U.S. Department of Labor | ||||||
Occupational Safety & Health Administration |
Directives
CPL 02-02-045 - CPL 2-2.45A - Process Safety Management of Highly Hazardous Chemicals-- Compliance Guidelines and Enforcement Procedures. |
Directives - Table of Contents |
Record Type: | Instruction |
Directive Number: | CPL 02-02-045 |
Old Directive Number: | CPL 2-2.45A |
Title: | Process Safety Management of Highly Hazardous Chemicals-- Compliance Guidelines and Enforcement Procedures. |
Information Date: | 09/28/1992 |
Standard Number: | 1910.109; 1910.119 |
OSHA Instruction CPL 2-2.45A September 28, 1992 Directorate of Compliance Programs Subject: 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals--Compliance Guidelines and Enforcement Procedures A. Purpose. This instruction establishes uniform policies, procedures, standard clarifications, and compliance guidance for enforcement of the standard for Process Safety Management of Highly Hazardous Chemicals, 29 CFR 1910.119 ("PSM standard"), and amendments to the standard for Explosives and Blasting Agents, 29 CFR 1910.109. B. Scope. This instruction applies OSHA-wide. C. References.
D. Cancellation. This instruction cancels:
E. Action. OSHA Regional Administrators and Area Directors shall ensure that all compliance and enforcement activities related to the PSM standard adhere to the guidelines of this instruction. F. Federal Program Change. This instruction describes a Federal program change which affects State programs. Each Regional Administrator shall:
G. Background. On February 24, 1992, OSHA promulgated the Final Rule for Process Safety Management of Highly Hazardous Chemicals. This standard originally became effective on May 26, 1992. An administrative stay delayed the effective date of paragraphs (f), (h), (j), and (l) until August 26, 1992. That stay has expired and the stayed provisions are now fully effective.
H. Enforcement Activity Related to the PSM Standard--Types of Inspections. 29 CFR 1910.119 has broad applicability to potentially hazardous processes that may exist in a wide variety of industries. Accordingly, enforcement activities related to the PSM standard--either to determine if an employer is covered by the standard or to assess the employer's compliance with it--may take place in any of the inspection types described below. The following guidelines shall apply to PSM-related compliance activity:
I. Inspection Resources. Appropriate levels of staff training and preparation are essential for compliance activities relating to the PSM standard. In particular, it is anticipated that PQV inspections will be highly resource-intensive; they will therefore require careful planning and coordination. The recommendations included as Appendix G of this instruction may be used as a guide for such planning.
J. PQV Inspection Scheduling. Due to the resource-intensive nature of inspections for compliance with the PSM standard, the Agency will be able to perform only a limited number of PQV inspections (as described at K. and L. of this instruction) each year. A special targeting and scheduling system is therefore necessary to maximize the effective use of inspection resources.
K. Scope of PQV Inspection. Comprehensive inspections under the PSM standard shall evaluate the procedures used by the employer and the process-related contract employers to manage the hazards associated with processes using highly hazardous chemicals. Normally, these inspections will embody a three-fold approach, which for reference is termed Program-Quality-Verification (PQV).
L. PQV Inspection Procedures. The procedures given in the FOM, Chapter III, shall be followed except as modified in the following sections:
M. Compliance Guidelines for Specific Provisions of 29 CFR 1910.119. Guidelines for assessing compliance with the provisions of the PSM standard are provided in Appendix A of this instruction.
N. Citations. Citations for violations of the PSM standard shall be issued in accordance with the FOM, Chapters IV and V, with the following additional directions:
O. Non-Mandatory Appendices to this Instruction. This instruction contains two non-mandatory appendices that are designed to provide additional compliance assistance.
