The Self-Regulation of Environmental Equipment

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Under the Environmental Quality (Clean Air) Regulations 2014, an owner or occupier of premises shall not , without giving prior written notification to the DOE Director-General.:-

  • Carry out any change in operation of his premises;
  • Carry out any work on any premises that may result in a source of emission;
  • Construct on any land, any building or premises designed or used for a purpose that may result in a new source of emission;
  • Make, cause, or permit to be made any change of, to, or in any plant, machine, or equipment used or installed at the premises that cause a material change in the quantity or quality of emission from an existing source; or
  • Carry out any changes or modifications to an existing air pollution control system.

The written notification shall be submitted to the state DOE not less than thirty days before the commencement of such work in a prescribed form.

Under Environmental Quality (Industrial Effluent) Regulations 2009, no person shall, without prior written notification to the Director General –

  • Carry out any work on any premises that may result in a new source of discharge of industrial effluent or mixed effluent;
  • Construct on any land, building or facility designed or used for a purpose that may cause the land or building or facility to result in a new source of discharge of industrial effluent or mixed effluent;
  • Make or cause or permit to be made any change of, to, or in any plant, machine, or equipment used or installed at the premises that cause a material change in the quantity or quality of the discharge or release from an existing source; or
  • Carry out upgrading work of an existing industrial effluent treatment system that may result in a material change in the quantity or quality of the discharge or release.

The written notification to carry out any work, construction or upgrading, or to make any change shall be submitted to the state DOE in the prescribed form within thirty days before the work or construction or upgrading commences.

Written Notification is required for the manufacturer and the designer to be fully responsible on the designs of the air pollution control system/air emission equipment/industrial effluent treatment system that are submitted.

There are 11 Written Notifications / Pemberitahuan Bertulis as below:

  • Centrifugal Dust Collector (Axial-Flow Vortex Tubes)
  • Centrifugal Dust Collector (Cyclone)
  • Spray Booth
  • Electrostatic Precipitator
  • Scrubber
  • Bag Filter
  • Fuel Burning Equipment
  • Incinerator
  • Generator
  • Exhaust / Vent (Chimney)
  • Industrial Effluent

The Written Notifications Forms contain information about the manufacturer, discharge emission or effluent, design of the equipment, design of the air pollution control system/industrial effluent treatment system, performance monitoring program and declaration from the manufacturer. For the forms listed above, each form may have specific equipment information prescribed in the form and manufacturer is required to furnish the required information.

Written Notification is implemented to replace Written Approval. The responsibilities of the equipment will lie on the authority for Written Approval because the authority approves it. But now with the implementation of Written Notification, the responsibility lies on the manufacturer and the authority will only taking note of the existence of the equipment.

The Importance of Framework to Manage HSE Aspects

A HSE Management System is an integrated approach where all the 3 HSE factors are effectively managed to reduce risks in the workplace and environment. The objective of a HSE Management System is to provide a structured management approach to control health, safety and environmental risks.

International standard ISO 45001:2018 Occupational Health and Safety Management Systems lists down requirements with guidance for use. ISO 14001;2015 Environment Management Systems sets out the criteria for an environmental management system.

Regardless of the industry you are in, all organisations need a comprehensive, well-documented HSE management system to ensure that all personnel are safe and environment are protected. A HSE management system must be written down, communicated and practised.

The key elements of a successful HSE management system include:

  • HSE plan and inspection checklists
  • Risk assessments and monitoring
  • Reporting
  • Training and induction

A HSE plan is a strategic action plan which sets out all current and prospective risks for the company. It provides an analysis of all risks present, with an outline of how to remove said risks. This HSE plan helps to set up a framework for all workers to follow and be held accountable to maintain the HSE record of the workplace. A HSE plan also comprises of HSE inspection checklists and emergency response plans.

Risk assessments document all risks in the workplace. This helps in protecting all workers and surrounding people from potential hazards. All areas of HSE non-compliance are outlined in the assessment and aid in ensuring proper solutions are in place. After risk assessment, risk monitoring is to be conducted depending on the risk level to maintain HSE in place.

