1.0 PURPOSE
This procedure has been developed to meet the requirements of OSHA Standard 1910.119 Process Safety Management of Highly Hazardous Substances (PSM). The purpose of the Process Safety Management standard is to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals.
2.0 RESPONSIBILITY
2.1 The facility owner is responsible for developing a PSM plan, which identifies potential hazards inherent to the facility processes.
2.2 The Nitro Construction Services Project Manager shall obtain a copy of the facility PSM plan and job-site implementation as it applies to Nitro Construction Services employees and sub-contractors.
2.3 The Project Manager shall assure that each employee is trained in the work practices necessary to perform his/her job safely and in accordance with the facility’s PSM Procedures.
2.4 All employees shall follow the requirements set forth in this procedure.
3.0 REFERENCES
29 CFR 1910.119
4.0 DEFINITIONS
4.1 Catastrophic Release – a major uncontrolled emission, fire, or explosion involving one or more highly hazardous chemicals that presents serious hazards to employees in the workplace.
4.2 Facility – the buildings, containers or equipment which contain a process.
4.3 Highly Hazardous Chemical – a substance possessing toxic, reactive, or explosive properties.
4.3 Hot Work – work involving electric or gas welding, cutting, brazing, or similar flame or spark-producing operations.
4.4 Material Safety Data Sheet – written or printed material concerning a hazardous chemical which is prepared in accordance with paragraph G of the OSHA Hazardous Communication Standard.
4.5 Normally Unoccupied Remote Facility – a facility that is operated, maintained, or serviced by employees who visit the facility only periodically to check its operation and to perform necessary operating or maintenance tasks. No employees are permanently stationed at the facility. Facilities meeting this definition are not contiguous with and must be geographically remote from all other buildings, processes, or persons.
4.6 Process – any activity involving a highly hazardous chemical including any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or combination of these activities.
4.7 Replacement in kind – a replacement that satisfies the design specification.
4.8 Trade secret – any confidential formula, pattern, process, device, information or compilation of information that is used in an employer’s business, and that gives the employer an opportunity to obtain an advantage over competitors who do not know or use it.
5.0 PROCEDURE
5.1 Certain facilities are required under OSHA’s Process Safety Management Standard to develop PSM plan that provides clear instructions for safely conducting activities involved in each covered process consistent with the process.
5.1.1 The host client shall advise Nitro Construction Services of any unique hazards presented by the contracted work or of any hazards found by the contracted work.
5.1.2 Employees shall abide by all safe work practices during operations such as lockout / tag out, confined space entry, the opening of process equipment or piping, and controls over the facility.
5.2 The PSM Standard covers 14 Elements that must be addressed in the facility owner’s PSM Plan.
1. Employee Participation
2. Process Safety Information (PSI)
3. Process Hazard Analysis (PHA)
4. Operating Procedures
5. Training
6. Contractor Safety
7. Pre-Startup Safety Review
8. Mechanical Integrity
9. Hot Work Program
10. Management of Change (MOC)
11. Incident Investigation
12. Emergency Planning and Response
13. Compliance Audits
14. Trade Secrets
6.0 THE 14 ELEMENTS OF PROCESS SAFETY MANAGEMENT
6.1 Section 1: Employee Participation
The standard requires employers (facility owners) to
• Develop a Written Plan of Action for the implementation of Employee Involvement.
• Consult with employees on the conduct of the development the process hazard analysis and of other PSM Elements.
• Provide access to PSM information.
6.2 Section 2: Process Safety Information (PSI)
The OSHA standard requires compiling of technical information on the process and equipment in the PSM covered units. This PSI shall include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process.
6.3 Section 3: Process Hazard Analysis (PHA)
A process hazard analysis must be conducted by a team with expertise in engineering and process operations, including at least one employee who has the experience and knowledge on the covered process being reviewed and one person who must be knowledgeable in the specific process hazard analysis methodology used. The process hazard analysis shall be appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process.
PHA review is required at least every five (5) years to update and revalidate by a qualified person to assure that the process hazard analysis is consistent with the current process.
PHA Documentation shall be retained for each process covered by this section, as well as the documented resolution of recommendations described previously for the life of the process, plus 10 years.
6.4 Section 4: Operating Procedures
The facility/owner shall develop and implement written operating procedures that provide clear instructions for safely conducting operations and maintenance. These operating procedures shall be readily accessible to employees and reviewed as often as necessary to assure that they reflect current operating practice. The facility owner shall certify annually that these operating procedures are current and accurate. The facility/owner shall also develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tag out; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. These safe work practices shall apply to employees and contractor employees.
6.5 Section 5: Training
Initial training: Each facility owner-operator must be trained in an overview of the process and in the operating procedures. The training shall include an emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee’s job tasks.
Refresher training shall be provided at least every three (3) years, and more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process.