P. Evaluation. Each Region shall develop a preliminary evaluation of the effectiveness of this program and submit it to the Directorate of Compliance Programs no later than September 30, 1995. The report shall include, at a minimum, the following items:
Q. Recording in IMIS. Information about PSM-related inspections shall be recorded in IMIS following current instructions given in the IMIS manual. Refer to Appendix H of this instruction for additional guidance. Joseph A. Dear Assistant Secretary DISTRIBUTION: National, Regional, and Area Offices All Compliance Officers State Designees NIOSH Regional Program Directors 7(c)(1) Consultation Project Managers OSHA Training Institute
Purpose. This appendix contains audit guidelines intended to assist the CSHO in investigating an employer's compliance with the PSM standard. It shall be used in conjunction with Appendix B, Clarifications and Interpretations of the PSM Standard, as the primary source of compliance guidance on 29 CFR 1910.119. Structure. The guidelines present a Program Summary, Quality Criteria References, and a Verification checklist for each of the PSM elements. 1. Guidelines for paragraphs c, g, h, k, m, and n are designed so that CSHOs who may not be specifically trained in chemical process plants or in the PSM standard can make a preliminary review of the required elements. 2. Guidelines for elements d, e, f, i, j, l, o, and p are oriented toward more detailed investigations. Use of the Verification Checklist. The verification of each program element is divided into three parts: Records Review, On-Site Conditions and Interviews. 1. The Records Review section describes the documentation of the programs as required by the PSM standard. During a preliminary inspection, the CSHO shall review the documentation for the entire PSM program to ascertain that all of the elements are developed. 2. Sections labeled On-Site Conditions and Interviews guide the CSHO in confirming that the programs are implemented. This confirmation involves observing conditions and procedures, and interviewing the operators, maintenance personnel, engineering support staff, contractors and contractor employees, as appropriate, to determine whether the implemented program matches the program outlined by the documentation.
3. The CSHO shall initially perform a representative number of observations and interviews for elements c, g, h, k, m, and n. A more detailed investigation will cover all 14 elements. During these detailed assessments, the CSHO shall review components from a representative number of processes, if multiple processes exist. To confirm implementation, the CSHO shall compare the conditions and the interview results with both the minimum requirements of the PSM standard and the program outlined by the employer's documents. Audit Guideline Documentation. As noted at P.2. of the body of this instruction, the Audit Guidelines are constructed as a series of questions relating to each of the pertinent provisions of the standard. 1. The questions are designed to elicit a determination of "Yes" or "No" by the CSHO as to whether compliance with the provision has been met. This shall be indicated in the column labeled Met Y/N. A "Y" or "Yes" in this column indicates the subsection meets requirements. An "N" or "No" indicates the employer does not meet the standard and an "NA" signifies that the subsection does not apply. 2. A determination of "No" for any provision indicates noncompliance; thus, any "No" shall normally result in a citation for a violation of that provision. 3. The CSHO shall thoroughly document each such determination in the case file. The Field Note Reference(s) space is used to cross-reference the PSM subsection with the CSHO's field notes. Field notes need not be rewritten when using these guidelines. The CSHO may record field note page numbers, videotape frame identification, photograph identification, and other documentation that refers to the requirements of the standard's elements. Basic Audit Information. In order to gather the information needed to audit the program, the CSHO shall answer the following questions for each element:
1. Who are the officials responsible for developing and implementing each of the program elements? 2. What are the requirements and the contents of each program element? 3. When are the required actions for each element completed and when are they required to be completed? 4. Where have actions been implemented or changed? 5. Why have the implementation decisions and priorities been made as recorded in the PSM documentation? 6. How is the program implemented and how is the program's effectiveness evaluated and improved (monitoring performance, followup and closure of outstanding items, etc.)? Interrelationship of Elements. An essential part of verifying program implementation is to audit the flow of information and activities among the elements. When information in one element is changed or when action takes place in one element that affects other elements, the CSHO shall review a sample of the related elements to see if the appropriate changes and followup actions have taken place. The following example demonstrates the interrelationship among the elements:
In summary, 11 PSM elements can be affected by changing one valve. A CSHO would check a representative number of these 11 elements to confirm that the required followup activities have been implemented for the new valve. Three key elements shall be routinely reviewed to verify that changes have been implemented. They are: * Operating Procedures; * Process Hazard Analysis; and * Training. These elements shall be crosschecked to see if they show that the changes have been followed through to completion.
I. PROGRAM SUMMARY The intent of this paragraph is to require employers to involve employees at an elemental level of the PSM program. Minimum requirements for an Employee Participation Program for PMS must include a written plan of action for implementing employee consultation on the development of process hazard analyses and other elements of process hazard management contained within 1910.119. The employer must also provide ready access to all the information required to be developed under the standard. II. QUALITY CRITERIA REFERENCES
III. VERIFICATION OF PROGRAM ELEMENTS A. Records Review 1. Does a written program exist regarding employee participation? [Criteria Reference .119(c)(1)] 2. Does the written program include consultation with employees and their representatives on the conduct and development of process hazard analyses and on the development of other elements in the PSM standard? [Criteria Reference .119(c)(2)] 3. Does the written program provide employees (including contractor employees) and their representatives access to process hazard analyses and all other information developed as required by the PSM standard? [Criteria Reference .119(c)(3)] B. On-site Conditions Not applicable. C. Interviews 1. Based on interviews with a representative number of employees and their representatives, have they been consulted on the conduct and development of the process hazard analyses? [Criteria Reference .119(c)(2)] 2. Based on interviews with a representative number of employees and their representatives, have they been consulted on the development of other elements of the Process Safety Management program? [Criteria Reference .119(c)(2)] 3. Based on interviews with a representative number of employees (including contractor employees) and their representatives, have they been informed of their rights of access and provided access to process hazard analyses and to all other information required to be developed by the PSM standard? [Criteria Reference .119(c)(3)] (Ask about unreasonable delays in access to information and whether time is given during the working hours to access information required by the PSM standard.)
