Action items

Review Scheduling A review scheduhng procedure should be estabhshed that documents who is responsible for initiating the review and when the review(s) should occur during the project. The scheduling needs to balance availability of process information, review technique used, and the impact of potential review action items on project costs (i.e., early enough to minimize the cost of any potential changes to the process). The aclual amount of time needed for the review should also be stated in the procedure. On the basis of the number of project reviews required and the estimated time needed for each review, the project cost estimate should include the cost for project reviews as part of the total cost for the project. 

Review Documentation The project review team leader has the ultimate responsibility for documenting the results of the project review. This responsibility may be delegated to a team scribe or secretary to record trie review minutes and issue a summary report with listed action items. The action items could address exceptions to company or industiy standards and government regulations, review team recommendations based on experience and knowledge, and further issues for study that could not be resolved during the review session. 

Progress on the action items should be documented in periodic progress reports to the review team leader or others assigned that functional responsibility. If no one is assigned the responsibihty of tracking this progress, completion of the action list wih probably be relegated to a lower priority and not be done. 

On rare occasions, the resolution of project review concerns or action items is a point of contention between review team and project team members. In such a case, a management structure must be in place to arbitrate such disputes. 

How do you resolve pre-startup safety review issues and action items ... 

When the analysis is complete, the PHA team leader will issue a report with action items. Items required to be done before start-up... 

After the PHA documentation is complete, each action item to be implemented before startup is given an estimated completion date and an assigned individual with responsibility to carry it out. Regular follow-up to ensure these action items are completed is essential to a timely startup. These responsibilities should be documented. 

An overall review of the management of change documentation package should be performed to ensure documentation update items (including material safety data sheets) are addressed and that PHA action items are complete. This can be done by one person but is often best achieved by a PSSR Team. The process needs to account for ... 

Assignment and follow-up of action items—responsibilities of each party... 

Acceptance or rejection of action items—right of review by each party, resolution of disagreements... 

Response and follow-up of PHA action items action items resolved and documented... 

It is essential to develop contacts within both companies to create an atmosphere of two-way communication. The toller should feel comfortable in asking for advice or assistance and this is best achieved by building rapport with their primary contacts from their client company. After an audit, the points of contact can be assigned responsibility for ensuring completion of individual action items. 

The client s personnel who had close involvement in the toll can best determine the toller s future status. A recommendation to use the toller again can be based upon the total experience including audit results and the toller s action item follow-up. A safe, responsive, conscientious toller that met the commercial requirements of the toll contract will most likely be given consideration on future tolls. As discussed in Chapter 2, The Toller Selection Process this recommendation can ease any future selection process for both parties when the toller in question is known to be technically capable. 

The results of a What-If/Checklist analysis are documented like the results of a What-lf analysis as a table of accident scenarios, consequences, safety levels, and action items. The results may also include a completed checklist or a narrative. The PrHA team may also document the completion of the checklist to illustrate its completeness. The PSM rule requires detailed... 

A HAZOP study is a systematic, tabular document of process deviations. The study gives the noimal operating conditions and analysis boundary conditions for each item and lists action items for further evaluation. Tables 3.34-3 and 3.3.4-4 are examples of HAZOP analysis of the Dock 8 HF Supply System and the Cooling Tower Chlorination System, respectively (for a more complete study see DOE, 1973). These example show the format for HAZOP tables. A typical HAZOP study... 

No No flow Valve V-19 CKiSCsj 111- V. ipori/cT ml. , header jslijL Ckl/ frozen Loss of HF to B-1 process unkiuivi.li consequences No knotvn protection 1 Action item level of prot availaldc. m conseqiK- ... 

Release HF into storage area potential injuries/fatalities if occupied Valve V-28 closed, forcing release to stack 5 Action item Con admin n action closed when open... 

Evaluate making the alkylation unit control building a safe haven during hazardous material releases administrative action items... 

This section addresses topics common to all PrHA methods. A step-wise procedure for conducting a PrHA according to PSM Rule requirements is presented, followed by recommended approaches for analyzing scenarios, deciding on action items, and incorporating facility siting and human factors into the PrHA. 

The critical results of a PrHA are a list of action items. Action items are written by the PrHA team any time additional effort is warranted to further analyze a specific accident scenario, eliminate the hazard, or reduce risks. Action items are not usually specific corrective actions. Rather, they alert management to potential problems that require action. Sometimes, action items suggest alternatives or recommend safety improvements. However, if a problem is simple, if a PrHA team is quite experienced, or if there is only one solution, an action item may recommend a specific corrective action. 

All action items are presented to management for review and evaluation, and for determination of what, if any, corrective actions should be taken to eliminate hazards or reduce risks. Because many action items may be generated during a PrHA, the team may choose to rank the items according to the probability of occurrence and/or the severity of the consequences of their corresponding accident scenarios. 

If the PrHA team is quite experienced, they may rank the action items according to the anticipated time and resources needed to implement changes. Or the team may make safety improvement and implementation recommendations. Ranking of action items or safety improvement recommendations may be valuable to management in several ways. It shows the significance that the PrHA team places on each item. It also allows management to prioritize the immediate efforts of corrective action and resolution. If resources are scarce, the ranking may affect the implementation schedule. 

The comments column may contain additional descriptive information or actions/ recommendations. The recommendations, sometimes with more detailed explanations, can be summarized in the report to produce a list of action items or suggestions for improving the safety of the process. These results should be reviewed with management to assure that the findings are transmitted to those ultimately responsible for any actions. 

For compliance with the PSM Rule, detailed explanations of the analysis action items and recommendations should be provided to management for review, and transmitted to those responsible for their resolution. 

In addition, it provides a list of potential actions that should be evaluated. Table 4.16 is an example of a HAZOP study worksheet. A typical HAZOP study report should include a brief system description, a list of drawings or equipment analyzed, the design intents, the HAZOP study tables, and a list of actions items. 

No No flow Valve V-19 closed HF Vaporizer inlet header plugged/frozen Loss of HF to B-l process consequences unknown. No known protection. 1 Action Item Determine die level of protection available and potential consequences in B-l Wing. 

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