipment specification writing, reviewing, and updating procedures reviewing training programs and training others investigating equipment failures for root causes and helping define corrective actions when requested

5 No.: BCF Page: Page 5 of 12 participating on teams to ensure quality control of materials and equipment when requested 3.9. Hot Work Approved employees participate by: writing Hot Work permits and procedures reviewing the Hot Work, Safe Work, Confined Space, Control of Hazardous Energy, and other standards preparing equipment for maintenance work and approving procedures and permits monitoring jobs in progress and being responsible for and correcting jobs that are not according to procedure or have unsafe aspects Management Of Change Employees participate by: recognizing what a change is and obtaining proper approvals before a change is made reviewing approved management of changes, when affected updating procedures, process diagrams, training manuals, TJAs, and maintenance files and training others in the changes, when requested reviewing change requests for safe operating designs Incident Investigation Employees participate by: participating in incident investigations when requested including injuries, fires, spills/releases, equipment damage, etc., for root causes and corrective actions to prevent recurrence attending training in incident investigations and writing up reports when assigned

6 No.: BCF Page: Page 6 of 12 reviewing incidents in safety meetings and being responsible for applying corrective action in their areas of work where applicable taking responsibility to report incidents, close calls, or situations where an accident may occur and helping to correct or identify corrective action needed stopping any job in progress where personnel could be injured or are not following standard operating procedures or safe work practices and procedures Emergency Planning and Response Employees participate by: responding to emergencies, where assigned participating in drills, critiques, and corrective action being assigned essential roles during emergencies helping develop and review emergency procedures as requested taking appropriate action (for non-essential or non-assigned personnel) per the emergency plan and instructing and notifying responding leaders of their safety according to their unit safety plan Compliance Audits Employees participate by: interviewing with auditors as requested and participating in audits and inspections within their units correcting or writing up corrective actions needed if sub-standard conditions are recognized tracking to completion through assignment or safety meeting reviews

7 No.: BCF Page: Page 7 of 12 sharing in the corporate audit reviews and reviewing the documented audit results Trade Secrets Employees participate by having PHAs, operating procedures, P&IDs, and other operating information supplied to them Risk Management Plan (RMP) Employees participate by providing calculations to determine the amount of listed toxic or flammable materials stored within equipment shared by facility processes, by assisting in development of off-site modeling of worst case release or alternative release scenarios, by identifying incidents for the fiveyear accident history, and by providing updated information for the plan as needed. Information on the site s plan is available from the Freeport EHS web page: EHS: Risk Management Program and the EHS Environmental Specialist for RMP. 4. Contractor Employees Who are Members of Daily Operations Teams (DOTs) 4.1. Employee Participation All employees are responsible to participate in site safety by: actively participating in safety meetings (where they attend) by giving safety suggestions, giving input for topics, identifying close calls for others to avoid, etc. participating in unit safety teams (when requested) assuring oneself of the safe nature of each job before starting being alert for unsafe conditions and acts and correcting and/or reporting promptly making safety suggestions to improve the overall program participating in inspections of contractor owned safety and emergency equipment (as requested)

8 No.: BCF Page: Page 8 of 12 carrying out work in a safe manner, using good judgment. and observing all applicable safety rules and procedures ensuring that areas of work are kept clean, picked up, and free of trash and unnecessary equipment 4.2. Process Safety Information Assist in keeping safety information updated, i.e., P&IDs, TJAs, instrumentation documentation, block flow diagrams, checklists, process manuals, etc. (as requested and according to MOC requirements) PHA Employees participate on PHA teams (when requested), review results of PHAs for accuracy, and review corrective actions (as requested). 4.4 Operating Procedures Employees participate by: using their knowledge, experience, and skills to help develop, update, review, and approve written procedures (as requested) giving input on procedures to avoid hazards (as recognized) and using PPE per procedures and safe practices following all operating procedures/ safe work practices and identifying and correcting (or reporting to correct) inadequate procedures 4.5. Training Employees participate by: assisting in development or reviewing training materials and programs as requested training others on safe work practices and procedures (as requested) attending training sessions when requested

9 No.: BCF Page: Page 9 of Contractors Employees participate by: reviewing work for following safe work practices and adhering to safe work permits and procedures participating in incident investigations for root cause (when requested) ensuring that equipment, processes, and areas are properly prepared for work reviewing accidents/incidents in safety meetings, when appropriate 4.7. Pre-Startup Safety Reviews Employees participate by: attending pre-startup reviews to ensure that changes to facilities are properly installed, maintained, and/or replaced (as requested) reviewing punch list items and ensuring that items are corrected before startup as agreed in team meetings, when requested 4.8. Mechanical Integrity Employees participate by: helping establish MI programs when requested scheduling and inspecting equipment as assigned keeping files updated of equipment specification when assigned assisting in writing, reviewing, and updating procedures when assigned investigating equipment failures for root causes and helping define corrective actions when requested

10 No.: BCF Page: Page 10 of 12 participating in teams to ensure quality control of materials and equipment when requested tracking work orders through closure when assigned 4.9. Hot Work Employees participate by: following hot work permits and procedures reviewing the Hot Work, Safe Work, Confined Space, Control of Hazardous Energy, and other standards pertaining to hot work responsibilities monitoring jobs in progress and correcting jobs that are not progressing according to procedure or have unsafe aspects Management Of Change Employees participate by: recognizing what a change is and obtaining proper approvals before a change is made reviewing approved management of changes (as necessary) Incident Investigation Employees participate by: participating (when involved) in incident investigations, including injuries, fires, spills/releases, equipment damage, etc., for root causes and corrective actions to prevent recurrence reviewing incidents in safety meetings and applying corrective action in their areas of work where applicable taking responsibility to report incidents, close calls, or situations where an accident may occur and to help correct or identify corrective actions needed stopping any job in progress in which personnel could be injured or are not following standard operating procedures or safe work practices and procedures

11 No.: BCF Page: Page 11 of Emergency Planning and Response Employees participate by: responding to emergencies when assigned participating in drills, critiques, and corrective actions (when assigned) helping to develop and review emergency procedures when requested taking appropriate action per the emergency plan and instructing and notifying responding leaders of their safety according to their unit safety plan Compliance Audits Employees participate by: interviewing with auditors as requested correcting or writing up corrective actions needed if sub-standard conditions are recognized tracking to completion through assignment or safety meeting reviews reviewing the documented audit results of items in their areas Trade Secrets Employees participate by having PHAs, operating procedures, P&IDs and other operating information supplied to them.

12 No.: BCF Page: Page 12 of Risk Management Plan Employees participate as requested by providing calculations to determine the amount of listed toxic or flammable materials stored within equipment shared by facility processes, by assisting in development of off-site modeling of worst case release or alternative release scenarios, by identifying potential incidents for the five-year accident history, and by providing updated information for the plan as needed. Information on the site s plan is available from the Freeport EHS web page: Environmental: Risk Management Program and the EHS Environmental Specialist for RMP. Related Documents OSHA PROCESS SAFETY MANAGEMENT EPA 40 CFR RISK MANAGEMENT PLAN