Process Safety Management Presentation PPT

Editor's Notes

• #1: By ‘little guy’ I mean small process -- PSM applicability triggered by hitting thresholds for one listed substance. Brady is a global supplier of identification solutions – signs and placards, tapes, labels, software and a wide array of specialty products. In Brady’s case, one facility out of 26 (that’s 115 employees out of 3,500 globally) is affected by OSHA’s Process Safety Management standard. I am responsible for the Environmental and Safety programs for that plant. Today I will share with you some of the strategies our covered facility in Milwaukee has employed to comply with the PSM standard, while functioning within a large organization that is not covered.
• #2: This is the text book definition of Process Safety Management. PSM is more that the OSHA standard. It originally was developed by AIChe (American Institute of Chemical Engineers) Center for Process Safety, refineries (American Petroleum Institute) and chemical manufacturers (Chemical Manufacturer’s Association -Responsible Care) as a management system for hazardous processes. We’ve all heard the tale of Bhopal, India, where over 2000 died from a release of Isocyanates. OSHA adopted these organizations’ framework, and on their heels was EPA with their Risk Management rule. My presentation today will deal solely on complying with the OSHA standard 1910.119 True Process Safety is a much more rigorous discipline than outlined in the OSHA standard.
• #3: Simply put, PSM exists to avoid this…..
• #4: PSM is an elemental approach. These elements are (in order as they appear in the standard):
• #5: All these elements interconnect and overlap with themselves, other OSHA compliance programs, and your copany’s processes and procedures, much like a tangled web…. Sometimes its hard to see the forest for all the (dead) trees the standard creates. Let’s briefly look at each element and its interconnections, and try to cut through the tangled web
• #6: Very basic first step, but one often taken haphazardly… let me explain…. At the covered Brady facility, only two process areas are impacted – the compounding and centralized cleanup areas. These are brought into the program because they are connected to underground storage tanks containing flammable solvents in excess of 10,000 pounds. We consider this connection ‘in process’ since the piping is directly connected to process tanks. These two process areas are segregated from the rest of the plant by walls – a visual and physical barrier. This is done to limit applicability and safeguard the process. In terms of scope, the rule impacts approx. 25,000 facilities – 127 industries and subgroups, and 3 million employees!
• #7: Run a cost/benefit analysis with your purchasing folks to determine if you can reduce inventory. The price breaks you get for purchasing and/or receiving bulk quantities probably won’t cover the expense and aggravation a full blown PSM program will require! If your company has an ERP (enterprise resource program) make sure the inventory management function is active. If not, lobby to activate it as a means of inventory control and reduction. This strategy is not ‘weaseling’ out. OSHA suggests these options in their own guidance documents. Remember the reason for the standard! Unfortunately in our case, considerable expense went into the underground storage tank system – high tech leak detection and cathode corrosion protection – that Brady was unwilling to abandon the capitol investment.
• #8: Pool chemical process in plant (chlorine). Mass evacuation was needed to protect neighbors. Interestingly enough, this was not a PSM covered facility. The pool chemicals were not ‘commercial or reagent’ grade so the process was exempt!
• #9: Front line workers – those that live and breathe the process – are critical to an effective program. OSHA knows it; so should you. At Brady we have made Process Safety and general plant safety a priority by using incentives. We have developed a point system for attending required training and participation in such activities as PHA PSSRs. A minimum number of points must be earned to participate in the company gainsharing program.
• #10: My advice – find a Ron. Ron has been a fixture at my facility for 25 years. He knows the coating and adhesive compounding process – its history, evolution, and secrets and has participated in building the Brady PSM program. He’s gruff and hard to get to know, but he’s the best asset a Safety Engineer can have. Do whatever you can to involve the ‘Rons’.
• #11: Here are the dead trees and acronymns
• #12: What do dead trees do? Combust. Do what you can to digitize, organize and cross reference everything. If the auditor or inspector can’t find it, you don’t have it.
