Put Process Safety First - chemicalprocessing.com … · 10. Establishing a quality assurance program to ensure that initial process-related equipment, maintenance materials and spare

Put Process Safety First

Process Safety eHANDBOOK

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TABLE OF CONTENTSTurn Up Process Safety Performance 6

Implementing an effective operational discipline program can help

Avoid Issues in Process Safety Management Compliance 16

Random inspections now make meeting all requirements even more crucial

Perform a Proper Pre-startup Safety Review 23

Protect personnel and processes by conducting a thorough review

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Even highly trained people make

mistakes Some errors have minor

consequences mdash but others poten-

tially can lead to catastrophic incidents

especially in a high-hazard chemical

process An effective process safety man-

agement (PSM) program anticipates that

people will make mistakes As Figure 1 [1]

depicts such a program includes the three

crucial elements process safety systems

that describe how to do work safely and

correctly a focus on safety culture and

leadership and an operational discipline

(OD) program to help ensure correct exe-

cution of system requirements and cultural

priorities every time

OD is essential to achieve excellent process

safety performance Excellent perfor-

mance means well-designed process

safety systems that function day-to-day as

intended and the prevention or effective

mitigation of incidents that could result in

fatalities serious injuries business interrup-

tion and environmental harm Of course

poorly designed or implemented process

Turn Up Process Safety PerformanceImplementing an effective operational discipline program can helpBy James A Klein ABSG Consulting Inc

FOUNDATION OF PROGRAMFigure 1 Three elements contribute to an effective process safety program Source Ref 1

safety systems and a weak organizational

safety culture can significantly undermine

the value of an OD program

The US Occupational Safety and Health

Administrationrsquos PSM regulation is over

25 years old and many companies in the

United States and elsewhere have imple-

mented PSM systems For several years

companies also have focused on safety

culture and leadership to help achieve their

process safety goals OD efforts mdash the com-

mitment by everyone in an organization to

always follow the systems and procedures

that have been developed mdash often receive

less attention but are crucial for reducing

human error If a company isnrsquot satisfied

with its process safety performance a new

or renewed effort on OD may represent one

of the best opportunities for improvement

HUMAN ERROR AND OD In an incident investigated by the US Chem-

ical Safety Board (CSB) [2] an operator

opened the bottom valve of an operating

polymerization reactor apparently bypassing

an active pressure interlock instead of open-

ing the bottom valve of a nearby reactor that

was being cleaned A large release of flam-

mable material from the reactor ignited the

resulting explosion led to five fatalities and

major damage to the facility The CSB con-

cluded among other findings that the facility

ldquodid not adequately address the potential for

human errorrdquo Of course human error often

is a major contributor to incidents [3 4] as

The KOA Sanitary Advantage line consists of high-quality

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Materials are made from 316L stainless steel with traceabil-

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shown by industry investigations of incidents

and near-misses

There are many causes of human error

Some common ones include [1]

bull human fallibility capability complacency

and commitment

bull training issues including procedure quality

and training effectiveness

bull workplace environment including accessi-

bility of information and distractions

bull familiarity with the work being done and

the time since it was last done

bull fitness-for-duty considerations such as

alcohol drugs stress and fatigue

bull urgency for completing a task quickly and

bull lack of risk recognition or sense

of vulnerability

The reality is that a company should antic-

ipate human error and provide appropriate

systems and safeguards to ensure errors

donrsquot lead to serious injuries and other

consequences especially if

work tasks include higher-risk

activities involving significant

process hazards OD addresses

human behavior in following

required systems and proce-

dures correctly every time to

consistently achieve safer and

more reliable operations Devel-

oping an OD program [5ndash9]

intended to support day-to-day

commitment by all company

personnel mdash in combination with

well-designed process safety systems and

a strong safety culture mdash can help both to

minimize the potential for human error and

confirm that process safety (and other) pro-

gram requirements are rigorously followed

A strong OD program can provide benefits

in a variety of areas [1] including

bull Environmental health and safety mdash pre-

vention or reduction of workplace injuries

occupational exposures process incidents

environmental releases and associated costs

bull Operations mdash decrease in unscheduled

shutdowns poor process utilization

inefficient use of staff incident-related

downtime and associated costs and

bull Quality mdash reduction in off-specification

product rework and waste lower yields

poor quality customer complaints and

associated costs

The safety triangle (Figure 2) illustrates

qualitatively that significant consequences

SAFETY TRIANGLEFigure 2 Minimizing lapses lower in the triangle often can help forestall more-serious events Source Ref 1

Catastrophic IncidentsInjuries

Serious IncidentsInjuries

Minor IncidentsInjuries

Near-misses

Unsafe Acts

Undesirable Acts

Focus of Operational Discipline

such as serious injuries or catastrophic inci-

dents (at the top of the triangle) often (but

not always) are the result of or predicted

by a larger number of smaller near-miss

events or unsafe acts and behaviors (at the

bottom of the triangle) Focusing on min-

imizing or eliminating potential problems

frequently can help prevent the more-se-

rious events An effective OD program

works to reduce undesirable actions at

the bottom of the triangle by encouraging

and supporting correct actions in follow-

ing program systems and procedures

This is especially important for higher-risk

activities involving significant process (or

other) hazards where the base of the tri-

angle may be very narrow mdash meaning that

even one mistake or unsafe action can lead

directly to a serious injury or other conse-

quence Ultimately OD programs aim to

help reduce the frequency and associated

risks of human error

PROGRAM CHARACTERISTICSA program must focus on both orga-

nizational and personal OD [167]

Organizational OD involves developing

the programs and work environment to

support strong OD as well as providing

resources for OD improvement efforts

Organizational OD efforts closely relate

to good safety culture and leadership

practices and supplement associated

management systems to promote and

achieve program goals Personal OD

characteristics target worker activities

at all levels of the organization to ensure

workers know what they need to do and

perform their work correctly and safely

every time

Good OD performance doesnrsquot happen on

its own It requires continued management

attention [7] mdash to demonstrate personal

attention and dedication provide appropri-

ate resources as needed implement and

use effective systems monitor and evalu-

ate actual performance and develop and

support effective processes to facilitate

employee understanding engagement and

follow-through

Organizational OD possesses four charac-

teristics [1]

bull Leadership focus Leaders emphasize and

provide a positive work environment

managing processes and resources for

effective programs and employee engage-

ment Leaders are personally involved

and passionate for safety and model the

behaviors they expect from everyone in

their organization

Leadership focus provides the foundation of any OD program

bull Employee engagement Employees at all

levels of the organization understand

and value the importance of safe work

activities and contribute to organizational

programs and activities

bull Procedure principles Correct ways of

doing work are defined and work is com-

pleted as planned following reviewed and

authorized systems and procedures

bull Housekeeping and workplace standards

Standards are established for maintain-

ing safe equipment tools and facilities

Employees are proud of their work envi-

ronment and consistently maintain high

levels of housekeeping

While related to safety culture these

characteristics serve to emphasize the OD

aspects of effective programs Leadership

focus provides the foundation of any OD

program mdash without it priority and support

for OD improvement canrsquot exist Leader-

ship also must promote strong employee

engagement too many uninvolved or

uninterested employees will limit an

organizationrsquos ability to achieve robust

performance An important part of lead-

ership focus therefore is providing the

culture and work environment to engage

employees at all levels of the organization

involving them as active participants in

safety programs and in achieving strong

performance The most visible results of

leadership focus and employee engage-

ment are employees following approved

systems and procedures operating

equipment within safe operating limits

and maintaining equipment and work

areas in safe operating condition

Personal OD has three characteristics [6]

bull Knowledge The employee understands

how to do the work task correctly

and safely

bull Commitment The person commits to

doing the tasks the right way every time

bull Awareness The individual anticipates

potential problems and recognizes

unusual situations

As Figure 3 highlights all three personal

characteristics are essential for achieving

high levels of OD performance a deficit in

one area can increase the risk of an error

The goal is to have a prepared skilled and

suitable work effort that can effectively

and safely deal with the existing work

environment rather than an unquestioning

focus on strict adherence to procedure

PERSONAL CHARACTERISTICSFigure 3 A deficit in any one area can undermine OD performance Source Ref 6

