Priority Facilities

In the course of assessing your company s current PSM status, you and your team have almost certainly gained a clear sense of which facilities pose the greatest risk, whether by virtue of inherent process hazards, human factors, management systems, or a combination. As you set priorities for implementation you should closely review information gleaned from the assessment tasks. In addition, you should try to validate or flesh out your impressions through some more quantitative analysis that can help to identify priority facilities. 

Stated simply, the extent of potential ha2aid depends on how much hazardous material a facility uses and the conditions under which it is contained. The quantity of material stored provides a measure of the size of any release that could result from a loss of plant integrity. The conditions under which it is contained can influence the extent of any damage that might result from the release. 

However, total quantities of hazardous materials do not, on their own, provide an entirely reliable measure of potential hazard. It is more useful to consider quantities of material within sections of the plant that can be isolated. The amount of material within these individual plant sections usually represents the largest credible release that could occur. Some examples of plant sections that may be isolated include tank farms, unloading racks, and separate process buildings. 

You can quickly identify these plant sections by reviewing process flow diagrams and valving arrangements. Isolation points are defined by control valves or powered block valves that can be remotely activated. Process hazard analysis techniques help you identify the maximum credible accident scenarios. (Note that manual valves should not be considered reliable isolation points unless they are located to be accessible following a major accident. However, remotely-activated valves can only be considered reliable isolation points if there are adequate reliability engineering and maintenance programs in place.) 

You should be able to estimate the quantities of material contained within a section from mechanical and operating data. You should also consider operating conditions, which should be available from the plant mass balance or from actual operating data. Simple hazard models can predict the size of vapor clouds, radiation hazards from fires, and explosion over-pressures. Such models are available from a number of sources. 

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If you have chosen a companywide strategy, you may want to begin with priority facilities another approach would involve launching the installation simultaneously throughout the company. If you re considering the latter, keep in mind that a companywide implementation strategy requires significant involvement of corporate staff. 

For facility-specific installation, it may make sense to start the installation process everywhere at once, paying particular attention to priority facilities. However, if your company is a decentralized one with many sites, you may wish to subdivide the installation by, for example, product lines or t) es of operations. 

Management should establish a program for updating hazards analyses to verify that the most recent hazards analysis reflects the current process. Flazards analyses should be reviewed periodically and updated as appropriate, with typical review intervals ranging between 5 years for high-priority facilities and 10 years for low-priority facilities. The priority factors listed above and changes in the facility should be considered in establishing review frequency. 

TTie U. S. Environmental Protection Agency (EPA) developed the Hazard Ranking System (HRS) (1) to determine priorities among releases, or threatened releases, from remediation sites. The HRS applies the appropriate consideration of each of the following site-specific characteristics of such facilities ... 

Most of the hydrocarbon emissions from iron and steel facilities are not captured by TRI. The EPA Office of Air Quality Planning and Standards has compiled air pollutant emission factors for determining the total air emissions of priority pollutants (e.g., total hydrocarbons, SO, NO, CO, particulates, etc.) from many iron and steel manufacturing sources. 

As this list suggests, the first priority for this facility is its own people, who will require the most comprehensive information and who should receive priority attention. Others on the list have widely varying information needs and levels of interest, all of which the facility manager must take into account in developing a communications plan. 

Another company may accomplish the same goal less formally. An ad hoc committee (at the corporate or facility level) might brainstorm on resource needs, discuss priority items with an empowered manager, and gain veriaal approval. The difference is one of style, as opposed to substance in both cases the task of identifying tools and training has been addressed. 

Criteria such as those suggested above can be usefully applied to the implementation strategy you have selected. In assessing your current PSM status, you will have gained considerable insight into which facilities warrant priority attention similarly, the assessment process sheds light on those PSM elements whose improvement will yield the most productive results. 

Whether you have chosen a facility-specific, a companywide, or a h) rid approach, it may be helpful to consider your priorities in terms of both facilities and PSM elements. The goal here is to help determine what needs doing, in what order, and with what level of effort. 

