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Process Safety Management

Process Safety Management


Here we are trying to understand the basic definition of “Process Safety Management (PSM)”, requirement in hazardous industries and its element for better implementation of systems.

The various lines of defense included in the design and operation of the process to prevent or reduce the release of hazardous chemicals must be evaluated and strengthened to ensure their effectiveness at all levels. Process safety is proactive and centers on the Safety Integrity of the process. 

Process Safety Management
Process Safety Management


Definition of Process Safety Management


"Process Safety Management is the proactive identification, evaluation and prevention of chemical releases that could occur as a result of failures in process, procedures, or equipment"-OHSA.

Process safety for the most part alludes to the anticipation of unwanted releases of chemicals, energy or other conceivably dangerous materials during process that can seriously affect the plant and nature.

After series of serious accidents (like Bhopal gas Tragedy & Piper alpha, North Sea) that occurred in 1980's, OSHA (Occupational Safety and Health Administration) developed Process Safety Management rules in 1992. These rules made mandatory in USA for Chemicals handling, storing/processing above a threshold value. Elements under PSM rule set the requirement for management of hazards associated with processes using highly hazardous chemicals.

Scope of Process Safety Management


Process Safety Management is applicable in a process which involves a chemical at or above the specified Threshold Quantities (TQ) listed in annexure of the Rule 29 CFR 1910.252 (a); or A process that involves a flammable liquid or gas at the site at a location, in an amount of 10,000 pounds (4,535.9 kg) or more..
  

Elements of Process Safety Management


For better understanding, all elements of Process Safety Management can be divided in different group.


Group-1: Knowledge and operational control
  • Process safety information
  • Operating procedures
  • Hot work permit and other Safe work practices
  • Contractors management
  • Training


Group-2: Hazard identification and controls
  • Process hazard analysis
  • Management of change
  • Pre-startup safety review
  • Mechanical integrity


Group-3: Incident learning and response
  • Incident investigation
  • Emergency planning and response


Group-4: Participation and Management
  • Employee participation
  • Compliance audit
  • Trade secretes


Elements of Process Safety Management
Elements of Process Safety Management



Knowledge and operational control


1.    Process Safety Information


The purpose of Process Safety Information (PSI) is to bring awareness to all employees, workers and their representatives involved in process operation to identify and understand the hazards posed by those processes involving hazardous chemicals by sharing information on process technology, process equipment and chemical hazards.

MSDS can be used as source for getting chemical information ie. toxicity, TLV, physical data, reactivity, etc. whereas information on process technology can be get from process flow diagram, process chemistry, safe limits of process parameters, etc. Information on equipment can be collected from its manufacturer data sheet, P&IDs and other engineering designs.


2.    Operating Procedures


The purpose of operating procedures is to provide clear instructions for performing particular process activities safely in consistent with the Process Safety.

The operating procedures shall be developed for each of the operating phases and must address below elements;


Operating phase:

  • Initial Startup
  • Normal operations & emergency operations
  • Normal shutdown & emergency shutdown


Operating limits:

  • Consequences of deviation
  • Steps required for correcting or avoiding deviation.


Safety, Health and Environments:

  • Properties and hazards of chemicals used in the process.
  • Exposure prevention measures (including engineering controls, administrative controls, and PPE)
  • Control measures on physical contact or airborne exposure occurs.
  • Quality control of raw materials and control of levels of stocks of hazardous chemicals.
  • Safety limits (e.g., interlocks, detection, or suppression systems) and their functions


Requirement of operating procedures
Requirement of operating procedures


3.    Hot work permit and other safe work practices


Working in hydrocarbon processing or/and handling installations presents special risk and in order to provide safe working conditions and to carry out the special work in restricted area safely, a Work Permit System shall be followed. The basic purpose of the Work Permit System is to ensure that work is carried out in the safest possible manner to prevent injuries to personnel and protect property damage by avoiding fire, explosion, or release of toxic chemicals.

The employer issues a permit for hot work activities that are performed in or near a covered process. The permit must document the fire prevention and protection requirements prior to beginning the hot work operations. It shall indicate the date authorized for hot work; and identify the object on which hot work is to be performed. The permit must be retained until completion of the hot work.


