PROCESS SAFETY MANAGEMENT EHS COMMUNICATOR Issue 4 2 Process Safety Management EHS Communicator June 2015 PROCESS SAFETY MANAGEMENT IN THIS ISSUE December 2014 Maintenance Systems This issue represents the 4th Edition of the Process Safety Management – EHS Communicator. 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 and forward any comments/questions to the EHS Dept. Note – electronic version available through EHS Webpage (www.ehs.psu.edu/) . Maintenance Systems It is recognized that with all equipment, at some point during its operations, maintenance work must be performed. This could take the form of Preventive Maintenance (PM) or repair maintenance work. Both types are required to maintain the safe operation of the equipment in question or repair some part of the equipment that is or has failed. Since this activity represents a deviation from standard operating conditions for the equipment, the activity presents unique hazards both to the individual(s) conducting the activity and to the normal operation of the equipment. The PSM Maintenance Systems program (PSM Element #12) has been developed to outline the requirements for University employees working on or around covered process areas. Maintenance Systems Overview of the Maintenance System Element within the PSM Program The primary purpose of this element is to clearly identify the work that is scheduled to take place (i.e. seal replacement on a pump), assess and control the specific hazards associated with the work (i.e. electrical – requiring Lockout/Tagout procedures to be followed), and to communicate the activities to appropriate site personnel. Due to the special requirements for maintenance activities within a PSM covered process area, only approved University employees are authorized to work on the equipment. These individuals are designated as “Authorized Employees” and require annual training to ensure they fully understand the key PSM program elements that impact these types of activities (e.g. Management of Change, Mechanical Integrity, Emergency Preparedness, etc.) and specific hazards associated with the covered process areas. Prior to beginning any non-routine maintenance activity, a Safe Work Permit (SWP) must be completed. The SWP must be jointly completed by the individual(s) conducting the work and the equipment operators. For additional information on the SWP, please refer to Issue 2 (Feb. 2015) of the “PSM - EHS Communicator”. Page 1 Mechanical Integrity Brief overview of the Mechanical Integrity Element and the critical role it plays within the PSM Program Page 2 PROCESS SAFETY MANAGEMENT EHS COMMUNICATOR | Issue 4 MAINTENANCE SYSTEMS Authorized Employee All maintenance work on PSM covered process equipment must be performed by a designated Authorized Employee. Mechanical Integrity The on-going reliability of all University equipment is extremely important to our core mission of teaching, research and service. Although all equipment is important, certain equipment and operations pose unique attributes that could have significant consequences associated with breakdowns or failures. These could include a significant shutdown of a specific operation (i.e. ability to make ice to support the ice rinks) or potential release of a hazardous substance impacting students, employees or the public. What is Mechanical Integrity? Mechanical Integrity or MI represents the PSM program component (Element #11) that outlines the requirements to ensure the ongoing reliability of process equipment. The goal is to minimize or avoid premature failure in certain process equipment that is critical to the continued safe operation of a process. Covered Processes Do you know the list of designated University covered processes within the PSM program? PSM – BY THE NUMBERS Equipment used to process, store, handle or control highly hazardous chemical / biological agent needs to be designed, constructed, installed and maintained to minimize the risk of releases. MI is primarily focused on maintaining the equipment in proper safe working order through implementation of the following element components: a) 5 Total number of PSM Metrics established by the PSM Focus Group for 2015. 177 Total Number of PSM training hours provided by the EHS Department for PSM program development and implementation. 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 2 b) c) d) e) Identification and categorization of equipment and instrumentation Written preventive and routine maintenance procedures Training for inspection, testing and maintenance activities Inspection and testing schedules Correction of equipment deficiencies identified For each covered process area, a list of equipment that is included within the MI element must be generated. The list will include all equipment that contains the highly hazardous chemical / biological agent or is critical to safe guarding the operation of the process (e.g. ventilation fans, scrubber systems, etc.). The following items shall be included in the MI equipment list; however, it is not intended to be an exhaustive list: ○ Pressure vessels (e.g. receivers, compressors, boilers, heat exchangers) and storage tanks, ○ Piping systems (including piping components such as valves), ○ Emergency relief devices and vent systems ○ Emergency shutdown systems ○ Controls (including monitoring devices and sensors, alarms and interlocks) ○ Pumps ○ Electrical system components ○ Safety systems (including fans, fire suppression, etc.) In addition, any other devices designated by the facility/operation personnel for the covered process as being potentially critical (a device which is more likely than another to result in or contribute to a major problem or loss if not properly maintained) to the safe operation of a process as a result of operating history or identified through a process hazard analysis. Tracking MI Data The PSM program provides some latitude for work units to manage the information required by the MI element. One logical source of maintaining key equipment information is Maximo. This powerful software platform enables discrete data management by equipment and can include work procedures, defined PM requirements, maintenance history and metric tracking. Although Maximo can be a useful tool within the MI element, it is recognized that certain information must be available in hard copy by the equipment operators in the field. Examples include, Piping and Instrumentation Diagrams (P&ID’s ) and safe operating limits. Please contact the EHS department to learn more about MI requirements and the established mechanisms to track equipment. ENVIRONMENTAL PROTECTION AGENCY The Environmental Protection Agency (EPA) issued an Enforcement Alert under the Clean Air Acts – Risk Management Plan (RMP) program associated with Anhydrous Ammonia at Refrigeration Facilities. To view the complete Alert use the following link: http://www2.epa.gov/sites/production/files/201502/documents/112renforcementalert.pdf