Knowledge Commitment

Awareness

when circumstances differ or change Of

course procedures and training should

cover possible deviations and the correct

ways to respond to them to help mitigate

any potential negative consequences

Efforts on personal OD necessarily relate

to other major programs for reducing

human error including human factors

analysis behavior-based safety human

performance technology and human reli-

ability assessment

ELEMENTS OF AN EFFECTIVE PROGRAMOD issues and problems typically are spe-

cific to an organization and local site often

varying in priority widely within

the same organization or facility

based on different safety cul-

tures leadership work activities

hazards geographic locations

and other factors While common

issues may exist within a larger

organization mdash for example no

current focus on OD mdash improve-

ment activities which should not

be prescriptive must be evaluated

locally to help identify and prior-

itize improvement opportunities

and goals For example one site

may have poorly developed pro-

cedures while another site may

lack housekeeping standards

Both factors can affect OD perfor-

mance but improvement requires

different approaches Effective

OD programs depending on the size of the

organization or site should consider one

umbrella goal for example implementing

an OD improvement program mdash but the

details of specific activities for achieving

better OD should be developed prioritized

and pursued based on specific local condi-

tions and issues as appropriate

Figure 4 [1] shows a recommended

approach for developing an effective OD

program The primary steps include

bull Focusing on OD improvement Without

specific management attention organi-

zationally and locally OD is unlikely to

improve in a sustained way

IMPLEMENTATION STEPSFigure 4 Following this approach can foster the development of an effective OD program Source Ref 1

Sustain improvements

Incidents Injuries Metrics

Self-assessment Surveys

Focus on OD improvement

Raise OD awareness

Prioritize improve-ments set goals and

provide resources

Evaluate OD performance

Monitor progress

bull Raising OD awareness Introduce all

employees to what OD is and why itrsquos

important You can do this by discussing

OD with employees in special workshops

or meetings safety meetings shift meet-

ings etc reinforcement day-to-day in

the workplace by management atten-

tion and practices is important Solicit

employee input on OD to help raise

awareness and identify specific issues

causes and possible solutions for fur-

ther evaluation

bull Evaluating OD performance Assess

current OD performance to establish a

starting point and identify potential OD

improvement opportunities based on

review of performance metrics incident

data audit results quality data and

potentially targeted surveys

bull Prioritizing OD improvements Focus on

key areas for enhancing performance

and opportunities that can produce

tangible results quickly Engage site

employees for input establish specific

goals and timing milestones and provide

resources Given the many competing

priorities for resources itrsquos generally

better to limit the initial number of

projects to help ensure success Then

identify and add new projects as current

ones finish

bull Monitoring progress Establish metrics

to check progress toward improvement

goals and schedule periodic manage-

ment reviews to support successful

project completion Also pay attention

to the greater work environment and

when appropriate modify project goals

based on new informationconditions

Recognize progress and successful proj-

ect completion and continue to engage

employees to support and provide input

on progress

bull Sustaining improvements As proj-

ects are successfully completed there

always will be additional improvement

opportunities Periodically repeat the

previous steps as needed to identify

prioritize and implement new projects

Ensure that gains made are supported

and preserved

Making significant progress on improv-

ing OD takes time A mix of projects

to achieve quick and relatively easy

improvements as well as longer-term

more-substantial progress is ideal to

establish value for the OD effort and

build momentum For example simpler

projects such as developing checklists

for higher-risk activities take less time

than needed for larger projects such as

Making significant progress on improving OD takes time

significantly revising operating procedures

or adding evaluation of OD in incident

investigations or audits

Improving OD is a continuous process It

involves a repeating cycle of identifying

completing and sustaining opportunities

and then pinpointing new opportunities to

pursue You always must assess changes

to technology operations hazards etc

these may provide additional needs for

OD program efforts

A variety of similar approaches are avail-

able for spurring organizational change

Here as an example are the best prac-

tices for leadership efforts to implement

and sustain effective OD programs in the

FLAME model [1]

bull Focus Develop a vision to enable

appropriate focus on OD effectively com-

municate it to develop awareness and

engage site personnel and provide daily

reinforcement through leadership atten-

tion and priorities

bull Leadership Leaders act as role models

committed to continuous improvement

and excellent OD performance through

use of effective consistent leader-

ship practices

bull Accountability Organization team and

individual goals include a focus on OD

with clear expectations on performance

feedback and recognition as appropriate

bull Measurement Metrics audits and other

tools are defined to periodically assess

site activities performance and progress

toward goals

bull Engagement Leaders provide a work

environment that fosters the engage-

ment and support of site personnel

based on good communication pro-

cesses employee input and involvement

and interdependent behaviors Site

personnel know they are important to

success and that their contributions

are valued

It may make sense to assign an OD

leader to give additional focus and

accountability on achieving an effective

program especially for larger companies

or facilities Ultimately the OD program

should provide

bull Tools to document and support effec-

tive work practices such as procedures

checklists fitness-for-duty programs

management systems etc

bull Training both initially and via periodic

refreshers to confirm that workers

understand how to complete their work

correctly and safely build value and

commitment for following established

procedures and systems every time

and support workers in anticipating and

planning for potential work problems

bull Time for building capability and experi-

ence completing work in a timely manner

and maintaining awareness of the work

environment

A VALUABLE PROGRAMPeople make mistakes sometimes with

potentially catastrophic consequences

Effective process safety programs mdash built

on foundations of safety culture and

leadership management systems and

operational discipline mdash anticipate and

manage the likelihood of human error

As Jim Collins stated in ldquoGood to Greatrdquo

[10] ldquoSustained great results depend

upon building a culture of self-disciplined

people who take disciplined actionrdquo If

your metrics tell you that improved pro-

cess safety performance is desirable to

meet company goals then an effective

OD effort as part of your process safety

program may provide the greatest oppor-

tunity for improving performance

JAMES A KLEIN is Minneapolis-based senior

consultant for ABSG Consulting Inc Email

him at jkleinabsconsultingcom

REFERENCES1 Klein James A and Vaughen Bruce K

ldquoProcess Safety Key Concepts and Practical

Approachesrdquo CRC Press Boca Raton Fla

(2017)

