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Course Material

This course material provides an overview of process safety, compliance with standards, process hazard analysis, standard operating procedures, safe work procedures, mechanical integrity, management of change, and auditing process safety systems. It also covers emergency response procedures. The material includes references to real incidents and the importance of auditing for enhancing safety awareness and measuring effectiveness. The course emphasizes the auditing process, including team composition, audit timing and scope, audit protocol, conducting the audit, documenting findings, and addressing recommendations.

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Course Material

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  1. Course Material • Overview of Process Safety • Compliance with Standards • Process Hazard Analysis • Standard Operating Procedures • Safe Work Procedures • Mechanical Integrity • Management of Change • Auditing Process Safety Systems • Emergency Response Procedures

  2. 8. Auditing Process Safety Management Systems 29 CFR 1910.119 (o) Process Safety Management for Biofuels This material was produced under grant SH-19479-09-60-F-36 from the Occupational Safety and Health Administration, U.S. Department of Labor. It does not necessarily reflect the views or policies of the U.S. Department of Labor, nor does mention of trade names, commercial products, or organizations imply endorsement by the U.S. Government.

  3. Explosion at Esso Longford PlantSeptember 25, 1998

  4. Longford, Australia Explosion Cost of Industry Disruptions A$ 1,300,000,000 Ref.: (Royal Commission 1999, International Petroleum Encyclopedia 1999)

  5. Longford, Australia Explosion Corporate PSM Audit

  6. Longford, Australia Explosion PSM Deficiencies • Risk identification • Training • Operating Procedures • PSM documentation • Communications

  7. Definition • PSM Systems Audit • PSM Process Audit Reference: Guidelines for Risk Based Process Safety , 2007, CCPS/AIChE, p.600

  8. Audit Benefits • Verify procedures • Determine improvements • Measure effectiveness • Enhance safety awareness Reference: Guidelines for Process Safety Documentation, 1995, CCPS/AIChE, p.245

  9. 1. Assemble an audit team Familiar with the process to be audited Experienced in PSM

  10. Audit team composition Team leader – Independent Subject matter experts (SMEs)

  11. Audit team composition Area supervisor of the area being audited Lead operator of the area being audited Reference: Plant Guidelines for Technical Management of Chemical Process Safety, Revised Edition, 1992, CCPS/AIChE

  12. 2. Determine the audit timing and scope • Employee Participation • Process Safety Information • Process Hazard Analyses • Operating Procedures • Training • Contractors • Safe work procedures

  13. OSHA PSM Elements 8. Mechanical Integrity 9. Hot work permit 10. Management of Change 11. Incident Investigation 12. Emergency Response 13. Compliance auditing 14. Trade Secrets

  14. OSHA PSM Website 29CFR1910.119 Part Number: 1910 Part Title: Occupational Safety and Health Standards Subpart: H Subpart Title: Hazardous Materials Standard Number: 1910.119 Title: Process safety management of highly hazardous chemicals Appendix: A, B, C, D

  15. PSM Audit Guidance Appendix C to §1910.119 -- Compliance Guidelines and Recommendations for Process Safety Management (Nonmandatory)

  16. 3. Written Audit Protocol Audit Protocol Audit Checklist

  17. Prepare for the audit Audit team Scope Timing Audit protocol

  18. 4. Pre-audit information required 1. Description of processes (PFDs) 2. Process Controls (P&IDs) 3. Organizational structure 4. PSM program description

  19. 4. Pre-audit information required 5. Past audit reports & resolution of recommendations 6. Summary of local regulations

  20. 5. Plan onsite activities

  21. 6. Kick-off Meeting Closeout Meeting

  22. 6. Conducting the Audit Record reviews Direct observations Interviews

  23. 6. Conducting the audit Record reviews 1. Employee participation 2. Process Safety Info 3. PHAs

  24. 6. Conducting the audit • 4. Operating Procedures • 5. Training • Mechanical Integrity • 13. Compliance auditing Record reviews

  25. 13. Compliance Auditing Requirements Every 3 years Keep past 2 audits Informal audits

  26. 6. Conducting the audit Direct Observations 6. Contractors 7. Safe work procedures 9. Hot work permit

  27. 6. Conducting the audit 10. Management of Change 11. Incident investigations 12. Emergency response plan Interviews

  28. Element 12 - Emergency Response Plan

  29. Element 14 Trade Secrets 14. Trade secrets Process Safety Information Process Hazard Analysis Operating Procedures Incident Investigations Emergency Response Compliance Audits

  30. 6. Conducting the audit Immediately inform facility management of imminent hazards

  31. 6. Conducting the audit Daily share preliminary findings and observations

  32. 6. Conducting the Audit Focus on the written protocol Audit Protocol

  33. Close-out Meeting Closeout Meeting

  34. 7. Document the audit Draft report Feedback Final report

  35. 8. Address audit findings and recommendations

  36. 9. Monitor completion of audit recommendations Final Audit Report

  37. Monitor PSM maturation over time for each facility

  38. Share best practices

  39. Remaining Course Material • Overview of Process Safety • Compliance with standards • Process Hazard Analysis • Standard Operating Procedures • Safe Work Procedures • Mechanical Integrity • Management of Change • Auditing Process Safety systems • Emergency response procedures

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