Process Safety Management

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no harm

to the environment

Process Safety Code

Responsible Care

®

Code of Management Practices

Making progress

toward our vision of

NO ACCIDENTS

NO INJURIES

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NOTICE

This Guide was prepared by JBF Associates, Inc. (JBFA) as an account of work sponsored by the American Chemistry Council. Neither JBFA, the Council, nor any of their employees, subcontractors, consultants, or other assigns makes any warranty, expressed or implied, or assumes any liability or responsibility for any use, or the results of such use, of any information, product, or process disclosed in this Guide, or represents that its use would not infringe privately owned rights.

This work is protected by copyright. The American Chemistry Council, which is the owner of the copyright, hereby grants a nonexclusive royalty-free license to reproduce and distribute this Guide, subject to the following limitations:

1. The work must be reproduced in its entirety, without alterations.

2. All copies of the work must include a cover page bearing the Council’s notice of copyright and this notice. Copies of the work made under the authority of this license may not be sold.

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ACKNOWLEDGE

The Process Safety Code of Management Practices was developed by the Safe Plant Operations Task Group under the auspices of the Engineering and Operations

Committee of the American Chemistry Council. This Resource Guide was written by Steve Arendt of JBF Associates, Inc. He distilled the information compiled by the Task Group during the

Code's development. At this Guide's publication, the Task Group had the following membership:

Ray Olsen, Chairman Exxon Chemical Company Percy Kavasmaneck

Union Carbide Chemicals and Plastics Company

Brynn Aurelius

Shell Chemical Company Vincent Boyen

Monsanto Company Harry Calsing

The B. F Goodrich Company Joseph Caporossi

American Cyanamid Company Larry Csengery

Shell Oil Company Kerian Fitzpatrick

ARCO Chemical Company Theodore F Henken

Chevron Chemical Company William Jordan

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Michael McCready

Union Carbide Chemicals and Plastics Company

John Oldner

The Dow Chemical Company

Hermann Ortega Air Products and Chemicals, Inc. Win Person

Henkel Corporation Philip Rasch

Hoechst Celanese Corporation Carl Rensink

First Chemical Corporation Lee Schaller

Du Pont Company MacGregor Scott

ARCO Chemical Company Adrian Sepeda

Occidental Chemical Corporation Loren Wassell

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Their technical insights, experiences, and suggestions were essential to the development of this Guide. The author also acknowledges the contributions of the following members of the American Chemistry Council Staff: Stephanie Bowen, Jayne Davis, Dave Hastings, Kyle Olson and Bob Ondocsin.

The author also wishes to recognize the groundbreaking work done by many other process safety professionals who, over the past few years, created much of the original thinking that this guide is based upon. In particular, the author extensively uses material from the Center for Chemical Process Safety's Guidelines for Technical Management of

Chemical Process Safety, the Organization Resources Counselors, Inc.'s report Recommendations for Process Hazards Management of Substances with Catastrophic Potential and the American Petroleum Institute's Guidelines for Management of Process Hazards - Recommended Practice 750.

The author is also indebted to the reviewers of this Guide at JBF Associates, Inc.: Don Lorenzo, Mike Roberts and Curt Rogers. And he wants to thank Karen Fisher, Coco Everett and Tom Williams for their skill and craftsmanship in preparing this document.

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Active participation in the Responsible Care initiative is an obligation of membership in the American Chemistry Council. A member's obligation to Responsible Care applies to all of its chemical businesses covered by the American Chemistry Council dues base. Each member company is expected to make a commitment to Responsible Care by:

Signing the Guiding Principles

Communicating the commitment to Responsible Care to employees

Making good-faith efforts to implement the Codes of Management Practices, participating in the self-evaluation process and meeting the expectations of the Responsible Care Program

Using the Responsible Care name and logo according to the terms and conditions as set forth in the Guidelines

for the Use of the Responsible Care Service Mark

The Process Safety Code is one of six currently planned Codes of Management Practices. The Code identifies

Management Practices that member companies should view as goals. This Resource Guide illustrates possible options for implementing the Process Safety Code. However, this Guide is not an exclusive, mandatory prescription, and the advice contained herein is not obligatory. Rather, it provides suggestions for consideration in your company's efforts to

continually improve process safety. Moreover, adherence to this Code may not be future process safety related regulations.

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TABLE OF CONTENTS

Notice 1

Acknowledgments 2

List of Acronyms and Initials 9

Glossary 10

THE PROCESS SAFETY CODE 14

INTRODUCTION 17

Background 17

Scope 22

Overview and Comparison of the Process Safety Code 22

How to Use This Resource Guide 23

IMPLEMENTING THE CODE IN YOUR COMPANY 28 MANAGEMENT LEADERSHIP IN PROCESS SAFETY 30 Management Practice 1 – Commitment 31 Management Practice 2 – Accountability 34 Management Practice 3 - Performance Measurement 36 Management Practice 4 - Incident Investigation 37 Management Practice 5 - Information Sharing 39 Management Practice 6 - CAER Integration 51 PROCESS SAFETY MANAGEMENT OF TECHNOLOGY 42 Management Practice 7 - Design Documentation 43 Management Practice 8 - Process Hazards Information 45 Management Practice 9 - Process Hazard Analysis 46 Management Practice 10 - Management of Change 48

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PROCESS SAFETY MANAGEMENT OF FACILITIES 50 Management Practice 11 – Siting 51 Management Practice 12 - Codes and Standards 53 Management Practice 13 - Safety Reviews 54 Management Practice 14 - Maintenance and Inspection 56 Management Practice 15 - Multiple Safeguards 57 Management Practice 16 - Emergency Management 59 MANAGING PERSONNEL FOR PROCESS SAFETY 60

Management Practice 17 - Job Skills 61

Management Practice 18 - Safe Work Practices 62 Management Practice 19 - Initial Training 64 Management Practice 20 - Employee Proficiency 65 Management Practice 21 - Fitness for Duty 66 Management Practice 22 – Contractors 67 IMPROVING PROCESS SAFETY PERFORMANCE 69

BIBLIOGRAPHY 70

APPENDIX. 73

Questions and Answers 73

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LIST OF TABLES

Table Description Page

1 Responsible Care Program Elements 2 Guiding Principles for Responsible Care

3 Summary of the Process Safety Code of Management Practices 4 Comparison of Process Safety Management Systems

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LIST OF ACRONYMS AND INITIALS

AIChE American Institute of Chemical Engineers AIHA American Industrial Hygiene Association ANSI American National Standards Institute API American Petroleum Institute

