Process Safety Management

of Highly Hazardous &

Explosive Chemicals

Operating Procedures, Safety Procedures &

Training
Now that the PHA’s Are
Competed or Underway…
 Operating
Safety
Procedures & Safety
Programs Must Be
Developed

 PHA Information
Can Be Used
Operating Procedures

1910.119(f)
Operating Procedures & Safety
Programs Must Consider:
 Initial start-up
 Normal operations
 operations
Temporary operations
 Emergency shutdown
 Emergency operations
 Normal shutdown
 Start-up following turnaround
 deviation
Consequences of deviation
 Steps required to correct or avoid deviation
Operating Procedures or
Standard Operating Procedures
(SOP’s)
 Where Did
Where Did This
This Methodology
Methodology Come
Come From?
From?

 Answer: The Military

 Definition: A standard operating procedure is a set of

instructions having the force of a directive, covering those
features of
features of operations
operations that
that lend
lend themselves
themselves to to aa definite
definite or
or
standardized procedure
standardized procedure without
without loss
loss of
of effectiveness.
effectiveness.
Standard Operating
Standard Operating Policies
Policies and
and Procedures
Procedures cancan be
be
effective catalysts
effective catalysts to
to drive
drive performance
performance improvement
improvement and and
improving organizational
improving organizational results.
results. Every
Every good
good quality
quality system
system
is based
is based on
on its
its standard
standard operating
operating procedures
procedures (SOPs).
(SOPs).
Operating Procedures
 Develop and implement written operating procedures*
consistent with the process safety information and addresses
at least the following elements:
 Initial start-up, normal and temporary operations
 Normal and emergency shut-down procedures
 Operating limits and consequences of deviation
 Hazards presented by the process

*Readily accessible to employees

Operating Procedures
 The operating procedures addressing
operating parameters will contain operating
instructions about:
 pressure limits
pressure limits
temperature ranges
 temperature ranges
flow rates…and
 flow rates…and
what to
 what to do
do when
when an
an upset
upset condition
condition occurs
occurs
what alarms
 what alarms and
and instruments
instruments are
are pertinent
pertinent ifif an
an
upset condition
upset condition occurs,
occurs, and
and other
other subjects.
subjects.
Operating Procedures - Start
Up…We Must

 Describe normal SOP's 

 Describe start-up SOP's

 Describe Shut-down
Describe Shut-down
SOP’s
SOP’s
Operating Procedures - Start
Up…We Must
 Include Sections such
Include such as:
as:
 Objectives
 Purpose
Concerns
 Concerns
Procedures
 Procedures
 Department
 Operator
Equipment Involved
 Equipment Involved
Location
 Location
 Related Documents

Let’s Look at An Example…

Process Safety Management Procedure - Revision HPR-1 Revision Date: 1-9-2009 by: SWD
Objective This procedure is designed to describe the Technical Operating
Specifications (TOS), and to set down the Standard Operating
Procedures for the safe operation of Ammonia High Pressure
Receiver 1 (HPR-1)
Purpose: The purpose of the TOS is to provide a description of the High
Pressure Receiver, to define the function of the receiver, its
operating conditions and limits, and consequences of deviation
from these limits; To describe controls and instrumentation and
safety systems, and set operating alignments.  The purpose of
the Standard Operating Procedure (SOP) is to set down the
proper steps for starting, monitoring normal operation, and
stopping and restarting the Receiver under normal and
emergency conditions
Concerns: Very Careful attention to valve positions, temperature, and
pressure levels is extremely important to the successful
completion of these procedures. Deviations from normal
operating limits could cause personal injury or death, small to
catastrophic release of ammonia or environmental damage, or
evacuation of, or injury to, members of the public. We seek to
prevent incidents such as:
Injury to operators and others in the area. Damage to the High
Pressure Receiver. Release of any quantity of Anhydrous
Ammonia refrigerant.
The company Lockout/Tagout program shall be followed when
taking the receiver out of service, while maintaining the
receiver, and while returning it to service. If Line-Breaking is
required, all Line-Breaking precautions described in the
company Line-Break Policy shall be observed. Additionally,
proper PPE shall be immediately available, or worn in response
to the threat level posed by the work and circumstances.
Department: Refrigeration
Operator: Qualified Refrigeration Operator(s)
Equipment: Ammonia High Pressure Receiver, HPR-1 outside the south compressor
room. Data from U-1-A: Vertical Receiver, Serial Number 124011,
National Board Number 8664, built in 1998, by E.L. Nickell Company.
MAWP: 250 psig @ 240 ｡ F
Location:
Related
Documents:
Initial Date of 4/1998
Development:
Authorized By:
Previous Revision: 4/1/1998
Annual Review By, 9/2001 plant engineer, utilities supervisor, two operators, the Process
and Date: Safety Management (PSM) coordinator, and an outside consultant
Operating Procedures
 Must be Developed for Each Equipment
Operation in the Covered Process
Refer to Block
 Refer Block Diagrams
 Refer to P&ID
Must Cover Normal
 Must Normal Operating
Operating Conditions,
Conditions,
Normal Operating Parameters, i.e..
Pressure/Flow/Current/ etc.
Must Follow Procedures &
 Must
Recommendations in PHA’s
Must Follow Form
 Must Form
Operating Procedures

