Yesterday, we
looked at four areas where Arboris could have identified and corrected
problems with the process before a disaster occurred. Today, we’ll look at
six more. Examine your own PSM program for completeness in these areas.
Plan for Contractors
Two
contractors were among those injured in the Arboris fire. The U.S.
Occupational Safety and Health Administration (OSHA) alleges that Arboris had
failed to develop safe work practices addressing contractors in violation of
29 CFR 1910.119(h). Arboris allegedly failed to what Contractor safe work
practices must cover
- The entrance, presence, and exit of contract
employees in covered process areas.
- The collection and evaluation of safety program and
performance information on prospective contractors—for example, the
collection and evaluation of the contractor’s OSHA 300 logs and safety
programs.
Action
items: Make sure that you have a plan in place for controlling
the movement of contractors in covered process areas. For contractors who
will be working on or near covered processes, have a procedure in place for
checking their safety record before they come on-site.
Use Your Pre-Start-Up
Safety Review
Employers
must perform a pre-start-up safety review for new and modified facilities
that confirms, before highly hazardous chemicals are added to a process, that
everything is in place that is needed to ensure the safety of the process.
Arboris allegedly failed to perform a pre-start-up safety review, in violation
of 29 CFR 1910.119(i), by failing to ensure that safety, operating,
maintenance and emergency procedures were in place.
This was a
“bonus” citation of sorts, for OSHA: In failing to have these procedures in
place as required at other points in its PSM program, Arboris also failed to
have them available for its pre-start-up safety review.
Action item: Your
pre-start-up safety review is your last chance to catch any potentially
hazardous errors and omissions. Make sure that workers have a checklist to
work through that will enable them to identify any problems.
Protect Your Mechanical
Integrity
The
mechanical integrity of any covered process is every bit as vital as the
behavior of the chemicals in the system. OSHA alleges that Arboris failed to
develop operational procedures to maintain the ongoing integrity of
equipment, in violation of 29 CFR 1910.119(j). Specifically, Arboris
allegedly did not:
- Develop written procedures covering the inspection,
testing, and maintenance of relief system components, piping system and
valves, and process vessels in its covered process.
- Update its computerized maintenance management system
software for the covered process to the software system in use for the
rest of the plant.
- Establish quality assurance procedures to insure that
equipment, maintenance materials, spare parts, and newly fabricated
equipment were suitable for the process applications in which they would
be used.
- Ensure that appropriate
checks and inspections were performed to ensure that equipment was
installed properly and consistent with design specifications and
manufacturer’s instructions.
- Ensure that inspections and tests were being
performed on pressure-relieving devices in the covered process.
- Ensure that any identified equipment deficiencies are
corrected in a timely fashion and before further use of the equipment.
Action items: Make sure
that your mechanical integrity procedures are as complete and thorough as your
PHA and safe operating procedures. If you’ve upgraded your management
systems, make sure that the upgrade extends to your covered processes as
appropriate. Check your inspection records to ensure that inspections are
actually being performed and that any identified issues are being addressed.
Investigate Any Incidents
The PSM
standard requires employers to fully investigate any incidents that occur in
a covered process. The investigation reports should include the names of the
members of the investigation team, the date the investigation began, a
detailed description of the incident, a list of contributing factors, any
recommendations arising out of the investigation, and documentation of how
those recommendations were addressed.
Arboris
had incident investigation reports for twenty different incidents involving
its covered process—but, according to OSHA, all of those incident reports
were missing one or more required elements, a violation of 29 CFR
1910.119(m). Among Arboris’ alleged failings were a failure to include
on its incident investigation team at least one representative of a
contractor who was working on the process at the time of the incident, and
failure to document the date that the inspection began.
Action item: Are your
incident investigation reports complete—including documentation of how
recommendations were addressed? If not, can you complete them?
Plan for Emergencies
The PSM
standard stresses planning and preparation but recognizes that even with all
that advance planning, pre-start-up review, and management of change, things
can still go wrong. That’s why you also
have to have a plan in place for handling emergencies under 29 CFR
1910.119(n), which references 29 CFR 1910.38, Emergency Action Plans, and
portions of 29 CFR 1910.120, the Hazardous Waste Operations and Emergency
Response (HAZWOPER) standard. Arboris allegedly violated this standard by
failing to create procedures to be followed by workers who remain to operate
critical plant equipment before evacuating.
Action item: If you are
covered by the PSM standard, you are also covered by the Emergency Action
Plans standard and may be covered by HAZWOPER. Make sure that you have done
what you need to in order to comply with all three standards.
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