Manual Conduct of Operations and Operational Discipline: For Improving Process Safety in Industry

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CTX Critical to Expectations are even more detailed practices at the site level. The table below provides a count of each layer of the model underneath a specific OE driver. RT examined more than 70 actual assessments to document a quantifiable decrease in the awareness of safety policies, procedures, and practices from the corporate level to the site level of an organization. The figure below outlines the existence of safety programs in the safety drivers around the perimeter.

Higher scores indicate that the respondents believe that those programs are strong. The red line indicates the corporate responses, the blue line is the project responses, and the green line is the site responses. This divergence from corporate to site is especially pronounced in a leadership development program, and just and fair practices and procedures. Reference: RSa. By drawing on a prioritization exercise, RT made this task more manageable.

The results of an Analytic Hierarchy Process AHP indicate which areas of a safety program can have the most immediate impact. This is not to say that items at the bottom of the table are unimportant but, rather, that the areas at the top should receive the first investigation. Research Publications. View Details Order Now. Presentations from CII Events. These process hazard analyses can be done in less time and with fewer people being involved.

Many small businesses have processes that are not unique, such as refrigerated warehouses or cold storage lockers or water treatment facilities. Where employer associations have a number of members with such facilities, a generic PHA, evolved from a checklist or what-if questions, could be developed and effectively used by employers to reflect their particular process; this would simplify compliance for them. When the employer has a number of processes that require a PHA, the employer must set up a priority system to determine which PHAs to conduct first.

A preliminary hazard analysis may be useful in setting priorities for the processes that the employer has determined are subject to coverage by the process safety management standard. Consideration should be given first to those processes with the potential of adversely affecting the largest number of employees.

This priority setting also also should consider the potential severity of a chemical release, the number of potentially affected employees, the operating history of the process, such as the frequency of chemical releases, the age of the process, and any other relevant factors. Together, these factors would suggest a ranking order using either a weighting factor system or a systematic ranking method. The use of a preliminary hazard analysis will assist an employer in determining which process should be of the highest priority for hazard analysis resulting in the greatest improvement in safety at the facility occurring first.

Detailed guidance on the content and application of process hazard analysis methodologies is available from the American Institute of Chemical Engineers' Center for Chemical Process Safety, E. Also, see the discussion of various methods of process hazard analysis contained in the Appendix to this publication. Operating Procedures Operating procedures describe tasks to be performed, data to be recorded, operating conditions to be maintained, samples to be collected, and safety and health precautions to be taken.

The procedures need to be technically accurate, understandable to employees, and revised periodically to ensure that they reflect current operations. The process safety information package helps to ensure that the operating procedures and practices are consistent with the known hazards of the chemicals in the process and that the operating parameters are correct.

Operating procedures should be reviewed by engineering staff and operating personnel to ensure their accuracy and that they provide practical instructions on how to actually carry out job duties safely. Also the employer must certify annually that the operating procedures are current and accurate. Operating procedures provide specific instructions or details on what steps are to be taken or followed in carrying out the stated procedures. The specific instructions should include the applicable safety precautions and appropriate information on safety implications.

For example, the operating procedures addressing operating parameters will contain operating instructions about pressure limits, temperature ranges, flow rates, what to do when an upset condition occurs, what alarms and instruments are pertinent if an upset condition occurs, and other subjects. Another example of using operating instructions to properly implement operating procedures is in starting up or shutting down the process.

In these cases, different parameters will be required from those of normal operation. These operating instructions need to clearly indicate the distinctions between startup and normal operations, such as the appropriate allowances for heating up a unit to reach the normal operating parameters. Also, the operating instructions need to describe the proper method for increasing the temperature of the unit until the normal operating temperatures are reached. Computerized process control systems add complexity to operating instructions. These operating instructions need to describe the logic of the software as well as the relationship between the equipment and the control system; otherwise, it may not be apparent to the operator.

Operations/Operational Discipline | OS

Operating procedures and instructions are important for training operating personnel. The operating procedures are often viewed as the standard operating practices SOPs for operations. Control room personnel and operating staff, in general, need to have a full understanding of operating procedures. If workers are not fluent in English, then procedures and instructions need to be prepared in a second language understood by the workers.

In addition, operating procedures need to be changed when there is a change in the process. The consequences of operating procedure changes need to be fully evaluated and the information conveyed to the personnel. For example, mechanical changes to the process made by the maintenance department like changing a valve from steel to brass or other subtle changes need to be evaluated to determine whether operating procedures and practices also need to be changed.

All management of change actions must be coordinated and integrated with current operating procedures, and operating personnel must be alerted to the changes in procedures before the change is made. When the process is shut down to make a change, then the operating procedures must be updated before re-starting the process. Training must include instruction on how to handle upset conditions as well as what operating personnel are to do in emergencies such as pump seal failures or pipeline ruptures. Communication among operating personnel and workers within the process area performing nonroutine tasks also must be maintained.