Reporting of HSE elements is needed to monitor the performance of HSE elements. HSE key performance indicators (KPI) are needed to measure the performance of the HSE aspects. These KPI help to identify areas that need improvement. KPI for HSE include Lost Time Injury (LTI), number of accidents and incidents, productive days, near misses, etc.

All workers need to receive adequate training on the various HSE rules and procedures at the worksite. A thorough training program includes all HSE aspects e.g. PPE training, fire drills, scheduled waste management, management of pollution control equipment, etc. These trainings must be recorded to keep track of the training to ensure a successful HSE management system. In conclusion, the management plays a critical role in making HSE management system a success.

The Importance of LOPA in Risk Management

Layer of Protection Analysis also known as LOPA is a risk management technique commonly used in the chemical process industry that can provide a more detailed, semi-quantitative assessment of the risks and layers of protection associated with hazard scenarios. LOPA is a means to identify the scenarios that present the most significant risk and determine if the consequences could be reduced by the application of inherently safer design principles. LOPA can also be used to identify the need for safety instrumented systems (SIS) or other protection layers to improve process safety.

LOPA is a risk assessment methodology which uses simplified, conservative rules to define risk as a function of both frequency and potential consequence severity. LOPA is defined as a simplified risk assessment of a one cause – one consequence pair.

Conceptually, LOPA is used to understand how a process deviation can lead to a hazardous consequence if not interrupted by the successful operation of a safeguard called an independent protection layer (IPL). An IPL is a safeguard that can prevent a scenario from propagating to a consequence of concern without being adversely affected by either the initiating event or by the action (or inaction) of any other protection layer in the same scenario.

Examples of IPLs are as follows:

  • Standard operating procedures,
  • Basic process control systems,
  • Alarms with defined operator response,
  • Safety instrumented systems (SIS),
  • Pressure relief devices,
  • Blast walls and dikes,
  • Fire and gas systems, and
  • Deluge systems.

LOPA can be used at any point in the lifecycle of a project or process, but it is most cost effective when implemented during front-end loading when process flow diagrams are complete and the P&IDs are under development. For existing processes, LOPA should be used during or after the HAZOP review or revalidation. LOPA is typically applied after a qualitative hazards analysis has been completed, which provides the LOPA team with a listing of hazard scenarios with associated consequence description and potential safeguards for consideration.

The six major steps to the LOPA process are as follows:

  1. Record all reference documentation
  2. Document the process deviation and hazard scenario under consideration by the team
  3. Identify all of the initiating causes for the process deviation and determine the frequency of each initiating cause
  4. Determine the consequence of the hazard scenario
  5. List the IPLs that can completely mitigate all listed initiating causes
  6. Provide specific implementable recommendations

There are four primary benefits to implementing LOPA over other SIL assignment methodologies procedures.

  1. Due to its scenario-related focus on the process risk, LOPA often reveals process safety issues that were not identified in previous qualitative hazards analysis.
  2. Process hazards are directly connected to the safety actions that must take place, providing clear identification of the safety instrumented systems and associated SIL.
  3. It has been proven effective in resolving disagreements related to qualitative hazards analysis findings.
  4. LOPA often identifies acceptable alternatives to the SIS, such as adding other layers of protection, modifying the process, or changing procedures. This provides options for the project team to evaluate using cost/benefit analysis, allowing the most cost effective means of risk reduction to be selected.

In conclusion, LOPA allows the safety review team an opportunity to discover weaknesses and strengths in the safety systems used to protect employees, the plant, and the public.

Safety of the Plant, Surrounding People, and the Environment – QRA

Quantitative Risk Assessment (QRA) is to evaluate risks in ensuring that major risks of facilities are understood and managed within ALARP.

QRA makes sure that:

  1. The hazards and the associated risks inherent in the design and operations are systematically identified and assessed.
  2. Basis to demonstrate safety has been identified and incorporated in the design.
  3. Arrangements are in place to manage these risks to ALARP.

QRA is a quantitative risk assessment approach which shall provide information on the following:

  1. Identification of hazards and potential hazardous events
  2. Estimation of likelihood, causes, possible escalation and consequences of hazardous events and the adequacy of the mitigation measures
  3. Identification of the dominating risk contributors and appropriate risk reduction, if applicable, which can potentially reduce the risk“>risk
  4. Demonstration of risk to as low as reasonably practicable (ALARP) in accordance to risk acceptance criteria.

