Process Safety Management - PowerPoint Presentation

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Process Safety Management:Management & Labor Working Together

Washington Administrative Code 296-67

Sponsored by the Chemicals and Petroleum Industry Slide2

Why Process Safety is ImportantSlide3

Why Process Safety is ImportantSlide4

Why Process Safety is ImportantSlide5

Why Process Safety is ImportantSlide6

Panel IntroductionsStephanie Arnold – Management (US Oil)Craig Bertucci – Labor (USW 12-591, Phillips 66)

Tony Bocek – Labor (BP Cherry Point)Sara Hough – Moderator (Shell)Slide7

Process Safety ManagementWAC 296-67

Employee Participation Process Safety Information

Process Hazard Analysis

Operating Procedures

Training

Contractors

Pre-Startup Safety Review

Mechanical Integrity

Hot Work Permit

Management of Change

Incident Investigation

Emergency Planning

and

Response

Compliance Audits

Trade SecretsSlide8

Process Safety InformationA compilation of written process safety information identifying the hazards

posed by a process. This must be accessible to all workers.

Must include information on the

hazards

of the highly hazardous chemicals used or produced, information on the

technology

, and information on the

equipmentSlide9

Process Hazard AnalysisA process hazard analysis is a thorough, orderly, systematic approach for identifying, evaluating, and controlling the

hazards of processes involving highly hazardous chemicalsPHA revalidations must be updated at least every five years

The employer must establish a

system

to promptly address the team’s findings

Documents what

actions

are to be taken and develop a

written schedule

of when these actions are to be completed

Communicate

the actions to operating, maintenance, and other employees who may be affected by the actionsSlide10

ContractorsPSM applies to contractors performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process

Contractor performance in PSM related activities must be tracked (We watch and they watch)

Contractors have access to the same Process Safety Information and follow the same safe work practicesSlide11

Pre-Startup Safety Review (PSSR)

The employer shall perform a pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information

The pre-startup review shall 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 adequate

For new facilities a PHA has been performed and recommendations have been resolved or implemented before startup; and modified facilities meet the requirements contained in the MOC section

Training of each employee involved in operating a process has been completedSlide12

Mechanical IntegrityWritten procedures are developed to maintain the ongoing integrity of process equipment

Training of employees involved in maintaining the ongoing integrity of the process equipmentInspection and Testing processes: proactive/preventative programs to ensure equipment is working properly

Equipment deficiencies shall be corrected in a safe and timely manner

Quality assurance of construction, installation, maintenance materials, spare parts, etc. are suitable for the processSlide13

Hot Work PermitThe employer shall issue a hot work permit for how work operations conducted on or near a covered process

The permit shall document that the fire prevention and protection in WAC 296-24-695 have been implemented prior to hot work beginningThe permit shall be kept on file until

completion of the hot workSlide14

Incident InvestigationPSM requires an investigation

to be started within 48 hours of each incident that resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical in the workplace

An investigation report is required to be written

Any recommendations from investigations must be promptly addressed and resolved

The report shall be reviewed with all affected personnel whose job tasks are relevant to the incidentSlide15

Emergency Planning and ResponseThe employer shall establish and implement an emergency action plan for the entire plant

In addition the emergency action plan shall include procedures for handling small releasesSlide16

Compliance AuditsEmployers shall certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed

The employer shall promptly determine and document an appropriate response to each of the findings of the audit and document that deficiencies have been correctedSlide17

Trade SecretsEmployers must make available all information

necessary for compiling process safety information, completing process hazard analyses, developing operating procedures, and performing incident investigations, emergency planning and response, and compliance audits, without regard to the possible trade secret status of such information

Subject to the rules and procedures set forth in WAC 296-62-053, employees and their designated representatives shall have access to trade secret information contained within the process hazard analysis and other documents required to be developed by this standardSlide18

Operating Procedures(Safe Work Practices)The employer must have written operating procedures that provide

clear instructions for safely conducting activities involved in each covered process consistent with the PSI and shall address each operating phase

The employer shall develop and implement safe work practices to provide for the control of hazards during operations such as lockout/

tagout

; confined space entry; opening process equipment or piping and control of entry into a facilitySlide19

Operating Procedures(Safe Work Practices)How do you choose what Operating Procedures to write for your workplace?

What are your thoughts on what Safe Work Practices are applicable to your facility?Slide20

TrainingEach employee involved in the operation of a covered process must be trained in an overview

of the process and in its operating procedures

Refresher training must be provided

at least every three years

, or more often if necessary

Employees involved in operating the process, must be consulted to determine the

appropriate frequency

of refresher trainingSlide21

TrainingWhat different kinds of Training are used at your site?What methods of training or techniques have you found to be effective?Slide22

Management of ChangeThe Employer shall establish and implement written procedures

to manage changes (except for replacements in kind) to process chemicals, technology, equipment, and procedures; and changes to facilities that affect a covered process

The procedures shall assure that the following considerations are addressed prior to any change: technical basis, impacts on safety & health, operating procedures, time period for change and authorization requirements for the change

A Pre Start-Up Safety Review shall also be performed prior to the change being used, including informing and training employees whose job tasks are affected.Slide23

Management of ChangeHow do you implement MOC to ensure that changes are evaluated and implemented safely?Should all MOC programs look the same across industries/facilities?

Any examples of “good catches” or “ah-ha” moments from doing an evaluation of a change?Slide24

Employee ParticipationEmployers shall develop a written plan of action regarding the implementation of the employee participation required by this section

Employers shall consult with employees and their representatives on the conduct of PHA’s and the development of the other elements of process management

Employers shall

provide

to employees and their representatives access to process hazard analyses and to all other information required to be developed by the standardSlide25

Employee ParticipationWhat does good Employee Participation look like? How do you know?Slide26

SummaryManagement and Labor are working together every day to sustain and continuously improve process safety in the state of Washington

We have to work together to eliminate process safety events from impacting our workforce and communities

Process Safety Management requires constant TLC by all partiesSlide27

WA PSM Advisory PanelCreated September 2015The purpose of this committee is to discuss ways to improve workplace safety and health

Representatives from Industry, Labor, and Government are members

Latest meeting was September 6, 2017 and the panel welcomes new membersSlide28

PSM Rule ChangesL&I announced intent to start formal Rule Making to revise the PSM rule in August 2017

http://www.lni.wa.gov/Safety/Rules/WhatsNew/Proposed.asp?RuleID=98Contact Tari Enos

for more information on how to participate in rule writing.

tari.enos@lni.wa.gov

Administrative Regulations Analyst

Division of Occupational Safety and Health

PO BOX 44620, Olympia, WA 98504-4620

Office 360-902-5541 | FAX 360-902-5619

If you are interested in participating on PSM Advisory Council, contact Devin Proctor:

http://www.lni.wa.gov/Safety/GrantsPartnerships/Committees/PSM/default.asp

devin.proctor@lni.wa.gov

Program Specialist

Division of Occupational Safety and Health

PO BOX 44610, Olympia, WA 98504-4610

Office 360-902-5895 | Cell 360-584-3111 | FAX 360-902-5438