The hazards of the tasks are to be conveyed to operating personnel in accordance with established procedures and to those performing the actual tasks. When the wok is completed, operating personnel should be informed to provide closure on the job. Employee Training All employees, including maintenance and contractor employees involved with highly hazardous chemicals, need to fully understand the safety and health hazards of the chemicals and processes they work with so they can protect themselves, their fellow employees, and the citizens of nearby communities.

However, additional training in subjects such as operating procedures and safe work practices, emergency evacuation and response, safety procedures, routine and nonroutine work authorization activities, and other areas pertinent to process safety and health need to be covered by the employer's training program. In establishing their training programs, employers must clearly identify the employees to be trained, the subjects to be covered, and the goals and objectives they wish to achieve. The learning goals or objectives should be written in clear measurable terms before the training begins.

These goals and objectives need to be tailored to each of the specific training modules or segments. Employers should describe the important actions and conditions under which the employee will demonstrate competence or knowledge as well as what is acceptable performance. Hands-on training, where employees actually apply lessons learned in simulated or real situations, will enhance learning. For example, operating personnel, who will work in a control room or at control panels, would benefit by being trained at a simulated control panel.

Upset conditions of various types could be displayed on the simulator, and then the employee could go through the proper operating procedures to bring the simulator panel back to the normal operating parameters. A training environment could be created to help the trainee feel the full reality of the situation but under controlled conditions. This type of realistic training can be very effective in teaching employees correct procedures while allowing them also to see the consequences of what might happen if they do not follow established operating procedures.

Other training techniques using videos or training also can be very effective for teaching other job tasks, duties, or imparting other important information. An effective training program will allow employees to fully participate in the training process and to practice their skills or knowledge. Employers need to evaluate periodically their training programs to see if the necessary skills, knowledge, and routines are being properly understood and implemented by their trained employees.

The methods for evaluating the training should be developed along with the training program goals and objectives. Training program evaluation will help employers to determine the amount of training their employees understood and whether the desired results were obtained. If, after the evaluation, it appears that the trained employees are not at the level of knowledge and skill that was expected, the employer should revise the training program, provide retraining, or provide more frequent refresher training sessions until the deficiency is resolved.

Those who conducted the training and those who received the training also should be consulted as to how best to improve the training process. If there is a language barrier, the language known to the trainees should be used to reinforce the training messages and information. Careful consideration must be given to ensure that employees, including maintenance and contract employees, receive current and updated training.

For example, if changes are made to a process, affected employees must be trained in the changes and understand the effects of the changes on their job tasks. Additionally, as already discussed, the evaluation of the employee's absorption of training will certainly determine the need for further training. Contractors Employers who use contractors to perform work in and around processes that involve highly hazardous chemicals have to establish a screening process so that they hire and use only contractors who accomplish the desired job tasks without compromising the safety and health of any employees at a facility.

For contractors whose safety performance on the job is not known to the hiring employer, the employer must obtain information on injury and illness rates and experience and should obtain contractor references. In addition, the employer must ensure that the contractor has the appropriate job skills, knowledge, and certifications e. Contractor work methods and experience should be evaluated.

For example, does the contractor conducting demolition work swing loads over operating processes or does the contractor avoid such hazards? Maintaining a site injury and illness log for contractors is another method employers must use to track and maintain current knowledge of activities involving contract employees working on or adjacent to processes covered by PSM. Injury and illness logs of both the employer's employees and contract employees allow the employer to have full knowledge of process injury and illness experience. This log contains information useful to those auditing process safety management compliance and those involved in incident investigations.

Contract employees must perform their work safely. Considering that contractors often perform very specialized and potentially hazardous tasks, such as confined space entry activities and nonroutine repair activities, their work must be controlled while they are on or near a process covered by PSM. A permit system or work authorization system for these activities is helpful for all affected employers. The use of a work authorization system keeps an employer informed of contract employee activities.

Thus, the employer has better coordination and more management control over the work being performed in the process area. A well-run and well-maintained process, where employee safety is fully recognized, benefits all of those who work in the facility whether they are employees of the employer or the contractor. Pre-Startup Safety Review For new processes, the employer will find a PHA helpful in improving the design and construction of the process from a reliability and quality point of view. The safe operation of the new process is enhanced by making use of the PHA recommendations before final installations are completed.

The initial startup procedures and normal operating procedures must be fully evaluated as part of the pre-startup review to ensure a safe transfer into the normal operating mode.

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For existing processes that have been shutdown for turnaround or modification, the employer must ensure that any changes other than "replacement in kind" made to the process during shutdown go through the management of change procedures. If the changes made to the process during shutdown are significant and affect the training program, then operating personnel as well as employees engaged in routine and nonroutine work in the process area may need some refresher or additional training. Any incident investigation recommendations, compliance audits, or PHA recommendations need to be reviewed to see what affect they may have on the process before beginning the startup.

Mechanical Integrity of Equipment Employers must review their maintenance programs and schedules to see if there are areas where "breakdown" is used rather than the more preferable on-going mechanical integrity program. Equipment used to process, store, or handle highly hazardous chemicals has to be designed, constructed, installed, and maintained to minimize the risk of releases of such chemicals.