2 ldquoVinyl Chloride Monomer Explosionrdquo Report

No 2004-10-I-IL US Chem Safety Bd

Washington DC (2007)

3 Kletz Trevor ldquoAn Engineerrsquos View of Human

Errorrdquo 3rd ed CRC Press Boca Raton Fla

(2001)

4 ldquoGuidelines for Preventing Human Error in

Process Safetyrdquo Ctr for Chem Proc Safety

AIChE New York City (1994)

5 Klein James A ldquoOperational Discipline in the

Workplacerdquo Proc Safety Progr pp 228ndash235

Vol 24 No 4 (Dec 2005)

6 Klein James A and Vaughen Bruce K ldquoA

Revised Model for Operational Disciplinerdquo

Proc Safety Progr pp 58ndash65 Vol 27 No 1

(March 2008)

7 Klein James A and Francisco Eduardo M

ldquoFocus on Personal Operational Discipline to

Get Work Done Rightrdquo Proc Safety Progr

pp 100ndash104 Vol 31 No 2 (June 2012)

8 ldquoConduct of Operations and Operational

Disciplinerdquo John Wiley amp Sons Hoboken NJ

(2011)

9 Vaughen Bruce K Klein James A and

Champion John C ldquoOur Process Safety

Journey Continues Operational Discipline

Todayrdquo Proc Safety Progr pp 478ndash492

Vol 37 No 4 (Dec 2018)

10 Collins Jim ldquoGood to Great Why Some

Companies Make the Leaphellip And Others

Donrsquotrdquo HarperBusiness New York City

(2001)

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copy R

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PROTECTYOUR

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A 1984 event shattered any concepts

of how much tragedy could occur

from a single industrial incident

such as a chemical leak Until then most

Americans probably never had heard of

the city of Bhopal India However a leak

in December of that year became known

forever simply as the Bhopal Disaster

Approximately 45 tons of dangerous methyl

isocyanate gas escaped from an insecti-

cide plant and spread airborne to heavily

populated areas thousands were killed and

countless others suffered health effects

Bhopal had a major impact on current and

future generations in the United States through

the Process Safety Management (PSM) regula-

tion set forth by the US Occupational Safety

and Health Administration (OSHA)

Simply stated its purpose is to regulate

highly hazardous chemicals (HHCs) to

reduce the possibility of or completely

prevent such a major chemical-related

incident from occurring again OSHA

Standard 29 CFR 1910119 focuses strictly

on potentially lethal HHCs not low-

risk releases

In addition the US Environmental Pro-

tection Agency (EPA) created a Risk

Management Program (RMP) as part of

the Clean Air Act in response to major

chemical accidents in Bhopal and Institute

West Virginia

OSHA promulgated its final PSM standard

on February 24 1992 and the EPA issued its

RMP rule on June 20 1996

Avoid Issues in Process Safety Management ComplianceRandom inspections now make meeting all requirements even more crucialBy Adam Jackson ACS Engineering

Both OSHA and the EPA essentially were on

the same track in moving to protect plant

workers and the public from HHC releases

The EPArsquos RMP has four sections offsite

consequence analysis where companies

must outline worst-case scenarios five-year

accident history (detailing only the most

serious accidents) prevention program

(similar to OSHArsquos PSM) and emergency

response program Many facilities mistakenly

think EPA and OSHA prevention programs

are the same However OSHArsquos PSM remains

the driving force in preventing or mitigat-

ing high-risk chemical release incidents

As stated by OSHA ldquoThe main purpose of

PSM of hazardous chemicals is to prevent

unwanted releases of hazardous chemicals

especially [where] employees and others

[could be exposed] to serious hazards An

effective PSM program requires a systematic

approach to evaluating the whole chemical

processrdquo The single overriding point is that

a facility canrsquot exceed a threshold of certain

chemicals found on OSHArsquos HHC list

KEY ELEMENTS OF COMPLIANCEThe first step in a PSM program is properly

understanding its fourteen essential com-

ponents mdash because compliance isnrsquot a brief

a-b-c exercise but may pose quite a few

challenges According to OSHA all the ele-

ments are interlinked and interdependent

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The series is available in four variants either one- or two-

headed and connected in series or parallel as a vacuum pump

or as a compressor All models come with EPDM or chemically

resistant PTFE-coated diaphragms for durability They handle ambient and media temperatures

down to 41 degF (5 degC) Head water cooling systems make them suitable for use at ambient and

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In brief the 14 components are

