PROCESS SAFETY MANAGEMENT
PROGRAM
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PROCESS SAFETY MANAGEMENT
PROGRAM
Northern Clearing, Inc. has the potential to perform work at Host facilities where
hazardous chemicals may be on site, and which may require protections defined under
OSHA’s Process Safety Management (PSM) regulation, found at 29 CFR 1926.64, and
29 CFR 1910.119. Therefore, we have implemented this PSM program where it applies.
This PSM program enables our employees who may work at a facility to prevent or
recognize the possibility of an occurrence, and minimizes the consequences of significant
releases of toxic substances as well as fires, explosions, and other types of catastrophic
accidents. Overall, the PSM program prevents accidental fatalities, injuries and illnesses
and avoids physical property damage by providing training and analyses of potential
hazards.
The “process” part of the Process Safety Management Program is any activity involving a
highly hazardous chemical including any use, storage, manufacturing, handling, or the
on-site movement of such chemicals, or combination of these activities. Any group of
vessels that are interconnected and separate vessels that are located such that a highly
hazardous chemical could be involved in a potential release shall be considered a single
process.
Our PSM prevents accidents because it focuses on the rules, procedures, and practices
established by our contractors, which govern individual processes, activities or pieces of
equipment. These rules are detailed and improved as necessary. They are also
communicated to and accepted by all persons at the facility, including contractors, such
as Northern Clearing, Inc. prior to commencing work.
At the same time, our PSM covers not only highly hazardous chemicals, but also those
that may be harmless in terms of flammability, explosivity, or toxicity, but, when mixed
with another substance, can produce a highly hazardous substance or situation. The
accidental mixing of some reactive chemicals can cause explosions or the release of toxic
vapors, situations that are clearly a threat to the life and health of workers at the site.
Like all PSM written programs, the following major elements are adddressed:
1. Purpose statement,
2. Employee participation plan,
3. Process safety information,
4. Process hazard analysis records,
5. Operating procedures,
6. Training,
7. Contracting,
8. Process equipment integrity maintenance procedures,
9. Non-routine work,
10. Management of change procedures
11. Incident investigation reports,
12. Compliance audit reports, and
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13. Emergency Action Plan.
The Health and Safety Director is the program coordinator. The Health and Safety
Director will review and update the program, as necessary. Copies of the written program
may be obtained from the appropriate Northern Clearing, Inc. personnel, such as the Job
Superintendent.
All employees, or their designated representatives, can obtain further information on this
written program or the process management standard form from the Personal
Administrator in the Corporate Headquarters.
To comply with the requirements established by OSHA, the Host facility has established
certain procedures and processes for its employees and contractors, such as our company.
Each of these processes has been identified and addressed, and the particular information
that may affect our employees is required to be forwarded prior to start-up of work
activities. In turn, we pass the information on to our employees prior to their start of
work at the specific facility and/or process.
EMPLOYEE PARTICIPATION
Our employees are a significant ally in helping the company to implement and maintain
an effective PSM program. We encourage employees to participate in:
1. Gathering process safety information,
2. Conducting and developing the PSM program elements and hazards assessments as
well as incident investigation findings, where appropriate
3. Obtaining access to process hazards analyses and the rest of the PSM program.
Information can be exchanged by conducting several safety meetings, tailgates, formal
training sessions, and working with the employees prior to and during the actual on-site
work processes. If we identify or cause any unique hazards, the Host contractor will be
promptly notified. Also, our employees will be trained in maintaining trade secret
information for confidential process safety management information.
TRAINING
Employee training is conducted prior to commencing work and if situations arise that
may lead to potential hazardous situations.
The Host facility, the senior
supervisor/superintendent or both can conduct it. Dependent on the specific facility site,
location, and potential hazards, the training may include:
1. Process safety information – Accurate and complete written information concerning
the process chemicals, process technology, and process equipment is essential to an
effective PSM program and to a process hazards analysis. Information is compiled
about chemicals, including process intermediates, comprehensive enough for accurate
assessments of the fire and explosion characteristics, reactivity hazards, the safety and
health hazards to workers, and the corrosion and erosion effects on the process
equipment and monitoring tools. Some of this data is included in the HazCom
training, as well.
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Part of the Host facility’s PSM program will include:
Block flow diagram or simplified process flow diagram;
Process chemistry;
Maximum intended inventory;
Safe upper and lower limits for such items as temperatures, pressures, flows or
compositions;
Evaluation of the consequences of deviations, including those affecting the
safety and health of employees; and
Consequences of any deviations in the process, including those affecting the
safety and health of employees.
Materials of construction,
Electrical classification,
Ventilation system design,
Material and energy balances for processes built after 5/26/92,
Piping and instrumental diagrams,
Relief system design and design basis,
Design codes and standards employed,
Safety systems (such as interlocks, detection, and suppression systems
2. Process hazard analysis records – Process hazard analysis (PHA), sometimes called
a process hazard evaluation, is one of the most important elements of the PSM
program. The PHA is an organized and systematic effort to identify and analyze the
significance of potential hazards associated with the processing or handling of highly
hazardous chemicals. PHA decisions for improving safety and reducing the
consequences of unwanted or unplanned releases of hazardous chemicals. PHA is
directed toward analyzing potential causes and consequences of fires, explosions,
releases of toxic or flammable chemicals and major spills of hazardous chemicals.
PHA focuses on equipment, instrumentation, utilities, human actions (routine and
non-routine), and external factors that might impact the process.
These
considerations assist in determining the hazards and potential failure points or failure
modes in a process.