ASME American Society of Mechanical Engineers ASTM American Society of Testing and Materials CCPA Canadian Chemical Producers Association CCPS Center for Chemical Process Safety CGA Compressed Gas Association CAA Clean Air Act

CAER Community Awareness and Emergency Response DOT Department of Transportation

DIERS Design Institute for Emergency Relief Systems DIPPR Design Institute for Physical Property Data EOC Engineering and Operations Committee EPA Environmental Protection Agency FMEA Failure Modes and Effects Analysis FTA Fault 73ree Analysis

HAZOP Hazard and Operability Analysis ISA Instrument Society of America

LEPC Local Emergency Planning Committee

MP Management Practice

MSDS Material Safety Data Sheet

NAM National Association of Manufacturers NFPA National Fire Protection Association

NIOSH National Institute for Occupational Safety and Health NJ-DEP New Jersey Department of Environmental Protection ORC Organization Resources Counselors

OSHA Occupational Safety and Health Administration P&ID Piping and Instrument Diagram

PFD Process Flow Diagram PSM Process Safety Management

RMPP Risk Management and Prevention Plan SPOTG Safe Plant Operations Task Group TCPA Toxic Catastrophe Prevention Act

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GLOSSARY

This Code uses key terms in a context that may be different than their associated regulatory definitions. However, adherence to this code does not relieve a company of the obligation to meet federal, state and local regulatory requirements.

Accident An unplanned, specific combination of events or circumstances that leads to an undesirable

consequence Accidental chemical An unplanned, sudden release of chemical(s) from release manufacturing, processing, handling and on-site

storage facilities to the air, water or land. It does not include permitted or other releases

Acute hazard The potential for injury or damage to occur as a result of an instantaneous or short duration exposure to the effects of an accident

Community Awareness and A program begun by the American Chemistry Council in 1985 and Emergency Response enhanced in 1989 when turned into a Code. It involves building (CAER) communication channels between industry and the

public, and creating emergency response planning mechanisms within companies

Chronic hazard The potential for injury or damage to occur as a result of prolonged exposure to an undesirable condition Code A set of management practices that Council members

must make a good-faith effort to implement to meet their Responsible Care commitment

Consequence The cumulative, undesirable result of an accident, usually measured in health/safety effects, environ mental impacts, loss of property and business costs

Consequence analysis The analysis of the expected effects of an accident, independent of its likelihood Dispersion models Mathematical models that characterize the transport of toxic-flammable materials

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Element A group of management practices within this code Event tree A logic model that graphically portrays the

combinations of events and circumstances in an accident Failure modes and effects A systematic, tabular method for evaluating the analysis (FMEA) causes and effects of component failures Fault tree A logic model that graphically portrays the

combinations of failures that can lead to a particular system failure or accident of interest

Hazard The inherent chemical or physical potential of a material or activity to harm people, property or the environment Hazard and operability A systematic, qualitative brainstorming approach for analysis (HAZOP) hazard evaluation that studies deviations from normal

process conditions

Human factors A discipline concerned with designing machines, operations and work environments so that they match human capabilities, limitations and needs. Includes any technical work (engineering, procedure writing, worker training, worker selection, etc.) related to the human factor in operator-machine systems

Incident An unplanned event or series of events and

circumstances usually involving equipment failures and human errors resulting in an undesired

consequence. If the outcome is severe, it is usually called an accident

Likelihood An estimate of the expected frequency or probability of occurrence of an event

Management practice The basic component of a code. It represents goals and objectives rather than prescriptive absolute or

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Material safety data sheet Near miss

Process hazard analysis Process hazard evaluation Process hazard review Process safety

Process safety activity Process safety management Quantitative risk assessment

Continual Improvement

A compilation of the toxicity, flammability, stability and reactivity hazards of a chemical. It is a legal document, required by OSHA's Hazard Communication Standard

An incident whose consequence would have been severe enough to have been classified as an accident, if not for a fortuitous event or if slightly different circumstances existed

An organized effort to identify and analyze hazards associated with chemical processes and operations so that they can be controlled It normally involves the use of qualitative techniques to identify and assess the significance of hazards and develop conclusions and recommendations. Occasionally, quantitative methods may be used to help prioritize risk reduction alternatives

A discipline that focuses on prevention of fires, explosions and accidental chemical releases at chemical process facilities. Excludes classic worker health and safety issues involving working surfaces, ladders, personal protective equipment and so forth

An example of a policy, program, tool or system that, if instituted, will help a company implement a management practice A program or activity involving the application of management principles and analytical techniques to ensure the process safety of chemical facilities. Focuses on preventing major accidents rather than dealing with classic worker health and safety issues

The systematic development of numerical estimates of the expected frequency and/or consequence of potential accidents that are then used to make decisions concerning the level of safety associated with a facility or operation

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Risk An estimate of human injury or economic loss in terms of both the accident likelihood and the magnitude of the loss or injury. The combination of the expected frequency (events/year) and

consequence (effects/event) of a single accident or a group of accidents

Risk assessment The systematic evaluation of the risk associated with potential accidents at complex facilities or operations Risk management The systematic application of management policies,

procedures and practices to the tasks of analyzing, assessing and controlling risk in order to protect employees, the general public and the environment as well as company assets, while avoiding business interruptions. Includes decisions to use appropriate engineering and administrative controls for reducing risk

Safety critical jobs Jobs, activities and tasks that, if improperly per formed,. have the potential to significantly increase the risk of a fire, explosion or accidental chemical release

Sound engineering practice The application of mandatory codes and standards supplemented by the use of voluntary codes, standards and guidelines, tempered by professional judgment What If Analysis A qualitative examination of a process or operation

conducted by asking questions that begin with "What if" concerning possible failures or errors

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THE PROCESS SAFETY CODE

PURPOSE

The Process Safety Code of Management Practices is designed to prevent fires, explosions and accidental chemical releases. The Code is comprised of a series of Management Practices that reflect this goal, with the expectation of continuous performance improvement for each Management Practice. The Practices are based on the principle that facilities will be safe if they are designed according to sound engineering practices; built, operated and maintained properly; and periodically reviewed for conformance.

Process safety is an interdisciplinary effort. Consequently, the Code is divided into the following four elements: management leadership, technology, facilities and personnel. Each element is composed of Management Practices. Individually, each Practice describes an activity or approach important to preventing fires, explosions and accidental chemical releases. Collectively, the Practices encompass process safety from the design stage through operation, maintenance and training. The scope of this Code includes manufacturing, processing, handling and on-site storage of chemicals. This Code must be implemented with full recognition of the community's interest, expectations and participation in achieving safe operations.

