Although ARA is fighting legislative and legal battles to prevent the Process Safety Management standard from being applied to retail facilities, ignoring the current regulatory environment is not an option.
The Occupational Safety and Health Administration is vigorously pursuing PSM through formal rulemaking -- and the wheel of government bureaucracy is consistent and heavy. Better to operate like the Scout motto: Be Prepared.
Traditionally, PSM standards have applied to oil refineries and food processors. However, broadening definitions and regulations now mean that ag retailers will also fall under these requirements as well.
In his breakout session at the ARA Conference & Expo, Michael Hazzan, Technical Manager at AcuTech, a process risk management expert, will help ag retailers better understand what they need to do and when in order to be in compliance with PSM.
Hazzan has more than 35 years of experience in process safety and risk analysis, process security, engineering, and plant operations. He has authored and extensively taught training courses in process safety and risk analysis, as well as security/SVA for the chemical/process and power industries. He has developed and conducted SVA and Facility Security Officer training to hundreds of chemical and petroleum industry representatives, as well as courses in various areas of process safety and risk management.
He has published 25 technical papers in the areas of process safety and risk and security, has served as an expert witness on process safety during the permit hearing process for a new chemical recycling facility. He is the co-author of the CCPS book, Guidelines For Analyzing And Managing The Security Vulnerabilities Of Fixed Chemical Sites, Inherently Safer Chemical Processes, 2nd, edition, Guidelines for Auditing Process Safety Management Systems, and a contributor to the CCPS book on Mechanical Integrity.
Hazzan served more than 26 years in the U.S. Navy, including 7 years on active duty in the nuclear submarine force.
To begin getting acquainted with PSM requirements, one of the first things Hazzan recommends ag retailers do is become comfortable with the idea of documenting almost everything they do in writing.
“There’s a popular mantra when it comes to OSHA’s views on PSM standards,” he said. “If it’s not written down, it never happened.”
For example, employers adhering to PSM requirements need to consult with employees (and their representatives when applicable) regarding efforts in developing and implementing PSM elements.
“This means you should develop a written plan of action for employee participation, consulting with employees during the PSM program development and making all this information under the PSM standard accessible to employees,” said Hazzan.
Management of Change
Then there’s the Management of Change requirement, which Hazzan said both OSHA and industry view as “one of the most important and necessary aspects of PSM.” This requires operators to establish and implement written procedures to manage changes to process chemicals, technology, equipment, and procedures; and to facilities that affect a covered process.
Examples of these would include new equipment, computer program revisions, and the routine replacement of pumps, valves, and other equipment that may be different from what is already in place.
“This element is intended to be a ‘speed bump,’ but not a road block to change,” said Hazzan. “Challenges to meeting this requirement include ensuring that all covered changes are identified and changing the previously ingrained practices and company culture on making changes.”
Written documentation also applies in the areas of Process Safety Information (PSI) and Process Hazard Analysis (PHA), he said.
“PSI enables those involved in the process to identify and understand hazards associated with it,” said Hazzan. “This includes information on any materials hazards present, the technology of the systems being used, and other equipment that might be involved. And this needs to be in a written form that is accessible to all employees. You can’t rely on someone’s memory to accomplish this.”
As for PHA, this should be a written analysis addressing such topics as process hazards at the facility, outlining the engineering and administrative controls used to address them, and the likely consequences of failing to adhere to these controls.
“This analysis should be updated and revalidated at least every five years using a team approach to assure that the PHA is consistent with the current process,” said Hazzan.
The Importance Of MI
Of all the many moving parts that will make up an ag retailer’s functioning PSM plan, said Hazzan, Mechanical Integrity (MI) is probably the most important.
“The first line of defense in process safety is to keep hazardous materials contained through well designed, operated, and maintained equipment,” he said.
As such, fully one-fourth of the 16-hour PSM training session was devoted to looking at the MI requirements in-depth.
For starters, MI covers virtually all the equipment at a facility involved in any type of process operations. This includes pressure vessels and storage tanks, piping systems (including their various components), relief and vent devices, emergency shutdown systems, pumps, and other controls such as monitoring devices, sensors, alarms, and interlocks. Written procedures covering all these items need to be established and employees need to be trained in maintaining equipment integrity.
“In addition, inspection, testing, and preventive maintenance should be performed on all process equipment, which is the heart and soul of the MI requirement,” said Hazzan. “The frequency of this should be consistent with manufacturer’s recommendations or more frequent if so determined through prior operating experience.”
He recommended adhering to Recognized And Generally Accepted Good Engineering Practices (RAGAGEPs) established by such organizations as the Compressed Gas Association, the American Society of Mechanical Engineers, and the American Petroleum Institute for guidance in this area.
For many in the processing sector, performing these kinds of proactive methods in their operations was usually not the norm, said Hazzan.
“Until PSM was implemented, most processing companies did not do preventive maintenance on their equipment,” he said. “Most had the philosophy of ‘we don’t fix anything until after it breaks.’”
According to Hazzan, common MI deficiencies include overdue inspections/testing, safety features that are bypassed (such as blocked in-relief valves), the use of pipe clamps to temporarily stop leaks, and pressure relief valves and other components that may have expired.
“MI is the most complicated PSM element in part because it involves many activities and groups/departments at the site,” he said. “Most companies are still working to comply with this element.”
Beyond these components of PSM, Hazzan advised ag retailers attending the training session to look at such areas as Standard Operating Procedures (SOPs).
“SOPs should be written in a style and level of detail that supports their use as training documents and should include storage and transfer operations not covered by the Department of Transportation,” he said. “Electronically available SOPs are okay, as long as there is at least one hardcopy available in the event of a power outage.”
Then, there’s auditing all PSM elements periodically.
“These should be conducted every three years, be done by at least one person that is knowledgeable in the processes of the facility, be certified, and filed with a written report,” said Hazzan. “And any corrective actions should be taken immediately once the audit is complete. Facilities cannot take the three years until the next audit to do this.”