QRA also supports statutory compliance under the Control of Industrial Major Accident Hazards (CIMAH) 1996 Regulations by Malaysian Government Department of Occupational, Safety and Health (DOSH), and HSE Case for upstream facilities.

QRA study/review shall be carried out throughout the full lifecycle of project, facilities and operation:

  1. Design Stage
  2. Operations Stage

The QRA shall be reviewed as follows:

  1. Onshore facilities – every three (3) years as part of CIMAH report review for Major Hazard Installation.
  2. Offshore facilities – every five (5) years as part of HSE Case review.
  3. Significant changes or modification to the project, facilities and operations that has the potential to introduce new hazards.

Among the common software used for the risk modelling and analysis:

  • Safeti
  • TNO Effects and Riskcurves

QRA is important to determine the risk of a facility whether it is acceptable or not hence it is important for the facility owner to conduct QRA to ensure the safety of the facility workers, surrounding people, and the environment.

Fail to Plan is Planning to Fail!

Emergency response plan is a definite plan to deal with major emergencies.

Emergency response plan includes:

  • All possible emergencies, consequences, required actions, written procedures, and the resources available.
  • Detailed lists of emergency response personnel including their cell phone numbers, alternate contact details, and their duties and responsibilities.
  • Floor plans.
  • Large scale maps showing evacuation routes and service conduits (such as gas and water lines).

An emergency response plan specifies procedures for handling sudden or unexpected situations to:

  • Prevent fatalities and injuries.
  • Reduce damage to buildings, stock, and equipment.
  • Protect the environment and the community.
  • Accelerate the resumption of normal operations.

The emergency response plan includes the forming of an Emergency Response Team (ERT). Each of the ERT members will have specific roles and responsibilities during an emergency. ERT generally consists of:

  • Emergency Commander
  • Emergency Coordinator
  • First Line Crew / Rescue Squad
  • First Aider
  • Security Team
  • Floor Warden

Completing a comprehensive plan for handling emergencies is a major step toward preventing disasters. Exercises and drills may be conducted to practice all or critical portions (such as evacuation) of the plan. The plan should be revised when shortcomings have become known and should be reviewed at least annually.

How Maintenance Teams can Avoid the Top OSHA Violations

Everything maintenance teams need to know about OSHA, its regulations, compliance standards and how to avoid OSHA violations.

Here’s a scary stat: 85 health and safety violations were committed every day across the US in 2018. In total, there were more than 31,000 fines doled out for breaking the Occupational Safety and Health Administration’s (OSHA) top 10 health and safety violations alone.

Besides the potential for accidents, injury, and death, these fines inflicted a heavy toll on the bottom line, costing businesses over $400 million last year.

Many of the top OSHA violations have a connection to everyday maintenance tasks, especially for those working in manufacturing. Another thing they had in common? They were all preventable.

With solid planning and some helpful technology, it’s easy for maintenance teams to avoid health and safety violations while creating a better health and safety program.

What is OSHA?

OSHA is the government-run organization in charge of assuring safe and healthy working conditions for millions of public and private sector employers and workers across the US. They do this by setting and enforcing standards and by providing training, outreach, education and assistance.

What is the purpose of OSHA?

OSHA is responsible for the hefty price tags attached to noncompliance and is the organization that maintenance teams have to impress most often when it comes to health and safety audits.

OSHA regulations, OSHA compliance, and OSHA penalties

The following is a brief rundown of the rules and responsibilities mandated by OSHA and the impact of breaking these regulations.

What are employers responsible for?

Under OSHA law, employers are responsible for providing a safe and healthy workplace for their workers. Employers must provide workers with a hazard-free workplace and must follow all OSHA standards. Employers must find and correct all safety and health problems, first by changing working conditions, like switching to safer chemicals, and then by providing protective equipment.

Besides the potential for accidents, injury, and death, OSHA violations inflicted a heavy toll on the bottom line, costing businesses over $400 million last year.

