Over the past two decades, the US Occupational Safety and Health Administration (OSHA) has put in place regulatory programs to protect the safety of workers in industrial plants. One such program is the process safety management (PSM) standard, which contains requirements for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable or explosive chemicals. More recently, OSHA has developed special emphasis programs to target specific industries, notably the petroleum refining and chemical industries, and enhanced its auditing processes and inspection priorities. Result: Owners are facing tougher inspections and stiffer fines. Here are some insights into what this means for owners, managers and operators today.
Reports from recent inspections indicate that four inspection items, in particular, are challenging owners today:
- Process safety information (PSI)
- Process hazard analysis (PHA)
- Mechanical integrity (MI)
- Management of change (MOC).
In fact, failure to meet the standard in these four areas has resulted in the highest number of citations in the refining industry in recent years. As a result, owners must reevaluate their PSM programs and ensure that they are taking a rigorous approach to developing, documenting and implementing them.
In one case, owners developed and rolled out their revised and enhanced PSM program over the course of a couple of years, while continuing to operate existing facilities and build major expansions that had to integrate the changing regulatory environment. When the petroleum industrys National Emphasis Program (NEP) audits began, they significantly changed the program once they saw the nature of the citations being issued. For example, they observed that OSHA inspectors were examining equipment, operations and safety procedures from a new perspective and (more importantly) were interpreting the regulations from a new perspective.
With PSI, OSHA inspectors are requiring owners to produce documentation. Failure to produce documentation has become a citable deficiency. This has required firms to develop comprehensive document filing and tracking systems for PSI so they can be readily found when requested by OSHA or needed by project or process engineers. Gone are the days of plant personnel saying, Oh, its in the file room somewhere.
Another challenging area is that of the PHA, which includes requirements for a facility siting study. OSHA inspectors interpret the regulation broadly: along with renewing the PHAs of covered process units and equipment on a five-year cycle, which is part of the regulation, they expect to see that the facility siting study has been revalidated every five years just like any other PHA.
Inspectors are also taking a close look at MI and MOC. They expect to see documentation showing that owners have carefully assessed and prevented hazards through their change-management programs. For example, a worker might think nothing of changing out a stainless-steel valve for a valve composed of another chemical-resistant material if the stainless-steel replacement valve is out of stock. However, the alternative might react chemically with the material that is being processed, resulting in a catastrophic failure.
In other cases, a required change made by engineering might not always be communicated to operations. Additionally, a change may be properly communicated; however, associated changes in operating procedures and training may not be, as required by the regulations. OSHA is closely looking at these types of gaps to ensure that changes are communicated and documented in all relevant process safety elements such as PSI, PHAs, operating procedures, training and any other elements impacted.
MOC, as noted previously, impacts many elements of a PSM program. It must be well-documented to enable a thorough five-year revalidation of the PHA of a particular unit or piece of equipment. In particular, any changes or incidents related to that piece of equipment must be reviewed in detail so that the hazard analysis team can ensure that the appropriate changes have been made without a negative impact on the safety of the process as it was designed.
Focus of enhanced audits
OSHA began performing enhanced PSM audits of the refining industry in June 2007 as a result of the March 23, 2005, BP Texas City incident. It expanded them to the chemical industry and other industries covered by the OSHA PSM standard from July 30, 2011. These chemical NEPs were piloted in two regions (I and VII) starting July 2009. In these audits, they focus on highly toxic chemicals, especially ammonia, chlorine and hydrofluoric acid.
The inspection process itself has become more arduous and detailed. For example, in its NEP audits, OSHA has brought in large teams to conduct detailed reviews over long periods (in some cases, up to six months). These teams have often focused on one or two units. They have taken piping and instrumentation drawings, walked through a unit, and noted differences between the drawings and the field conditions. Discrepancies resulted in citations for failure to maintain current drawings.
There have been a few surprises. In addition to the greater rigor and detail of these audits, they are also touching additional departments in the plant. For example, inspectors have required that everyone inside the plant, even office workers, have a basic understanding of the heating, ventilation and air conditioning (HVAC) design and, more important, how to shut it down in case of an alarm signaling a chemical release in the refinery or chemical plant. Some facilities are revising their HVAC control system to allow shutdown of all systems feeding a building upon activation of a single switch or button located at a readily available interior building location, such as a hallway.
Internal compliance auditing
An effective internal compliance auditing program is key to protecting workers and the surrounding community, and it gives plants a better chance of coming through an inspection with fewer citations.
There are a number of ways to address internal compliance auditing, depending on the size and makeup of the company. For example, larger sites with internal auditing staff who understand the present inspection process, including areas receiving greater attention, can probably perform these audits themselves. An independent engineer with expertise in PSM can provide additional perspective to an internal team. Some owners periodically contract with an independent auditing firm to perform the entire audit.
In any case, it is critically important to ensure that the internal compliance auditing team comprises people with PSM experience, strong understanding of the regulations, and contact with peers in other companies who can provide additional insights.
Of course, a successful internal compliance audit is predicated on a well-structured and fully documented PSM program. And, in turn, this requires leadership, ideally by an engineer with not only PSM experience but also experience or knowledge of all aspects of the unit such as operations, engineering and technology, and who can lead a multi-functional team that will implement all of the PSM elements. Finally, the key to any successful program is management support by providing proper resources, funding and overview to ensure an effective program.
An effective PSM program that protects the safety of workersand proves itself in the eyes of OSHArequires that owners, managers and operators observe this time-tested advice: Dont assume anything. Develop a comprehensive PSM program and a comprehensive internal compliance auditing process, and focus on the program elements that really make the difference. These are key to surviving and thriving in the era of the enhanced OSHA PSM audit. HP
Clifford Reese, PE, is a business leader and senior associate of SSOE Group, an international engineering, procurement and construction management firm. He has over 25 years experience with global engineering, chemical and petrochemical manufacturing and construction, specializing in implementations of new capacity and innovative process development programs, including coal gasification, biofuels and specialty chemical and refinery projects.
Bruce Taylor, PE, CPEA, is a vice president of Midland Engineering Ltd., an engineering, consulting and auditing firm providing services in such diverse fields as organic chemicals, agricultural chemicals, pharmaceuticals, inorganic chemicals, refining, power generation and polymers. He has over 35 years of industry and consulting experience developing, implementing and auditing safety and process safety programs and management systems in the plastics, chemical, pharmaceutical and refining industries.