The process safety management program in each facility is complemented by workplace health and safety programs, as well as waste and release reduction programs which address and minimize releases and waste generation. These three programs, and others, will help assure that American Chemistry Council member facilities are operated in a manner that protects the environment and the health and safety of personnel and the public.

RELATIONSHLP TO GUIDING PRINCIPLES

The Code helps achieve several of the Responsible Care Guiding Principles:

• To recognize and respond to community concerns about chemicals and our operations

• To make health, safety and environmental considerations a priority in our planning for all existing and new plants and processes

• To operate our plants and processes in a manner that protects the environment and the health and safety of our employees and the public

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MANAGEMENT PRACTICES

Each member company shall have an ongoing process safety program which includes:

Management Leadership

1. Leadership by senior management through policy, participation, communications and resource commitments in achieving continuous improvement of performance

2. Clear accountability for performance against specific goals for continuous improvement 3. Measurement of performance, audits for compliance and implementation of corrective actions

4. Investigation, reporting, appropriate corrective action and follow-up of each incident which results or could have resulted in a fire, explosion or accidental chemical release

5. Sharing of relevant safety knowledge and lessons learned from such incidents with industry, government and the community

6. Use of the Community Awareness and Emergency Response (CAER) process to assure public comments and concerns are considered in design and implementation of the facility's process safety systems

Technology

7. Current, complete documentation of process design and operating parameters and procedures

8. Current, complete documentation of information relating to the hazards of materials and process technology 9. Periodic assessment and documentation of process hazards, and implementation of actions to minimize risks

associated with chemical operations, including the possibility of human error

10. Management of changes to chemical operations to maintain or enhance the safety originally designed into the facility

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Facilities

11. Consideration and mitigation of the potential safety effects of expansions, modifications and new sites on the community, environment and personnel

12. Facility design, construction and maintenance using sound engineering practices consistent with recognized codes and standards

13. Safety reviews on all new and modified facilities during design and prior to start-up 14. Documented maintenance and inspection programs that ensure facility integrity

15. Sufficient layers of protection through technology, facilities and personnel to prevent escalation from a single failure to a catastrophic event

16. Provision for control of processes and equipment during emergencies resulting from natural events, utility disruptions and other external conditions

Personnel

17. Identification of the skills and knowledge necessary to perform each job

18. Establishment of procedures and work practices for safe operating and maintenance activities

19. Training for all employees to reach and maintain proficiency in safe work practices and the skills and knowledge necessary to perform their job

20. Demonstrations and documentation of skill proficiency prior to assignment to independent work, and periodically thereafter

21. Programs designed to assure that employees in safety critical jobs are fit for duty and are not compromised by external influences, including alcohol and drug abuse

22. Provisions that contractors either have programs for their own employees consistent with applicable sections of this Code or be included in the member company's program, or some combination of the two.

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INTRODUCTION BACKGROUND

The chemical process industry (CPI) in the U.S. is extremely diverse. It produces a multitude of chemical compounds during the manufacture of commercial goods including fuels, plastics, foods, pharmaceuticals, pesticides, textiles, metals and other important commodities. The thousands of chemicals involved range from innocuous materials to those posing various potential risks to safety, health and the environment. Considering that there are now tens of thousands of facilities handling hazardous chemicals, the occasional occurrence of accidents cannot be avoided entirely. But, many process accidents should be anticipated and actions to prevent them or mitigate their effects can be taken.

In 1988, the U.S. chemical industry publicly declared its support for a continuous effort to improve the industry's responsible management of chemicals. Through the American Chemistry Council, the industry energized this declaration by establishing the Responsible Care initiative and its 10 Guiding Principles. Moreover, Responsible Care was made an obligation of Council membership, and now, all Council members have pledged their support, and implementation is underway. Table 1 presents an overview of the Responsible Care initiative.

Using Codes of Management Practices to specify qualitative performance guidelines for member companies is one of the important features of the Responsible Care initiative. Initially, five groups of codes have been defined by the Responsible Care Coordinating Group. Each group of codes provides a framework that member companies can use to satisfy their obligation of making a good-faith effort toward achieving the Guiding Principles of Responsible Care. The codes are developed by working groups composed of technical experts from member companies.

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Responsible Care Program Elements Guiding Principles

A statement of the philosophy and commitment by each member company regarding environmental, health and safety responsibilities in the management of chemicals. The Executive Contact of each member company signs a pledge committing the company to operating its facilities according to the 10 Guiding Principles

Codes of Management Practices

Codes focus on Management Practices in specific areas of chemical manufacturing, transportation and handling. Specific objectives are outlined to help companies satisfy the spirit of the Guiding Principles. Member companies are to make good-faith efforts to achieve these qualitative performance goals and continually improve performance

Public Advisory Panel

A group of environmental, health and safety professionals, along with members from various public sectors, assists the industry in identifying and developing programs and actions that are responsive to public concerns

Member Self-Evaluations

Reports, measurements and other demonstrations of program implementation document progress toward improved environmental, health and safety performance in the responsible management of chemicals

Executive Leadership Groups

In periodic regional meetings, senior industry representatives review Codes of Management Practices under development, discuss progress on implementing existing codes, and identify areas where assistance from the Council or other companies is needed

Obligation of Membership

Bylaws obligate member companies to abide by the Guiding Principles, to participate in the development of the codes and programs and to make good-faith efforts to implement the program elements of the Responsible Care initiative

One of the five groups of codes is the Safe Plant Operations Code. This code is made up of two component codes: the Process Safety Code and the Employee Health and Safety Code. The Process Safety Code of Management Practices is designed to prevent fires, explosions and accidental releases of chemicals. The management practices defined in the Code are statements of goals based on the principle that facilities will be safe if they are designed according to sound engineering practices; built, operated and maintained properly; and periodically reviewed for conformance to the Code.

The Employee Health and Safety Code is directed at the day-to-day, classic worker health and safety issues such as the proper use of personal protective equipment, hot work permits, confined space entry procedures, occupational exposure, medical surveillance and so forth. Together these two codes define the management practices necessary to satisfy the Responsible Care Guiding Principles relating to the safe and healthful operation of chemical manufacturing facilities.

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SCOPE

While the Process Safety Code forms the foundation for industry's pursuit of the goal of accident-free chemical operations, no one can guarantee such an end result. Nonetheless, this Code, and the Responsible Care initiative in general, is dedicated in spirit to the goal of "zero accidents" and is committed to the continual improvement of process safety performance in an effort to reach that goal.

