Guidelines for the management of change for process safety pdf




















This information shall consist of at least the following:. Hazardous effects of inadvertent mixing of different materials that could foreseeably occur. Note: Safety data sheets meeting the requirements of 29 CFR Safe upper and lower limits for such items as temperatures, pressures, flows or compositions; and,. An evaluation of the consequences of deviations, including those affecting the safety and health of employees.

Where the original technical information no longer exists, such information may be developed in conjunction with the process hazard analysis in sufficient detail to support the analysis. The employer shall document that equipment complies with recognized and generally accepted good engineering practices. For existing equipment designed and constructed in accordance with codes, standards, or practices that are no longer in general use, the employer shall determine and document that the equipment is designed, maintained, inspected, tested, and operating in a safe manner.

The employer shall perform an initial process hazard analysis hazard evaluation on processes covered by this standard. The process hazard analysis shall be appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process. Employers shall determine and document the priority order for conducting process hazard analyses based on a rationale which includes such considerations as extent of the process hazards, number of potentially affected employees, age of the process, and operating history of the process.

The process hazard analysis shall be conducted as soon as possible, but not later than the following schedule:. No less than 25 percent of the initial process hazards analyses shall be completed by May 26, ;. No less than 50 percent of the initial process hazards analyses shall be completed by May 26, ;. No less than 75 percent of the initial process hazards analyses shall be completed by May 26, ;.

Process hazards analyses completed after May 26, which meet the requirements of this paragraph are acceptable as initial process hazards analyses. These process hazard analyses shall be updated and revalidated, based on their completion date, in accordance with paragraph e 6 of this standard. The employer shall use one or more of the following methodologies that are appropriate to determine and evaluate the hazards of the process being analyzed. The identification of any previous incident which had a likely potential for catastrophic consequences in the workplace;.

Engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases. Acceptable detection methods might include process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors. A qualitative evaluation of a range of the possible safety and health effects of failure of controls on employees in the workplace.

The process hazard analysis shall be performed by a team with expertise in engineering and process operations, and the team shall include at least one employee who has experience and knowledge specific to the process being evaluated. Also, one member of the team must be knowledgeable in the specific process hazard analysis methodology being used.

The employer shall establish a system to promptly address the team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions.

At least every five 5 years after the completion of the initial process hazard analysis, the process hazard analysis shall be updated and revalidated by a team meeting the requirements in paragraph e 4 of this section, to assure that the process hazard analysis is consistent with the current process. Employers shall retain process hazards analyses and updates or revalidations for each process covered by this section, as well as the documented resolution of recommendations described in paragraph e 5 of this section for the life of the process.

The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements.

Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner.

Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment;. The operating procedures shall be reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities. The employer shall certify annually that these operating procedures are current and accurate.

These safe work practices shall apply to employees and contractor employees. Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, shall be trained in an overview of the process and in the operating procedures as specified in paragraph f of this section.

The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks. In lieu of initial training for those employees already involved in operating a process on May 26, , an employer may certify in writing that the employee has the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as specified in the operating procedures.

Refresher training. Refresher training shall be provided at least every three years, and more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process. The employer, in consultation with the employees involved in operating the process, shall determine the appropriate frequency of refresher training. Training documentation. These changes include organizational changes as they relate to process chemicals, technology, equipment, procedures, and changes to facilities that affect a process covered by the PSM Standard 29 CFR Organizational changes, such as changes resulting from mergers, acquisitions, reorganizations, staffing changes, or budget revisions, may affect PSM at the plant level and trigger a PSM MOC procedure.

For example, when the number of employees operating a process is to be reduced due to an organizational change, operators may not be able to continue the proper implementation of existing operating procedures. Budgetary changes can have a similar effect. Organizational changes that have no relationship to plant-level PSM processes, such as changes to corporate or administrative personnel whose duties do not relate to operations or maintenance functions, do not trigger PSM MOC procedures.

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By Sam McNair, P. Not a MyNAP member yet? Register for a free account to start saving and receiving special member only perks. All safety assessments and practices exist within the context of an organization, and as a result, the environment in which a company operates and the safety culture that it fosters within its walls affect the efficacy of any hazard control system. This chapter presents process safety management PSM from both a general perspective and with specific reference to the system implemented at Bayer CropScience Bayer and considers the context in which this system operates in Institute, WV.



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