1 Compiling adequate process safety

information This requires developing

and maintaining written safety materials

identifying workplace processes and

equipment issues

2 Conducting a process hazard analysis

The assessment may include pinpointing

potential accidental release sources deter-

mining the location of previous releases

that could have become catastrophic and

estimating effects of such releases

3 Consulting with employees about assess-

ments and chemical accident prevention

plans and providing appropriate access

to these materials

4 Setting up a system to respond to work-

place hazard-assessment findings

5 Reviewing the workplace hazard and

response system

6 Developing written procedures for the

chemical processes including procedures

for each operating phase operating limita-

tions and safetyhealth considerations

7 Providing written safetyoperating infor-

mation and training for employees

8 Giving contractors and contract employ-

ees appropriate information and training

9 Educating and training employ-

ees and contractors in emergency

response procedures

10 Establishing a quality assurance program

to ensure that initial process-related

equipment maintenance materials and

spare parts are fabricated and installed

consistent with design specifications

11 Creating maintenance systems for criti-

cal process-related equipment to ensure

ongoing mechanical integrity

12 Performing pre-startup safety

reviews of all newly installed or modi-

fied equipment

13 Putting in place written procedures for

change management relative to pro-

cess chemicals technology equipment

and facilities

14 Investigating every incident resulting in

or that could have resulted in a major

accident and reviewing findings for

modifications they may suggest

Because OSHArsquos PSM program deals with

such a serious issue HHCs the penalties

for non-compliance can be steep Compa-

nies may incur fines of up to $500000 and

individuals may get hit with fines of up to

$250000 for wide-ranging non-compli-

ance including reportable releases injuries

and even simply not meeting paperwork

requirements Additionally they may face

civil lawsuits and in a worst-case scenario a

company may be forced to shut down

Given the complexities involved compa-

nies canrsquot address compliance simply on

an ad-hoc or low-priority basis but should

develop a risk mitigation program to satisfy

OSHArsquos PSM

OSHA stresses that companies canrsquot meet

compliance standards on a shoestring

budget and should allocate approximately

3 of gross revenue to the task OSHA

actually affords companies some flexibil-

ity in spending Over a five-year period

large companies should spend 11 of

their gross revenue and small compa-

nies 32 These arenrsquot rigid figures but

underscore that compliance should not

be unbudgeted or have an unrealistically

low budget

Every company subject to PSM should

designate a suitable individual to be in

charge during the entire compliance pro-

cess Typically most companies lack a

ldquoglove fitrdquo employee but at chemical

companies the person chosen preferably

should be an engineer ideally one special-

izing in mechanical integrity If a company

doesnrsquot have an appropriate individual

a common-sense approach is to retain a

PSM engineering consultant with at least

five years of experience The consultant

may continue on a permanent basis or

temporarily until the company can fill the

position internally

Finally a crucial element in every PSM

compliance process is developing a

cost-effective and reasonable plan for

accomplishing the goals Success is ldquoall

in the detailsrdquo Companies find that a

well-managed highly functional program

more than meets expectations for being

in compliance and avoiding penalties In

other words effective management is key

to compliance

COMMON MISTAKES The road to compliance can lead to many

potential wrong turns Indeed companies

make a number of common mistakes Letrsquos

look at six and how to remedy them

bull Believing training of everyone is the

all-purpose answer Itrsquos not After training

companies must effectively police the

system to help ensure that all the compli-

ance efforts are proceeding as intended

bull Over-emphasizing efficiency Too many

projects appear to fly through hazard and

operability (HAZOP) reviews but donrsquot

work once they are completed Focus on

the details and take the time to do the

job right

bull Taking the attitude that ldquoanything within

the fence line is considered by the com-

pany to be part of PSMrdquo Although an

interesting concept it can create prob-

lems Once such a policy is formally

stated regulatory inspectors must accept

the policy at face value which may be

to the companyrsquos detriment Re-evaluate

what actually applies to PSM

bull Failing to consider the Facility Car Seal

Program (which mandates that all pres-

sure valves must be car sealed open) as

part of PSM Realistically to be effective

a car seal program must be regularly

verified documented and audited Con-

sider any car seal found broken or any

safety-critical manual valve found in an

improper position as a PSM ldquonear missrdquo

bull Not performing mechanical integrity

inspections on schedule Many people

clearly understand the potential negative

consequences but delays still happen

all too often Audits usually reveal that

a percentage of pressure vessel tank

instrument and rotating equipment

inspections are overdue Companies

should recognize this reality and take

the appropriate action When an inspec-

tion must be postponed initiate a

management-of-change procedure to

determine what if any additional safe-

guards are required until the delayed

inspection occurs If overdue inspec-

tions are a continuing problem perform

a formal root cause analysis to deter-

mine why

bull Paying inadequate attention to compe-

tency standards These are expressed

in terms of outcome and specify both

the knowledgeskill necessary and its

appropriate application for adequate per-

formance in the workplace When properly

addressed competency assurance can

lead to significant improvements and

ensure requirements are met For more on

this topic check out ldquoDiscover the Bene-

fits of a Competency-Based Approachrdquo

httpgooglDeL9fs

A RECENT WRINKLEAs sometimes occurs with major reg-

ulations details get fine-tuned or

substantially revised over time Between

the mid-1990s and 2007 the PSM pro-

gram spurred improvements but some

catastrophic incidents still occurred So

OSHA decided to revise the PSM National

Emphasis Program (NEP)

In 2011 a new Chemical NEP went into effect

following the success of a pilot program for

the petroleum industry that was implemented

in 2007 Identified as OSHA Instruction CPL

03-00-14 PSM Covered Chemical Facilities

National Emphasis Program it generally is

called CHEMNEP The NEP for refineries and

CHEMNEP which are similar but not identical

programs both involve an in-depth look at

the now well-known fourteen major elements

As a whole CHEMNEPrsquos intent is to conduct

focused inspections at randomly selected

facilities nationwide chosen from a listing

of sites that likely have covered processes

Because the pilot CHEMNEP uncovered

many problems similar to those discovered

in the Petroleum NEP OSHA expanded the

program nationally both to increase aware-

ness of dangers and push employers more

forcefully toward preventing HHC releases

The ldquotop tenrdquo points to know about the new

CHEMNEP for chemical plant operators in

no ranking order are

bull It became effective immediately with no

expiration date

bull CHEMNEP now encompasses all OSHA

regions Unlike the pilot programs chemi-

cal plant operators must participate

bull Targets include types of workplaces simi-

lar to those in the pilot that had submitted

Program 3 Risk Management Plans to the

EPA have an NAICS code for explosives

manufacturing are in OSHArsquos data-

base for being cited previously for PSM

issues and are known to be operating a

PSM-covered process

bull In determining what to inspect OSHA will

select the ldquomost hazardous processrdquo based

on several factors including age chemical

quantity in the process how many workers

and contractors are present ongoing main-

tenance and incident or ldquonear missrdquo reports

bull Each OSHA office nationally must

complete 3ndash5 programmed CHEMNEP

inspections annually mdash one must relate

to ammonia refrigeration and the rest to

ldquootherrdquo PSM-covered processes

bull OSHA stresses that implementation out-

weighs documentation

bull The new CHEMNEP features dynamic list

questions which rotate from time to time

and arenrsquot disclosed publicly

bull Employers must produce multiple types

of documents including a listing of

PSM-covered processes itemization of

the plantrsquos units and maximum-intended

inventories three years of OSHA 300

logs summary description of the compa-

nyrsquos PSM program details about process

and safety systems and PSM incident

reports for selected units

bull Even a single issue potentially may yield

multiple citations For example one

valve change could impact eleven differ-

ent elements

bull Abatement verification and documen-

tation now are mandatory unlike in the

pilot NEP

EMBRACE PSM COMPLIANCE The very concept of regulation especially

in the industrial sector typically engen-

ders only grudging compliance out of

necessity and threats of penalties Yet

few events galvanize such support for

change and regulation as did the Bhopal

and Institute tragediesrsquo heavy loss of life

and widespread non-fatal injuries So

although OSHArsquos PSM doesnrsquot garner uni-

versal acclaim the chemical industry and

other industries with potential for major

HHC incidents largely support it

Likewise while critics may complain that

any regulation is too complicated or dis-

tracts too much from work devoted to

profitability the general consensus on

PSM is that continuing to do ldquobusiness

as usualrdquo puts employees and the public

at needless risk from HHCs and a new

direction had to be taken because the

issue is just too important Following the

PSM regulations can be done sensibly

either internally or by calling in outside

experts

ADAM JACKSON is vice president engineering and

technical services for ACS Engineering Houston

E-mail him at adamjacksonacsengineeringcom

Reaction Calorimetry

wwwfauskecom infofauskecom +1 630 323 8750

bull THT-RCbull Mettler-Toledo RC1bull ChemiSens CPA 202

To determine required cooling capacity understand process changes and scale-up implications FAI performs reaction calorimetry using

Safety Parameters Obtainedbull Heat of Reactionbull Instantaneous Heat Flowbull Heat Capacitybull Kinetics

bull Adiabatic Temperature Risebull Maximum Temperature of Synthetic Reaction (MTSR)bull Pressure Relief Vent Size

Key Uses Understanding thermal potential of desired reactions designing cooling systems scale-up and process optimization by adjusting temperature recipe and addition rates

Adiabatic amp Isothermal Calorimetry

To determine critical safety parameters to avoid undesired reactions FAI performs heat flow and adiabatic calorimetry using

bull Vent Sizing Package 2 (VSP2TM)

bull Advanced Reactive System Screening Tool (ARSSTTM)

bull Thermal Activity Monitor (TAM)

bull Setaram C80bull Accelerating Rate Calorimeter (ARCreg)bull Differential Scanning Calorimeter (DSC)bull Thermal Gravimetric Analysis (TGA)