4.    Contractors Management


This element applies to contractors who perform maintenance or repair work, major renovations or specialized work in or in addition to a covered process, and not to contractors who provide auxiliary services, such as concierge, catering, laundry, delivery or other services, procurement services.

Employer Responsibilities:

  • For selecting the contractor, obtain and evaluate his safety performance.
  • Inform contractual employers about the known potential risks of fire, explosion or toxic substances related to the work and process of the contractor.
  • Explain On -Site Emergency Plan.
  • Develop and implement safe work practices consistent with his activities.
  • Periodically evaluate the performance of contract employers.


Contract Employer Responsibilities:

  • Assure his employees are trained in the relevant work practices and made aware on potential fire, explosion, or toxic release hazards and emergency action plan. Training record must be maintained.
  • Create a file with the identity of the contractual employee, the date of the training and the means used to verify if the employee has fully understood the training.
  • Inform any unique hazards presented at his workplace.

Read more on contractor management



5.    Training


All employees before being involved in operating a process must be trained in an overview of the process and in its operating procedures to manage the process safely and efficiently. Employer may certify in writing that the employees have the required competency to safely carry out the duties and responsibilities.

Update courses should be given at least every three years, or more frequently if necessary, to each employee involved in the implementation of a process, to ensure that the employee understands and complies with the current operational procedures of the process. The training file must be maintained.


Hazard identification and control



6.    Process Hazard Analysis


The purpose of Process Hazard Analysis (PHA) is to minimize the likelihood of the occurrences and consequences of a dangerous substance release by identifying, evaluating, and controlling the events that could lead to the release. It provides information that helps you make decisions to improve safety and reduce the effects of unwanted or unplanned emissions of hazardous chemicals.

Process hazard Analysis
Process hazard Analysis


Initial Process Hazard Analysis: The employer must perform an initial Process Hazard Analysis (hazard evaluation) on all processes covered by this standard.

Selection of the methodology: The Process Hazard Analysis methodology selected must be appropriate to the complexity of the process and must identify, evaluate. and control the hazards involved in the process. The employer must, as the case may be, use one or more of the following methods to determine and assess the hazards of the analyzed process.
i.e. What-if, Checklist, What-if/checklist, Hazard and Operability Study (HAZOP), Failure Mode and Effects Analysis (FMEA), Fault Tree Analysis (FTA), or an appropriate equivalent methodology.


Factors to be included in the PHA: Whichever method(s) are used, the PHA must address the following:
  • The hazards of the process.
  • Consideration of previous incident that had a potential for catastrophic consequences in the workplace.
  • Technical and administrative controls that apply to hazards and their interrelations, such as the correct application of detection methods to provide early emission alerts. (Acceptable detection methods may include monitoring and process control instruments with alarms and detection equipment such as oil sensors).
  • Consequences of the failure of technical and administrative controls.
  • Facility location.
  • Human factors and a qualitative evaluation of a range of possible effects on the safety and health of employees in the workplace in case of failure of controls.


Team Formation for Process Hazard AnalysisThe PHA must be performed by a team with experience in engineering and process operations, and this team must include at least one employee who has experience and knowledge of the process to be evaluated. In addition, a team member must know the specific analysis methods.

Establishment of Recommendation Tracking System: The employer must establish a system to address promptly the team's findings and recommendations; assure that the recommendations are resolved in a timely manner and documented. Develop a written schedule of when these actions are to be completed; complete actions as soon as possible; and communicate the actions to operating, maintenance, and other employees whom work is assigned and who may be affected by the recommendations or actions.

Re-validation and Updating of Process Hazard Analysis: At least every five years after the completion of the initial process hazard analysis, the hazard analysis shall be updated and re-validated by a team to assure that the PHA is consistent with the current process.

Record Keeping: Employers must retain the PHA and any update or extension for any process found in this section, as well as the documented resolution of the recommendations.



7.    Management of Change


The intent of the Management of Change (MOC) is to manage modifications to technology, equipment, facilities, processing conditions or any changes within the documented technology, which are not a replacement in kind. All plant changes should be identified and reviewed prior to their implementation and the impact of design; operational and procedural Changes on process safety should be addressed and controlled.

Written procedure of MOC: The employer must establish and implement written procedures to manage the changes (with the exception of "in-kind substitutions") to treat chemicals, technology, equipment and procedures; and changes in the characteristics that affect a covered process.