The Process Safety Code prescribes Management Practices designed to prevent major process accidents and to help achieve several of the Responsible Care Guiding Principles. (The primary principles that this Code addresses are highlighted in the list of Guiding Principles presented in Table 2.) Collectively, these practices address process safety issues throughout the life cycle of a process - from conception and design, through construction and start-up, and continuing with long-term operation of the facility. The scope of this Code includes all phases of on-site operation:

• Manufacturing • Storage

• Processing • Handling

Moreover, these management practices deal with a variety of activities, including normal operation, maintenance, training, process modifications and capital improvements.

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Guiding Principles for Responsible Care

To recognize and respond to community concerns about chemicals and our operations

• To develop and produce chemicals that can be manufactured, transported, used and disposed of safely

To make health, safety and environmental considerations a priority in o r planning for all existing and new products and processes

• To report promptly to officials, employees, customers and the public, information on chemical-related health or environmental hazards and to recommend protective measures

• To counsel customers on the safe use, transportation and disposal of chemical products

To operate our plants and facilities in a manner that the environment and the health and safety of our employees and the public

• To extend knowledge by conducting or supporting research on the health, safety and environmental effects of our products, processes and waste materials

• To work with others to resolve problems created by past handling and disposal of hazardous substances

• To participate with government and others in creating responsible laws, regulations and standards to safeguard the community, workplace and environment

• To promote the principles and practices of Responsible Care by sharing experiences and offering assistance to others who produce, handle, use, transport or dispose of chemicals

Figure 1 illustrates the relationship of the companion codes of Responsible Care and provides a basis for discussing the limits of the scope of the Process Safety Code. Three code groups (Safe Plant Operations; Distribution; and Release Reduction and Waste Management) comprise the main thrust of responsible care of chemicals. The CAER code group plays a unique role in unifying all of the public communication activities under its existing community outreach network. The Product Stewardship code group provides the glue that ties all of the others together; it addresses potential concerns both in the development stage and once products are "out on the shelf." Each of these groups of codes is undergoing development and the relationships of one code group to another may change with time as the Responsible Care initiative matures. The following are brief descriptions of the five codes (other than the Process Safety Code).

Dirtribution - This Code seeks to reduce the risk that transportation and off site storage of chemicals poses to the public,

to carriers, to contractor and company employees and to the environment. It applies to all modes of transportation (i.e., pipeline, barge, truck, ship and rail) and to distribution activities (e.g., storage, transfer and repackaging) occurring while chemicals are in transit between member companies and their suppliers and customers. The Distribution Code contains Management Practices on the following topics:

• Distribution risk management • Compliance review and training • Carrier safety fitness

• Chemical handling and storage

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Waste and Release Reduction and Waste Management - This Code consists of two parts: the Waste and Release

Reduction Code (the WARR Code was approved in April 1990) and the Waste Management Code (scheduled for approval in the fall of 1991). The WARR Code is designed to achieve ongoing reductions in the amount of all

contaminants and pollutants released and in the amount of wastes generated at facilities. The Waste Management Code will address the handling of remaining pollutants after the implementation of the WARR Code.

When combined, the WARR Code and Waste Management Code will contain Management Practices on the following topics:

• Commitment

• Inventory releases and wastes • Evaluation of risks

• Communication of risks and attention to public concerns (using the CAER Code) • Establishment of reduction priorities and goals

• Implementation of reduction plans • Measurement of progress

• Communication of progress for feedback (using the CAER Code) • Integration with business plans

• Research and development

• Outreach to industry, customers and suppliers • Protection of the environment

• Mitigation of past handling and disposal problems

When examined in conjunction with the Process Safety Code, the Waste and Release Reduction and Waste Management Codes address the release and waste generation factors during the design/redesign of manufacturing and other processes. They also guide the handling, decommissioning, and disposal of process equipment.

Employee Health and Safety - This Code addresses traditional worker health and occupational safety issues. It contains

Management Practices on the following topics:

• Administration • Analysis

• Prevention and control • Training and communication

The employee safety topics covered under this Code are distinctly different from the process safety concerns addressed in the Process Safety Code. Together with the Process Safety Code, these two codes make up the Safe Plant Operations Code.

CAER - This Code is the focal point for all code activities that involve communication with the public. It also includes

those activities involving emergency response following an accident. The CAER Code contains Management Practices relating to community outreach and emergency response on the following topics:

• Employee education • Incident recovery • Communications training • Risk assessment

• Public education • Emergency response plan • Outreach program • Response training

• Policy • Emergency exercises • Effectiveness evaluation • Facility tours

• Two-way dialogue with • Information sharing employees and community

The Process Safety Code complements the CAER Code in the area of communication of relevant process safety information.

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Product Stewardship - This Code focuses on the proper management of products at each stage in their life cycle. The

goal is to design, develop, manufacture, transport, use and dispose of products safely and with minimal environmental impact. It involves a number of functional areas within the member company organization (R&D, manufacturing, distribution and sales and marketing) as well as suppliers, outside contractors, distributors and customers.

OVERYIEWAND COMPARISON OF THE PROCESS SAFETY CODE

The Process Safety Code is divided into four elements: • Management leadership

• Facilities • Technology • Personnel

Each of these elements characterizes a particular aspect of chemical process safety assurance, and each element is composed of management practices. Table 3 lists each of the 22 Management Practices defined by this Code.

Table 3 Summary of the Process Safety Code of Management Practices

MANAGEMENT LEADERSHIP Commitment Accountability Performance Measurement Incident Investigation Information Sharing CAER Integration FACILITIES Siting

Codes and Standards Safety Reviews

Maintenance and Inspection Multiple Safeguards Emergency Management TECHNOLOGY

Design Documentation Process Hazards Information Process Hazard Analysis Management of Change PERSONNEL

Job Skills

Safe Work Practices Initial 71; wining Employee Proficiency

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e past two years, much effort has been expended defining appropriate activities for what is now called Process Safety Management. In 1 ation Resources Counselors published a report, later provided to the U.S. Occupational Safety and Health Administration,

mendations for Process Hazards Management of Substances with Catastrophic Potential. The Center for Chemical Process Safety of the A

of Chemical Engineers published guidelines for Technical Management of Chemical Process Safety. More recently, the American Pe published a recommended practice entitled Management of Process Hazards.

ublications have many features in common. Many of the management systems and safety assurance activities are the same - albeit or tly. Some have different activities to meet the special needs of the particular focus group. Table 4 is a comparison of the basic components

systems, including this Process Safety Code.

cular, this Process Safety Code embraces all of the key aspects of the three other PSM systems listed in Table 4. The main extension of t the other PSM systems are: (1) the emphasis placed on management leadership, (2) the use of the CAER process to share relevan tion with industry and the public and (3) the pioneering effort to characterize a company's role in assuring that employees in safety critical uty. Enthusiastic management support is already recognized and accepted as the primary catalyst for companies to be successful in con ng process safety. On the other hand, sharing experience and assuring fitness for duty are crucial elements that may be difficult to achieve.