Safety Parameters Obtainedbull Activation Energybull Rate Constantsbull Non-Condensable Gas Generationbull Vapor Pressure

Key Uses Thermal hazard screening compatibility studies safe operating temperatures (TMR ADT24) safe transport (SADT) quantify shelf life oxidation studies emergency relief system (ERS) design and process scale-up

Ref Stoessel Thermal Safety of Chemical Processes

Thermal hazards testing aims to collect reaction rate data to assess whether a specified quantity of a material can be safely used while avoiding runaway chemical reactions This data is important when considering processing long-term storage or shipping of a material Fauske amp Associates LLC (FAI) uses many tools to understand and eliminate undesired reactions accommodate process upset scenarios and optimize a clientrsquos desired process chemistry A list of tools and their applications are provided below

FAUSKEamp A S S O C I A T E S L L C

Thermal Hazards Testing

FAIrsquosAdvanced Reactive

System Screening Tool (ARSST)

FAIrsquosVent SizingPackage 2

(VSP2)

bull Heat of Reaction of Desired and Undesired Reactions

bull Measured Adiabatic Temperature Rise

bull Pressure Relief Vent Size

A pre-startup safety review (PSSR)

is a critical element of the pro-

cess safety management (PSM)

program mandated by the United States

Occupational Safety and Health Admin-

istration (OSHA) However due to time

constraint and budget pressures the temp-

tation to rush or completely neglect the

PSSR often exists

OSHA implemented the PSM program in

1992 It spelled out the need for a PSSR

in 29 CFR (Code of Federal Regulations)

1910119(i)

1910119(i)(1) mdash The employer shall perform

a pre-startup safety review for new facilities

and for modified facilities when the mod-

ification is significant enough to require a

change in the process safety information

1910119(i)(2) mdash The pre-startup safety

review shall confirm that prior to the intro-

duction of highly hazardous chemicals to

a process

1910119(i)(2)(i) mdash Construction

and equipment is in accordance with

design specifications

1910119(i)(2)(ii) mdash Safety operating

maintenance and emergency procedures

are in place and are adequate

1910119(i)(2)(iii) mdash For new facilities a

process hazard analysis [PHA] has been

performed and recommendations have

been resolved or implemented before

startup and modified facilities meet the

requirements contained in management

of change paragraph (l)

Perform a Proper Pre-startup Safety Review Protect personnel and processes by conducting a thorough review before operating new or updated unitsBy John C Wincek DEKRA Process Safety

1910119(i)(2)(iv) mdash Training of each

employee involved in operating a process

has been completed

The PSSR frequently is the last line of

defense before bringing an updated or new

process online to ensure

bull It has been designed properly

bull The equipment and process information is

complete and available

bull The equipment is installed per the

bull A PHA has been conducted and associ-

ated documented recommendations have

been addressed

bull Documented safety operating mainte-

nance and emergency procedures are

adequate and complete

bull All training of operations personnel has

been finished

One item not specifically spelled out in

this regulation but probably included in

the intent for equipment is the safety

instrumented system (SIS) with associ-

ated distributed control system (DCS)

programmable logic controllers (PLC)

and stand-alone digital or analog con-

trollers and alarm systems It provides

alarms to alert operators if the process is

starting to get out of control and inter-

locks to take certain actions intervene

or even stop the process if necessary

Ensuring the automated valves associ-

ated process instrumentation alarms and

interlocks are active and functioning as

designed can require significant time and

effort before starting a new or updated

process or restarting a process after a

major shutdown

INCIDENTS UNDERSCORE IMPORTANCEIn March 2005 the BP Texas City refinery

suffered a major disaster that killed 15 and

injured more than 170 others (For details

see the report issued by the US Chemical

Safety Board (CSB) httpbitly2RumKXU)

BP hadnrsquot properly conducted safety criti-

cal checks The CSB investigators found an

inoperative pressure control valve a defec-

tive high-level alarm and an uncalibrated

sight-glass level transmitter as well as por-

table trailers with non-essential personnel

located too close to the process

In incidents at two other sites improperly

conducted PSSRs of process control and

system settings led to equipment and pro-

cess damage with financial and business

impact Fortunately neither caused deaths

or injuries

In the first event equipment manufactured

in Europe and shipped to the United States

had a 50-Hz motor setting remaining from

preliminary testing overseas That setting

should have been changed to 60 Hz for

US operations Failure to alter the set-

ting caused the motor to run slower and

resulted in a process shutdown due to high

temperature Operational steps taken while

cooling the process led to a propagating

fireball explosion that caused extensive

damage to the outdoor process equipment

and some siding on the building

In the other incident a manufacturing opera-

tion replaced a circuit board treating this as

an in-kind change although the board actu-

ally was an updated version The site didnrsquot

conduct a PSSR and thus didnrsquot uncover

that several critical interlocks werenrsquot oper-

ational due to the board replacement The

result was a damaged shaft plus repair and

replacement cost and the associated lost

production time (8ndash10 weeks)

