SP-39 – Employee Participation Program (11/27/2010)

Purpose:

Definitions:

Responsibilities:

Procedure:

MOC Form:

Purpose:

This Employee Participation Program describes the various approaches that Company XYZ-Cadet uses to involve
associates in the elements of process safety management (PSM). This program’s purpose is to outline the
activities which demonstrate compliance with the Employee Participation elements of OSHA’s Process Safety
Management Standard regulation and EPA’s Risk Management Plan and to encourage employees to actively
participate in the process safety management systems.

This plan does not list all the activities that our associates perform that are important to safety. These programs
also address the requirements of the BPSM Standard.

Definitions:

Associate – Company XYZ Employee

BPSMS - Company XYZ Process Safety Management System

CAR – Corrective Action Response

EPA – Environmental Protections Agency

MOC – Management of Change

PAR – Preventative Action Request

PSSR – Pre-Start Up Safety Review

Responsibilities:

 Plant Manager- Participate in BPSMS program development and implementation as outlined in this program
and other BPSMS standards. Ensure associates are afforded and use participation opportunities as outlined in
this program and the associate participation plan. Provide feedback on BPSMS development and
implementation. Provide access to BPSMS information needed by both Company XYZ and contract
associates. Observe the provisions of the Trade Secret Program. Ensure associates attend required safety
meetings, and that content and attendance is documented.

 PSM Coordinator- Update and distribute the Associate Participation Program description. Coordinates program
activities with other BPSMS activities. Oversees program development and implementation. Acts as key
policymaker and arbitrator for issues associated with the program. Resolve any BPSMS information access
difficulties identified by Company XYZ and contract associates. Request, respond to and resolve comments
from associates about Company XYZ’s development and implementation of BPSMS programs and ensure all
suggestions receive a formal response.
 Company XYZ associates- Provide feedback and suggestions on BPSMS development and implementation.
Observe the provisions of the Trade Secret Program. Ensure that BPSMS information necessary for
performing work safely has been obtained prior to performing assigned task. Report any difficulties in obtaining
BPSMS information to the Plant Manager or PSM Coordinator. Attend and participate in required safety
meetings.

 Contract associates and supervisors-Comply with the Contractor Safety Program requirements and provide
contract associates with BPSMS information and performing required implementation tasks. Provide access
and resolve any difficulties identified by contract associates in accessing BPSMS information. Observe the
provisions of the Trade Secret Program. Report any difficulties in obtaining BPSMS information to a contract
associate supervisor or Company XYZ Plant Manager/PSM coordinator

Procedure (General):

Employee Participation Program

Company XYZ Cadet encourages participation by:

 Consulting with associates on the development of the various requirements of BPSM including PHAs,
Incident Investigations, SOPs, etc.
 Providing associates with access to information developed under this rule.
 Involving associates in complying with the various elements based upon their knowledge, skills, and
experience.
 Encouraging associates to submit safety suggestions via CAR, PAR and management of change systems.
 Participating on the teams to ensure associates are completing daily tasks in a safe manner.

PROCESS SAFETY INFORMATION

Associates participate in the process safety information element by:

 Assisting in collecting and verifying existing information.

 Assisting in keeping required information continually up to date.
 Documenting and providing input on changes to P&IDs, loops, and equipment drawings etc. which fall out
of normal work processes.
 Communicating observations during normal conduct of work specifically those that reflect operational
issues.
 Viewing and utilizing PSI as needed.

PROCESS HAZARD ANALYSIS (PHA)

The results of PHAs are shared with all affected associates and final PHA reports are located in the Computer room
and are available on line in the BQS system. Associates participate in the process hazard analysis element by:

 Participating as team members in PHAs and revalidations.

 Understanding the results of the PHA and revalidations and resolution of recommendations.
 Participating in the implementation efforts, as result of changes brought about by the PHA.

OPERATING PROCEDURES

Associates participate in the operating procedures element by:

 Performing operations task in accordance with operating procedures.