Considerations to be addressed prior to any change: The procedures shall assure that the following considerations are addressed prior to any change:
  • The technical basis for the proposed change
  • Impact of change on safety and health
  • Modifications to operating procedures
  • Necessary time period for the change
  • Authorization requirements for the proposed change


Communication and Training: Employees involved in the operation, maintenance and hired employees whose functions may be affected by a change in the process must receive training in the change before the start of the process or an affected part of the process. They must be informed of the scope of the process hazards.

Process safety Information Update: On the off chance that an adjustment in this segment changes the procedure data, this data ought to be refreshed likewise

Operating Procedure Update: If a change covered by this section results in a change in the operating procedures or practices, such procedures or practices shall be updated accordingly.



8.    Pre-Startup Safety Review


The purpose of Pre-Startup Safety Review (PSSR) is to ensure that new/modified facility is ready for safe and continuous operation.
The PSSR must confirm the following, prior to the introduction of highly hazardous chemicals to a process.
  • Construction and equipment meet design specifications.
  • Safety, operation, maintenance and emergency procedures are present and adequate.
  • For new modified facilities, a MOC procedure had been followed, and all HAZOP recommendations have been implemented before startup.
  • Training of each employees involved in operating a process has been completed.


9.    Mechanical Integrity


The purpose of mechanical integrity is to ensure the availability of process and components on demand as per the design intent, which include the following:
  • Pressure vessels and storage tanks.
  • Piping systems.
  • Relief & vent systems and devices.
  • Emergency shutdown systems.
  • Critical controls (including monitoring devices and
  • sensors, alarms, and interlocks); and
  • Pumps and Compressors

We must ensure written procedures to maintain the ongoing integrity of process equipment, training for process maintenance activities to assure that the employee can perform the job tasks in a safe manner and inspections shall be performed on process equipment. Inspection and testing must be done as per set procedure and in consistence applicable manufacture recommendation and good engineering practices. All inspection and test shall be well documented.
All the equipment deficiencies that are outside acceptable limits shall be corrected in a safe timely manner. Ensure that all equipment is fabricated as per the specification and installed properly in consistent with design specifications and the manufacturer's instructions. Maintenance materials, spare parts and equipment should be suitable for intended application.



Incident Learning and Response



10. Incident investigation



A workplace process incident is an indication that prevention was ineffective and that prompt changes need to be made, Therefore, every process incident and Near Miss must be recorded and thoroughly investigated to prevent recurrence of the incident.

Investigation of Incidents/Near-Miss Involving highly hazardous chemicals: Each incident shall be investigated which resulted in or could reasonably have resulted in a catastrophic release of highlyhazardous chemical in the workplace.

Initiation of Investigation: An incident investigation shall be initiated as promptly as possible, but not later than 48 hours following the incident.

Formation of Team: An incident investigation team must be established with at least one person familiar with the process involved, including an employee hired if the incident concerned the work of the contractor and others with the appropriate knowledge and experience to thoroughly investigate and investigate the incident.

Content of Investigation Report: A report shall be prepared at the conclusion of the investigation which includes at a minimum date of incident, the date on which the Investigation began, description of the incident, the factors that contributed to the incident; and any recommendations tracking from the investigation.

Recommendation racking System: The employer shall establish a system to promptly address and resolve the incident report findings recommendations. Resolutions and corrective actions shall be documented.

Report Review: The report should be evaluated with all relevant personnel whose functions are relevant to the conclusions of the incident, including employees.

Retention of Reports: Incident investigation reports shall be retained for five years.



11. Emergency Planning and Response


Most emergencies, such as major fires, explosions, toxic emissions, oil spills, etc., can be controlled by carefully assessing possible planned events and developing a plan to deal with such situations, organize exercises or perform appropriate tests. carry out effective implementation at the time of the emergency. An emergency action plan (ERP) for the entire facility must comply with the provisions of 29 CFR 1910.38. In addition, the ERP will include procedures for dealing with small emissions.

Written and oral Emergency Action Plans: An EAP must be in written, kept in the workplace, and available to employees for review. However, an employer with a maximum of 10 employees can verbally communicate the plan to employees.