I. PROGRAM SUMMARY The intent of this paragraph is to provide complete and accurate information concerning the process which is essential for an effective process safety management program and for conducting process hazard analyses. Therefore in accordance with the schedule set forth in paragraph (e)(1) the employer is required to compile written process safety information on process chemicals, process technology, and process equipment before conducting any process hazard analysis. II. QUALITY CRITERIA REFERENCES
III. VERIFICATION OF PROGRAM ELEMENTS A. Records Review 1. Has written process safety information been compiled before conducting any process hazard analysis (PHA)? [Criteria Reference .119(d)] 2. Is information included pertaining to the hazards of the highly hazardous chemicals used or produced by the process, and does the information include at least: [Criteria Reference .119(d)(1): .1200(g)]
NOTE: MSDS's meeting the requirements of 29 CFR 1910.1200(g) may be used to the extent they contain the information required. 3. Is information included concerning the technology of the process, and does it include at least: [Criteria Reference .119(d)(2)]
(Where the original technical information no longer exists, it may be developed in conjunction with the PHA.) 4. Is information included pertaining to equipment in the process, and does it include at least: [Criteria Reference .119(d)(3)(i)]
5. Has the employer documented that equipment complies with recognized, generally accepted good engineering practices? [Criteria Reference .119(d)(3)(ii)] (Review the documentation for evidence that compliance with the appropriate consensus standards has been researched.) 6. Has the employer determined and documented that existing equipment designed and constructed in accordance with codes, standards, or practices no longer in general use are designed, maintained, inspected, tested, and operating in a safe manner? [Criteria Reference .119(d)(3)(iii)] (Documentation may be through methods such as: documenting successful prior operation procedures; documenting that the equipment is consistent with the appropriate editions of codes and standards; or performing an engineering analysis to determine that the equipment is appropriate for its intended use.) B. On-site Conditions 1. Do observations of a representative sample of process chemicals and equipment indicate that the process information is complete? [Criteria Reference .119(d)] (Information that does not correspond to the actual conditions demonstrates incomplete information. Check critical equipment and components to see if they have been properly identified. 2. Do observations of a representative sample of process components indicate that the process complies with recognized and generally accepted good engineering practice? [Criteria Reference .119(d)(3)(ii)] (Review a representative number of safety devices such as pressure relief devices for proper sizing according to the maximum anticipated pressure.) 3. Do observations of a representative sample of the existing equipment designed and constructed according to codes, standards, or practices no longer in general use indicate that this equipment is inspected and is operated in a safe manner (as documented by the employer)? [Criteria Reference .119(d)(3)(iii)] C. Interviews Process Hazard Analysis (PHA) Team: 1. Based on interviews with a representative number of PHA team members, was the process safety information complete before the process hazard analysis was conducted? [Criteria Reference .119(d)] Operators: 2. Based on interviews with a representative number of operators, is MSDS information readily available to the operators who work with hazardous materials? [Criteria Reference .1200] Engineers (if any; or other qualified persons capable of providing the information requested; see Note, p. A-2): 3. Based on interviews with a representative number of engineers, has the employer documented that the process equipment complies with recognized and generally accepted good engineering practice? [Criteria Reference .119(d)(3)(ii)] (Ask about the technical bases for design and selection of equipment, the materials of construction, electrical classifications, relief devices sizing versus maximum anticipated pressures, installation procedures to assure equipment meets design specifications, etc.) For more information on Process Safety Information, see Appendix D, references 8. and 9.
