Ok so I may or may not be working for a very small local chemical plant as I haven't made my decision yet. So my question to you is this.. if you owned a small old plant that you wanted to bring up to PSM compliance what would you're To Do list look like? I'm thinking that if it were me them my list would include stuff like:
-Bring in contractor to clean up my equipment records, pump;ids etc (i.e. similar to the group we had in Company X)
-Get some software in place to input inspection data (i.e. I'm thinking of looking into maybe Lloyd's Register Capstone's RBMI software or ...)
- look into software for managing MOCs
- Set up a Reliability program (note. not sure where to start with this one other than maybe a simple spread sheet for now)
If you could throw some ideas my way it would be greatly appreciated so that I can get a better feel for what I might be getting myself into.
Here is my Answer:
First read the PSM law, its a short read and very understandable (OSHA
1910.119). I have condensed it in the powerpoint for simplicity, you
need to read the real thing. It is here:
http://www.osha.gov/pls/
Next clarify your scope with the company. Are you doing all of PSM or
just "Mechanical Integrity"? All of PSM includes Training, Operating
Procedures, Contractors, PHA, Mechanical Integrity.
Use the psm assessment.doc document to do your own assessment
of what they are doing today and identify gaps. As much as you can
document what they are doing that meet the requirements you can save a
lot of time and effort.
Identify the units to be included by having your Chemical Engineers use Appendix A to see what units are qualified. Exclude all units from your PSM procedures that are not required (sulfur plants, utilities, etc)
For each element of the standard, this is what I would do:
1910.119(c) Employee Participation
Write a document which describes what information is available to employees and how they access it.
1910.119(d) Process Safety Information
* Identify what you have and what is missing or out of date
* Develop plans to get what is missing and make sure what you have is up to date. (Hire some contractors who know what they are doing. I can recommend some if need be.)
* For some things like P&ID updates, have your own people do it. Have your operators walk them all down and mark them up. Have a contractor make the changes and draw them up. If you have nothing, bring in the laser scanning guys and have them scan the whole unit and give you drawings and 3D models - it will be cheaper and easy to update but very expensive up front.
1910.119 (e) Process Hazard Analysis
* Put together a schedule to do PHA's and bring in a contractor to start running them. Schedule them so they stretch out over 5 years because they need to be done every 5 years and you don't want to do them all at once every 5 years.
1910.119 (f) Operating Procedures
* Decide on a format and have your operators start writing down everything they do on a routine basis. Consider somebody like RWD to come in and do this for you if your people can't do it. If your operators can read and write it's much cheaper if they do it.
1910.119 (g) Training
* As you get Procedures done. Conduct Operator training on the new procedures and document.
* Specifically identify what training you consider "required" and how often it needs to be done. Keep it to the minimum that meets the requirements.
1910.119 (h) Contractors
* Put together a simple audit and audit your contractors. Ask them to close gaps and re-audit them when they are done. Make sure you follow up and document.
1910.119 (i) Pre Startup Safety Review
* Write a procedure for walking down, HAZOP-ing, and verifying as-built for any change to P&ID and any new installation. Include a checklist with sign off.
1910.119 (j) Mechanical Integrity
* Specifically applies to Pressure vessels and storage tanks; Piping systems (including piping components such as valves); Relief and vent systems and devices; Emergency shutdown systems; Controls (including monitoring devices and sensors, alarms, and interlocks) and, Pumps.
You need inspections, thickness calcs and corrosion rates and next inspection dates for pressure vessels tanks and piping. Calcs and test results and test intervals for relief valves. Regular system tests for emergency shutdown systems and controls (make sure only those that are critical to controlling the process and alarms/shutdowns are counted, indication only instruments need not be included). Pumps is pretty vague - OSHA really only looks for overspeed trip testing on turbine driven pumps. Put in a PM plan on other pumps and you are covered.
* You need written procedures that cover your mechanical integrity program (what gets done when by whom)
1910.119 (k) Hot Work Permit
* If not already covered, go work someplace else. This facility is not safe! Make sure the Hot Work process meets all the PSM requirements. Modify if not.
1910.119 (l) Management of Change
* Define what a "change" is and write a procedure on what must be done when something is changed. Turn what the law says into a procedure for the site. Put together a sign off process to make sure
requirements are met. Buy and MOC software and implement at site. Write your process around the software workflow.
1910.119 (m) Incident Investigation
* Define what an incident is, who will do an investigation and standardize on a process. I recommend Kepner-Tregoe "Problem Analysis"
1910.119 (n) Emergency Response
* Write an Emergency Response Plan. I can probably get a copy of one as an example if you need one.
1910.119 (o) Audits
* Set up a PSM Audit process and a regular audit frequency (the attached PSM Assessment doc is it). Start self-auditing and get a third party to audit you every 3 - 5 years. You may want to do this up front tocover your butt.
1910.119 (p) Trade Secrets
* Nothing to do here. It says you can't use "Trade Secrets" as an excuse to not communicate hazards to your employees.
Good luck and have fun with this. It's a 5 year job.
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