Properly performed PSSRs would have

prevented these three events Ensuring

a thorough PSSR requires both qualified

employees and knowledgeable safe-

ty-minded management The PSSR also

should get reviewed and approved before

allowing processes to be brought online

or restarted

Effectively conducted PSSRs can prevent

incidents and the resultant harm to per-

sonnel equipment damage and loss of

production and profits According to OSHA

the ultimate responsibility lies with plant

or facility management to ensure a PSSR is

properly conducted before a covered pro-

cess is started

Unfortunately some common errors often

undermine efforts

bull failure to conduct a PSSR after process

modifications or a prolonged equip-

ment outage

bull assembling a team without the necessary

knowledge and skills to adequately per-

form the PSSR

bull skipping or forgetting parts of the PSSR

needed to ensure the process is com-

pleted and ready to start

bull omitting critical safety features from the

review or not checking them for proper

installation and operation and

bull lack of appropriate approval steps for the

PSSR before proceeding to start or restart

the process

Following good practices can help ensure

a PSSR is performed properly Five key

ones are

1 Assign a leader to be in charge of the

PSSR team This person should have

sufficient authority to delay the startup

if the team identifies a significant defi-

ciency Given that such a delay could

lead to a serious financial loss very

strong pressure to allow a deficient pro-

cess to start up may arise So the leader

must have the personality skills knowl-

edge determination and organizational

authority to resist such pressure

2 The leader should assemble an appropri-

ate multi-disciplined team of personnel

(design and construction engineering

instrument and controls maintenance

operations safety and supervisors) to

complete the PSSR and the additional fol-

low-up activities

3 The team should use a checklist or other

suitable PSSR form to verify all required

parts of the PSSR are completed

4 Ensure the team understands all the

process equipment subject to the PSSR

This should include tanks vessels reac-

tors mixers connecting piping etc as

appropriate as well as the associated

instrumentation and controls including

the DCS or PLC

5 If necessary consider using third-party

contractors and consultants to supply

necessary information or technical

expertise on the equipment or process

under review

A CRITICAL STEPA PSSR may resemble a hazard analysis

although itrsquos not aimed solely at identifying

new hazards Rather the PSSR is intended

to ensure the plant or process about to be

started is safe and operable

Donrsquot treat a PSSR as just an exercise in

filling out a form or ticking boxes on a

checklist Sometimes itrsquos necessary to per-

form nondestructive or other appropriate

tests on the equipment instrumentation

and control systems in the field before

starting a process You must do whatever

is required to have high confidence the

equipment and associated instrumentation

and control systems function properly as

designed and intended and critical safety

devices canrsquot be bypassed

A PSSR mainly serves for verification not

the identification of new hazards It pro-

vides the last opportunity for the team

associated with a project to ensure the

possibility of an unsafe condition doesnrsquot

exist before the process goes into opera-

tion and potentially hazardous chemicals

are introduced In addition it enables the

team responsible for the design operation

and maintenance of the process including

facility management to check mdash before

starting up mdash that effective procedures

have been written and the operators and

maintenance personnel have been trained

on the process

JOHN C WINCEK is consulting manager process safety

Americas for DEKRA Process Safety Princeton NJ

Email him at Johnwincekdekracom

Visit the lighter side featuring draw-

ings by award-winning cartoonist

Jerry King Click on an image and you

will arrive at a page with the winning

caption and all submissions for that

particular cartoon

ADDITIONAL RESOURCESEHANDBOOKSCheck out our vast library of past eHandbooks that offer a

wealth of information on a single topic aimed at providing

best practices key trends developments and successful

applications to help make your facilities as efficient safe

environmentally friendly and economically competitive

as possible

UPCOMING AND ON DEMAND WEBINARSTap into expert knowledge Chemical Processing editors

and industry experts delve into hot topics challenging

the chemical processing industry today while providing

insights and practical guidance Each of these free webi-

nars feature a live QampA session and lasts 60 minutes

WHITE PAPERSCheck out our library of white papers covering myriad

topics and offering valuable insight into products and solu-

tions important to chemical processing professionals From

automation to fluid handling separations technologies and

utilities this white paper library has it all

PROCESS SAFETY WITH TRISH amp TRACITrish Kerin director of IChemE Safety Centre and Chemical

Processingrsquos Traci Purdum discuss current process safety

issues offering insight into mitigation options and next steps

ASK THE EXPERTSHave a question on a technical issue that needs to be

addressed Visit our Ask the Experts forum Covering

topics from combustion to steam systems our roster of

leading subject matter experts as well as other forum

members can help you tackle plant issues

JOIN US ON SOCIAL MEDIA

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CHEMICAL PROCESSING

PRODUCT FOCUS

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environment

(2017)

(2001)

Vol 24 No 4 (Dec 2005)

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(2011)

Vol 37 No 4 (Dec 2018)

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West Virginia

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PSM-covered process

ent elements

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major shutdown

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cess is started

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the process

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PRODUCT FOCUS

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of vulnerability

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their organization

and safely

unusual situations

Awareness

ability assessment

Raise OD awareness

provide resources

Monitor progress

ther evaluation

ones finish

on progress

and preserved

OD program efforts

FLAME model [1]

tion and priorities

ship practices

toward goals

are valued

should provide

environment

(2017)

(2001)

Vol 24 No 4 (Dec 2005)

(March 2008)

(2011)

Vol 37 No 4 (Dec 2018)

(2001)

copy R

Ereg |

PROTECTYOUR

T +1 704 716 7022T +49 2961 7405-0

risk releases

West Virginia

PRODUCT FOCUS

equipment issues

to these materials

response system

response procedures

fied equipment

and facilities

OSHArsquos PSM

low budget

position internally

to compliance

job right

mine why

httpgooglDeL9fs

expiration date

PSM-covered process

ent elements

pilot NEP

experts

(VSP2)

PSSR often exists

1910119(i)

a process

has been completed

been addressed

been finished

major shutdown

or injuries

or restarted

cess is started

undermine efforts

ment outage

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the process

ones are

low-up activities

the DCS or PLC

under review

on the process

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as possible

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PRODUCT FOCUS

and near-misses

and commitment

of vulnerability

associated costs

Near-misses

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Undesirable Acts

every time

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teristics [1]

their organization

and safely

unusual situations

Awareness

ability assessment

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provide resources

Monitor progress

ther evaluation

ones finish

on progress

and preserved

OD program efforts

FLAME model [1]

tion and priorities

ship practices

toward goals

are valued

should provide

environment

(2017)

(2001)

Vol 24 No 4 (Dec 2005)

(March 2008)

(2011)

Vol 37 No 4 (Dec 2018)

(2001)

copy R

Ereg |

PROTECTYOUR

T +1 704 716 7022T +49 2961 7405-0

risk releases

West Virginia

PRODUCT FOCUS

equipment issues

to these materials

response system

response procedures

fied equipment

and facilities

OSHArsquos PSM

low budget

position internally

to compliance

job right

mine why

httpgooglDeL9fs

expiration date

PSM-covered process

ent elements

pilot NEP

experts

(VSP2)

PSSR often exists

1910119(i)

a process

has been completed

been addressed

been finished

major shutdown

or injuries

or restarted

cess is started

undermine efforts

ment outage

form the PSSR

the process

ones are

low-up activities

the DCS or PLC

under review

on the process

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as possible

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PRODUCT FOCUS

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and commitment

of vulnerability

associated costs

Near-misses

Unsafe Acts

Undesirable Acts

every time

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teristics [1]

their organization

and safely

unusual situations

Awareness

ability assessment

Raise OD awareness

provide resources

Monitor progress

ther evaluation

ones finish

on progress

and preserved

OD program efforts

FLAME model [1]

tion and priorities

ship practices

toward goals

are valued

should provide

environment

(2017)

(2001)

Vol 24 No 4 (Dec 2005)

(March 2008)

(2011)

Vol 37 No 4 (Dec 2018)

(2001)

copy R

Ereg |

PROTECTYOUR

T +1 704 716 7022T +49 2961 7405-0

risk releases

West Virginia

PRODUCT FOCUS

equipment issues

to these materials

response system

response procedures

fied equipment

and facilities

OSHArsquos PSM

low budget

position internally

to compliance

job right

mine why

httpgooglDeL9fs

expiration date

PSM-covered process

ent elements

pilot NEP

experts

(VSP2)

PSSR often exists

1910119(i)

a process

has been completed

been addressed

been finished

major shutdown

or injuries

or restarted

cess is started

undermine efforts

ment outage

form the PSSR

the process

ones are

low-up activities

the DCS or PLC

under review

on the process

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as possible

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PRODUCT FOCUS

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and commitment

of vulnerability

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their organization

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unusual situations

Awareness

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ther evaluation

ones finish

on progress

and preserved

OD program efforts

FLAME model [1]

tion and priorities

ship practices

toward goals

are valued

should provide

environment

(2017)

(2001)

Vol 24 No 4 (Dec 2005)

(March 2008)

(2011)

Vol 37 No 4 (Dec 2018)

(2001)

copy R

Ereg |

PROTECTYOUR

T +1 704 716 7022T +49 2961 7405-0

risk releases

West Virginia

PRODUCT FOCUS

equipment issues

to these materials

response system

response procedures

fied equipment

and facilities

OSHArsquos PSM

low budget

position internally

to compliance

job right

mine why

httpgooglDeL9fs

expiration date

PSM-covered process

ent elements

pilot NEP

experts

(VSP2)

