Questions of the Week
Primatech posts weekly questions relating to various aspects of safety, security and risk on the home page of our website together with answers to provide visitors with the opportunity to test and improve their knowledge of these subjects. This page contains questions and answers that have appeared in previous weeks.
Is it OK to conduct a process safety audit during a maintenance turnaround?
Typically, audits are conducted when the facility is operating so that a broader scope can be addressed. However, process safety programs do apply to other modes of operation, such as turnarounds, and their design and implementation for those modes should also be addressed.
Do I need to develop an mechanical integrity (MI) procedure to replace a light bulb?
OSHA's process safety management (PSM) standard requires that written procedures be developed to maintain the on-going integrity of process equipment. A list of critical process equipment whose failure may lead to a loss of containment of a highly hazardous chemical must be identified for which procedures are required. Procedures should also be developed for any task, such as changing a light bulb, where covered hazards are present and risks may be involved.
What equipment should be included in the MI program?
Critical equipment. Equipment that upon failure may affect or impact a release of the highly hazardous chemicals.
What are some typical ground rules for how the PHA meeting will be conducted?
There are no stupid questions
- There are no bad ideas
- Team consensus is sought for worksheet entries
- All participants are considered to be peers for the performance of the PHA
- Everyone contributes
- Start on time, end on time
- Frequent breaks will be taken
- How you will handle common situations that may arise
- E.g. use of the flip chart as a parking lot for issues outside the scope and objectives of the study
Is there a standard risk ranking matrix that has been developed for use to rank PHA scenarios?
OSHA PSM rule at 29 CFR 1910.119(e)(3)(vii) states "A qualitative evaluation of a range of the possible safety and health effects of failure of controls on employees in the workplace” be used." The preamble of this particular provision of the standard states that "This evaluation is for the purpose of guiding decisions and priorities in planning for prevention and control, mitigation, and emergency response." To summarize, as long as it meets the above test, any risk ranking matrix is acceptable. There are no specified criteria for matrix size, numbering scheme or additional parameters (financial, environmental, reputation, etc.).
What is the most challenging aspect of the PSI element?
To keep it up to date. A management system that establishes responsibilities and guidelines for collecting, storing, and maintaining the process safety information would minimize the potential for having information that does not reflect the current process. A good MOC / PSSR program that includes follow-up and monitoring of open action items derived from an MOC or PSSR will also ensure this happens.
Who should be trained in management of change (MOC) procedures?
Everyone that works in or for the covered process; Management, Procurement, Finances and HR personnel can also make decisions that affect process safety, even without being on-site.
Why is PHA performed on procedures?
The focus on equipment in a conventional PHA may lead to overlooking some hazard scenarios resulting from procedures not being followed properly.
If a risk reduction measure is required, does the PHA team have to recommend a specific solution?
No, the team may simply identify the need to develop a specific risk reduction measure to address the problem identified.
What is the importance of good recordkeeping during PHA?
- Review by regulators
- Use in decision-making
- Linking to later studies
- Use with other PSM elements, e.g. MOC, II, Audits
- Operator training and writing procedures
- Process troubleshooting
- Contractual obligations
- Insurance company requirements
- Future reference