I. PROGRAM SUMMARY The intent of this paragraph is to require the employer to develop a thorough, orderly, systematic approach for identifying, evaluating and controlling processes involving highly hazardous chemicals. Minimum requirements include: (1) Setting a priority order and conducting analyses according to the required schedule; (2) Using an appropriate methodology to determine and evaluate the process hazards; (3) Addressing process hazards, previous incidents with catastrophic potential, engineering and administrative controls applicable to the hazards, consequences of failure of controls, facility siting, human factors, and a qualitative evaluation of possible safety and health effects of failure of controls on employees; (4) Performing PHA by a team with expertise in engineering and process operations, the process being evaluated, and the PHA methodology used; (5) Establishing a system to promptly address findings and recommendations, assure recommendations are resolved and documented, document action taken, develop a written schedule for completing actions, and communicate actions to operating, maintenance and other employees who work in the process or might be affected by actions; (6) Updating and revalidating PHA's at least every 5 years; and (7) Retaining PHA's and updates for the life of the process. II. QUALITY CRITERIA REFERENCES
III. VERIFICATION OF PROGRAM ELEMENTS A. Records Review 1. Has the employer determined and documented a priority order for conducting initial PHA's based on a rationale that includes at least these factors: [Criteria Reference .119(e)(1)]
2. Are the initial PHA's for processes covered by the PSM standard being performed as soon as possible? [Criteria Reference .119(e)(1)] 3. Does the priority schedule for PHA's assure that all initial PHA's will be performed by 5/26/97 and that: [Criteria Reference .119(e)(1)]
(PHA's completed after May 26, 1987 which meet the requirements of this paragraph are acceptable as initial PHA's; they must be updated and revalidated at least every 5 years.) 4. Does the hazard evaluation use one or more of the following PHA methodologies: [Criteria Reference .119(e)(2)]
(See Appendix B for a discussion of appropriate methodologies). 5. Does the PHA address the following: [Criteria Reference .119(e)(3)]
(For example, potential injury, maximum release of hazardous materials, property damage, etc.) 5. (Continued) Does the PHA address the following: [Criteria Reference .119(e)(3)]
(Such controls may include appropriate application of detection methodologies to provide early warning of releases; inventory reduction; substitution of less hazardous materials; protective systems such as deluges, monitors, foams; increased separation distances; modification of the process temperature or pressure; redundancy in instrumentation; etc.)
(Review calculations, charts, and other documents that verify facility siting has been considered. For example, safe distances for locating control rooms may be based on studies of the individual characteristics of equipment involved such as: types of construction of the room, types and quantities of materials, types of reactions and processes, operating pressures and temperatures, presence of ignition sources, fire protection facilities, capabilities to respond to explosions, drainage facilities, location of fresh air intakes, etc.)
(Such factors may include a review of operator/process and operator/equipment interface, the number of tasks operators must perform and the frequency, the evaluation of extended or unusual work schedules, the clarity and simplicity of control displays, automatic instrumentation versus manual procedures, operator feedback, clarity of signs and codes, etc.)
6. Are the process hazard analyses performed by teams with expertise in engineering and process operations, including at least one employee with experience and knowledge specific to the process being evaluated and one member knowledgeable in the specific PHA methodology used? [Criteria Reference .119(e)(4)] 7. Has a system been established to promptly address the team's findings and recommendations? [Criteria Reference .119(e)(5)] Review a representative sample of the documentation. Has the system been able to:
8. Are the PHA's updated and revalidated at least every five years by a qualified team meeting the requirements in paragraph (e)(4), to assure that the process hazard analysis is consistent with the current process? [Criteria Reference .119(e)(6)] 9. Are all initial PHA's, updates or revalidations, and documented resolutions of recommendations kept for the life of the process? [Criteria Reference .119(e)(7)] B. On-site Conditions 1. Do observations of a representative sample of process-related equipment indicate that obvious hazards have been identified, evaluated, and controlled? [Criteria Reference .119(e)(1)] (For example, hydrocarbon or toxic gas monitors and alarms are present; electrical classifications are consistent with flammability hazards; destruct systems such as flares are in place and operating; control room siting is adequate or provisions have been made for blast resistant construction, pressurization, alarms, etc.; pressure relief valves and rupture disks are properly designed and discharge to a safe area; pipework is protected from impact; etc.) 2. Do observations of a representative sample of process-related equipment indicate that PHA recommendations have been promptly resolved? [Criteria Reference .119(e)(5)] C. Interviews PHA Team Member: 1. Based on interviews with a representative number of the PHA team members, are the PHA methodologies used appropriate for the complexity of the process? [Criteria Reference .119(e)(1)] 2. Based on interviews with a representative number of the PHA team members, is the priority order for conducting PHA's based on the extent of the process, the number of potentially affected employees, the age of the process, and the operating history of the process? [Criteria Reference .119(e)(1)] 3. Based on interviews with a representive number of the PHA team members, have the following been addressed: [Criteria Reference .119(e)(3)]
4. Based on interviews with a representative number of the PHA team members, do the members have the appropriate expertise in engineering, process operations, and the process methodology used? Does one member of the team have experience and knowledge in the specific process? [Criteria Reference .119(e)(4)] 5. Based on interviews with a representative number of the PHA team members, does the system established by the employer address the team's findings and recommendations promptly? [Criteria Reference .119(e)(5)] Operators and maintenance: 6. Based on interviews with a representative number of operator and maintenance employees, have the PHA's addressed the recognized hazards of the process and previous incidents which had a likely potential for catastrophic consequences? [Criteria Reference .119(e)(3)] 7. Based on interviews with operator, maintenance, and other employees who may be affected by PHA recommendations, have actions taken to resolve PHA (5) findings been communicated to these employees? [Criteria Reference .119(e)(5)] For more information on PHA, see Appendix D, references: 8.; 9.; 10.; 11.; 12.; 13.; 14.; 15.; 16.; 17.; 25.; 26.; 27, Part I, Section UG-125; 31.; 32.; and 33.