Other guidelines that employers must follow include:

  • Prominently displaying official OSHA requirements, OSHA citations, and injury and illness data.
  • Informing workers about hazards in a language they can understand through training, labels, alarms, and other methods.
  • Keeping accurate records of work-related injuries and illnesses.
  • Performing tests in the workplace, such as air sampling.
  • Providing the required personal protective equipment at no cost to workers.
  • Not retaliating against workers for using their rights under the law.

These are some examples of the broad policies employers at production facilities need to follow. However, there are many OSHA regulations that apply to specific industries or in certain regions. Some examples of these standards include providing fall protection, ensuring safety in confined spaces, putting guards on dangerous machines, and providing respirators to employees.

What rights and responsibilities do workers have?

Workers also have a responsibility to attend training, ensure they report unsafe work, and follow guidelines set out by employers and OSHA. In addition to their responsibilities, workers also have several rights under OSHA laws, including:

  • The right to file a confidential complaint to have their workplace inspected.
  • The right to receive copies of the results from health and safety tests and monitoring.
  • The right to participate in an OSHA inspection and speak in private with the inspector.
  • The right to file a complaint with OSHA if they have been retaliated against by their employer.
  • The right to file a complaint if punished or retaliated against for acting as a whistleblower.

How are OSHA standards created?

OSHA standards-setting process is a multi-step activity that relies heavily on public engagement. New standards can be recommended either by OSHA itself or through third-party petitions from organizations like the National Institute for Occupational Safety and Health, state and local governments, and labour representatives.

After deciding to move forward with a new standard, OSHA often asks the public for their feedback and insight. After considering all information and testimonies, OSHA develops and issues a final standard that becomes enforceable.

What happens during an OSHA inspection?

When OSHA finds employers who are in violation of the regulations, inspections are initiated without advance notice by compliance officers. Here’s how the on-site inspections usually happen:

  • The compliance officer presents their credentials.
  • They explain why the workplace was selected for inspection and describe the inspection process, including walkaround procedures, employee representation, and employee interviews.
  • The compliance officer and facility representatives walk through the workplace, inspecting for hazards.
  • The compliance officer talks with the employer and employee representatives about their findings.
  • If no hazards or OSHA violations are found, the inspection is over. If an inspector finds violations or serious hazards, they may issue a citation and/or fine. A citation outlines methods that can be used to fix a problem and a deadline for correcting the issue, as well as the date by which the corrective actions must be completed.

What are the fines for OSHA violations?

Fines for non-compliance of OSHA regulations can vary based on the seriousness of the violation and the organization’s record and the industry. However, OSHA has outlined maximum fines, which for 2018 include $13,260 for minor and serious violations and $132,598 for willful or repeat violations.

The most common OSHA violations

Below are the 10 OSHA violations most frequently committed by workplaces in 2018:

OSHA ViolationNumber of violations in 2018
Fall Protection – General Requirements (Standard 1926.501)7,270
Hazard Communication (Standard 1910.200)4,552
Scaffolds – General Requirements (Standard 1926.451)3,336
Respiratory Protection (Standard 1910.200)3,118
Lockout/Tagout (Standard 1910.147)2,944
Ladders (Standard 1926.1053)2,812
Powered Industrial Trucks (Standard 1910.178)2,294
Fall Protection – Training Requirements (Standard 1926.503)1,982
Machine Guarding (Standard 1910.212)1,972
Personal Protective and Lifesaving Equipment – Eye and Face Protection (Standard 1926.95)1,536

How maintenance teams can prevent OSHA violations

Here are a few tools and techniques maintenance teams can use to steer clear of violating some OSHA regulations. Each of these tips can be implemented through maintenance management software, such as a CMMS.

Hazard communication

It’s never easy to tear yourself away from a job when your to-do list is a mile long. Then again, when you don’t make time for health and safety tasks, it can result in a huge fine. Over 4,500 companies faced this exact situation in 2018 after they violating the OSHA’s hazard communication standard by failing to provide proper hazard training and maintain the necessary data sheets.

OSHA is also responsible for the hefty price tags attached to noncompliance, and is the organization maintenance teams have to impress most often when it comes to health and safety audits.