TO USE THIS RESOURCE GUIDE

source Guide is designed to equip you with a thorough understanding of the Process Safety Code of Management Practices so that you c elp your company meet its Responsible Care obligations. However, this Guide is not a "how to" manual for executing specific technical

management activities. Instead, this Guide provides an interpretation of the Code's Management Practices, describes the scope of the to other Responsible Care segments and provides advice on how you can help achieve continual process safety improvement.

tion designated by Tab 3 describes the general tasks that may have to be performed in implementing this code in your company and d es for prioritizing code activities. The sections of this Guide designated by Tabs 4-7 describe each of the 22 Management Pracdca that co

elements of the Process Safety Code. For each practice, process safety codes are provided that may be useful in your quest for continual

mprovement. Not all of these activities are appropriate for every company or for every facility or division within a company. You should , and perhaps add others, that fit your company's needs and culture. Secondly, cuwnples are given for each activity to illustrate how compan ave successfully implemented them. Finally, pitfaffs and considcmnons are discussed so that you will be better equipped to meet future hallenges. Space is provided for you to take notes and to personalize this guide with ideas that you think may help your company or facili e Guide may be updated periodically; please feel free to use the form provided at the rear of the Guide to compile your comments and sug ubmit them to the American Chemistry Council.

to consider when assessing process safety performance and when completing the self-evaluation portion of the Responsible Care initia d in the section designated by Tab 8. The Bibliography (Tab 9) section provides an extensive list of authoritative references that compan seful in creating effective process safety management programs. The Appendix (Tab 10) provides a list of typical questions that arose du

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Comparison of Process Safety Management Systems

AMERICAN CHEMISTRY COUNCIL

RESPONSIBLE CARE ement Leadership mitment untability rmance Measurement ent Investigation mation Sharing R Integration ogy n Documentation ss Hazards Information ss Hazard Analysis gement of Change s s and Standards y Reviews

enance and Inspection ple Safeguards gency Management nel kills Work Practices Training oyee Proficiency s for Duty actors

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CENTER FOR CHEMICAL PROCESS SAFETY tability

Knowledge and mentation

Reviews and Design dures anagement ment of Change Equipment Integrity Investigation and Performance Factors

ds, Codes and Laws and Corrective Actions

ement of Process Safety wledge

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NIZATION RESOURCES COUNSELORS Safety Information Hazards Analysis ment of Change in ss 'Ibchnology ng Procedures g -Related Incident igation g

ent Quality Assurance ical Integrity

-up Safety Review ment of Change in ties

ncy Response and ol

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CAN PETROLEUM INSTITUTE Safety Information Hazards Analysis ment of Change ng Procedures ork Practices g

Equipment and Mechanical Integrity -up Safety Review

ncy Response and ol

-Related Incident igation

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Creating a process safety management program from scratch and implementing the Responsible Care Process Safety Code is an imposing challenge. Fortunately, many companies have implemented at least some of the provisions of this Code. The following are some basic tasks that you may consider performing in your company's good-faith effort to implement the Code and to satisfy your Responsible Care commitment.

1. Develop a thorough understanding of the Process Safety Code and its relationship to other Responsible Care codes. This Resource Guide should be a good start in helping you understand the scope of the Process Safety Code. As other codes and resource guides are developed, the scope definition and relationship of the codes will evolve. The American Chemistry Council is planning training seminars to aid member companies in implementing Responsible Care. Take advantage of these courses and attend Responsible Care information meetings to share your experiences with other companies.

2. Identify current company activities related to proem safety management

Most companies are already doing many of the activities discussed in the Management Practices. However, these activities may be highly decentralized. Perform a thorough survey of corporate and plant engineering activities. Create an inventory listing of departments and people responsible for performing process safety work.

3. Compare the Process Safety Code of Management Practices and examples of process safety activities to the process safety management inventory at your company and facility.

Identify gaps in programs at both the corporate and local plant levels. Determine departments and people best suited to make the necessary adjustments.

4. Determine priorities for implementing new process safety management activities.

Making some adjustments may be easy, such as extending an existing vessel inspection program to cover a forgotten class of equipment at a plant. Other improvements may be more difficult to make - it may take a long time to develop the in-house resources to do the job. Each company must evaluate its priorities based the risk of its operations, the exposure created by having an incomplete process safety management program and the available resources for implementing new programs.

5. Develop a program plan for fully implementing the Management Practices of the Process Safety Code.

Write a detailed plan outlining schedule, resources needed and individual responsibilities for implementing each new activity. Update the plan periodically (e.g., quarterly) - this will aid you in performing the self-evaluation of your company's performance.

6. Execute the process safety improvements.

Be deliberate and start with small steps. Early successes will spur interest and support. Attend American Chemistry Council sponsored Responsible Care meetings to share your experience with others and learn better ways to implement your programs.

The way you implement this Code in your company will be influenced by many factors. Company size will play a role. Large companies may already be doing much of what is required in the Management Practices, and they will probably have the necessary resources to satisfy the Code in a reasonable amount of time. Small companies, on the other hand, may have more limited resources for implementing new programs. But, through mutual aid arrangements with large

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The evolving regulatory climate will also affect how companies choose to implement the management practices of the Process Safety Code. Several states have already passed laws requiring companies to perform tasks that will satisfy many of the Process Safety Code obligations. OSHA has proposed a new rule (29 CFR 1910.119) mandating that companies have programs in place to manage process hazards. Also, the 1990 Clean Air Act contains a number of features requiring companies to do more to prevent major chemical accidents. The requirements of applicable state and federal regulations relating to process safety management will certainly affect the priority and speed with which you may ultimately implement the Process Safety Code. However, adherence to the Process Safety Code may not guarantee regulatory compliance, now or in the future.

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MANAGEMENT LEADERSHIP IN PROCESS SAFETY

The foundation of any effort to improve process safety has to be management leadership. Although leadership and initiative are needed throughout all levels of an organization, it is crucial that senior management provide visible support and encouragement. Words alone are never enough; true commitment to continual improvement of process safety must be evidenced by management actions that reinforce a company's safety policies and goals.