 For Shut-down Procedures…

Remember:
 Most operations must be shut down in a
specific order!
specific order!
 Failure to follow these shut down
procedures could results in a catastrophic
procedures
release or system failure
Ammonia Plant Explosion Caused by
Improper Shut-down of Engine Room
Operating Procedures
 Operating Limits
 Operating Limits
Must be Understood
 Pressures
 Flows
 Electrical Potential
 Tolerances
Operating Procedures -
Hazards of the Process
 Operating
Procedures Must
Identify the Hazards
Process in
of the Process in All
All
Phases:
 Start Up
Start Up
 Normal Operating
Conditions
Conditions
 Temporary Operating
Condition
Condition
 Emergency Shut-
down
down
 Now That We’ve Completed
the Operating Procedures
We Must Develop Safety Work Practices,
Programs & Procedures for Covered
Processes
Safe Work Practices

1910.119(f)(1)
Safe Work Practices
•Develop and implement safe work practices* to provide for
the control of hazards during operations such as:
–Lockout/tagout;
–Confined space entry;
–Line Opening process equipment or piping; and
–Control over entrance into a facility by maintenance,
contractor, laboratory, or other support personnel

*These safe work practices apply to contractor employees as well

Safe Work Practices

 Safe Work Practices, Programs &

Procedures must:
 Be specific to the Covered Process
Follow Procedures & Recommendations
 Follow Recommendations in
in
the PHA’s
Follow Procedures in the Operating
 Follow
Procedures
Procedures
 Must be Able to be Tracked
Follow Form
 Follow
Safe Work Practices

 Lockout Tagout - One of the Most

Important Procedures in PSM
 Must be Written Carefully & Follow all
Procedures (PHA’s, Operating
Procedures)
 Must be Followed to the Letter!
Safe Work Practices
 Lockout/Tagout in
PSM
 Why not Use Digital
Imaging in
Imaging in Your
Your
Procedures to
Procedures to Identify
Identify
Critical Lockout
Critical Lockout /Tagout
/Tagout
Positions
Positions
Safe Work Practices
 Line Opening
Permits
 Identify Procedures
for Opening
for Opening any
any
Process Line
Process Line in
in aa
Covered Process
Covered Process
Must Include
 Must Include
Hazards of
Hazards of the
the Line
Line
Opening
Opening
 PPE Required
Safe Work Practices
Line & Equipment Opening
 A Hazard Review Must Completed for All
Line/Equipment Hazards Including:

 HAZARDOUS MATERIALS IN SYSTEM

 POTENTIAL PHYSICAL HAZARDS
 BARRICADING AS REQUIRED
 FIRST AID IF EXPOSED
 LOCATION OF SAFETY EQUIPMENT
 PPE REQUIRED FOR LINE OPENING
Safe Work Practices-
Hot Work
A Program Must be Developed for the Covered Process
That Requires:
 A Hot Work Permit be Issued for ALL Hot Work
Performed in the Plant by Employees or Contractors
 A Permit must be Posted at the Location of the Hot
Work
 A Fire Watch Is Required
 A Fire Extinguisher or Other Appropriate Fire
Fighting Equipment Must Be Present, Fire Watch
must be Trained in its use
Paper Mill Explosion & Fire Caused
by Failure to Follow Hot Work
Procedures
Safe Work Practices

 Must be Specific for the Covered

Process
 May Require Additional Program other
than Lockout Tagout, Line Opening &
Hot Work…such as Confined Space,
Electrical Safe Work Practices,
Combustible Dust
Now That We’ve Developed
Safe Work Practices

We Have to Train
Training

1910.119(g)
PSM 29CFR1910.119(g)
Requires
(G) Training
(G) Training (Initial,
(Initial, Refresher,
Refresher, and
and Documentation)
Documentation)
(paragraphs (g)(1),
(paragraphs (g)(1), (g)(2),
(g)(2), and
and (g)(3)).
(g)(3)).