I. PROGRAM SUMMARY The intent of this paragraph is to provide clear instruction for conducting activities involved in covered processes that are consistent with the process safety information. The operating procedures must address steps for each operating phase, operating limits, safety and health considerations, and safety systems and their functions. II. QUALITY CRITERIA REFERENCES
III. VERIFICATION OF PROGRAM ELEMENTS A. Records Review 1. Do written operating procedures exist for each covered process? Do the procedures provide clear instructions for conducting activities safely? [Criteria Reference .119(f)(1)] 2. Do the operating instructions address, as a minimum, step for each operating phase, including: [Criteria Reference .119(f)(1)(i)] * Initial start-up? * Normal operations? * Temporary operations? * Emergency shutdowns? * Conditions requiring emergency shutdown? * Assignment of shutdown responsibility to qualified operators? * Emergency operations? * Normal shutdown? * Start-ups following a turnaround or emergency shutdown? 3. Do the operating procedures include operating limits that outline consequences of process deviation and steps required to correct or avoid deviations? [Criteria Reference .119(f)(1)(ii)] 4. Have safety and health considerations been included in the operating procedures? Do they include at a minimum: [Criteria Reference .119(f)(1)(iii)]
5. Are safety systems and their functions included in the operating procedures? [Criteria Reference .119(f)(1)(iv)] 6. Are the operating instructions consistent with the process safety information? [Criteria Reference .119(f)(1)] 7. Are operating procedures readily accessible to employees who work in or maintain a process? [Criteria Reference .119(f)(2)] 8. Are operating procedures reviewed as often as necessary to assure that they reflect current operating practice? Are they certified annually by the employer that they are current and accurate? Do they reflect current operating practices that have resulted from changes in: [Criteria Reference .119(f)(3)] * Process chemicals? * Technology? * Equipment? * Facilities? 9. Have safe work practices been developed and implemented for employees and contractors to control hazards during operations such as: [Criteria Reference .119(f)(4)] * Lockout/tagout? * Confined space entry? * Opening process equipment or piping? * Control over entrance into a facility by maintenance, contractor, laboratory or other support personnel? B. On-site Conditions 1. Does observation of a representative sample of processes indicate that the written operating procedures are being implemented? [Criteria Reference .119(f)(1)] 2. Does observation of a representative sample of processes indicate that the written operating procedures are readily accessible to employees who work or maintain a process? [Criteria Reference .119(f)(2)] 3. Does observation of a representative sample of processes indicate that operating procedures reflect current practice, including changes that result from process chemicals, technology, equipment, and facilities? [Criteria Reference .119(f)(3)] (Observe to see if actual procedures match the written operating procedures.) 4. Does observation of representative operations indicate that safe work practices have been implemented for company and contractor employees? Do such work practices include, where appropriate: [Criteria Reference .119(f)(4)] * Lockout/tagout? * Confined space entry? * Opening process equipment or piping? * Control over entrance into a facility by maintenance, contractor, laboratory, and other support personnel? C. Interviews 1. Based on interviews with a representative number of operators, are the written operating procedures implemented for each covered process? [Criteria Reference .119(f)(1)] 2. Based on interviews with a representative number of operators, do operating procedures provide clear instructions for safely conducting activities? [Criteria Reference .119(f)(1)] (Specifically ask for conditions requiring emergency shutdown, the operating limits of a particular process or item of equipment, what might occur if a deviation from those limits should take place, steps to avoid the deviation, and precautions necessary to prevent exposure to hazardous chemicals.) 3. Based on interviews with a representative number of employees who work in or maintain a process, are the operating procedures readily accessible? [Criteria Reference .119(f)(2)] 4. Based on interviews with a representative number of operators and maintenance employees, do the operating procedures reflect current operating practice? [Criteria Reference .119(f)(3)]
I. PROGRAM SUMMARY The intent of this paragraph helps employees and contractor employees understand the nature and causes of problems arising from process operations, and increases employee awareness with respect to the hazards particular to a process. An effective training program significantly reduces the number and severity of incidents arising from process operations, and can be instrumental in preventing small problems from leading to a catastrophic release. Minimum requirements for an effective training program include: Initial Training, Refresher Training, and Documentation. II. QUALITY CRITERIA REFERENCES