The goal of the Management Leadership element is to ensure that process safety goals and objectives are defined and communicated throughout a company, and that responsibility and accountability for results are assigned. Six Management Practices (MPs) have been defined as essential components of process safety management leadership. The following sections discuss each practice. First, process safety activities are defined that may be useful in your quest for continual process safety improvement. Not all of these activities are appropriate for every company or for every facility within a company. You should choose the ones, and perhaps add others, that fit your company's needs and culture. Secondly, examples are given for each activity to illustrate how companies like yours have successfully implemented them. Finally, pitfalls and considerations are discussed so that you will be better equipped to meet future process safety challenges. Space is provided for you to take notes and to personalize this Guide with ideas that you think may help your company or facility.

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Management Practice 1: Commitment

Leadership by senior management through policy, participation, communications and resource commitments in achieving continuous improvement of performance

Clear definition and communication of process safety goals and objectives are critical to achieving long-term safe plant operation. Company management is responsible for establishing a corporate culture that places high value on safety. To be effective, a proper mind set must be developed, nurtured and rewarded in a continual, visible fashion.

PROCESS SAFETY ACTIVITIES

1.1 Establish a formal corporate process safety policy. Collect information on other companies' process safety policies.

Compose a written statement that describes your company's process safety philosophy. Distribute and display it with other important company policies.

Publicize formal adoption of the policy by the corporate board of directors.

Develop guidelines to help each business group or corporate functional area implement the policy.

Establish a mechanism for senior management to solicit candid employee feedback about the process safety policy during its development and implementation. This can be done during plant visits, safety reviews and inspections.

1.2 Define corporate and line management organizations for implementing process safety initiatives.

• Form committees or task forces, where appropriate, to suggest structural changes that promote process safety. • Provide an organization chart.

• Clearly define process safety responsibilities in job descriptions.

• Establish levels of authority for making process safety-related decisions. • Emphasize hiring professionals with process safety expertise.

13. Commit adequate resources to sustain continual improvement of process safety-

• Establish budget items, as necessary, for specific process safety development programs.

• Provide incentives and recognition (e.g., special awards, compensation) to employees who demonstrate extraordinary initiative in pursuing process safety.

• Acquire necessary equipment, tools, software and facilities (e.g., computer software for emergency relief system design and release prediction).

• Provide training and instruction to employees. Develop process safety training programs and materials. Use outside specialists as necessary to supplement internal expertise.

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1.4 Personally participate in an open, active manner in activities that visibly demonstrate process safety commitment. Regularly attend process safety committee meetings.

Discuss process safety incidents at staff meetings.

Chair steering groups for company process safety committees. Participate in plant inspections.

Generate a high profile for process safety by being active in process safety groups (e.g., Responsible Care, CAER, CCPS, NAM, local emergency planning committees).

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PITFALLS AND CONSIDERATIONS

Inconsistent management leadership (or a lack of management leadership principles) will undermine the credibility of process safety policies. Employees watch management to see if their actions bear out verbal and written commitment to the company process safety policy. The minute one ignores even a minor safety infraction (e.g., even though it's company policy, someone decides not to wear a hardhat and safety glasses to go to the lunchroom because they'll be outside for only a minute), management credibility evaporates and others may mimic "the boss's" performance. Long-term commitment as evidenced by consistent enforcement of company safety policies is essential to the success of process safety management programs.

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PROCESS SAFETY ACTIVITIES Management Practice 2- Accountability

Clear accountability for performance against specific goals for continual improvement

Everyone who has process safety responsibilities, from senior management to process operators, must exercise appropriate authority and judgment and understand and submit to being accountable for their process safety performance. 21 Establish specific process safety related goals to use in determining whether

continual improvement is being made.

• Use industry information to establish injury and incident rate targets. Include process-related fatalities.

• Use company experience to set targets for reducing the frequency of process safety-related accidents, incidents, near misses, reportable releases, etc. Develop incentives and systems to encourage complete reporting.

• Define goals (i.e., short- and long-term) for reducing accidental releases, property losses and business interruption. 2.2 Uniformly enforce codes, standards and procedures that promote process safety.

• Provide resources to stay informed of the evolving legal and regulatory climate relating to process safety. • Ensure that company standards are followed and that any exceptions are properly authorized.

• Verify compliance with applicable consensus standards (e.g., ASME, NFPA, ANSI, AS'1'M) through a project safety review program (MP13).

2.3 Define a mechanism for reviewing management accountability for process safety.

• Include specific process safety goals in yearly personal objectives. Ensure that there is a performance rating inspection during periodic performance appraisals.

• Encourage creative goal setting methods in promoting personal achievement in continual improvement of process safety.

• Provide incentives to encourage individuals to make the correct "safetyfirst" decisions in the face of production or other competing needs.

2.4 Establish a management system to ensure compliance with the Process Safety Code of Management Practices. • Define a plan for verifying that the commitment to process safety through the Responsible Care program is being

met.

• Establish management criteria for periodic review of conformance with these Management Practices. • Identify deficiencies and develop strategies and plans for expeditiously correcting them.

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PITFALLS AND CONSIDERATIONS

Specific process safety goals are difficult to define. Avoid vague prescriptions in performance goals, such as "operate unit safely." Instead, start deliberately by choosing a few very specific, measurable targets (e.g., complete annual process safety audit of five facilities per month, achieve 90% attendance at shift process safety seminar, implement/ resolve all recommendations from the last periodic process hazard review of the facility). React appropriately (e.g., recognition, promotion, letters of reprimand) to improved/ inadequate process safety performance.

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Management Practice 3: Performance Measurement

Measurement of performance, audits of compliance, and implementation of corrective actions.

Accountability for one's commitment (or lack thereof) to the Guiding Principles of Responsible Care that address process safety cannot be achieved unless management measures and reacts to the process safety performance of the affected individuals. Once measurement systems are in place, management can perform periodic audits, prescribe corrective actions for areas that need improvement and support awards for people who have achieved their performance goals. (See Tab 8 for more information on process safety performance evaluations.)

PROCESS SAFETY ACTIVITIES

3.1 Establish a program to verify operating facilities' compliance with proem safety objectives. • Define the physical and organizational scope of the program.

• Commit adequate personnel for performing audits.

• Coordinate Process Safety Code audits with other regular audits (e.g., loss prevention, boiler, environmental) to avoid duplication.

• Establish a system to measure the effectiveness of the audit program. • Develop lists of corrective measures.

3.2 Verify that corrective actions have been implemented in a timely fashion. • Assign specific responsibilities for correcting identified deficiencies. • Establish target completion dates along with a resource plan.

• Require documentation of actions that resolve audit recommendations.