 Paragraph (g)(1)
Paragraph (g)(1) requires
requires employers
employers to to train
train
employees operating dangerous process. Paragraph
(g)(2) requires
(g)(2) requires that
that the
the employer
employer provide
provide refresher
refresher
training at least every three years. Paragraph (g)(3)
requires the
requires the employer
employer toto prepare
prepare aa record
record that
that
contains the name of employee, the date of training,
and the
and the means
means used
used to
to verify
verify that
that the
the employee
employee
understood the training
PSM Training
 PSM Training Programs Must be Developed
for:
 Affected Employees
Affected Employees -- Those
Those not
not Directly
Directly Involved
Involved
in the Process Operation
 Authorized Employees - Those Directly Involved in
the Process
the Process Operation
Operation
Contractors Who
 Contractors Who May
May Perform
Perform Work
Work onon aa Covered
Covered
Process
Process
Vendors/Visitors who
 Vendors/Visitors who May
May Visit
Visit the
the Facility
Facility and
and
May Potentially be Exposed to the Covered
Process
Process
PSM Training

 Training Must Be Performed as Follows:

 Initial training
Prior to work
 Prior work assignment
 Waved for those already in a process

 Refresher training
 Every three years
 All Training Must be Documented
PSM Training

 Training Subjects Must Include at Least:

Lockout Tagout
 Lockout
Hot Work
 Hot
 Line & Equipment Opening
Confined Space (if applicable)
 Confined
Emergency Response
 Emergency
 Examples of Training
PSM training example including the
means used to verify that the
employee understood the training.
Let’s Use Hot Work
Procedures
Safe Work Practices

Hot Work Program

EXAMPLES OF
HOT WORK
Safe Work Practices
Hot Work
Burning, Welding, Grinding

Our Program Requires

 A Hot Work Permit be Issued for ALL Hot
work Performed in the Plant by Employees or
Contractors
 Permit must be Posted at the Location of the
Hot Work
 Fire Watch Is Required
 Fire Extinguisher Must Be Present, Fire
Watch must be Trained in its use
Safe Work Practices
HOT WORK
PERMIT MUST BE
COMPLETED PRIOR TO
BEGINNING WORK
INVOLVIING ANY HOT
WORK
PERMIT SHALL BE
DISPLAYED AT THE
LOCATION OF THE
ACTUAL HOT WORK
OPERATION
VERIFICATION OF UNDERSTANDING WORKSHEET
HOT WORK

CIRCLE THE CORRECT ANSWER

1. A HOT WORK permit must be obtained prior to beginning HOT.work by
welders and contractors before beginning a job.
TRUE
2. A HOT WORK permit is not necessary if just burning and grinding is being
done on a job.
FALSE
3. Contractors are not required to obtain HOT WORK permits.
FALSE
4. The employee or contractor will obtain a HOT WORK permit from his
supervisor and must determine if conditions are safe and have a fire watch if
necessary.
TRUE
5. HOT WORK is permitted in explosive atmospheres, around hazardous tanks
and equipment.
FALSE
6. The following protective measures can be used: damp sand on floors, protective
shields, or fire resistant coverings while Hot Work is taking place.
TRUE
7. 35 feet is a good safe distance for covered combustibles to be away from HOT
WORK.
TRUE
8. Fully charged and operable fire extinguishers and/or hose lines shall be
available and ready.
TRUE
9. The HOT WORK permit shall be posted at the job site, and the supervisor shall
retain the permits for three (3) days.
TRUE
10. The fire watch does not have to be trained in fire extinguishing and is not
responsible for sounding an alarm in the event of a fire.
PSM Operating Procedures
Summary
 You Must
You Must Develop
Develop and
and implement
implement written
written operating
operating
procedures consistent with the process safety
information and
information and addresses
addresses at
at least
least the
the following
following
elements:
elements:
 Initial start-up,
Initial start-up, normal
normal and
and temporary
temporary operations
operations
 Normal and
Normal and emergency
emergency shut-down
shut-down procedures
procedures
 Operating limits and consequences of deviation
 Hazards presented by the process
PSM Safe Work Practices
Summary
 Safe Work Practices, Programs &
Procedures must:
 Be specific to the Covered Process(s)
Recommendations in
 Follow Procedures & Recommendations in
the PHA’s
 Follow Procedures in the Operating
Procedures
Procedures
 Must be Able to be Tracked
Form
 Follow Form
PSM Training
Summary
 PSM Training Programs Must be Developed
for All Necessary Workers and Contractors
 Verification of Understanding is Required
 Training Must Be Performed as Follows:
 Initial training
 Prior to
Prior to work
work assignment
assignment
 Waved for
Waved for those
those already
already in
in aa process
process
 Refresher training
 Every three
Every three years
years
 All Training Must be Documented
 What’s Next?

In the Last Session, we

will Cover Contractor
Pre-Qualification,
Emergency Planning &
Response Audits, and
EPA Risk Management
Plans (RMP)