 Consulting during procedure development/implementation to determine if the procedure adequately affects
what is really done and what needs to be done to better reflect what steps are necessary to attain the
desired results in a safe and environmentally responsible manner.
 Actively communicate to management any changes that are recommended to the operating procedure as
opportunities for improvements are identified.

TRAINING

Associates participate in the training element by:

  Assisting with the development of customized training based upon associate need which allows for input
regarding course material, training frequency, and evaluation methods.
 Receiving and understanding initial and refresher training for all associates.
 Providing on the job training for other associates.
 Raising safety concerns during training sessions.

CONTRACTORS

Associates participate in the contractor element by:

 Ensuring that contractors follow the required safe work practices and safety rules.
 Verifying that contractor safety requirements are consistent with requirements that Company XYZ Cadet
has for its own associates when performing similar tasks.
 Having a questioning attitude and reporting at risk contractor actions.
 Suggesting new/revised contractor safety requirements based on experience and lessons learned.
 Preparing equipment so contractors can work on equipment safely and to monitor contractor activities.

PRE-STARTUP SAFETY REVIEW (PSSR)

Associates participate in the pre-startup safety review element by:

 Participating in pre-start up reviews on new and/or modified processes and equipments.

 Ensuring that all departments concur that the equipment is fit for service and ready for startup.
 Having a questioning attitude, completing informal pre-startup safety reviews on their own, and initiating
dialogue on identified concerns.

MECHANICAL INTEGRITY

Associates participate in the mechanical integrity element by:

 Ensuring that maintenance associates are involved in developing and updating procedures that implement
the safe work practice and mechanical integrity requirements of the BPSM program.
 Providing input for equipment history and recording observed data.
 Assisting in the development of inspections, test and preventative maintenance plans for equipment items.
 Performing maintenance and inspection/test task in accordance with defined schedules and procedures.

HOT WORK PERMIT (SAFE WORK PRACTICES)

Associates participate in the hot work element by:

 Assisting in developing the format and content of safe work practices and safety policies.
 Following safe work practice and policies and ensuring that others are doing the same.
 Suggesting revisions/additions and updates to safe work practices and policies as appropriate.
 Participating in the review of safe work practices procedures through involvement in safety meeting
discussions and safety committees.

MANAGEMENT OF CHANGE

Associates participate in the management of change element by:

 Identifying changes where appropriate associated with job tasks and/or equipment and initiating
management of change reviews.
 Assisting in reviews of proposed changes as appropriate.
 Receiving and understanding training/communication of changes, including changes to BPSM programs.

INCIDENT INVESTIGATION

Associates participate in the incident investigation element by:

 Identifying and reporting incidents that occur and initiating investigations.

  Identifying and reporting near-miss and process safety incidents that occur and initiating investigations.
 Participating as team members during investigations.
 Participating in discussions concerning the report findings during safety meetings.

EMERGENCY PLANNING AND RESPONSE

Associates participate in the emergency planning and response element by:

 Identifying and reporting emergency situations.

 Performing appropriate response actions in the event of an emergency and in emergency drills.
 Providing information to emergency planners about unique hazards, response, and evacuation issues in
plant areas.
 Participating in emergency action plan and hazardous waste and emergency operations training.
 Participating in critiques as the result of drills and actual incidents to elicit comments and observations,
identify learnings, identify opportunities for performance improvement and improve both emergency
response planning and responder performance.

COMPLIANCE AUDITS

Associates participate in the compliance audit element by:

 Reviewing and commenting on audit protocols if needed.

 Participating as team members in audits, as applicable.
 Serving as interviewees as part of audits and providing information as necessary to support audits.
 Receiving and understanding the results of the audits and resolution of audit findings/observations.

TRADE SECRETS

Associates participate in the trade secret element by:

 Observing the limitations of confidentiality agreements in the use of BPSM information

Authorization:

Plant Manager           Date

 
Process Safety Coordinator       Date

 
S/H/E Stewardship Manager        Date