PROCESS SAFETY MANAGEMENT EHS NEWSLETTER
Issue 1
Process
Safety
Management
EHS
Newsletter
December 2014
IN THISDecember
ISSUE
PROCESS SAFETY MANAGEMENT
2014
PSM Development Update
PSM Development Update
Process Safety Management Program Development
Update; Overview of PSM Focus Group Activities
Page 1
Welcome to the 1st Edition of the Process
Safety Management – EHS Newsletter. The
intent of this internal publication is to
provide updates, guidance, information and
reference material to the University
community impacted by the Process Safety
Management (PSM) initiative. Please feel
free to share the document or reference the
EHS Webpage (www.ehs.psu.edu/) for the
on-line version.
Program Development Update
It doesn’t seem that long ago that the Pegula
Ice Arena ceremonial groundbreaking event
took place (April 20, 2012) but we have
already entered our second Hockey season in
one of the nation’s best college hockey
venues. Although there has been a lot of
visible activity taking place since the Spring
of 2012, there has also been a lot of activity
behind the scenes when the University
embarked on its new initiative to efficiently
and safely manage the arena’s new Ice Plant.
The initiative is known as Process Safety
Management or simply PSM.
What is PSM? Basically, it is a defined
management system to ensure critical assets
are managed and operated within safe limits
to minimize the likelihood of a release that
could lead to a fire, explosion, exposure, or
business interruption.
To develop this new program a PSM Focus
Group was formed with representatives from
Intercollegiate Athletics, College of
Agricultural Sciences, Materials Research
Institute, Office of Physical Plant and
Environmental Health & Safety. The initial
focus was associated with the ammonia
refrigeration systems within the University
which includes a portion of the Creamery
operation in addition to the new Ice Plant.
The PSM Focus Group has been meeting
since April assessing and developing the
program elements for the University’s PSM
initiative. Based on various inputs including
existing programs, process safety culture and
wide spread impact to different operating
units, the team identified 17 key program
elements. To assist the Focus Group, smaller
work groups of subject matter stakeholders
were formed to focus on specific elements
within the PSM program. These “SubGroups” were charged with developing a
proposed process that would work in the
field to address the requirements of a specific
element. More information on the 17
program elements and Sub-Groups will be
provided in subsequent Newsletters.
Management of Change
Brief review of the Management of Change (MOC)
Element within the Process Safety Management
Program
Page 2
PROCESS SAFETY MANAGEMENT EHS NEWSLETTER | Issue 1
2
Management of Change
EQUIPMENT – ACCESS CONTROL
Management of Change, or MOC, is one of
the 17 elements within the University’s PSM
program. What is an MOC? Keep reading to
learn more about the element purpose and
associated requirements within the
University’s PSM program.
What is an MOC?
Equipment
Understanding equipment safe operating conditions,
defined written procedures and maintaining equipment
are critical components of the PSM program.
Access Control
Due to the unique hazards associated with PSM Covered
Areas, additional training requirements are required for
access into these areas.
PSM – BY THE NUMBERS
100%
Percentage of Developed and Approved Compliance
Guidelines for each of the 17 Program Elements
81%
Percentage of Approved Written Procedures for the 17
Program Elements
FOR MORE INFORMATION
Contact: Charles Williams, Process Safety
Program Manager, EHS Dept. for more
information on Penn State’s PSM Program
865-6391
cmw33@psu.edu
Have you ever heard that change is constant?
Did you ever ask yourself what series of
incremental changes were introduced to
some aspect of your work environment that
lead you to the current situation? Change
can and should be good – without change
processes can become outdated, inefficient
or less competitive. When it comes to PSM,
change is also good but it needs to be
appropriately managed and assessed prior to
implementation.
Therefore, the purpose of the MOC element
within PSM is to manage changes to process
chemicals/biological agents, technology,
equipment, procedures; and changes to
facilities or organizational changes that
affect a covered process. Prior to making a
change certain considerations must be
addressed including:
○ technical basis for the proposed
change
○ impact on health, safety and the
environment
○ modifications to operating
procedures
○ notification and training affected
employees
○ how are any risks associated with the
change appropriately managed
In almost every situation, a single person
within the work unit or University would be
unable to consider all the above issues prior
to implementing a change, so a review team
has been developed. These individuals who
must be familiar with the covered process are
charged with considering the potential
overall impact to the process prior to
implementing the change.
To facilitate this review process, an MOC
Form has been developed by the MOC SubGroup (MOC Form available on the EHS
Webpage under the Workplace Safety tab
and Process Safety Management button
(http://www.ehs.psu.edu/workplacesafety/process-safety-management).
The MOC Form must be prepared by the
individual or department proposing to make
a change within the covered process area.
Sufficient information must be collected for
the review team to complete their
assessment. For example, with equipment
changes specifications including materials of
construction, safe operating parameters, and
safety systems are required as part of the
MOC assessment.
Once the scope of the MOC is defined and
the appropriate information collected, the
Form and supporting documentation is
distributed to the review team. To proceed
with the change, the entire review team
must “Approve” the MOC.
After the MOC is Approved by the review
team, it isn’t the end of the MOC process.
Depending on the complexity of the change
(e.g. change in procedural requirements vs.
installation of a new heat exchanger) an
additional review may be required prior to restarting the covered process area. For
changes that involve equipment, a PreStartup Safety Review (PSSR) is required to
ensure the field installation was completed
as it was designed and approved through the
MOC review.
Does Every Change Require an
MOC?
Almost every change will require an MOC;
however, if it can be considered an “In-Kind
Replacement”, the MOC process is not
required. What is an In-kind Replacement? It
is basically any process or equipment change
performed in accordance with established
design specifications. An example would be
replacing a Hansen Solenoid Valve – Model
#HS4A with the same valve.
CHEMICAL SAFETY BOARD
Chemical Safety Board (CSB) – the members of
the CSB Board identified modernization of
Process Safety Management Regulations
(OSHA 29 CFR 1910.119) as the Agency’s
Second “Most Wanted Safety Improvement”
[More information to follow in subsequent
Newsletters regarding the CSB – stay tuned]