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Again, the Host contracting organization has conducted this Process Hazard
Analysis (PHA) prior to Northern Clearing, Inc. arriving on-site. The
Information has been shared with our company, where applicable, using the
following methodologies:
What-If;
Checklist;
What-If/Checklist;
Hazard and Operability Study (HAZOP);
Failure Mode and Effects Analysis (FMEA);
Fault Tree Analysis; or
An appropriate equivalent methodology.
3. Operating procedures – These procedures describe tasks to be performed, data to be
recorded, operating conditions to be maintained, samples to be collected, and safety
and health precautions to be taken. The procedures are technically accurate,
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Initial startup;
Normal operations;
Temporary operations;
Emergency shutdown, conditions for an emergency shutdown, and assignment
of shutdown responsibility;
Emergency operations;
Normal shutdown; and
Startup following a turnaround, or after an emergency shutdown.
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Safety and health considerations including:
- Properties of and hazards presented by, the chemicals used in the process;
- Precautions necessary to prevent exposure, including engineering controls,
administrative controls, and personal protective equipment;
- Control measures to be taken if physical contact or airborne exposure occurs;
- Quality control for raw materials and control of hazardous chemical inventory
levels; and
- Any special or unique hazards.
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Safety systems and their functions.
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Also, operating procedures must be readily available near each process area during
production. They must be stored in an office or filing cabinet that is locked when
employees are present.
Northern Clearing, Inc. is provided this information after the reviews are conducted,
where appropriate. The Health and Safety Director +or his designee is responsible for
reviewing the operating procedures to make sure they are current and accurate and also
reviews operating procedure changes that result from changes in process chemicals,
technology, equipment, and the facility.
The facility may have safe work practices which limit employee and contract employee
exposure to covered process areas and which control hazards in situations such as
lockout/tagout; confined space entry; opening process equipment or piping; and control
over into a facility by maintenance, contractor, laboratory, or other support personnel.
The Host facility provides information on the safety and health hazards of the chemicals
and processes that our employees may come in contact with for the protection of
themselves, their fellow employees, the Host facility employees, and the citizens of
nearby communities. While training in Hazard communication will help employees to be
more knowledgeable about the chemicals they work with as well as familiarize them with
reading and understanding MSDSs, additional training will be covered in this PSM
program in subjects such as operating procedures and safety work practices, emergency
evacuation and response, safety procedures, routine and non-routine work authorization
activities, and other areas pertinent to process safety and health.
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All training and retraining records containing the identity of the employee, the date of
training, and the means used to verify that they understood their training are attached to
this PSM program.
SUB-CONTRACTING
Our company does hire sub-contractors. These sub-contractors go through the same
training as all other Northern Clearing, Inc. employees.
NON-ROUTINE WORK
Non-routine work activities (i.e., lockout/tagout, line breaking, confined space entry, and
hot work permits) are controlled by the Host facility, and communicated to those doing
the work. In addition, our other safe work practices and programs such, as
lockout/tagout, energy control, etc. will apply as well. Information is provided via
postings and safety meetings to our employees regarding non-routine work activities.
These training programs are documented and the records maintained in the Corporate
Headquarters. In addition, if the work being performed may create other hazards, this
information is discussed with both our employees as well as the Host facility
representatives.
Hot work permits must be obtained by the Host facility. Their procedures must be
followed to avoid fires and explosions, and the use and limitations must be understood
and followed. No hot work is permitted without a permit, unless previously discussed
and agreed upon. All workers prior to commencing work understand site-specific details.
EMERGENCY ACTION PLANS
The Host facility is required to have some system in place to address emergencies. Their
system, which may be alarms, horns, buzzers, whistles, etc. will be identified prior to any
work commencing and relayed to all Northern Clearing, Inc. employees that are assigned
to work at the site. In addition, if the employee’s duties or responsibilities change or if
the plan is changed, this will be reviewed and explained to employees, as well. The
emergency action plan will follow requirements established by 29 CFR 1910.38
including evacuation routes, etc. No one will be allowed to return until the “all clear”
signal is sounded.
The Job Superintendent will also be responsible for a daily roster of our employees. In
the event of an evacuation, when employees gather in a pre-determined area, the
supervisor will take roll call and verify in writing that all personnel have left the hazard
area.
Where possible, all equipment will be shut down prior to evacuation; at a minimum, the
main power source should be disconnected or shut off by the site supervisor or operators
prior to evacuation.
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The Host Company will be responsible for providing emergency telephone numbers for
reporting fires or other hazards and for medical and emergency assistance. These will be
prominently posted for all employees to use if necessary.
INCIDENT INVESTIGATION REPORTS
Incident investigation is the process of identifying the underlying causes of incidents and
implementing steps to prevent similar events from occurring. With our incident
investigations, we intend to learn from past experiences and thus avoid repeating past
mistakes. Incidents that need to be investigated are the types of events that result in or
could reasonably have resulted in a catastrophic release. Some of the events could be
“near hit,” meaning that a serious consequence did not occur, but could have. These
incidences are to be investigated within 48 hours by appropriate supervisors and reports
filed; the incident investigation report, retained for at least five years, include at least the
following:
• Date of the incident;
• Description of the incident;
• Recommendations resulting from the investigation;
• Date the investigation began; and
• Factors that contributed to the incident, and corrective actions
At least every three (3) years, the Health and Safety Director completes a compliance
audit, which evaluates and certifies compliance with the PSM Program to verify that
procedures and practices developed in the PSM are adequate and are being followed.
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