PSSR often exists

1910119(i)

a process

has been completed

been addressed

been finished

major shutdown

or injuries

or restarted

cess is started

undermine efforts

ment outage

form the PSSR

the process

ones are

low-up activities

the DCS or PLC

under review

on the process

particular cartoon

as possible

Button 1

PRODUCT FOCUS

and near-misses

and commitment

of vulnerability

associated costs

Near-misses

Unsafe Acts

Undesirable Acts

every time

follow-through

teristics [1]

their organization

and safely

unusual situations

Awareness

ability assessment

Raise OD awareness

provide resources

Monitor progress

ther evaluation

ones finish

on progress

and preserved

OD program efforts

FLAME model [1]

tion and priorities

ship practices

toward goals

are valued

should provide

environment

(2017)

(2001)

Vol 24 No 4 (Dec 2005)

(March 2008)

(2011)

Vol 37 No 4 (Dec 2018)

(2001)

copy R

Ereg |

PROTECTYOUR

T +1 704 716 7022T +49 2961 7405-0

risk releases

West Virginia

PRODUCT FOCUS

equipment issues

to these materials

response system

response procedures

fied equipment

and facilities

OSHArsquos PSM

low budget

position internally

to compliance

job right

mine why

httpgooglDeL9fs

expiration date

PSM-covered process

ent elements

pilot NEP

experts

(VSP2)

PSSR often exists

1910119(i)

a process

has been completed

been addressed

been finished

major shutdown

or injuries

or restarted

cess is started

undermine efforts

ment outage

form the PSSR

the process

ones are

low-up activities

the DCS or PLC

under review

on the process

particular cartoon

as possible

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and near-misses

and commitment

of vulnerability

associated costs

Near-misses

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follow-through

teristics [1]

their organization

and safely

unusual situations

Awareness

ability assessment

Raise OD awareness

provide resources

Monitor progress

ther evaluation

ones finish

on progress

and preserved

OD program efforts

FLAME model [1]

tion and priorities

ship practices

toward goals

are valued

should provide

environment

(2017)

(2001)

Vol 24 No 4 (Dec 2005)

(March 2008)

(2011)

Vol 37 No 4 (Dec 2018)

(2001)

copy R

Ereg |

PROTECTYOUR

T +1 704 716 7022T +49 2961 7405-0

risk releases

West Virginia

PRODUCT FOCUS

equipment issues

to these materials

response system

response procedures

fied equipment

and facilities

OSHArsquos PSM

low budget

position internally

to compliance

job right

mine why

httpgooglDeL9fs

expiration date

PSM-covered process

ent elements

pilot NEP

experts

(VSP2)

PSSR often exists

1910119(i)

a process

has been completed

been addressed

been finished

major shutdown

or injuries

or restarted

cess is started

undermine efforts

ment outage

form the PSSR

the process

ones are

low-up activities

the DCS or PLC

under review

on the process

particular cartoon

as possible

Button 1

every time

follow-through

teristics [1]

their organization

and safely

unusual situations

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ability assessment

Raise OD awareness

provide resources

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ther evaluation

ones finish

on progress

and preserved

OD program efforts

FLAME model [1]

tion and priorities

ship practices

toward goals

are valued

should provide

environment

(2017)

(2001)

Vol 24 No 4 (Dec 2005)

(March 2008)

(2011)

Vol 37 No 4 (Dec 2018)

(2001)

copy R

Ereg |

PROTECTYOUR

T +1 704 716 7022T +49 2961 7405-0

risk releases

West Virginia

PRODUCT FOCUS

equipment issues

to these materials

response system

response procedures

fied equipment

and facilities

OSHArsquos PSM

low budget

position internally

to compliance

job right

mine why

httpgooglDeL9fs

expiration date

PSM-covered process

ent elements

pilot NEP

experts

(VSP2)

PSSR often exists

1910119(i)

a process

has been completed

been addressed

been finished

major shutdown

or injuries

or restarted

cess is started

undermine efforts

ment outage

form the PSSR

the process

ones are

low-up activities

the DCS or PLC

under review

on the process

particular cartoon

as possible

Button 1

and safely

unusual situations

Awareness

ability assessment

Raise OD awareness

provide resources

Monitor progress

ther evaluation

ones finish

on progress

and preserved

OD program efforts

FLAME model [1]

tion and priorities

ship practices

toward goals

are valued

should provide

environment

(2017)

(2001)

Vol 24 No 4 (Dec 2005)

(March 2008)

(2011)

Vol 37 No 4 (Dec 2018)

(2001)

copy R

Ereg |

PROTECTYOUR

T +1 704 716 7022T +49 2961 7405-0

risk releases

West Virginia

PRODUCT FOCUS

equipment issues

to these materials

response system

response procedures

fied equipment

and facilities

OSHArsquos PSM

low budget

position internally

to compliance

job right

mine why

httpgooglDeL9fs

expiration date

PSM-covered process

ent elements

pilot NEP

experts

(VSP2)

PSSR often exists

1910119(i)

a process

has been completed

been addressed

been finished

major shutdown

or injuries

or restarted

cess is started

undermine efforts

ment outage

form the PSSR

the process

ones are

low-up activities

the DCS or PLC

under review

on the process

particular cartoon

as possible

Button 1

ability assessment

Raise OD awareness

provide resources

Monitor progress

ther evaluation

ones finish

on progress

and preserved

OD program efforts

FLAME model [1]

tion and priorities

ship practices

toward goals

are valued

should provide

environment

(2017)

(2001)

Vol 24 No 4 (Dec 2005)

(March 2008)

(2011)

Vol 37 No 4 (Dec 2018)

(2001)

copy R

Ereg |

PROTECTYOUR

T +1 704 716 7022T +49 2961 7405-0

risk releases

West Virginia

PRODUCT FOCUS

equipment issues

to these materials

response system

response procedures

fied equipment

and facilities

OSHArsquos PSM

low budget

position internally

to compliance

job right

mine why

httpgooglDeL9fs

expiration date

PSM-covered process

ent elements

pilot NEP

experts

(VSP2)

PSSR often exists

1910119(i)

a process

has been completed

been addressed

been finished

major shutdown

or injuries

or restarted

cess is started

undermine efforts

ment outage

form the PSSR

the process

ones are

low-up activities

the DCS or PLC

under review

on the process

particular cartoon

as possible

Button 1

ther evaluation

ones finish

on progress

and preserved

OD program efforts

FLAME model [1]

tion and priorities

ship practices

toward goals

are valued

should provide

environment

(2017)

(2001)

Vol 24 No 4 (Dec 2005)

(March 2008)

(2011)

Vol 37 No 4 (Dec 2018)

(2001)

copy R

Ereg |

PROTECTYOUR

T +1 704 716 7022T +49 2961 7405-0

risk releases

West Virginia

PRODUCT FOCUS

equipment issues

to these materials

response system

response procedures

fied equipment

and facilities

OSHArsquos PSM

low budget

position internally

to compliance

job right

mine why

httpgooglDeL9fs

expiration date

PSM-covered process

ent elements

pilot NEP

experts

(VSP2)