• Establish a system to track corrective action efforts. For example, how many were completed last quarter? How many are in progress? How many are behind schedule? How many are under study?

• Establish a priority authorization system for approving resources (i.e., capital items, staff, etc.) for process safety-related items.

PITFALLS AND CONSIDERATIONS

Measurement systems ultimately fail when the gathered data do not match reality. Management must ensure that audits are not carried out in a perfunctory manner. Another pitfall is that of inadequate follow-up. Once an audit is complete, resolution of all items must be vigorously pursued. The importance of establishing appropriate process safety priorities must be promulgated throughout the company and then reinforced in performance appraisals. Just as company accountants monitor accounts payable, so too must process safety specialists track the status of corrective actions to improve process safety performance.

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Management Practice 4: Incident Investigation

Investigation, reporting, appropriate corrective action and follow-up of each incident that results or could have resulted in a fire, explosion or accidental chemical release

Process safety-related incidents are unplanned events that result in undesired consequences such as fires, explosions or releases of toxic/hazardous materials. Incidents of interest include not only those that propagate to a fully developed catastrophic result, but also precursor events, those near misses that by circumstance or design were terminated before a more severe consequence resulted.

Major incidents may recur in the same unit, at the same facility, within the same company and within the industry unless forceful measures are taken to prevent them. Thus, in order to continually improve process safety performance, a company should have an aggressive and persistent program for investigating incidents, ferreting out causes, and determining effective corrective measures. Periodically reviewing the circumstances of previous accidents and determining whether similar circumstances have evolved again is an especially effective process safety assurance activity.

PROCESS SAFETY ACIVITIES

4.1 Establish an incident investigation policy.

• Define internally reportable incidents and develop reporting criteria.

• Develop an environment where employees feel empowered and obligated to report incidents, and feel safe from retribution.

• Create an incident review committee or other structure, with senior management involvement, to ensure incident reports are acted upon by the company. Highlight recommendations from previous incidents that have yet to be implemented. • Plan for dealing with incidents in advance. This will help maximize the safety benefits of lessons learned.

• Define lines of authority and priorities when dealing with incidents (e.g., securing the site to prevent further harm, site preservation for collection of data and evidence, cleanup and reconstruction). Ensure proper coordination with emergency response personnel

42 Develop an incident investigation program. • Create incident investigation guidelines.

• Establish investigation team criteria and lists of company resources and sources of special expertise. • Provide the necessary tools and guidance for team members.

• Establish a mechanism for tracking incident reports. Ensure that it follows the life cycle of incidents as they occur, as they are investigated and as results are acted upon.

• Provide criteria for intracompany involvement. Define appropriate roles for legal, public relations and labor relations departments. Sometimes it will be appropriate to perform an investigation under attorney-client privilege.

• Provide resources for enlisting third-party participation by outside experts and specialists needed because of unavailability of company personnel.

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• Ensure the separation of the investigation activity (e.g., data gathering) from follow-on efforts (e.g., disciplining of employees).

4.3 Communicate lessons learned to all appropriate company groups.

• Maintain an incident log and frequency monitoring system. Ensure that incident investigation reports become a part of the process hazards information package (MP8).

• Provide guidelines for writing investigation reports, having them reviewed for other considerations (e.g., legal and public relations) and distributing them to appropriate personnel within the company.

• Develop recommended actions from the results of an investigation. Assign responsibilities and schedules for implementing corrective measures.

• Provide results and lessons learned (MP5) to appropriate authorities and to other company divisions that could be affected (e.g., other company units with similar processes). Coordinate information sharing using CAER outreach (MT6).

• Provide feedback, from the investigation program, on ways to improve company response to incidents. Periodically review the results from past investigations with new employees.

PITFALLS AND CONSIDERATIONS

Lack of adequate planning is a major cause of failure to properly investigate and learn from incidents. Local responsibility must be assigned for site preservation. Ultimately, the success of a company's program is dependent upon how thoroughly and quickly the results are communicated and acted upon within operating facilities. If legal issues and boundaries have not been agreed upon in advance, then the information flow is stymied and valuable time may be lost.

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Management Practice 5: Information Sharing

Sharing of relevant safety knowledge and lessons learned from such indents with industry, government and the community.

Communicating important process safety information to other companies may help prevent accidents and save lives. Responsible sharing of information can be an important factor in maintaining credibility with the local government and communities surrounding a facility.

PROCESS SAFETY ACTIVITIES

5.1 Establish a formal policy for timely publication of process safety related information.

• Prepare a written internal clearance procedure involving appropriate corporate departments (e.g., legal, public relations, technical).

• Encourage in-house legal counsel to establish prerelease approval criteria for generic information, protecting confidential/proprietary data.

• Identify communication media with which information should be routinely shared.

• Encourage publication of process safety papers and presentation of talks to process safety-related conferences and industry groups.

5.2 Establish a formal policy for employee participation with outside groups to foster information sharing- Identify local groups that should receive company information and support.

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5.3 Coordinate information sharing policies with tent investigation practices (MP4) and emergency management (MP16) for publication of accurate information during prolonged emergency situations.

• Designate a room with a telephone for the media to use during an emergency.

• Designate specific plant personnel to interact with local media until corporate staff support arrives.

PITFALLS AND CONSIDERATIONS

Companies that perfunctorily restrict sharing of information hurt themselves and the industry in the long-run. An uninformed public promotes suspicion, not trust. Companies should proactively encourage sharing of appropriate information that could improve industry's overall process safety performance. However, special training of company technical spokespersons may be required for "media" events. Plants must be prepared to supply facts and cooperate with the media during emergencies to avoid incorrect and damaging speculation that inevitably occurs in the absence of timely information sharing. Technical papers or press releases should be reviewed to prevent disclosure of inaccurate or inflammatory information.

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Management Practice 6: CAER Integration

Use of the CAM process to assure that public comments and concerns are considered in design and implementation of the facility's process safety system

The CAER Code of Management Practices provides for reliable emergency response to facility events that could have "beyond-the-fenceline" effects and promotes public dialogue through outreach to responsible community organizations. The Process Safety Code of Management Practices supports the objectives of the CAER Code; companies should use the process already set up through CAER to consider public concerns in the safe operation of process facilities. Companies should take advantage of opportunities to share appropriate technical information and relevant results from internal process hazard reviews with Local Emergency Planning Committees (LEPC).

PROCESS SAFETY ACTIVITIES

6.1 Implement the proactive features of CAER that relate to process safety outreach to the public. • Review the commitment stated in the CAER Code.

