Using contractors involves an outside organization that will create risk to the site company. The contractors who are unfamiliar with the facility may create process hazards to the company. Thus companies must recognize and address challenges associated with using contractors; and select contractors based on stringent criteria. Only then can the company ensure safety of all people (onsite and offsite).
Contractor management is a system of controls to ensure that contracted services support safe facility operations. This element addresses the selection, acquisition, use, and monitoring of such contracted services. Systems must be established for qualifying firms based upon not only their technical capabilities, but also their safety programs and safety records.
The boundaries of authority and responsibilities must be clearly defined for any contractor that works at the facility. Periodic monitoring of contractor safetyperformance and auditing of contractor management systems is required. After completion of the work, evaluation of the safetyperformance should help to determine whether the contractor can be used again in any future work.
Contractors are not familiar with the facility safety controls and procedures hence the company needs to train them to understand the safety controls and procedures prior to them starting their work. The company must also make contractor to aware that they treat safety seriously and the contractors must adhere to all safety rules, guidelines, procedures, etc. while performing their job. Training must be provided to contractors if they are handling critical tasks that may create major process safety hazards.
Don’t treat contractor management as a petty issue, it can create process safety hazards if it is not well managed.
How to use Process Safety Analysis to the benefit of your process plant?
What is Process Hazard Analysis (PHA)? A PHA is required for any industrial process that makes use of hazardous chemicals. Its purpose is to identify the significance of scenarios (potential causes and consequences) that could result in fires, explosions, chemical spills and the release of toxic chemicals. It focuses on factors that might affect the process (equipment, instrumentation, utilities, human actions (routine and non-routine), and external factors).
Steps in the PHA Process
Methods for Conducting the PHA:
What-if Study – for review of an uncomplicated processes;
Checklist – for a more complicated process using a checklist;
Hazard and Operability Study (HAZOP) – a structured method to analyze possible deviations in design conditions;
Failure Mode and Effects Analysis (FMEA) – a systematic study of component failures that could conceivably affect the safety of the operation;
Fault Tree Analysis – either a qualitative or a quantitative model of all the undesirable outcomes, that could result from a specific initiating event; or
An appropriate equivalent method.
The process hazard analysis is best performed by a team with expertise in engineering and process operations. The PHA team should include:
Employees who have experience with and knowledge of the process being evaluated; and
Team leader who has knowledgeable in the specific PSM analysis methodology being used in the evaluation.
It is advised that, at least every five years after the completion of the initial process hazard analysis or whenever there is a change in process, the process hazard analysis must be updated and revalidated by a qualified team to ensure that the hazard analysis is consistent with the current process.
The objective of a Management of Change (MOC) program is to ensure all changes to a process are properly reviewed and hazards introduced by the change are identified, analyzed, and controlled prior to resuming operation.
It is also one of the 14 elements of Process Safety Management.
MOC is important for every change because there are many details, and questions that maintenance and engineering have to answer satisfactorily to make this a safe process. Prior to any change, the following are considered:
Authorization requirements for the proposed change.
The MOC element helps to ensure that changes to a process do not inadvertently introduce new hazards or increase risk of existing hazards. It also includes steps to help to ensure that potentially affected personnel are notified of the change and that pertinent documents, such as procedures, etc. are kept up–to-date.
Why is MOC important?
Because if a proposed modification is made to a hazardous process without an appropriate review, the risk of a process safety accident could increase significantly.
Where/When is it done?
MOC reviews are conventionally done in operating plants and increasingly done throughout the process life cycle of a plant
Who does it?
An employee or stake holder originates a change request. Qualified personnel will then review the request to determine if any potentially adverse risk impacts could result from the change, and may suggest additional measures to manage risk. Based on outcome of the review, the change is either authorized for execution, amended, or rejected. Often, final approval for implementing the change comes from another designated individual, independent of the reviewers. Many personnel are normally involved in making the change, notifying or training potentially affected employees, and updating documents affected by the change.
Organizations usually have written procedures detailing on how MOC will be implemented. The change can be implemented once the change is approved. Potentially affected personnel are informed of the change and/or provided with more detailed training, as necessary, prior to the change taking place.
Higher risk situations usually needs greater for formality and thoroughness in the implementation of a MOC protocol. Facilities with an evolving or weaker process safety culture may require more prescriptive MOC procedures, more frequent training, and greater command and control management system features to ensure good MOC implementation discipline.
So, is your company equipped with a robust MOC system and procedures? It is time to consider and implement a good safety culture by introducing MOC system or improve your current MOC practice so that it can directly or indirectly reduce process hazards.
Well, Process Safety Management (PSM) is the proactive identification, evaluation and mitigation or prevention of chemical releases that could occur as a result of failures in processes, procedures, or equipment (OSHA, U.S.). When applied correctly, process safety management could aid to prevent fires, explosions and the release of hazardous chemicals that could pose a safetyrisk to workers or the general public.
Let’s understand briefly and go through each of the 14 elements of PSM!
Employee is the human asset of the company and they are also the ones to determine the safety of a plant. Hence employee participation in PSM programs are important. Employee participation is for employees, production, maintenance, and staff to be involved in all aspects of the PSM program at your site, and to have representation in the development, discussion, and eventual solution to issues around the process hazard analysis.
According to OSHA’s PSM mandates, “The employer shall complete a compilation of written process safety information before conducting any process safety hazard analysis required by the standard.” It means that all workers should be able to access and understand the technical data regarding the highly-hazardous-chemicals-related risks they face on the job.
Process Hazard Analysis
Process Hazard Analysis requires that engineers and maintenance leaders analyze the consequences of safety failures. This process analysis will be conducted as a team and includes at least one person “who has experience and knowledge specific to the process being evaluated” and is “knowledgeable in the specific process hazard analysis methodology being used.”
Startups following a turnaround, and after an emergency shutdown is included in this element. Standard Operating Procedures of these events should be documented and practiced by the operation and maintenance team.
Contractors must be well-informed of the hazards they face. Under the PSM National Emphasis Program, “The employer, when electing a contractor, shall obtain and evaluate information regarding the contract employer’s safetyperformance and programs. The employer shall inform contract employers of the known potential fire, explosion or toxic release hazards related to the contractor’s work and the process.”
Pre-startup Safety Review
OSHA expects employers to perform pre-startup safety reviews for both new and modified facilities even for a change in a single component.
Periodic, documented inspections are required for several systems, including pressure vessels and storage tanks, piping systems, relief and vent systems and devices, pumps, controls, etc. The inspectors conducting these inspections must not only be officially trained, their testing procedures must follow “recognized and generally accepted good engineering practices,” according to OSHA.
Hot Work Permit
Every employer needs to issue permits to employees and contractors who perform high-temperature work (e.g. welding) near covered processes. They also need to train their personnel to post and file these permits.
Management of Change
Many organizations choose to issue an MOC for every change because there are many details, and questions that maintenance and engineering have to answer satisfactorily to make this a safe process. Prior to any change, the following are considered:
Authorization requirements for the proposed change
An investigation is performed into all incidents that result in, or could reasonably have resulted in, a catastrophic release of highly hazardous chemicals (HHC).
Emergency Planning and Response
It requires employers to establish and implement an emergency action plan, including a plan to handle small releases.
According to the PSM-NEP, “Employers 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.” It is also a requirement to retain the last two most recent audit reports.
Some companies attempted to protect proprietary information by keeping process details from their employees. To enhance worker safety, the “trade secrets” which may affect their health and safety are divulged to the workers.
Now that you have the basic knowledge about the 14 elements of PSM, find out how to manage them!