PSSR often exists

1910119(i)

a process

has been completed

been addressed

been finished

major shutdown

or injuries

or restarted

cess is started

undermine efforts

ment outage

form the PSSR

the process

ones are

low-up activities

the DCS or PLC

under review

on the process

particular cartoon

as possible

Button 1

OD program efforts

FLAME model [1]

tion and priorities

ship practices

toward goals

are valued

should provide

environment

(2017)

(2001)

Vol 24 No 4 (Dec 2005)

(March 2008)

(2011)

Vol 37 No 4 (Dec 2018)

(2001)

copy R

Ereg |

PROTECTYOUR

T +1 704 716 7022T +49 2961 7405-0

risk releases

West Virginia

PRODUCT FOCUS

equipment issues

to these materials

response system

response procedures

fied equipment

and facilities

OSHArsquos PSM

low budget

position internally

to compliance

job right

mine why

httpgooglDeL9fs

expiration date

PSM-covered process

ent elements

pilot NEP

experts

(VSP2)

PSSR often exists

1910119(i)

a process

has been completed

been addressed

been finished

major shutdown

or injuries

or restarted

cess is started

undermine efforts

ment outage

form the PSSR

the process

ones are

low-up activities

the DCS or PLC

under review

on the process

particular cartoon

as possible

Button 1

(2017)

(2001)

Vol 24 No 4 (Dec 2005)

(March 2008)

(2011)

Vol 37 No 4 (Dec 2018)

(2001)

copy R

Ereg |

PROTECTYOUR

T +1 704 716 7022T +49 2961 7405-0

risk releases

West Virginia

PRODUCT FOCUS

equipment issues

to these materials

response system

response procedures

fied equipment

and facilities

OSHArsquos PSM

low budget

position internally

to compliance

job right

mine why

httpgooglDeL9fs

expiration date

PSM-covered process

ent elements

pilot NEP

experts

(VSP2)

PSSR often exists

1910119(i)

a process

has been completed

been addressed

been finished

major shutdown

or injuries

or restarted

cess is started

undermine efforts

ment outage

form the PSSR

the process

ones are

low-up activities

the DCS or PLC

under review

on the process

particular cartoon

as possible

Button 1

copy R

Ereg |

PROTECTYOUR

T +1 704 716 7022T +49 2961 7405-0

risk releases

West Virginia

PRODUCT FOCUS

equipment issues

to these materials

response system

response procedures

fied equipment

and facilities

OSHArsquos PSM

low budget

position internally

to compliance

job right

mine why

httpgooglDeL9fs

expiration date

PSM-covered process

ent elements

pilot NEP

experts

(VSP2)

PSSR often exists

1910119(i)

a process

has been completed

been addressed

been finished

major shutdown

or injuries

or restarted

cess is started

undermine efforts

ment outage

form the PSSR

the process

ones are

low-up activities

the DCS or PLC

under review

on the process

particular cartoon

as possible

Button 1

risk releases

West Virginia

PRODUCT FOCUS

equipment issues

to these materials

response system

response procedures

fied equipment

and facilities

OSHArsquos PSM

low budget

position internally

to compliance

job right

mine why

httpgooglDeL9fs

expiration date

PSM-covered process

ent elements

pilot NEP

experts

(VSP2)

PSSR often exists

1910119(i)

a process

has been completed

been addressed

been finished

major shutdown

or injuries

or restarted

cess is started

undermine efforts

ment outage

form the PSSR

the process

ones are

low-up activities

the DCS or PLC

under review

on the process

particular cartoon

as possible

Button 1

PRODUCT FOCUS

equipment issues

to these materials

response system

response procedures

fied equipment

and facilities

OSHArsquos PSM

low budget

position internally

to compliance

job right

mine why

httpgooglDeL9fs

expiration date

PSM-covered process

ent elements

pilot NEP

experts

(VSP2)

PSSR often exists

1910119(i)

a process

has been completed

been addressed

been finished

major shutdown

or injuries

or restarted

cess is started

undermine efforts

ment outage

form the PSSR

the process

ones are

low-up activities

the DCS or PLC

under review

on the process

particular cartoon

as possible

Button 1

equipment issues

to these materials

response system

response procedures

fied equipment

and facilities

OSHArsquos PSM

low budget

position internally

to compliance

job right

mine why

httpgooglDeL9fs

expiration date

PSM-covered process

ent elements

pilot NEP

experts

(VSP2)

PSSR often exists

1910119(i)

a process

has been completed

been addressed

been finished

major shutdown

or injuries

or restarted

cess is started

undermine efforts

ment outage

form the PSSR

the process

ones are

low-up activities

the DCS or PLC

under review

on the process

particular cartoon

as possible

Button 1

low budget

position internally

to compliance

job right

mine why

httpgooglDeL9fs

expiration date

PSM-covered process

ent elements

pilot NEP

experts

(VSP2)

PSSR often exists

1910119(i)

a process

has been completed

been addressed

been finished

major shutdown

or injuries

or restarted

cess is started

undermine efforts

ment outage

form the PSSR

the process

ones are

low-up activities

the DCS or PLC

under review

on the process

particular cartoon

as possible

Button 1

mine why

httpgooglDeL9fs

expiration date

PSM-covered process

ent elements

pilot NEP

experts

(VSP2)

PSSR often exists

1910119(i)

a process

has been completed

been addressed

been finished

major shutdown

or injuries

or restarted

cess is started

undermine efforts

ment outage

form the PSSR

the process

ones are

low-up activities

the DCS or PLC

under review

on the process

particular cartoon

as possible

Button 1

PSM-covered process

ent elements

pilot NEP

experts

(VSP2)

PSSR often exists

1910119(i)

a process

has been completed

been addressed

been finished

major shutdown

or injuries

or restarted

cess is started

undermine efforts

ment outage

form the PSSR

the process

ones are

low-up activities

the DCS or PLC

under review

on the process

particular cartoon

as possible

Button 1

(VSP2)

PSSR often exists

1910119(i)

a process

has been completed

been addressed

been finished

major shutdown

or injuries

or restarted

cess is started

undermine efforts

ment outage

form the PSSR

the process

ones are

low-up activities

the DCS or PLC

under review

on the process

particular cartoon

as possible

Button 1

PSSR often exists

1910119(i)

a process

has been completed

been addressed

been finished

major shutdown

or injuries

or restarted

cess is started

undermine efforts

ment outage

form the PSSR

the process

ones are

low-up activities

the DCS or PLC

under review

on the process

particular cartoon

as possible

Button 1

has been completed

been addressed

been finished

major shutdown

or injuries

or restarted

cess is started

undermine efforts

ment outage

form the PSSR

the process

ones are

low-up activities

the DCS or PLC

under review

on the process

particular cartoon

as possible

Button 1

or restarted

cess is started

undermine efforts

ment outage

form the PSSR

the process

ones are

low-up activities

the DCS or PLC

under review

on the process

particular cartoon

as possible

Button 1

low-up activities

the DCS or PLC

under review

on the process

particular cartoon

as possible

Button 1

particular cartoon

as possible

Button 1

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Put Process Safety First - chemicalprocessing.com … · 10. Establishing a quality assurance program to ensure that initial process-related equipment, maintenance materials and spare