Lessons Learned: Common Pitfalls of PSM Programs

Lessons Learned: Common Pitfalls of PSM Programs

John Phillips, Summit Refrigeration Group

January 29, 2018

PSM: Performance Standard

• PSM is a “performance standard” not a “prescriptive standard” – it doesn’t tell us exactly what to do.

• All the steps to comply are not listed.

• PSM says you must have a procedure and you must decide how much information to include in it.

- It doesn’t tell you to conduct PSM meetings, but that you must involve employees.

- It doesn’t tell you to conduct weekly inspections, instead, they require periodic inspections and you have to determine the appropriate frequency.


• OSHA wants employers to provide a workplace that is safe for employees.

• But because One Size Does Not Fit All, OSHA wants you to spend some time and think about how best to achieve a safe working environment, and to implement safety precautions that work for your operations.

- They don’t want to inhibit your operations, but they do want you to work safely.


• So it is up to each employer, EHS department, manager, supervisor and safety team to implement and enforce a safety program so that it becomes part of the company’s culture.

• Written program procedures are developed for each PSM element.

- Make sure your written program ACCURATELY reflects what you really do.

- Make sure your supporting documentation actually reflects what is in your written plan.

Common Pitfalls of PSM Programs:Employee Participation

Employee Participation Regulatory Requirements:(1)Employers shall develop a written plan of action regarding the implementation of the employee participation required by this paragraph.

(2) Employers shall consult with employees and their representatives on the conduct and development of process hazard analyses, and on the development of the other elements of process safety management in this standard.

(3) Employers shall provide to employees and their representatives access to process hazard analyses, and all other information required to be developed under this standard.

Common Pitfalls of PSM Programs:Employee Participation

• Document your employee participation – don’t simply say you involve employees – have something to actually prove it.

- Especially Operators

• Make sure the documentation used by HR, EHS, Risk Management matches the forms your written program identifies.

Common Pitfalls of PSM Programs:Process Safety Information (PSI)

• Top ChemNEP PSM Element Violation, FY14 thru FY1


• PSM CFR §1910.119(d)(3)(i)(F) requires that a facility have documentation describing the “Design Codes and Standards Employed” readily available for each PSM chemical process. This documentation serves multiple purposes:

- Demonstrates that the process was designed/installed in accordance with recognized practices (often referred to a RAGAGEP – recognized and generally accepted good engineering practice)

- Provides a basis for future audits and inspections. Codes and standards change over time, but that does not necessarily force a facility toward upgrades

- Serves a guideline for approving changes to a chemical process. When Design Codes and Standards Employed is clearly documented, an owner or his representative can objectively verify changes against the code/standard which can help avoid disputes later


• For ammonia refrigeration, the International Institute of Ammonia Refrigeration (IIAR) is the organization that we, and OSHA, look to.

• Currently, IIAR has published the following standards which cover all aspects of refrigeration system design, installation, commissioning, and decommissioning:- ANSI/IIAR Standard 1-2012 American National Standard for Definitions and

Terminology Used in IIAR Standards

- ANSI/IIAR 2-2014 American National Standard the Safe Design of Closed-Circuit Ammonia Refrigeration Systems

- ANSI/IIAR Standard 3-2012 American National Standard for Ammonia Refrigeration Valves


- ANSI/IIAR Standard 4-2015 Installation of Closed-Circuit Ammonia Refrigeration Systems

- ANSI/IIAR Standard 5-2013 Start-up and Commissioning of Closed-Circuit Ammonia Refrigeration Systems

- ANSI/IIAR Standard 7-2013 Developing Operating Procedures for Closed-Circuit Ammonia Mechanical Refrigerating Systems

- ANSI/IIAR Standard 8-2015 Decommissioning of Closed-Circuit Ammonia Refrigeration Systems


• Future Standards:

- IIAR 6 Working Title: Inspection, Testing, and Maintenance of Safe Closed-Circuit Ammonia Refrigeration Systems

• This proposed standard specifies minimum criteria for inspection, testing, and maintenance of closed-circuit ammonia mechanical refrigeration systems, including the ammonia side of a cascade refrigeration system.