III. VERIFICATION OF PROGRAM ELEMENTS A. Records Review 1. For employees and contractor employees involved in operating a process do initial and refresher training records exist? Do the records contain the identity of the employee, the date of the training, and the means used to verify that the employee understood the training? [Criteria Reference .119(g)(1)(i)] 2. Has each employee and contractor employee been trained before being involved in a newly assigned process (except employees involved in operating a process prior to 5/26/92)? [Criteria Reference .119(g)(1)(i)] 3. If initial training has not been given to employees and contractor employees involved in operating a process prior to 5/26/92, is there written certification that they have the required knowledge, skills and abilities to safely carry out the duties and responsibilities specified in the operating procedures? [Criteria Reference .119(g)(1)(ii)] (Review the documents to make sure the certification has not been invalidated by a change in duties.) 4. Has each employee and contractor employee involved in operating a process been trained in an overview of the process and the operating procedures including: [Criteria Reference .119(g)(1)(i)] * Steps for each operating phase? Initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, and startup following a turnaround or emergency shutdown * Operating limits? Consequences of deviations and steps required to avoid deviations * Safety and health considerations? Properties and hazards of chemicals used and precautions for preventing exposure * Safety systems and their functions? 5. Has the employer consulted with employees and contractor employees involved in operating the process to determine the appropriate frequency for refresher training? Is the frequency at least once every 3 years? [Criteria Reference .119(g)(2)] B. On-site Conditions Verification is not required. [Criteria Reference .119(g)(1) or (2)] C. Interviews 1. Based on interviews with a representative number of employees, has their training emphasized specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to their tasks? [Criteria Reference .119(g)(1)(i)] 2. Based on interviews with employees named as having provided consultation, has the employer consulted with employees involved in operating the process to determine the appropriate frequency of refresher training? [Criteria Reference .119(g)(2)]
I. PROGRAMS SUMMARY The intent of this paragraph is to require employers who use contractors to perform work in and around processes that involve highly hazardous chemicals to establish a screening process so that they hire and use contractors who accomplish the desired job tasks without compromising the safety and health of employees at a facility. The contractor must assure that contract employees are trained on performing the job safely, of the hazards related to the job, and applicable provisions of the emergency action plan. NOTE: The term contractor includes subcontractor. II. QUALITY CRITERIA REFERENCES
III. VERIFICATION OF PROGRAM ELEMENTS A. Records Review - Employer's Program [Criteria Reference .119(h)(1)] 1. Does the program include all contractor activities that have the potential for affecting process safety, including--but not limited to--contractors performing maintenance or repair, turnaround, major renovation or specialty work on or adjacent to covered processes? (Contractors performing incidental services which do not influence process safety such as janitorial work, food and drink services, laundry, delivery, and other supply services need not be included However, contractors performing construction, demolition, equipment installation, and other work that may affect the safety of a covered process should be included.) 2. Is the information regarding the contractor's safety performance and programs obtained and evaluated for selection of contractors? [Criteria Reference .119(h)(2)(i), .119 Appndxs C & D] 3. Are the contract employers informed, prior to the initiation of the contractors' work at the site, of the known potential fire, explosion, or toxic release hazards related to the contractors' work and the processes? [Criteria Reference .119(h)(2)(ii)] 4. Are contract employers informed, prior to the initiation of the contractors' work at the site, of the applicable provisions of the emergency action plan required by .119(n)? [Criteria Reference .119(h)(2)(iii)] 5. Have safe work practices to control the entrance, presence and exit of contract employers and contract employees in covered process areas been developed and implemented? [Criteria Reference .119(h)(2)(iv); .119(f)(4)] 6. Are contract employers periodically evaluated for their performance in fulfilling their obligations to: [Criteria Reference .119(h)(2)(v)]