Maintaining records and providing health and safety training is often a hassle, even if it’s extremely important. Having an efficient method for storing employee information can go a long way in saving you time and helping you stay compliant. Create employee profiles for everyone on the maintenance team. On each profile, list the training that person has, the dates they completed training, and the training they still need. Make sure to note deadlines for certification renewals on each profile. Create a notification system so both you and the employee are alerted about any training that is about to expire. Lastly, use these profiles to communicate any hazardous situations or changes in policy to all staff.

Lockout/tagout

Lockout/tagout violations ranked as the fifth-most-common breach of OSHA regulations during 2018, even with it being standard procedure across the maintenance and manufacturing world. Facilities were cited for failing to implement an energy control program and to provide training.

Energy control programs help maintenance staff avoid being injured by the massive amounts of hazardous energy that is often stored by equipment. Although many facilities have an energy control program, they are often not implemented properly.

One of the biggest obstacles to policy implementation is a lack of accessibility. Technicians are extremely busy and are often overwhelmed on a daily basis. If they are working on an asset, need to conduct a lockout/tagout and don’t know the proper procedure, it’s not likely that they will spend valuable time looking for the information. Making an energy control program document available digitally and accessible through a mobile device eliminates this problem, is a factor in the successful implementation and helps facilities avoid a costly OSHA violation.

Fall protection – training and general requirements

Companies were handed over 9,000 fines for inadequate fall protection in 2018, with these violations scoring top spot and eighth place on the OSHA’s list. The most common rules that were broken were failing to provide sufficient training and proper protective equipment.

Training your whole workforce might be the end goal of your fall protection plan, but it might not be realistic in the short term. However, there are a few ways employers can better manage their existing pool of trained maintenance staff to avoid violating OSHA regulations. You must be able to cross-reference work orders with staff who are certified (and who have proof of certification). The best way to do this is through a digital maintenance work order system. This system can tell you who is available and the best person to do the job, so no one is working at heights without the proper training.

Equipment for fall protection often includes harnesses, guardrails, anchors, and other, larger pieces. These items need to be maintained and stored properly. That is why a well-built inventory management system is a must for safety and to avoid OSHA violations. The ability to track where parts are stored, their history of use, and how often they’ve been maintained is crucial. It ensures that workers know where to find the proper protective equipment when they need it and that they know it will be in optimal working condition. Having a digital inventory system makes this information more accessible and creates a more efficient process.

Machine guarding

Machine guarding was another common OSHA violation in 2018, averaging 5.5 infractions per day. Inspectors cited companies for point of operation and for guards that were not attached to machines.

It’s easy to assume this violation can be avoided by simply walking around your facility, installing guards where needed and training staff to always use them when necessary. However, this isn’t a set-it-and-forget-it issue. It requires an ongoing effort to ensure guards are installed and maintained properly. A guard may rust over time, diminishing its effectiveness. An employee may remove a guard for a project and not replace it properly or at all. That is why you and your maintenance team must be diligent about machine guarding.

One way to ensure consistency with machine guarding at your facility is through automated work orders and maintenance triggers. Determining a maintenance trigger for each guard will help you plan an inspection, repair, or replacement well ahead of time. For example, a certain guard may be slated for replacement every three months. These maintenance triggers can then be scheduled using an automated work order system to ensure you’ll be alerted of upcoming maintenance or inspection for machine guards so tasks don’t fall through the cracks and leave you vulnerable to citations or fines.

Personal protective and lifesaving equipment

The last entry on the OSHA’s list of top violations is one that can apply to many maintenance activities and can have a huge impact on safety. There were over 1,500 instances of facilities failing to provide personal protection equipment (PPE) and lifesaving equipment or failing to ensure employees used them in the right situation.

PPE can vary from job to job in a facility. One maintenance task may require an individual to wear hearing protection while another may call for a dust-blocking face mask. It can be difficult for staff to remember what PPE is associated with which job, which means tasks are not always completed in the safest way (or in accordance with OSHA regulations).

Solving this problem can be as easy as attaching a checklist to each maintenance task or asset that outlines the required PPE. Not only will this standardize PPE practices at your facility, but it also reminds the staff what they should be doing. If the checklist is available in a digital format, it is even more accessible to staff, which means that the protocols are more likely to be followed.

Source: https://www.fiixsoftware.com/blog/maintenance-avoid-top-osha-violations/