Hazardous Industries:

Process Safety Standard Requirements Help Mitigate Risk

In hazardous industries, an important and complex topic is risk and how to reduce it. Companies operating hazardous processes know all too well the risks associated with highly hazardous chemicals. The potential for an accidental release of these chemicals can occur at any time if they are not properly controlled.

That’s why all facility personnel working in hazardous areas must be informed and trained on the safety and health hazards of chemicals and procedural requirements and expectations, such as operating procedures, safe work practices, emergency response and evacuation, and other areas pertinent to the work areas, which fall under a process safety management (PSM) system. They must also be kept up to date on any changes made to any procedures or processes.

Emphasis must be placed on PSM measures and guidelines, including adherence to standards, such as the Occupational Safety and Health Administration (OSHA) 29 CFR 1910.119 – Process Safety Management of Highly Hazardous Chemicals, which contains requirements for managing highly hazardous chemicals.

The OSHA standard emphasizes how to manage the hazards and lists 14 safety requirements relating to PSM:

1.  Employee Participation
2.  Process Safety Information
3.  Process Hazards Analysis
4.  Operating Procedures
5.  Training
6.  Contractors
7.  Pre-Startup Safety Review
8.  Mechanical Integrity (instrument only, installation, calibration, testing)
9.  Hot Work Permits
10. Management of Change
11. Incident Investigation
12. Emergency Planning and Response
13. Compliance Audits
14. Trade Secrets

For our purposes here, we will cover six of these key safety requirements that help mitigate risk in hazardous industries.

1. Process Safety Information

As a priority in understanding potential hazards in a facility, companies must first develop and maintain documentation to identify chemical and process safety hazards along with the equipment and technology used in their processes. Companies are required to provide a list of the following three areas that include, but are not limited to, certain elements:

  • Information on highly hazardous chemicals – toxicity data; permissible exposure limits; reactivity data; corrosivity data; physical data; thermal and chemical stability data; chemical incompatibility data.
  • Technology documentation – up-to-date process descriptions, including written procedures, block flow diagrams or simplified process flow diagrams; special concerns relating to process chemistry; maximum intended inventory; safe operating ranges (upper and lower limits) for such items as temperatures, pressures, flows or compositions; and an evaluation of the consequences of deviations, including those affecting the safety and health of personnel.
  • Process equipment information – materials of construction (including protective coatings); piping and instrument diagrams (P&IDs); electrical classifications of equipment; relief system design and design basis; sampling systems; ventilation system design; design codes and standards used; material and energy balances; safety systems such as interlocks, detection, or suppression systems.

2. Process Hazards Analysis (PHA)

A workplace hazard assessment is another requirement. A PHA helps identify, evaluate, and control hazards in processes that involve hazardous chemicals. Facilities must evaluate the hazards in operating a given process unit. A PHA/hazard and operability (HAZOP) study or other audit must be performed to determine any safety-related issues or to identify those situations or potential system failures that could happen to cause an accident or issue.

Adherence to one or more of the following methods is required to help determine and evaluate hazards in processes:

  • What-if
  • Checklist
  • Failure mode and effects analysis (FMEA)
  • Fault tree analysis
  • Appropriate equivalent methodology

The PHA process is not an easy task and often requires external help from a third-party facilitator or an engineering consultant with broad industry experience in process operations and the specific evaluation and analysis methods used. They can help divide a facility into sections and address each process unit at a time, identifying hazards and the potential events that could cause injuries and costly damage to critical systems. For a PSM program, OSHA requires process hazard analyses, updates and recommended resolutions for each process be ongoing, documented and readily available.

3. Operating Procedures

The operating procedures must be developed and clearly communicated company-wide to ensure personnel perform and implement all activities properly and safely. The procedures also must be consistent with the process safety information requirements and best practices must be applied. The procedures should be kept up-to-date and emphasize each operating phase, including:

  • Initial startup
  • Normal operation
  • Temporary operation
  • Emergency operations, including emergency shutdowns, conditions under which to declare a shutdown, and assignment of shutdown responsibility startup following a turnaround or after an emergency shutdown

Personnel must also have up-to-date documentation on all safety and health considerations.

4. Management of Change

Management of change (MOC) is a set of best practices that helps protect personnel from injury or illness in hazardous industries. MOC procedures are used to manage changes to process chemical technology, equipment and facility processes. These procedures are kept up-to-date and communicated to personnel who must be trained on all as early as possible prior to any equipment implementation.

The following information must be provided, reviewed and approved by key personnel (typically a cross-functional team) prior to any changes and include:

  • Technical basis for the change
  • Impact of the change on personnel safety and health
  • Modifications to operating procedures
  • Necessary time period for the change

5. Pre-Startup Safety Review

Prior to introducing hazardous materials into a process area, documentation must indicate that a pre-startup safety review was conducted confirming:

  • Construction is in accordance with design specifications.
  • Safety, operating, maintenance, and emergency procedures are in place and are adequate.
  • PHA recommendations have been addressed and actions necessary for startup have been completed.
  • Operating procedures are in place and each operating employee has been trained.
  • The review team’s acceptance that the process is ready to be released to operations.

6. Mechanical Integrity (instrument only, installation, calibration, testing)

Industrial companies must maintain written procedures about the ongoing integrity of critical process equipment. This ensures the equipment is properly designed, installed, and operated safely.

These PSM requirements apply to the following components and equipment:

  • Piping systems (including components, valves)
  • Pressure vessels and storage tanks
  • Relief and vent systems and devices
  • Controls (monitoring devices, alarms, sensors, interlocks)
  • Emergency shutdown systems
  • Pumps

Personnel who are involved in any activity or task related to the process must understand the procedures and associated hazards and be trained on all. The equipment must be inspected and tested using the procedures and good engineering best practices. The frequency of inspections/tests shall be consistent with applicable codes and standards, or more frequently if operating experience so dictates.

By following best practices and standards requirements, you can minimize risk and protect individuals working in and around hazardous areas. No matter the task or the industry, on-the-job safety must encompass every aspect of your daily work preparation, through and extending beyond a job’s completion.

Be safe!