7. Has the host employer ensured, through periodic evaluations, that the training provided to contractor employees by the contractor employer is equivalent to the training required for direct hire employees? [Criteria Reference .119(h)(2)(v)] 8. If the employer has identified deficiencies in the performance of contract employers, what action has the employer taken to correct the deficiencies? [Criteria Reference .119(h)(2)(v)] 9. Does the employer maintain a contract employee injury and illness log related to the contractor's work in process areas? [Criteria Reference .119(h)(2)(vi)] Records Review - Contractor's Programs 10. Are all contractor employees trained in the work practices necessary to perform their jobs safely? [Criteria Reference .119(h)(3)(i)] 11. Is each contract employee instructed in the known potential fire, explosion, or toxic release hazards related to his/her job and the processes and applicable provisions of the emergency action plan? [Criteria Reference .119(h)(3)(ii)] 12. Is there documentation that each contract employee has received and understands the required training? [Criteria Reference .119(h)(3)(iii)] 13. Do the contract employee training records contain the following: [Criteria Reference .119(h)(3)(iii)] * The identity of the employee? * The date of the training? * The means used to verify that the training was understood? 14. Are there means to assure that contract employees follow the safety rules of the facility, including safe work practices required in .119(f)(4)? [Criteria Reference .119(h)(3)(iv); .119(f)(4)] (Review evidence of enforcement by the contractor.) 15. Is the employer advised of any unique hazards presented by the contract employer's work or any hazards found by the contract employer's work? [Criteria Reference .119(h)(3)(v)] B. On-site Conditions 1. Based on a representative sample of observations of contractor employees, has the employer's program to control their entrance, presence, and exit been implemented? [Criteria Reference .119(h)(2)(iv)] 2. Based on a representative sample of observations of contractor employees, do they follow the safety rules of the facility? [Criteria Reference .119(h)(3)(iv)] (These rules include the employer's safe work practices such as lockout/tagout, confined space entry, and opening process equipment or piping; they may also include other rules such as excavation procedures or use of PPE.) C. Interviews 1. Based on interviews with contractor employers, did the host employer obtain and evaluate information regarding the contractor's safety performance and programs for selection of contractors? [Criteria Reference .119(h)(2)(i); .119 Appndxs C & D] 2. Based on interviews with contractor employers, have they been informed of the known fire, explosion, or toxic release hazards related to their work and the processes in which they are involved prior to the initiation of their work at the site? [Criteria Reference .119(h)(2)(ii)] 3. Based on interviews with contractor employers, have they been informed of the applicable provisions of the employer's emergency action plan prior to the initiation of their work at the site? [Criteria Reference .119(h)(2)(iii)] 4. Based on interviews with contractor employers and employees, have work practices to control their entrance, presence, and exit of covered process areas been implemented? [Criteria Reference .119(h)(2)(iv)] 5. Based on interviews with the contractor employer, has the employer periodically evaluated the contractor's performance in fulfilling the obligations required in .119(h)(3) to: [Criteria Reference .119(h)(2)(v)] * Assure their employees are trained in safe work practices needed to perform the job? * Assure their employees are instructed in the known potential fire, explosion, or toxic release hazards related to the job and the applicable provisions of the emergency action plan? * Document the required training and the means to verify their employees have understood the training? * Assure their employees follow the facility safety rules and work practices? * Advise the employer of unique hazards presented by the contractor's work? 6. Based on interviews with the contractors employer, has the host employer ensured, through periodic evaluations, that the training provided to contractor employees by the contractor employer is equivalent to the training required for direct hire employees? [Criteria Reference .119(h)(2)(v)] 7. Based on interviews with the contractor employer, if the employer has identified deficiencies in the performance of contract employers, what action has the employer taken to correct the deficiencies? [Criteria .119(h)(2)(v)] 8. Based on interviews with a representative number of contractor employees, has the contractor employer trained them in the work practices necessary to perform their jobs? [Criteria Reference .119(h)(3)(i)] 9. Based on interviews with a representative number of contractor employees, are they being instructed in the known potential fire, explosion, or toxic release hazards related to their work and the processes in which they are involved? [Criteria Reference .119(h)(3)(ii)] 10. Based on the interview with a representive number of contractor employees, have they been instructed in the applicable provisions of the emergency action plan? [Criteria Reference .119(h)(3)(ii)] (Ask them to explain the plan and evacuation procedures.) 11. Based on interviews with a representative number of contractors employees, has the contract employer assured that they follow the safety rules of the facility? [Criteria Reference .119(h)(3)(iv)] (Ask how safe work practices, entry restrictions for the facility, and use of required PPE are enforced.) For additional information on Contractors, see Appendix D, reference 16.