Where an effective informal system exists and is followed, the issue is one of style, not substance. A facility or unit may have a strong safety culture and sound safety practices, but its managers lack the habit of form documentation, or simply don t think it is important. Assuming that safety performance meets applicable standards, you will probably assign cases like these a relatively low priority, compared with other noncompliance situations. Cases like these are also often the easiest to fix since the fundamentals are already in place, what s required is simply to formalize the informal system by preparing and implementing documentation procedures. 

In the immediate term, however, your plan may be most effective if you focus on the specific needs and priorities you have identified in the course of your work so far. If you clearly define the scope of your plan, and it directly addresses specific needs, your efforts will be far more successful than if you try to do all things for all people. Moreover, focusing on priority needs will almost certainly provide a sound basis for expansion or adaptation for example, procedures developed to address training for operators using high-hazaid materials at one facility (see Rextown vs. Effingham in Figure 5-2) should be readily adaptable to lower-hazard substances at another facility— far more so than the other way around. 

Focus. The Manwood pilot emphasizes PSM s Management of Change element for two reasons 1) this element is fairly complex, which means the pilot will properly exercise the new system, and 2) the facility manager had identified MOC as a priority for review and improvement. 

While you may wish to defer a firm decision about where, specifically, to start rolling out the system until the pilot test is completed, it s wise to consider a number of options as part of the planning process. The priorities you identified in Chapter 5 (both facilities and elements) provide useful guidance similarly, the implementation strategy you have adopted (companywide, facility-specific, or hybrid) will affect these decisions. 

As part of developing the PSM implementation plan (Chapter 5), you and the team identified benefits unique to the approach you selected, using them to help win management s approval. For example, your plan may focus on priority elements because the assessment you conducted suggests that this method will yield the greatest overall improvement in safety performance. And, as part of the pilot test described in this chapter, you focused on facility-specific benefits to enlist the support of local management and staff. 

Which facilities should have highest priority ... 

Facilities with gaps in compliance or the highest risks should have highest priority. Other considerations might be poor existing performance or a recent deterioration in performance. 

When deciding which facilities have priority, consider the inherent risk (which depends on the type and quantity of hazardous materials and the conditions under which they are processed and stored) and the extent to which these risks are controlled. 

Contract review This requirement will have a much higher priority if you use contract labor routinely or are likely to have project work at your facility. This review ensures that PSM, ESH, and quality have been adequately addressed in all contracts. 

Handling, storage, packaging, and delivery After-sales servicing Product safety and liability Purchaser supplied equipment These requirements may not apply to all chemical manufacturing facilities. Where they are required, they are most likely the partial responsibility of the marketing function and you should work with them to establish relevant priorities. 

The toxicological profiles are developed in response to the Superfund Amendments and Reauthorization Act (SARA) of 1986 (Public law 99-499) which amended the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA or Superfund). This public law directed ATSDR to prepared toxicological profiles for hazardous substances most commonly found at facilities on the CERCLA National Priorities List and that pose the most significant potential threat to human health, as determined by ATSDR and the EPA. The availability of the revised priority list of 275 hazardous substances was announced in the Federal Register on November 17, 1997 (62 FR 61332). For prior versions of the list of substances, see Federal RegisternoiiCQS dated April 29, 1996 (61 FR 18744) April 17, 1987 (52 FR 12866) October 20, 1988 (53 FR 41280) October 26, 1989 (54 FR 43619) October 17, 1990 (55 FR 42067) October 17, 1991 (56 FR 52166) October 28, 1992 (57 FR 48801) and February 28, 1994 (59 FR 9486). Section 104(i)(3) of CERCLA, as amended, directs the Administrator of ATSDR to prepare a toxicological profile for each substance on the list. 

The Comprehensive Environmental Response, Compensation, and Liability Aet (CERCLA) [42 U.S.C. 9601 et seq ], as amended by the Superflind Amendments and Reauthorization Aet (SARA) [Pub. L. 99-499], requires that the Agency for Toxic Substances and Disease Registry (ATSDR) develop jointly with the US. Enviromnental Protection Agency (EPA), in order of priority, a list of hazardous substances most commonly found at facilities on the CERCLA National Priorities List (NPL) prepare toxicological profiles for each substance included on the priority list of hazardous substances and assure the initiation of a research program to fill identified data needs associated with the substances. 

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