• Future Standards:

- IIAR 9 Working Title: Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) for Existing Closed-Circuit Ammonia Refrigeration Systems

• This proposed standard will help companies ascertain whether or not their existing systems should be updated to reflect new requirements from newly published and revised standards. This standard provides a method of evaluating existing systems against requirements that should apply to all closed-circuit ammonia refrigeration systems, regardless of age, and will help determine what can or can't be "grandfathered" in regarding to system design.


• Other Applicable Design Codes and Standards- Other organizations that publish design codes and standards that are

applicable to ammonia refrigeration. • Uniform Mechanical Code

• International Mechanical Code

• ASME – Boiler and Pressure Vessel Code Section VIII

• ASME – ASME 31.5 Refrigeration Piping and Heat Transfer Components

• ISEA – ISEA Z358.1 Emergency Eyewash & Shower Equipment

• ASHRAE – ASHRAE 15 Safety Standard for Refrigeration Systems

• NFPA – NFPA 1 Fire Code

• International Fire Code


• The PSM regulation requires that a facility document the codes and standards that were (and are) adhered to at their facility. This requirement relates to:

- design

- installation

- operation

- maintenance


• Best Practice: Require the designer and/or installer to provide a signed statement specifying the codes and standards that were used during design and construction of the process.

Sample Statement


Grandfathering

Scenario:• Cold Storage Facility was built in

1969 in accordance with 1967UMC


Grandfathering

Scenario:• In 1998, modifications were made

to the machinery room:• New compressor installed• AHJ required ventilation,

detection, and relief system to be upgraded

• All changes performed in accordance with 1997 UMC


Grandfathering

Scenario:• In 2014, facility hired a

contractor to construct a new cold storage room:• No machinery room

modifications required• New room must comply

with 2012 IMC and ANSI/IIAR 2-2008 Addendum B

• Facility elected to upgrade detection for entire facility to comply with 2012 IMC


• Documenting PSI RAGAGEP Compliance- U-1 Forms


• Documenting PSI RAGAGEP Compliance- Equipment drawings


• Documenting PSI RAGAGEP Compliance- Equipment Bulletins


Outdated, incomplete, or nonexistent P&IDs

• If Process Safety Information is the foundation of a PSM program, then Piping and Instrument Diagrams (P&IDs) are the cornerstone. P&IDs must include at least the following:

• Process Equipment

• Piping

• Valves

• Control Valves

• Relief Valves

• Instruments (gauges, sensors, transducers)



• Regular review of P&IDs is essential to anyone who desires to be familiar with a system.

- Since PSM requires that employees be trained in an “overview of the process”, what better opportunity to obtain an “overview of the process” than to walk the system with a P&ID in hand.


Relief System Design

• Relief System Design and Design Basis is typically governed by the mechanical code and/or IIAR 2 at the time of construction.

- ANSI/IIAR 2-2014 has dedicated an entire chapter (Chapter 15) to the topic of overpressure protection.


Relief System Design• Compliant Relief System Design and Design Basis documentation will include

at least the following information:

- Basis of the relief system design (code/standard used)

- Name of each piece of equipment required to be protected by relief valves

- Specifications for each piece of equipment required to be protected by relief valves (e.g. length and diameter of pressure vessels)

- Manufacturer / model of each relief valve

- Set pressure (psig) of each relief valve

- Capacity (scfm or lb/min) of each relief valve

- Analysis proving that the set pressure and capacity are adequate

- Diameter and length of discharge termination piping

- Analysis proving that the discharge termination piping does not adversely affect relief valve performance (maximum allowable backpressure)


Ventilation System Design

• Documentation must be prepared that describes the “as-built” design of the existing ventilation system(s). Ideally, this documentation will include:- Functional description of the ventilation system – Description of fan

control, alarm signals, normal vs. emergency ventilation, etc.

