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Todd B. Jekel

Spirit of PSSRR i f 1910 119(i)Review of 1910.119(i)Linkage with other elements of the standardReview of OSHA-issued interpretations related to PSSRsrelated to PSSRs Recommendations from CCPS & others

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A comprehensive, documented reviewof the design & construction of newof the design & construction of new and modifications to covered processes to verify that they are acceptable and the PSM requirements are in place prior to using the process.

A quality assurance process intended toi t d d h d i t d d◦ assure no unintended hazards are introduced

◦ assure risks are properly evaluated & minimized◦ be exercised during

the life of the project& l t d b f& completed beforechanges areimplemented

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Regulatory [1910.119(i)]

New construction & process expansion is partNew construction & process expansion is part of the life of most plantsWe cannot overlook the value of a functioning PSSR program◦ Quality assurance check of MOC

Easily is short changed in the rush of getting the◦ Easily is short changed in the rush of getting the project up-and-running to make & store product

“OSHA believes that one of the most important and necessary aspects of aimportant and necessary aspects of a process safety management program is appropriately managing changes to the process.”◦ So important that PSSR is built around

monitoring the quality of the MOC process

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Reference: 1910.119(i)

PSSRPolicy

ABC Foods, Inc.

(1) 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 g g q gin the process safety information

Reference: 1910 119(i)Reference: 1910.119(i)(2) The pre-startup safety

review shall confirm that prior to the introduction of highly hazardous chemicals to a process:(i) Construction and equipment is in accordance(i) Construction and equipment is in accordance

with design specifications;(ii) Safety, operating, maintenance, and

emergency procedures are in place and are adequate;

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Reference: 1910.119(i)(2) cont.

(iii) For new facilities, a process hazard analysis has been performed and recommendations have been resolved or implemented before startup; and modified facilities meet the requirements contained in management of change, 1910.119(l).

(iv) Training of each employee involved in operating a process has been completed.

Note references these other sections of the PSM Standardsections of the PSM Standard

◦ Process safety information (d)◦Operating procedures (f)◦ PHA (e)◦ PHA (e)◦MOC (l)◦ Training (g)

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Reference: 1910.119(i)

(1) 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 g g q gin the process safety information

It seems pretty straight forward…do we even need a definition of “significant?”

“ i h i f◦ “…require a change in process safety information”

◦ Pretty broad definition. What constitutes a “change”?

Is any addition to PSI a change?Can you think of a change that is not “significant” but does change PSI?but does change PSI?

MOC process◦ Does your MOC form have a checkbox to

indicate whether or not the change requires PSSR?

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Chemical informationTechnology information◦ Block flow & P&IDs◦ Inventory◦ Safe limits (pressures, temperatures, flows, …)◦ Consequences of deviationEquipment information◦ Materials of construction◦ Electrical classification◦ Safety system designs (relief, ventilation, interlocks,

detection systems, emergency shutdowns, etc.)◦ Material and energy balances

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

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Description Yes No

Plant expansion in a facility that will raise inventory f h i l b TQof chemical above TQ

Adding an additional identical evaporator to an existing cold space

Adding plate pairs to a plate-frame evaporator

Replacing a Hansen HA4A regulator with an R/S A4ABringing an evaporator back online after cleaning aBringing an evaporator back online after cleaning a strainerBringing a compressor back online after changing to a different coalescing filter

Recommendation: Include a number of examples of changes that areof examples of changes that are considered “significant” (i.e. trigger events) as-defined in your program and consistent with the requirements of 1910.119

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Process Hazard Analysis

Operating

Employee Participation

Incident Investigation

DesignProcess

p gProcedures

Training

PSSR

PSMProcess

MOC

Process Safety

InformationMechanical

Integrity

Contractors

PSSR

Compliance Audits Emergency

Planning

Process Safety

Information

Process Hazard Analysis

Operating

MOC

Operating Procedures

Training

Employee Participation

PSSRCompliance

Audits

Mechanical Integrity

ContractorsIncident

InvestigationEmergencyPlanning

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Appropriate personnel should be included (team for large projects)included (team for large projects)