Training documentation. The facility owner shall ascertain that each employee involved in operating a process has received and understood the training required by this paragraph. The facility owner shall prepare a record that contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training.
6.6 Section 6: Contractors
This section applies to contractors performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process. It does not apply to contractors providing incidental services that do not influence process safety, such as janitorial work, food and drink services, laundry, delivery, or other supply services.
The contract employers (Nitro Construction Services) requirements per the OSHA PSM standard are as follows:
• Shall assure that each contract employee is trained in the work practices necessary to safely perform his/her job.
• Shall assure that each contract employee is instructed in the known potential fire, explosion, or toxic release hazards related to his/her job and the process, and the applicable provisions of the emergency action plan.
• The contract employer shall document that each contract employee has received and understood the training required by this paragraph. The contract employer shall prepare a record that contains the identity of the contract employee, the date of training, and the means used to verify that the employee understood the training.
• The contract employer shall assure that each contract employee follows the safety rules of the facility including the safe work practices required by OSHA.
• The contract employer shall advise the employer of any unique hazards presented by the contract employer’s work, or of any hazards found by the contract employer’s work.
6.7 Section 7: Pre-Startup Safety Review (PSSR)
It is a requirement to perform pre-startup safety reviews for new and modified facilities when the modification is significant enough to require a change in the process safety information. The purpose of the Pre-Startup Review is to confirm that, prior to the introduction of highly hazardous chemicals to a process:
• Construction and equipment is in accordance with design specifications.
• Safety, operating, maintenance, and emergency procedures are in place and are adequate.
• Modified facilities meet the requirements contained in the Management of Change.
• Training of each employee involved in operating a process has been completed.
6.8 Section 8: Mechanical Integrity
This section applies to process equipment, such as pressure vessels and storage tanks; Piping systems (including piping components such as valves); relief and vent systems and devices; emergency shutdown systems; controls (including monitoring devices and sensors, alarms, and interlocks) and, pumps.
Written procedures are written and established by the facility owner to maintain the on-going integrity of equipment in the PSM covered processes.
Each employee shall be trained that is involved with the on-going integrity of the process equipment in an overview of that process and its hazards and in the procedures applicable to the employee’s job tasks to assure that the employees can perform the job tasks in a safe manner.
Testing and inspections (T&Is) shall be performed on process equipment and must follow recognized generally accepted good engineering practices, manufacturer’s recommendations & operating experience for the conduct & frequency.
6.9 Section 9: Hot Work
The facility owner shall issue a hot work permit for hot work operations conducted on or near a covered process. The permit shall document that the fire prevention and protection requirements in 29 CFR 1910.252(a) have been implemented prior to beginning the hot work operations.
At a minimum, the permit shall indicate the date(s) authorized for hot work and identify the object on which hot work is to be performed. The permit shall be kept on file until completion of the hot work operations.
6.10 Section 10: Management of Change (MOC)
The facility owner shall establish and implement written procedures to manage changes (except for “replacements in kind”) to process chemicals, technology, equipment, procedures; and changes to facilities that affect a covered process.
Prior to the change, the following considerations must be addressed:
• The technical basis for the proposed change;
• Impact of change on safety and health;
• Modifications to operating procedures;
• Necessary time period for the change; and,
• Authorization requirements for the proposed change.
Affected employees and contract employees shall be trained by the facility owner in the change prior to the start-up of the process or affected part of the process.
6.11 Section 11: Incident Investigation
The facility owner shall investigate each incident that resulted in, or could reasonably have resulted in a catastrophic release of a highly hazardous chemicals in the workplace. An incident investigation team consisting of at least one person knowledgeable in the process involved, a contract employee if the incident involved work of the contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident shall conduct the incident investigation.
A report shall be prepared by the facility owner at the conclusion of the investigation that includes at a minimum:
• Date of incident
• Date investigation began
• Description of the incident
• Factors that contributed to the incident
• Recommendations resulting from the investigation
The report shall be reviewed with all affected personnel whose job tasks are relevant to the incident findings including contract employees where applicable. Incident investigation reports shall be retained by the facility owner for five (5) years.
6.12 Section 12: Emergency Planning & Response
The facility owner shall establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38(a). and 29 CFR 1910.120(a), (p) and (q). In addition, the emergency action plan shall include procedures for handling small releases within each PSM covered process unit.
6.13 Section 13: Compliance Audits
The facility owner shall certify compliance with the provisions of the PSM Standard at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed.
6.14 Section 14: Trade Secrets
The facility owner shall make all information necessary to comply with the section available to those persons responsible for compiling the process safety information, those assisting in the development of the process hazard analysis, those responsible for developing the operating procedures, and those involved in incident investigations, emergency planning, and response and compliance audits without regard to possible trade secret status of such information.
Any trade secret information released to Nitro Construction Services under the PSM standard shall remain confidential.