Process Safety Management

of Highly Hazardous &

Explosive Chemicals

Operating Procedures, Safety Procedures &

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

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

 Answer: The Military

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

*Readily accessible to employees

Operating Procedures

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

 Describe normal SOP's

 Describe start-up
start-up SOP's

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

Let’s Look at An Example…

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

 Must be Developed for Each Equipment

Operation in the Covered Process
 Refer to Block Diagrams

 Refer to P&ID
 Must Cover Normal Operating Conditions,

Normal Operating Parameters, i.e..
Pressure/Flow/Current/ etc.
 Must Follow Procedures &

Recommendations in PHA’s
PHA’s
 Must Follow Form

Operating Procedures

 For Shut-down
Shut-down
Procedures…Remember:
Procedures…Remember:
 Most operations must be shut down in a
specific order!
 Failure to follow these shut down
procedures could results in a catastrophic
release or system failure
Ammonia Plant Explosion Caused by
Improper Shut-down of Engine Room
Operating Procedures


 Operating Limits
 Operating Limits

Must be Understood
 Pressures
 Flows
 Electrical Potential
 Tolerances
Operating Procedures -
Hazards of the Process

 Operating
Procedures Must
Identify the Hazards
of the Process in All
Phases:

 Start Up
 Normal Operating
Conditions
 Temporary Operating
Condition
Shut-
 Emergency Shut-

down
 Now That We’ve Completed
the Operating Procedures
We Must Develop Safety Work Practices,
Programs & Procedures for Covered
Processes
Safe Work Practices
1910.119(f)(1)
Safe Work Practices
•Develop and implement safe work practices* to provide for
the control of hazards during operations such as:
–Lockout/tagout;
–Confined space entry;
–Line Opening process equipment or piping; and
–Control over entrance into a facility by maintenance,
contractor, laboratory, or other support personnel

*These safe work practices apply to contractor employees as well

Safe Work Practices

 Safe Work Practices, Programs &

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

 Lockout Tagout - One of the Most

Important Procedures in PSM
 Must be Written Carefully & Follow all
Procedures (PHA’s,
(PHA’s, Operating
Procedures)
 Must be Followed to the Letter!
Safe Work Practices


 Lockout/Tagout in
PSM
 Why not Use Digital
Imaging in Your
Procedures to Identify
Critical Lockout
Critical Lockout /Tagout
/Tagout
Positions
Safe Work Practices


 Line Opening
Permits
 Identify Procedures
for Opening any
Process Line in a
Covered Process
 Must Include

Hazards of the Line
Opening
 PPE Required
Safe Work Practices
Line & Equipment Opening
 A Hazard Review Must Completed for All
Line/Equipment Hazards Including:

 HAZARDOUS MATERIALS IN SYSTEM

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

 Must be Specific for the Covered

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

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


 Paragraph (g)(1) requires employers to train
employees operating dangerous process. Paragraph
(g)(2) requires that the employer provide refresher
training at least every three years. Paragraph (g)(3)
requires the employer to prepare a record that
contains the name of employee, the date of training,
and the means used to verify that the employee
understood the training
PSM Training


 PSM Training Programs Must be Developed
for:
 Affected Employees - Those not Directly Involved
in the Process Operation
 Authorized Employees -- Those
 Those Directly
Directly Involved in
the Process Operation
 Contractors Who May Perform Work on a Covered

Process
 Vendors/Visitors who May Visit the Facility and
May Potentially be Exposed to the Covered
Process
PSM Training

 Training Must Be Performed as Follows:

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

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

 Training Subjects Must Include at Least:

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

Hot Work Program

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

Our Program Requires

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

CIRCLE THE CORRECT ANSWER

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

In the Last Session, we

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