10/7/2008

Todd B. Jekel

` Spirit of PSSR
` R i
Review off 1910
1910.119(i)
119(i)
` Linkage with other elements of the
standard
` Review of OSHA-issued interpretations
related to PSSRs
` Recommendations from CCPS & others

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 10/7/2008

` A comprehensive, documented review

of 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 to

◦ assure no unintended
i t d dh hazards
d are iintroduced
t d d
◦ assure risks are properly evaluated &
minimized
◦ be exercised during
the life of the project
& completed
l t d before
b f
changes are
implemented

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 10/7/2008

` Regulatory [1910.119(i)]
` New construction & process expansion is part
of the life of most plants
` We cannot overlook the value of a functioning
PSSR program
◦ Quality assurance check of MOC
◦ 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 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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 10/7/2008

PSSR
Policy

Reference: 1910.119(i) 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
g enough
g to require
q a change
g
in the process safety information

Reference: 1910.119(i)
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
with design specifications;
(ii) Safety, operating, maintenance, and
emergency procedures are in place and are
adequate;

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 10/7/2008

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 Standard

◦ Process safety information (d)

◦ Operating procedures (f)
◦ PHA (e)
◦ MOC (l)
◦ Training (g)

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 10/7/2008

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
g enough
g to require
q a change
g
in the process safety information

` It seems pretty straight forward…do we even

need a definition of “significant?”
◦ “…require
“ i a change
h in
i process safety
f
information”
◦ Pretty broad definition. What constitutes a
“change”?
x Is any addition to PSI a change?
x Can you think of a change that is not “significant”
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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 10/7/2008

` Chemical information
` Technology information
◦ Block flow & P&IDs
◦ Inventory
◦ Safe limits (pressures, temperatures, flows, …)
◦ Consequences of deviation
` Equipment 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 prepre-startup

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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 10/7/2008

Description Yes No
Plant expansion in a facility that will raise inventory
off chemical
h i l above
b 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 A4A

Bringing an evaporator back online after cleaning a
strainer
Bringing a compressor back online after changing to
a different coalescing filter

` Recommendation: Include a number

of 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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 10/7/2008

Incident Process
Investigation Hazard
Employee Analysis
Participation

Operating
p g
MOC Procedures

Training
PSM Design
Process Process

PSSR

Contractors

Compliance
Audits Process
Emergency Mechanical
Safety
Planning Integrity
Information

Process
Process Hazard
Safety Analysis
Information
Operating
Employee Procedures
Participation

MOC
Training
Compliance
Audits PSSR

Contractors
Incident
Investigation
Mechanical Emergency
Integrity Planning

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 10/7/2008

` Appropriate personnel should be

included (team for large projects)
Personnel Verifies & signs off on
PSM coordinator None (ideally)
Maintenance supervisor or Operating procedures
staff
Engineering manager PSI, MOC, Design/construction
specifications
Safety director/representative Training
Purchasing representative Receipt of specified materials
Plant manager MOC
Corporate engineer PHA
Note: whomever signs off is the person verifying the
appropriate changes have been made

` Corporate or plant personnel?

◦ May depend on the size of the project
j

` 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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 10/7/2008

` 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-

short & long
long-form
form PSSR
PSSR, monitor
◦ Short- vs. Long-form ratio
◦ Random sample short-form PSSRs to assure
reasonableness of using short-form

` OSHA-Identified Common PSSR

Problems
◦ Not done before introduction of ammonia
◦ Not done by competent personnel
◦ Construction documents not used as the
basis of the Pre-Startup
p Safety
y Review
◦ P&ID’s not current when the Pre-Startup
Safety review is performed

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 10/7/2008

` Tolley – 1996
◦ What changes are significant enough to be
called a “new” facility?
x …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.
x …PSSR standard
d d would ld b
be applicable
l bl to ""new ffacilities
l andd
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 PSSR

` Have multiple level of PSSRs (simple → complex)
◦ Risk based determination of complexity
` Audit PSSR process to streamline future PSSRs
` PSSR team
◦ Broad involvement to steep PSSR into plant “culture” &
i
insure employee
l participation
ti i ti
◦ Independent of specific project or subproject

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 10/7/2008

Increased Severity of Event

Low Serious Catastrophic

High Medium Higher Higher

Incre
eased Likelihood
of Event

Moderate Lower Medium Higher

Low Lower Lower Medium

` 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
sign-off
off

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 10/7/2008

` Project cost greater than $X

◦ Tied to corporate capital request rules
` New type of equipment or chemicals (first
application on site)
` Three or more piping tie-in points
` New control systems or modification to
controls that could affect safety controls or
interlocks
` Fire protection system changes
` Reuse of used or previously mothballed
equipment

` Could an RIK that involves the shutdown of

y
the system or a p
portion of the system
y be
subject to a PSSR?

` Said another way, could a PSSR be utilized for

an RIK requiring shutdown?
◦ Simplified checklist to insure
th t maintenance
that i t procedure
d iis
followed

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 10/7/2008

` Move (or extend) some aspects of review to

post startup
p 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 use
` Consider additional
additional, focused PSSRs that provide QA of
maintenance & SOPs
◦ Integrated into operating procedure revalidation, OJT or
supervision/review

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