PSM And RMP Audits: What Manufacturers Can Do To Find And Correct Deficiencies
By Judith Lesslie
This is Part 2 of a series. If you missed Part 1, you can find it here.
Those who work in high hazard industries are familiar with the OSHA Process Safety Management (PSM) and U.S. EPA Risk Management Plan (RMP) requirements for routine audits to assess and verify compliance with these regulations. In Part 1, we reviewed specific types of concerns that have been identified at many manufacturing sites for several of the PSM/RMP elements. In Part 2, we review the following elements: MOC/PSSR, Process Safety Information, Operating Procedures, Mechanical Integrity, Process Hazard Analysis, and Training.
Management of Change (MOC) and Pre-Startup Safety Review (PSSR) are two elements that are joined at the hip. Almost all sites have occasional one-off failings in their MOC and PSSR systems, but very common program-level failures occur around failure to conduct adequate PSSRs prior to approval for startup; failure to follow-up or document punch list items from PSSRs; and failure to conduct or document adequate training or informing of affected personnel prior to startup. While organizational changes are not specifically required to be included in a site’s MOC system, organizational change management is considered RAGAGEP for PSM facilities, so it behooves covered sites to ensure that changes to personnel and changes to the organizational structure are managed appropriately.
Like MOC and PSSR, most sites have occasional failings in the Process Safety Information (PSI) element, which describes information pertaining to the HHC that is required to be available. Larger gaps of PSI are present more often than you might think, including such areas as a clear electrical area classification map, basic process control system alarm documentation (including those identified in process hazard analyses), poor instrumentation documentation, failure to identify safety upper and lower operating limits and the consequences of deviations from those limits, failure to ensure that the process safety time available for operator response to alarm safeguards (as identified in PHAs) is adequate. Ventilation system design information is another area where documentation is frequently lacking as well.
Operating Procedure element failures often echo the PSI failures mentioned above, most particularly in the areas of identification of safety upper and lower operating limits, the consequences of deviations from those limits, and the steps required to correct or avoid deviations. In a similar vein, safety systems and their functions are sometimes not well-covered in operating procedures. It is also relatively common to identify procedures that do not explicitly cover operating phases, such as startup, shutdown, temporary or emergency operations. Finally, a surprising number of facilities fail to annually certify that operating procedures are current and accurate.
Mechanical Integrity (MI) is a huge element, covering vessels, tanks, piping systems, relief devices, emergency shutdown systems, controls, and rotating equipment. While MI programs for mechanical equipment are typically better developed than those for instrumentation and control systems, there are still relatively common concerns identified for mechanical equipment. These include non-code-compliant inspection reports, failure to use appropriately certified inspection personnel, and failure to include components such as hoses, expansion joints, check valves, or other less common mechanical components in the program when they are critical to covered processes. MI program concerns with controls (including monitoring devices and sensors, alarms, and interlocks) and emergency stop functions are even more common. These include failures to categorize criticality, failure to test or inspect (including very serious failures to test process safety e-stops, instruments, and interlocks), and failure to align process hazard analysis (PHA) safeguards with the equipment included in the MI program.
Speaking of PHAs, this is an area where quality varies widely across facilities. While most sites do have PHA reports, it is far too common to find covered process PHAs that are of poor quality, that use non-standard practices, and that are neglected once completed. PHAs are overdue more frequently than you might anticipate as well. There are many sources of good PHA practices and initiating cause data. It behooves facilities to ensure that the personnel responsible for executing the PHA program are well-trained in current industry practices and have good software tools for executing PHAs. It is also important that PHA recommendations and actions to ensure the integrity of identified safeguards are a part of the program expectations. Related to this, PHA recommendations should receive a high level of management attention to ensure they are completed to expectations in a timely manner.
The Training element is one of those typically in pretty good shape at many facilities. However, it is not uncommon to find that employees involved in operating the process are not involved in determining the appropriate frequency for refresher training.
The Stakes
The PSM and RMP regulations have proven over time that they are excellent practices to drive the reduction of serious process safety incidents. It is far better for a company and sites to find and correct their own PSM and RMP system deficiencies than for a serious incident to occur or for a regulatory agency to identify it. Are you positive that the commonly found concerns reviewed above are not present at your facility?
So What?
If you have not previously taken a deep dive into the assessment of the topics above at your site, now would be a good time to do so. If you do not have the right expertise in your staff to assess PSM and RMP compliance in these areas, consider selecting a process safety consultancy with deep experience and expertise to assist you. Their range of experience enables external auditors to share the general methods proven to drive good PSM and RMP compliance across industry. This independence from the site and company has the best probability of a careful assessment with fresh eyes on the relevant critical systems and leads to more efficient compliance with the necessary standards.
Judith Lesslie, CFSE, CSP, is Senior Principal Specialist at aeSolutions