Facility and Operational Changes

Plants are often upgraded, modified, or reconstructed in some manner. Examples range from minor equipment modifications to large scale demolition and construction projects. 

One major concern is whether current operations must continue during such changes. This can present significant hazards and safety problems. 

The use of outside contractors to execute the work is also of concern. Contractors must be aware of and follow all site safety regulations. The subjects of contractor communication, training, and awareness of hazards are discussed in Section 4.6. 

A preconstruction safety and health conference should be held with the contractor, who should be briefed on the plant s safety program, first-aid facilities, emergency procedures, and special safety equipment for operational hazards. 

An implementation plan should be developed and reviewed before construction begins. It shotdd include 

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If a proposed change falls outside of plant specifications, codes of practice, or is relatively new technology, then a chemical process safety review team evaluation may be in order. Different organizations provide various names to process safely review teams, such as Safe Operations Committee, Hazards Review Committee, Technical Support Team, Facility and Operations Change Review Committee, or Chemical Process Safety Review Team. Typically, this technical safely committee is chaired by... 

A system is in place to identify changes in laws, regulations, health, and environmental conditions and to reflect those changes in the facilities and operations affected ... 

Most oil companies offer a planned lubrication maintenance (PLM) service that will meet these requirements with the minimum of effort on the part of the customer. These schemes provide logical routing for the lubrication operative, balanced workloads and clear instructions to those responsible for specific tasks associated with lubrication and fault-reporting facilities. Many schemes are now designed for computer operation, which also accommodate plant and grade changes, operation costs and manpower planning. It is essential that any such scheme should be adaptable to individual requirements. 

The CAA compliance deadline may cause companies to install simple end-of-pipe emissions controls, instead of pollution prevention process changes. In order to limit this practice and encourage waste minimization, U.S. EPA allows owners and operators of combustion facilities to request a one-year extension to the compliance period in cases where additional time is needed to install pollution prevention and waste minimization measures that reduce the amount of hazardous waste entering combustion feedstreams.16 Requests for a one-year extension must reasonably document that the waste minimization measures could not be installed in time to meet the three-year compliance period. Decisions to grant the extensions will be made by U.S. EPA or authorized state programs. 

The main business of most chemical companies is to manufacture products by means of controlled chemical reactions. The reactivity that makes chemicals useful can also make them hazardous. Chemical reactions are usually carried out without mishap, but sometimes they get out of control because of problems such as the wrong or contaminated raw material being used, changed operating conditions, unanticipated time delays, failed equipment, incompatible materials of construction, or loss of temperature control. Such mishaps can be worse if the chemistiy under both normal and abnormal conditions is not fully understood. Therefore, it is essential that chemical process designers and operators understand the nature of the reactive materials andchemistry involved and what it takes to control intended reactions and avoid unintended reactions throughout the entire life cycle of a process facility. 

Company A is a major pharmaceutical manufacturer with worldwide operations. The U.S. Chemical Safety and Hazard Investigation Board (CSB) staff visited a site with both pilot-plant facilities and pharmaceutical manufacturing operations. The company is continually developing new and innovative chemistry, which results in frequent changes in the chemicals handled and manufacturing techniques used. 

Company D is a large pharmaceutical manufacturer with worldwide operations. CSB staff visited a pilot-plant facility and thermal hazards laboratory. Pilot-plant operations included the use of several batch chemical reactors. Like Company A, this company also frequently changes chemicals handled and manufacturing techniques. 

It is also important for chemical facilities to develop partnerships with the communities and customers they serve. Partnerships help to build credibility within communities and establish public confidence in utility operations. People who live near chemical facility structures can be the eyes and ears of the facility, and can be encouraged to notice and report changes in operating procedures or other suspicious behaviors. 

Rate of change or frequency of modifications to the facility, its operations, personnel, processes, and equipment... 

Study the immediate impact of the event on the facility and people to see if changes to the layout or the way people operate it can reduce their exposure... 

Source control and waste minimization can be extremely effective in reducing the costs for in-plant controls and end-of-pipe treatment, and in some cases can eliminate the need for some treatment units entirely. The first step is to prepare an inventory of the waste sources and continuously monitor those sources for flow rates and contaminants. The next step is to develop in-plant operating and equipment changes to reduce the amount of wastes. The following are some of the techniques available for the pesticides manufacturing facilities. 

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