Personnel Verifies & signs off onPSM coordinator None (ideally)Maintenance supervisor or staff

Operating procedures

Engineering manager PSI, MOC, Design/construction specifications

Safety director/representative TrainingPurchasing representative Receipt of specified materialsPlant manager MOCCorporate engineer PHA

Note: whomever signs off is the person verifying theappropriate changes have been made

Corporate or plant personnel?◦ May depend on the size of the projectj

Desirable characteristics for PSSR leader◦ Is independent of the work being done,◦ Is knowledgeable of the process, and◦ Sees value in QA’ing the project?

Do you have anyone within your plant utility department’s hierarchy that qualifies?◦ Will likely require a team approach

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Number of issues with startup◦ Safety issues are more important than operability

issues

Number of PSSRs compared to MOCs on a yearly basis

If you have short & long form PSSR monitorIf you have short- & long-form PSSR, monitor◦ Short- vs. Long-form ratio◦ Random sample short-form PSSRs to assure

reasonableness of using short-form

OSHA-Identified Common PSSR ProblemsProblems◦ Not done before introduction of ammonia◦ Not done by competent personnel◦ Construction documents not used as the

basis of the Pre-Startup Safety Reviewp y◦ P&ID’s not current when the Pre-Startup

Safety review is performed

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Tolley – 1996What changes are significant enough to be◦ What changes are significant enough to be called a “new” facility?

…a "facility" means buildings, containers and equipment which contain a process. A facility constructed on a work site where there are no other facilities is considered a new facility.

d d ld b l bl " f l d…PSSR standard would be applicable to "new facilities and to modified facilities which contain a covered process", that is, a process in which (at any one point in time) there is a threshold quantity or great amount of a HHC.

Identify events that should trigger PSSRHave multiple level of PSSRs (simple → complex)Have multiple level of PSSRs (simple → complex)◦ Risk based determination of complexityAudit PSSR process to streamline future PSSRsPSSR team◦ Broad involvement to steep PSSR into plant “culture” &

i l ti i tiinsure employee participation◦ Independent of specific project or subproject

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Increased Severity of Event

Low Serious Catastrophic

High Medium Higher HigherIncre

Moderate Lower Medium Higher

Low Lower Lower Medium

eased Likelihoodof Event

Lower Risk◦ Use short-form or simple PSSR◦ Simple PSSR is not “less important”, just lower level

of effort

Higher Risk◦ Use long-form PSSR◦ Increase effort & sign-offIncrease effort & sign off

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Project cost greater than $X◦ Tied to corporate capital request rulesNew type of equipment or chemicals (first application on site)Three or more piping tie-in pointsNew control systems or modification to controls that could affect safety controls or interlocksFire protection system changesReuse of used or previously mothballed equipment

Could an RIK that involves the shutdown of the system or a portion of the system be y p ysubject to a PSSR?

Said another way, could a PSSR be utilized for an RIK requiring shutdown?◦ Simplified checklist to insure

th t i t d ithat maintenance procedure isfollowed

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Move (or extend) some aspects of review to post startupp p◦ Operability issues◦ Hearing protection◦ Controls commissioning◦ Functional testing of safeties & interlocks (if able)

Integrate verification into MOC process◦ Need to be able to separate MOC & PSSR for auditing, etc.Require more than simply “check & sign”◦ Document list & versions reviewed, etc.Review the use of PSSR within your facilities during a compliance audit◦ If PSSR is not consistently used, investigate why bypassed

& propose changes to the process to increase useConsider additional focused PSSRs that provide QA ofConsider additional, focused PSSRs that provide QA of maintenance & SOPs◦ Integrated into operating procedure revalidation, OJT or

supervision/review