• #13: AKA the PHA. It’s a comprehensive look at all aspects of the process – what has happened, what could happen, and suggestions (recommendations) for preventing disaster from happening.
• #14: What-if, checklist, Hazard and Operability Study (HazOp), Failure Mode and effects analysis (FMEA), Fault Tree, or an appropriate equivalent. Information needed: PNIDS, Incidents, Process drawings.
• #15: The tool we have chosen at Brady is PHA-Pro. There are several software PHA systems out in the marketplace. This particular one lets you choose a methodology that best fits your needs.
• #16: The tool allows you to record what-if senerios and rank them on a risk matrix
• #17: More important is the ability to track the resulting recommendations from the PHAs. As your group creates recommendations, have the PHA leader keep the group focused on the reason for the exercise…..
• #18: I suggest creating a poster and hanging it in the meeting room where the PHA is conducted. Your team is not meeting to troubleshoot quality, productivity or human resource issues! Yes, these are important to the business, and you may want to have a white board to capture good points as they come up, but limit time spent on them. Strive to create a list of relevant recommendations – those that minimize or eliminate the risk of catastrophe
• #21: Document, document, document. Find a software tool – anything that can demonstrate to a COSH that you’ve made a good faith effort to train your people. Does your Human Resources department have a training tracking software tool? Can you enlist them to keep track of these records? Can the tool filter records by PSM training?
• #22: Document, document, document. How many times have you heard of fires being caused by contractors working on the roof or HVAC systems? Contactors are very common in our outsourced environment. Without proper training and respect for your processes, they are your weakest link!
• #26: More dead trees. Intent is to assure that the design, fabrication, procurement, installation, and maintenance of covered process equipment is in keeping with the manner appropriate for its intended purpose.
• #28: Our home-grown data base helps manage various aspects of non-routine tasks in the PSM covered areas, as well as in the rest of the plant. As you can see, it crosses several OSHA required programs. This allows us to have trained employees apply for their own work permits, based on their valid training file. The result is a permit that is traceable for internal auditing.
• #30: Human Resources / Purchasing / Engineers / Facility Managers – all need to be educated on MOC process
• #31: One seemingly simple change can create ripples through the many PSM elements. An auditor/ inspector knows this and will follow the trail
• #32: Make Incident Investigation a plant-wide program (company-wide if you can swing it). If Human Resources manages you Worker’s Compensation Insurance issues, enlist their help (and budget). By integrating incident investigation with overall efforts to reduce injuries, you tap into a larger pot of money. You also have access to trend analysis of OSHA rates that can be compared to industry standards. One caveat….. Have a system to keep PSM incidents separate. Be able to filter these out in case of an audit or inspection.
• #33: I already know you have a plan, but make sure it was not created in a vacuum, and that other department’s plans weren’t either. Have a meeting of the minds to cover all bases. Take a holistic approach Enlist the geek squad (computer experts), Upper management (business protection), Facilities Managers (security and physical plant), Human Resources, Purchasing (supply chain issues), Marketing (customer service assurance) Make the entire organization aware of your PSM challenges and use someone else's budget when possible!
• #34: Necessary evil. Lean into it and treat it like an opportunity. Realize that there will be findings and that each is a chance to improve your program. And remember, you’ll do it all again in three years so don’t take the band-aid approach. No one likes to hear their baby is ugly, but its better hearing it from a paid consultant than from OSHA
• #35: Remember why PSM…… PSM is not a three ring binder that a consultant prepares and you put on your bookshelf to gather dust. It is an ever evolving system that you make work, given your unique business situation and your interpretation of the required elements. Your system won’t and shouldn’t look like Brady’s, (trust me, we have an ugly baby too), but I hope some of the insights I’ve provided can be adapted to your program.
• #36: You are not alone… This is the digital age and we have so much information on the web. American Institute of Chemical Engineers / Center for Chemical Process Safety
• #37: Shameless plug for the man and my chumms!