Documentation process safety management

Today, Canadian process safety management guidelines are based on those promulgated by the US. Center for Chemical Process Safety and are contained in the document. Process Safety Management (Center for Chemical Process Safety 1992). The dozen elements of process safety management are identified in Table 21-2 and very closely track with those of the OSHA requirement, but there are differences. 

It is incumbent upon the toller to develop and follow internal management systems as appropriate to support business needs, production needs, process safety, environmental responsibility, and worker health. The selection process should have considered whether or not satisfactory systems are in place. Nevertheless, the contract or auxiliary documents may be the vehicle used to help ensure that the system reviewed is the system actually used for completing the toll in question. Within the process safety management system, the management of change and training elements are essential subsystems. 

The audit team, through its systematic analysis, should document areas that require corrective action as well as where the process safety management system is effective. This provides a record of the audit procedures and findings and serves as a baseline of operation data for future audits. It will assist in determining changes or trends in future audits. 

This document presents cm approach for implementing Process Safety Management (PSM) within our company, prepared for the Core Management Group s review. It is organized to include the following sections ... 

Each PSM system can then be examined to determine what system modifications (if any) are needed to address the new issues. For example, the process hazard assessment system might be modified to include participation by industrial hygienists to identify potential sources of exposure. Some process safety management systems (e.g., process documentation) may require no modification to support a wider scope. 

The CCPS approach to chemical process safety management has been described in a number of documents ... 

Gathering audit data can be accomplished through observations, documents, and interviews. The data obtained is used to verify and validate that the process safety management systems are implemented and functioning as designed. Data gathering can be aided oy the use of audit samples, where a representative number of items are audited to draw a conclusion, and by using self-evaluation questionnaires. 

Document Chemical Reactivity Risks and Management Decisions Process Knowledge and Documentation Process Risk Management Process Safety Information Process Hazard Analysis Operating Procedures Operational Control... 

This Concept Series book supports several of the twelve elements of process safety enunciated in Guidelines for the Technical Management of Chemical Process Safety, including process knowledge and documentation, process risk management and enhancement of process safety knowledge. The purpose of the book is to assist designers and operators of chemical facilities to understand and reduce potential hazards associated with static electricity. 

Common sense and the OSHA Chemical Process Safety Management Law requires an audit of compliance to the Management of Change. Periodic review and documentation of a sites activities in managing aspects of personnel and process safety is often a part of an organization s culture. A good audit can measure the actual versus intended effectiveness of various programs. 

There may also be legal obligations associated with the review results. A properly administered process safety management program will help minimize legal exposures. All recommendations produced by the study should be circulated in draft form to all interested parties within the company. The report should be consistent with other hazard assessment reports, and there should be a follow up procedure to manage recommendations in a timely and effective manner. All steps in the process should fully document the resolution path for each recommendation. 

Determine the probability and severity of each consequence, and document if desired (for determining probability and severity levels the user is referred to the company s Process Safety Management Documents and Appendix C). 

This document is intended as a typical guideline and reference book that may be applied at petroleum, petrochemical and chemical facilities. It is suggested that this document is used as a practical reference to prepare the safety review requirements for these and related industries, and their process safety management systems. 

This publication is intended to provide guidance to HAZOP (Hazard and Operability) and What-If review teams associated with the petroleum, petrochemical, and chemical industries. It describes the nature, responsibilities, methods and documentation required in the performance of such reviews. This ensures the reviews are conducted in a timely, effective and professional manner as may be prescribed by a company s Process Safety Management (PSM) Policy. 

The ORC document emphasized the application of management control systems to facilities processing highly hazardous chemicals. The ORC report helped form a new law within the United States. The new standard, OSHA 1910.119, Process Safety Management of Highly Hazardous Chemicals, is part of the U.S. Code of Federal Regulations and was drafted in July 1990, and implemented on May 26, 1992. 

The first major element is Employee Participation [29 CFR 1910.119 (c)]. This requires that affected employees (those who could be affected by an incident) not only have access to pertinent Process Safety Management information, but also be allowed to provide input to its development and use. It is expected that affected employees will be trained in the standard s content. Many companies not only welcome employees input, but also involve them in the development and management of the individual elements. It is expected that all employee participation in PSM implementation will be documented. ... 

Pick up a dictionary and find the entry for procedure. One definition is a particular course or mode of action. A simple statement, but to procedure users, writers, and managers concerned with process safety, the word procedure impUes much more. The Center for Chemical Process Safety s approach to Process Safety Management relies on written procedures to document both hands-on operations and maintenance activities as well as to describe the Process Safety Management S5retem itself. This book was written to help select and implement actions that will... 

The need to keep procedures up-to-date and accurate is a theme that mns throughout this book. Chapter 2 clearly shows that document control is a key element of process safety, environmental responsibihty, and quality. A workable Process Safety Management system requires that you control the access, review, approval, revision, and maintenance of procedures. If your plant has a Total Quality Management System in place, such as ISO 9000, document control for operating and maintenance procedures is essential to keep your certification current. 

Unfortunately, according to Industrial Safety and Hygiene News Process Safety Management Report Card, the written operating procedure requirement is the element of the OSHA PSM Rule for which most citations are written. "Many facihties don t document the procedure or they make changes and don t gp through and document them formally in writing." ... 

This appendix shows how the major elements of process safety management are reflected in API s RP 750, OSHA PSM Rule, and Environmental Protection Agency (EPA) regulations. The common points of each of the three documents are listed. 

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