This requires that a mechanical integrity program be in place to ensure the continued integrity of process equipment. Elements of a mechanical integrity program include identifying and categorizing equipment and instrumentation, inspections and tests and their frequency; maintenance procedures; training of maintenance personnel; criteria for acceptable test results; documentation of test and inspection results; and documentation of manufacturer recommendations for equipment and instrumentation.

Process Defenses The first line of defense an employer has is to operate and maintain the process as designed and to contain the chemicals. This is backed up by the second line of defense which is to control the released chemicals through venting to scrubbers or flares, or to surge or overflow tanks designed to receive such chemicals. This also would include fixed fire protection systems like sprinklers, water spray, or deluge systems, monitor guns, dikes, designed drainage systems, and other systems to control or mitigate hazardous chemicals once an unwanted release occurs.

Written Procedures The first step of an effective mechanical integrity program is to compile and categorize a list of process equipment and instrumentation to include in the program.

by CCPS (Center for Chemical Process Safety)

This list includes pressure vessels, storage tanks, process piping, relief and vent systems, fire protection system components, emergency shutdown systems and alarms, and interlocks and pumps. For the categorization of instrumentation and the listed equipment, the employer should set priorities for which pieces of equipment require closer scrutiny than others. Inspection and Testing The mean time to failure of various instrumentation and equipment parts would be known from the manufacturer's data or the employer's experience with the parts, which then influence inspection and testing frequency and associated procedures.

Also, applicable codes and standards-such as the National Board inspection Code, or those from the American Society for Testing and Materials, American Petroleum Institute, National Fire Protection Association, American National Standards institute, American Society of Mechanical Engineers, and other groups-provide information to help establish an effective testing and inspection frequency, as well as appropriate methodologies. The applicable codes and standards provide criteria for external inspections for such items as foundation and supports, anchor bolts, concrete or steel supports, guy wires, nozzles and sprinklers, pipe hangers, grounding connections protective coatings and insulation, and external metal surfaces of piping and vessels.

These codes and standards also provide information on methodologies for internal inspection and a frequency formula based on the corrosion rate of the materials of construction.

Process Safety: Walk The Line

Also, internal and external erosion must be considered along with corrosion effects for piping and valves. Where the corrosion rate is not known, a maximum inspection frequency is recommended methods of developing the corrosion rate are available in the codes.

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Internal inspections need to cover items such as the vessel shell, bottom and head; metallic linings; nonmetallic linings; thickness measurements for vessels and piping; inspection for erosion, corrosion, cracking and bulges; internal equipment like trays, baffles, sensors ad screens for erosion, corrosion or cracking and other deficiencies.

Some of these inspections may be performed by state or local government inspectors under state and local statutes. However, each employer must develop procedures to ensure that tests and inspections are conducted properly and that consistency is maintained even where different employees may be involved. Appropriate training must be provided to maintenance personnel to ensure that they understand the preventive maintenance program procedures, safe practices, and the proper use and application of special equipment or unique tools that may be required.

This training is part of the overall training program called for in the standard. Quality Assurance A quality assurance system helps ensure the use of proper materials of construction, the proper fabrication and inspection procedures, and appropriate installation procedures that recognize field installation concerns. The quality assurance program is an essential part of the mechanical integrity program and will help maintain the primary and secondary lines of defense designed into the process to prevent unwanted chemical releases or to control or mitigate a release.

Equipment installation jobs need to be properly inspected in the field for use of proper materials and procedures and to ensure that qualified craft workers do the job. The use of appropriate gaskets, packing, bolts, valves, lubricants and welding rods needs to be verified in the field. Also, procedures for installing safety devices need to be verified, such as the torque on the bolts on rupture disc installations, uniform torque on flange bolts, and proper installation of pump seals.

If the quality of parts is a problem, it may be appropriate for the employer to conduct audits of the equipment supplier's facilities to better ensure proper purchases of required equipment suitable for intended service. Any changes in equipment that may become necessary will need to be reviewed for management of change procedures. Nonroutine Work Authorizations Nonroutine work conducted in process areas must be controlled by the employer in a consistent manner. The hazards identified involving the work to be accomplished must be communicated to those doing the work and to those operating personnel whose work could affect the safety of the process.

A work authorization notice or permit must follow a procedure that describes the steps the maintenance supervisor, contractor representative, or other person needs to follow to obtain the necessary clearance to start the job. This procedure also must provide clear steps to follow once the job is completed to provide closure for those that need to know the job is now completed and that equipment can be returned to normal.

Safety Performance through Operational Discipline

Managing Change To properly manage changes to process chemicals, technology, equipment and facilities, one must define what is meant by change. In the process safety management standard, change includes all modifications to equipment, procedures, raw materials, and processing conditions other than "replacement in kind. For example, the operating procedures contain the operating paramaters pressure limits, temperature ranges, flow rates, etc. While the operator must have the flexibility to maintain safe operation within the established parameters, any operation outside of these parameters requires review and approval by a written management of change procedure.

Management of change also covers changes in process technology and changes to equipment and instrumentation. Alarm Management. Performance Management.

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Relief Device Management. Operator Rounds. Incident Mobile. Inspection Mobile. Condition Assessment.