- Fan specifications – Airflow, static pressure, motor type, blade material

- Room characteristics – Dimensions, volume, make-up air dampers

- Design basis – Code or standard to which the ventilation system was designed

Common Pitfalls of PSM Programs:Process Hazard Analysis (PHA)

• One of the top 3 ChemNEP Violations for FY14 thru FY16


Regulatory Requirements:

(3) The process hazard analysis shall address:

(i) The hazards of the process;

(ii) The identification of any previous incident which had a likely potential for catastrophic consequences in the workplace;

(iii) Engineering and administrative controls applicable to the hazards and their interrelationships, such as appropriate application of detection methodologies to provide early warning of releases. (Acceptable detection methods might include process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors.);

(iv) Consequences of failure of engineering and administrative controls;

(v) Facility siting;

(vi) Human factors; and

(viii) A qualitative evaluation of a range of the possible safety and health effects of failure of controls on employees in the workplace.


• Failure to address the consequences of the failure of administrative controls used in the process

• Failure to document the resolution of the findings and recommendations

• Failure to update and revalidate the PHAs at least every 5 years

Common Pitfalls of PSM Programs:Standard Operating Procedures (SOP)

• One of the top 4 violations cited during NEP audits, FY14 thru FY16


• Procedures are generic in nature, not equipment specific

• Operators not included in development (review for accuracy)

• Not reviewed and certified annually

• Safe work practices not developed- Line break

- Ammonia unloading

- Relief valve replacement

- Lockout/tagout, not equipment specific

- Confined space

- Respiratory protection


• IIAR Standard 7, Developing Operating Procedures for Closed-Circuit Ammonia Mechanical Refrigerating Systems


• IIAR Standard 7, Revised, for Public Review

Common Pitfalls of PSM Programs:Training

Regulatory Requirements

Section 1910.119(g) of the Process Safety Management (PSM) Standard states:

(i) Training

(ii) (1) Initial Training

(i) Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, shall be trained in an overview of the process and in the operating procedures as specified in paragraph (f) of this section. The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee’s job tasks.


(ii) In lieu of initial training for those employees already involved in operating a process on May 26, 1992, an employer may certify in writing that the employee has the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as specified in the operating procedures.

(2) Refresher Training: Refresher training shall be provided at least every three years, and more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process. The employer, in consultation with the employees involved in operating the process, shall determine the appropriate frequency of refresher training.


• Have operators been trained on the operating procedures?

- Does this include contractor employees hired to operate the system?

• Training can be one or more of these methods

- Classroom

- Observations

- Hands-on

- Annual operating procedure review and certification


• Is training documented?

Regulatory Requirement

(3) Training Documentation:The employer shall ascertain that each employee involved in operating a process has received and understood the training required by this paragraph. The employer shall prepare a record which contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training.

Common Pitfalls of PSM Programs:Contractors

Regulatory Requirements:

(2) Employer Responsibilities.

(i) The employer, when selecting a contractor, shall obtain and evaluate information regarding the contract employer’s safety performance and programs.

(ii) The employer shall inform contract employers of the known potential fire, explosion, or toxic release hazards related to the contractor’s work and the process.

(iii) The employer shall explain to contract employers the applicable provisions of the emergency action plan required by paragraph (n) of this section.

(iv) The employer shall develop and implement safe work practices consistent with paragraph (f)(4) of this section, to control the entrance, presence and exit of contract employers and contract employees in covered process areas.

(v) The employer shall periodically evaluate the performance of contract employers in fulfilling their obligations as specified in paragraph (h)(3) of this section.


(vi) The employer shall maintain a contract employee injury and illness log related to the contractor’s work in process areas.

(3) Contract employer responsibilities.

(i) The contract employer shall assure that each contract employee is trained in the work practices necessary to safely perform his/her job.

(ii) The contract employer shall assure that each employee is instructed in the known potential fire, explosion or toxic release hazards related to his/her job and the process, and the applicable provisions of the emergency action plan.

(iii) The contract employer shall document that each contract employee has received and understood the training required by this paragraph. The contract employer shall prepare a record which contains the identity of the contract employee, the date of training, and the means used to verify that the employee understood the training.

(iv) The contract employer shall assure that each contract employee follows the safety rules of the facility including the safe work practices required by paragraph (f)(4) of this section.

(v) The contract employer shall advise the employer of any unique hazards presented by the contract employer’s work, or of any hazards found by the contract employer’s work.


• Suggestions for developing and implementing a Contractor Program

- Decide who will be responsible for developing and implementing the contractor program.

