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6 minutes reading time (1268 words)

PSM Implementation is a Challenge -- Maintaining Compliance is Even Harder

PSM Implementation is a Challenge -- 
Maintaining Compliance is Even Harder

The Process Safety Management rule (PSM), OSHA 1910.119, was implemented in the early 90’s, more than 20 years ago. Implementation was driven by a number of tragic accidents in the process industry. However, despite the long history of the rule and multiple preventable, catastrophic incidents, many companies still have not fully implemented PSM. Companies that have implemented the PSM rule often find it very challenging to maintain compliance. 

Becht Engineering has conducted numerous PSM, due diligence and mechanical integrity audits and discovered deficiencies in PSM compliance. We have even discovered major gaps in some facilities that have done well during OSHA audits. These plants were generally located where there are limited numbers of hydrocarbon and chemical processing facilities. OSHA simply lacked the local resources and skills to perform adequate audits. These plants can be highly vulnerable to both incidents and fines since they may assume everything is in compliance. In the event of an incident they can be subject to large fines if an experienced team does the investigation and discovers deficiencies in compliance. These facilities are essentially “flying under the regulatory radar screen.”

It is important to maintain a sense of vulnerability in our industry. Constant vigilance and attention to detail are needed for safe operation of these facilities. Some of the accidents that drove the PSM rule are listed below. It is highly likely these accidents would not have happened in a plant that is in full compliance with the rule.

  • Flixborough, UK, 1974 cyclohexane release and explosion due to a faulty piping modification that failed, resulting in 28 fatalities, approximately 80 injuries and nearly 2000 buildings outside the plant damaged.
  • Bhopal, India, 1984 methyl isocyanate release resulting in over 3700 fatalities and over 170,000 people treated at hospitals and temporary medical facilities. Accident primarily due to poor maintenance practices and safety systems being out of service.
  • North Sea, 1988, hydrocarbon release and explosion destroying a major offshore platform resulting in 167 fatalities and an insured loss of $3.4 billion. Cause was improper maintenance turnover and starting equipment open to the atmosphere.
  • Pasadena, Texas, 1989 release of flammable gas and explosion resulting in 23 fatalities and 314 injuries due to an improper valve line up after maintenance. The initial explosion registered 3.5 on the Richter scale.

The 14 required elements of the PSM rule simply make sense and are basic elements of a strong Operational Excellence and reliability program.  These elements include:

  • Maintaining process safety information on all covered areas of the facility.
  • Purchasing and installing equipment in accordance with recognized standards.
  • Performing hazards analysis by a competent team on a periodic basis.
  • Maintaining equipment in accordance with manufacturer’s recommendations, using appropriate codes for inspection and recording information on these tests and inspections.
  • Correcting deficiencies in equipment before return to service or preparing an engineering justification to operate until repairs are made.
  • Evaluating any change in the process or equipment before implementation.
  • Conducting a pre-startup safety review before placing new equipment or processes in operation.
  • Training operations, maintenance and contract personnel in the hazards of the process and how to perform their jobs.

As we can see these are simple, basic requirements that only make sense in a plant processing highly hazardous materials. So why have companies and plants been deficient in implementing and maintaining the rule?

The rule requires the operating company to execute daily activities in multiple areas to maintain compliance. A process plant can contain thousands of pieces of equipment that must be properly designed, installed, operated and maintained. This can be highly challenging in a world of employee turnover, cost cutting, lack of management knowledge of the requirements and lack of discipline. Becht Engineering personnel have significant experience in implementing, maintaining and auditing the PSM rule.  Our strength in this field comes from the fact most of our employees are from operating companies and many lived through implementation and maintaining compliance.

Many of the elements of the rule require continuous evaluation and input to plant data systems. In this blog we will examine a few of the elements of the rule and discuss the challenges to maintain compliance.

1910.119(d) Process Safety Information

This section of the rule requires extensive effort during implementation. Accurate information must be maintained in a controlled system so that only one copy and version of the information is available to be used in the plant. This information must be compiled and accurate prior to initiation of the Process Hazard Analysis section required by the rule. Information includes toxicity, exposure limits, physical data, reactivity, corrosive properties, chemical and thermal stability and hazards of inadvertently mixing different chemicals. Information must also include information on the process technology including items such as a block flow diagram, process chemistry, inventories, safe upper and lower process limits and consequence of deviation. Information must be compiled on equipment including materials of construction, P&IDs, electrical classification, relief system design, design codes used, safety interlock systems and material and energy balances. The design must be in accordance with a term called RAGAGEP or Recognized and Generally Accepted Good Engineering Practices. In the event the plant was built to codes and standards that are no longer in use, the owner must demonstrate the equipment is acceptable to operate.

It is clear that implementation of this section of the rule is a daunting task. Equally important is the plant must have systems in place to maintain and continuously update the information. This can include input from new modifications, projects, hazards analysis findings and other adjustments impacting the information such as new product slate or debottleneck.

1910.119(j) Mechanical Integrity

Compliance with the requirements of the Mechanical Integrity section of the rule is very challenging and Becht Engineering has significant experience with many aspects of the section of the rule. Our expertise includes inspection planning, failure analysis, metallurgical evaluation, equipment design and evaluation of deficiencies such as crack like flaws in equipment.

Many aspects of the Mechanical Integrity section of the rule focus on RAGAGEP. The owner must implement programs to assure the ongoing integrity of the equipment and the programs must meet generally accepted good engineering practice. For example, equipment manufacturers may recommend certain preventative maintenance programs. In the event the owner wants to deviate from these recommendations, an engineering justification for an alternate method must be prepared and documented. The rule also requires periodic tests and inspections be documented, including who performed the inspection, date, what was done and results. If the equipment does not pass the inspection, it must be repaired before returning to service or an engineering justification demonstrating the equipment is safe to operate must be prepared and monitored until the repair is completed. Maintaining this documentation is critical to compliance, reliability and safe operation of the plant.

The employer must also implement a quality assurance program for all new equipment. The employer must confirm the equipment is designed and constructed to be suitable for the service and have a program in place to assure the equipment is installed correctly. Spare parts and maintenance materials must also be suitable for the intended service.

1910.119(0) Compliance Audits

The rule requires compliance audits be conducted every three years to assure the procedures and practices used in the facility are adequate and being followed. The employer must address and correct findings in a timely manner. Becht Engineering has personnel that can supplement audit teams, utilize standard audit protocols and provide independent facilitation for audits.

As we have seen, implementing and maintaining compliance with OSHA 1910.119 can be an ongoing challenge. However the rule provides a basic framework for improved operation of processing facilities. It simply makes good sense. 

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Sunday, 20 January 2019

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