• Establish coordination between company CAER representatives and those responsible for process safety issues. • Use existing CAER outreach mechanisms to advise the public of company development and process expansion plans. • Use the CAER process to open a dialogue with the community to receive their concerns about plant activities connected with process safety.

• Act on the community's advice and provide feedback concerning company decisions and their impact on process safety to the community within a reasonable time.

• Encourage company employees to be process safety ambassadors within the community (e.g., giving talks and

distributing information concerning process safety provisions that exist to limit community risk, being a member of an LEPC).

• Use opinion surveys to perform periodic evaluations of the effectiveness of process safety outreach.

PITFALLS AND CONSIDERATIONS

Don't attempt to implement this Management Practice without coordinating it with the existing CAER framework set up within your company. Carefully select information that is appropriately presented for layperson review - don't just distribute lengthy technical reports. On the other hand, don't overly restrict the furnishing of pertinent process safety data because you think it's too complex for the public to understand. Try to avoid the appearance of hearing, but not listening; respond to public concerns in a timely fashion.

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PROCESS SAFETY MANAGEMENT OF TECHNOLOGY

Management leadership can focus on several areas to improve process safety. One general area is Technology. Managing process safety through technology involves making the inherent design and operating characteristics of a new process as free as possible from major hazards. This is achieved through proper process design; retention of important process information concerning potential hazards; and examination of the possible causes, effects and significance of equipment failures, instrument and software malfunctions and human errors. In addition, programs should be established to identify and control changes to process technology and operation so that new hazards are not inadvertently introduced.

The goal of the Process Safety Technology element is to ensure that chemical processes are designed and operated with a level of risk that is acceptable to the company, and ultimately to the regulators and the public. Four Management Practices (MPs) have been defined as essential components of process safety technology. The following sections discuss each practice. First, process safety activities are defined that may be useful in your quest for continual process safety improvement. Not all of these activities are appropriate for every company or for every facility within a company. You should choose the ones, and perhaps add others, that fit your company's needs and culture. Secondly, examples are given for each activity to illustrate how companies like yours have successfully implemented them. Finally, pitfalls and considerations are discussed so that you will be better equipped to meet future process safety challenges. Space is provided for you to take notes and to personalize this guide with ideas that you think may help your company or facility.

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Management Practice 7: Design Documentation

Current, complete documentation of process design and operating parameters and procedures

The long-term safe operation of a process facility depends on company personnel having a thorough knowledge of the design bases for the processes. Maintaining current, complete design documentation for mature processes is not easy, but it is essential for process safety success. If "upto-date" information is not available when a process change is considered, designers could make the wrong choice in specifying equipment size, materials of construction, new operating limits and so forth. Preserving this institutional memory along with process hazards information (MP8) forms the foundation for process hazard evaluations (MP9) and the plant's management of change process (MP10). Efficient management of design documentation helps improve a company's ability to manage the risk of chemical operations.

PROCESS SAFETY ACTIVITIES

7.1 Develop a system for retaining an archive of current design information and a history of significant revisions. • Develop and retain process description, chemistry and reaction data.

• Develop and retain process flow sheets, P&)Ds and interlock logic diagrams (e.g., use computer-aided drawing system).

• Develop and retain equipment fabrication data sheets and inspection records.

Develop and retain design bases for process equipment, especially safety systems (e.g., assumptions for relief valve sizing, rationale for interlocks and safety-related alarm setpoints).

Determine criteria for deciding how frequently (e.g., yearly, every five years or only when significant changes occur) to formally update the design information archive. Dovetail with the management of change system (MP 10).

7.2 Update safe operating ranges for key process variables.

Define safe operating limits based on current process feeds and recipes.

List limiting conditions for continuous process operation (e.g., Should operations be allowed to continue without the emergency shutdown system in service? For how long?).

Establish limits for operating ranges and procedures for dealing with equipment failures or abnormal process parameters. Explain the consequences of exceeding stated safety limits.

7.3 Procedures for normal operations and for dealing with pros upsets and emergencies must be current

Provide dated copies of procedures in control rooms.

Periodically review procedures with operators on the job. Verify that actual practice is reflected in procedures. Create a mechanism to solicit and review operator suggestions for procedure changes.

Consider storing all procedures in a computer data base, so the current procedure can be printed out when needed. Require all non-routine jobs to have written procedures that have been evaluated by the facility's management of change process (MP 10).

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PITFALLS AND CONSMERATIONS

Production pressure during the last stages of construction, maintenance turnaround and start-up may impair a company's abilities to keep their process design documentation up-to-date. Changes implemented with no formal review will allow the actual process design and operating practices to become different from the design of record. The key to maintaining "evergreen" documentation is to do it right once, and then, with the help of a good change control process (see MP10), to regularly update the design package throughout the process lifetime.

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Management Practice &Process Hazards Information

Current, complete documentation of information relating to the hazards of materials and process technology

The documentation of process hazards should cover all materials and operations used in a process. This information must be current and readily available to personnel, because maintaining a good understanding of the hazards that surround them leads to more deliberate and safer operations. Combined with accurate design documentation (MP7), this information is vital to long-term safe operation and regulatory compliance. Recent right-to-know regulations dictate that much of this information be made available to the public.

PROCESS SAFETY ACTIVITIES

8.1 Maintain current, accessible information on material characteristics (e.&, tarzicity, flammability, reactivity) • Establish a data base for physical and chemical property data. Computerize, if possible, to improve accessibility. • Maintain up-to-date MSDSs in all operating units.

• Maintain a company archive of hazards information that can be easily updated.

• Establish a purchasing system to ensure that essential hazards information for new materials is available when required (e.g., upon delivery or when drawn from the storeroom for use in the field).

8.2 Maintain a system for malting current process hazards information available to employees- • Develop process hazards information articles for the plant newsletter.

• Maintain files of process hazards data in an accessible form (e.g., computer data base) that all affected personnel can use.

• Periodically review important process hazards data with the operating staff (e.g., monthly shift safety meetings). • Provide a means for soliciting input from employees about ways to upgrade hazards information.

PITFALLS AND CONSIDERATIONS

There is a vast amount of material hazards information that must be kept current and available to employees. Many materials unknown to process hazards information managers can accumulate in a facility. Personnel can often use normal supply requisition procedures to order new materials to experiment with, and it is difficult to control these new materials. Purchasing controls must be established to ensure that any new materials used in the facility are logged into the process hazards information system and that data on these materials are made available in a timely fashion to potentially affected employees. It is especially difficult to control the use of "foreign" materials by outside contractors or sample materials provided by vendors who want you to try their products. Changes to existing process hazards information should be made through the management of change program (MP 10).

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