- Decide what procedures will be followed to select contractors and to evaluate a contractor’s safety performance and programs.

- Decide how you will inform contract employers of potential fire, explosion or toxic release hazards related to the ammonia refrigeration system.

- Develop and implement safe work practices for controlling the entrance, presence, and exit of contract employees into the process area.

- Establish procedures to periodically review the work and safety performance of contract employers working at the facility.

- Develop a contract employee injury and illness log relating to the contract employer’s work in the process area.

- Prepare a written contractor program.


• Training documentation

- Hazards of the process (employer responsibility)

- Facility safety rules (employer responsibility)

- Emergency Action Plan (employer responsibility)

- Safely perform job task (contractor responsibility)

Common Pitfalls of PSM Programs:Management of Change & Pre-Startup Safety Review

• MOC and PSSR often go hand – in – hand.

- Regulatory Requirements:

• (1) The employer shall establish and implement written procedures to manage changes (except for “replacements in kind”) to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.

• (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 in the process safety information.


• Common Issues

- Make sure the written program reflects actual practices

- Missing documentation

- Incomplete documentation

- No follow through updating PSI documentation, procedures, training


- Consider modifying the MOC form to identify specific PSI that might need updating when a change is made and developing a “Commissioning Checklist”


• Second most cited element, NEP inspections FY14 thru FY16

Common Pitfalls of PSM Programs:Mechanical Integrity

• Citation detail


• Equipment specific guidelines for inspections, tests, and maintenance procedures- Compressor Installation, Operation, and Maintenance (IOM) manuals

- Evaporators IOM manuals

- Condenser IOM manuals

- Refrigerant Pump IOM manuals

- Ammonia Detection IOM manuals


• Non-equipment specific guidelines for inspections, tests, and maintenance procedures- IIAR Bulletin No. 109 Guidelines for: IIAR Minimum Safety Criteria for a

Safe Ammonia Refrigeration System

- IIAR Bulletin No. 110 Guidelines for: Start-up, Inspection and Maintenance of Ammonia Mechanical Refrigerating Systems

• IIAR 6-201x Standard for Inspection, Testing, and Maintenance of Safe Closed-Circuit Ammonia Refrigeration Systems (currently under public review)

– This proposed standard specifies minimum criteria for inspection, testing, and maintenance of closed-circuit ammonia mechanical refrigeration systems, including the ammonia side of a cascade refrigeration system.


• Inspections mean NOTHING if they’re not documented.

- Document all your inspections, tests and MI deficiencies corrections.

Regulatory Requirement:- (iv) The employer shall document each inspection and test that has been

performed on process equipment. The documentation shall identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test.

• Add the tracking systems necessary to follow through on maintenance activities, inspections, and other changes that have been identified as necessary.

Common Pitfalls of PSM Programs:Emergency Planning & Response

• Does the facility have an emergency action plan?

- Is the plan up to date?

- Is the plan reviewed and updated on a regular basis?

- Is the plan readily available to employees?


• Does the plan include, at a minimum, the following:

- Escape procedures and routes?

• Exit doors marked, lighted?

• Exit routes clear?


- Procedures for post-evacuation employee accounting?

- Preferred means to report emergencies?

- Duties and procedures of employees who remain to operate critical equipment?

- Perform rescue and medical duties?

- The names for persons or locations to contact for more action plan information?

- Employee alarm systems?


• Are evacuation maps and signs posted throughout the facility?

• Are employees trained?

- Initially, when the plan is developed?

- During their initial site orientation?

- During regular refresher training?

- Whenever their responsibilities change?

- Whenever the plan changes?

- Documented?


1910.38(d)

- Employee alarm system: An employer must have and maintain an employee alarm system. The employee alarm system must use a distinctive signal for each purpose and comply with the requirements in § 1910.165.


• Are the alarms:- Distinctive and recognizable for each purpose of the alarm?

- Can they be heard above ambient noise and light levels by all employees in the affected portions of the workplace?

- Are procedures to initiate the alarm clearly established?

- Does the alarm take priority over routine communication?

- Are emergency telephone number/instructions posted?