Minimum elements of an Emergency Action Plan: An ERP must include at least below;

  • Procedures for registering a fire or other emergency:
  • Emergency evacuation procedures, including type of evacuation and allocation of exit routes.
  • Procedures for Remaining Employees to Perform Critical Factory Operations Before Evacuating
  • Procedures for reporting to all employees after evacuation.
  • Procedures to be followed by employees performing rescue or medical operations; and
  • The name or position of each employee (whom employees can contact) who needs more information about the plan or an justification of their duties under the plan.


Employee Alarm System: Have and maintain an Employee Alarm System (EAS). The EAS must use a distinctive signal for each purpose and comply with the legal requirements.

Training: Designate and train employees to assist in a safe and orderly evacuation of other employees.

Review of Emergency Action Plan: Review the EAP with each employee covered by the plan:
  • At the point when the arrangement is created, or the worker is at first allotted to a vocation.
  • When the employee's obligations under the plan change.
  • When the plan is modified.



Participation and Management



12. Employee participation


The purpose of employee participation is to consult with employees, workers and their representatives on hazard assessments posed by those processes involving highly hazardous chemicals by sharing information on process technology, process equipment and development of chemical accident prevention plans. It provides the access to these documents and other records required under the standard.


13. Compliance audit


The purpose of compliance audit is identification of vulnerable areas and specific potential hazards i.e. one of the prime functions of loss prevention in process industry. Auditing is an important means for performing this function.

Standard Requirements:

Evaluation of Compliance: Top management must ensure that they have evaluated consistence with the arrangements of the MSP something like at regular intervals to confirm that the systems and practices created under the standard are proper and followed.

Auditor: The compliance audit shall be conducted by at least one person knowledgeable in the process.

Audit Report: A report of the findings of the audit shall be developed.

Response to the Audit Findings: Employers will immediately determine an appropriate response to each of the compliance audit findings and document and document that the deficiencies have been corrected.

Retention of Audit Report: Employers must retain the two most recent compliance audit reports.

Management review: Management must demonstrate their commitment toward effective implementation and monitoring of PSM programme.
  • Regular management review including action follow up from previous reviews.
  • Review process safety leading and lagging indicators
  • Review PSM audit findings and action plan
  • Review PSM elements gap analysis and action plan


14. Trade secretes


Ensure all relevant information must be made available by employers to all those people who are participated and consulted in development of emergency response plan in consistence with hazard analysis. necessary information to all responsible persons who must comply the process safety information, those responsible for developing the operating procedures, performing incident investigations, and compliance audits, without regard to the possible trade secret status of such information. Nothing in PSM, however, prohibits the employer from requiring those persons to enter into confidentiality agreements not to disclose the information.
  

Conclusion:


Process Safety management is applicable in highly hazardous industries which handle hazardous chemical at or above the specified threshold quantity. Industries viz. Retail facilities, Oil or Gas well drilling or servicing, normally unoccupied remote facilities are excluded from scope.

There are several benefits of process safety management viz. ensures safe workplace for workers, reduces Risk to nearby community, reduces Risk to adverse environment impact, increases assets reliability with reduced downtime &  losses, ensures high score in International Safety Rating System, provides a powerful risk management tool, reduces Insurance premium, integrates with existing Quality, Environment & Safety Management System, facilitates structured approach towards business, management with better controls, etc.

Related Articles

How to measure performance of process safety management

Reporting of Process Safety Incidents and near misses

Safe Mechanical completion, pre-commissioning, startup | Oil and Gas Facility

  

18 comments:

  1. Sir, thank you very much for sharing such detail information on process safety management

    ReplyDelete
  2. Replies
    1. If something wrong with basic process safety system, There is role of alarms

      Delete
  3. Sir, what is diffence between Hazop and Hazid

    ReplyDelete
    Replies
    1. Hazard and operability (HAZOP) is a technique used to identify both potential hazards and potential operability problems due to deviation in the design intent. It helps to review the design intent of the particular installation or process system by applying guide words related to the parameters of each process to discover the causes of deviation, adequacy and effectiveness of the safeguards and then recommend controls. Use a risk matrix to determine the probability and consequences of failure.
      HAZOP is generally conducted for new facilities, modification to existing facilities through MOC, and every 5 years for operational facilities.
      Hazard Identification (HAZID) is a technique used to identify hazards based on standard checklists prepared with reference to best industry practices, standards, rules and regulations, experience and best engineering practices. Provides input to the primary risk assessment for credible events or scenarios.

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