- Are manual alarms unobstructed, conspicuous, and readily accessible?

- Maintained in operating condition?

- Tested appropriately and restored to normal operating condition as soon as possible after test?

- Non-supervised systems tested not less than every two months?

- Supervised systems tested at least annually?

- Serviced, maintained, and tested by appropriately trained persons?


• If the facility DOES NOT respond to emergencies:

- Is the facility included in the community emergency response plan? (frequent violation)

- Are there mechanisms in place to notify emergency responders?

- Are there procedures for handling small releases?

Common Pitfalls of PSM Programs:Compliance Audit

• Action items that were generated from the previous audit have not been closed out in time for the next audit cycle.

• Audits have not been conducted every three years as required by the PSM Standard.

Common Pitfalls of PSM Programs:ANSI/IIAR 2-2014 Eyewash and Safety Shower Requirements

• ANSI/IIAR 2-2014 §6.7.1 General- Each machinery room shall have access to a minimum of two

eyewash/safety shower units, one located inside the machinery room and one located outside of the machinery room, each meeting the requirements in Section 6.7.3. Additional eyewash/safety shower units shall be installed such that the path of travel in the machinery room is no more than 55 ft to an eyewash/safety shower unit.

• ANSI/IIAR 2-2014 §6.7.2 Path of Travel- The path of travel within the machinery room to at least one

eyewash/safety shower unit shall be unobstructed and shall not include intervening doors.


• ANSI/IIAR 2-2014 §6.7.3 Installation Standard- Emergency eyewash/safety shower unit installations shall comply with

ANSI/ISEA Z358.1.

- The requirement for two (2) eyewash/safety shower units (inside and outside) represents a change compared to ANSI/IIAR 2-2008 Addendum B §13.1.6.1 which required that “an eyewash and body shower unit shall be located external to the machinery room and readily accessible via an exit. Note: It is recommended that additional such units be located accessibly inside or outside the machinery room such that no unit is further than 10 seconds or 55 feet [16.8 m] from a hazard. Refer to ANSI/ISEA Z358.1-2009 for eyewash equipment guidelines.”


• Per the request of IIAR, OSHA has also provided helpful clarification regarding the location of eyewash and safety showers throughout the facility.

- Question #1: Would OSHA accept the use of personal protective equipment in lieu of permanent or portable eyewash/safety showers in cold environments? • Reply #1: No. OSHA would not accept the use of personal protective equipment

in lieu of eyewash/safety showers regardless of the environment. Further, there are emergency eye wash and safety shower products that have built-in heating elements for maintenance operations in cold environments.


- Question #2: If the ammonia refrigeration is in a sealed container (sic) where there is no intention of opening or repairing the pressure-containing envelope of the piping system, does 29 CFR 1910.151 (c) require an eyewash or emergency shower?

• Reply #2: No. However, as you recognized in your letter, for some maintenance operations, such as oil draining, equipment replacement, and valve and piping maintenance or repair, there is potential for exposure to ammonia. In those circumstances, the standard requires the employer to provide facilities for quick drenching or flushing of the eyes or body.

Common Pitfalls of PSM Programs:Final Thoughts

- Document your employee participation – don’t simply say you involve employees – have something to actually prove it.

- If you have listed chemicals (or others listed somewhere) that are below threshold amounts, remember that you are still subject to the general duty clause.


- Make sure your written program accurately reflects what you really do

- Make sure your supporting documentation actually reflects what is in your written plan

• Ensure all of your written documentation is up to date and filed in a format that is easily accessible

- Monitor your dates (i.e. annual operating procedure certification, reporting personnel changes, compliance audit due dates, re-submittal, etc.)

- Document ANY progress/ activity on required action items


- Inspections mean nothing if they’re not documented -document your inspections and inspection process.

- Document your emergency response drills & activities and appropriate follow up activities!

- Find someone to do your 3rd party audits that actually knows what they’re doing, and make sure they provide you with documentation necessary to fix what’s broke.

- Add the tracking systems necessary to follow through on maintenance activities, inspections, and other changes that have been identified as necessary.

Questions?

Documents

Lessons Learned: Common Pitfalls of PSM Programs