I. PROGRAM SUMMARY The intent of this paragraph is to make sure that, for new facilities an for modified facilities when the modification necessitates a change to process safety information, certain important considerations are addressed before any highly hazardous chemicals are introduced into the process. Minimum requirements include that the pre-startup safety review confirm the following: construction and equipment is in accordance with design specifications; safety, operating, maintenance, and emergency procedures are in place and adequate; for new facilities, a PHA has been performed and recommendations resolved or implemented; modified facilities meet the requirements of paragraph (1), management of change; and training of each employee involved in the process has been completed. II. QUALITY CRITERIA REFERENCES
III. VERIFICATION OF PROGRAM ELEMENTS A. Records Review 1. Has a pre-startup safety review been performed for all new facilities and for modified facilities when the modification is significant enough to require a change in process safety information? [Criteria Reference .119(i)(1)] 2. Do pre-startup safety reviews confirm that prior to the introduction of highly hazardous chemicals to a process: [Criteria Reference .119(i)(2)]
2. (Continued) Do pre-startup safety reviews confirm that prior to the introduction of highly hazardous chemicals to a process: [Criteria Reference .119(i)(2)]
On-site Conditions 1. Do observations of new or modified facilities indicate that prior to the introduction of highly hazardous chemicals:
C. Interviews (See NOTE, p. A-2.] 1. Based on interviews with a representative sample of operators, maintenance employees, and engineers, can it be confirmed that the construction and equipment are in accordance with design specifications prior to introducing highly hazardous chemicals to a process? [Criteria Reference .119(i)2(i)] 2. Based on interviews with a representative sample of operators, maintenance employees, and engineers, are safety, operating, maintenance, and emergency procedures in place prior to introduction of highly hazardous chemicals into a process? Are these procedures adequate? [Criteria Reference .119(i)2(ii)] 3. Based on interviews with a representative sample of operators, maintenance employees, and engineers, is a PHA performed and are recommendations resolved prior to a startup that introduces highly hazardous chemicals into a new process? [Criteria Reference .119(i)2(iii)] 4. Based on interviews with a representative sample of operators, maintenance employees, and engineers, do modified facilities meet requirements of paragraph (1), Management of Change prior to introducing a highly hazardous chemical? [Criteria Reference .119(i)2(iii)] 5. Based on interviews with a representative sample of operators, is training completed for each employee involved in operating the process prior to the introduction of a highly hazardous chemical? [Criteria Reference .119(i)2(iv)]
I. PROGRAM SUMMARY The intent of this paragraph is to assure that equipment used to process store, or handle highly hazardous chemicals is designed, constructed; installed, and maintained to minimize the risk of releases of such chemicals. This requires that a mechanical integrity program be in place to assure the continued integrity of process equipment. The elements of a mechanical integrity program include the identification and categorization of equipment and instrumentation, development of written maintenance procedures, training for process maintenance activities, inspection and testing, correction of deficiencies in equipment that are outside acceptable limits defined by the process safety information, and development of a quality assurance program. II. QUALITY CRITERIA REFERENCES
III. VERIFICATION OF PROGRAM ELEMENTS A. Records Review 1. Does the written mechanical integrity program include? [Criteria Reference .119(j)(1)] * Pressure vessels and storage tanks * Piping systems and components such as valves * Relief and vent systems and devices * Emergency shutdown systems * Controls (including monitoring devices and sensors, alarms and interlocks) * Pumps 2. Are there written procedures to maintain the on-going integrity of process equipment? Does the documentation indicate the procedures have been implemented? [Criteria Reference .119(j)(2)] 3. Has training been provided to each employee contractor employee involved in maintaining the on-going integrity of process equipment in the following: [Criteria Reference .119(j)(3)] * An overview of the process and its hazards? * Procedures applicable to the employee's job tasks to assure that the employee can perform the job tasks in a safe manner? (Review certification documents for employees doing non-destructive tests, welding on pressure vessels, etc., where these certifications are required.) 4. Are inspections and tests performed on each item of process equipment included in the program? [Criteria Reference .119(j)(4)(i)] 5. Do inspection and testing procedures follow good engineering practices? [Criteria Reference .119(j)(4)(ii)] 6. Are inspection and test frequencies consistent with the manufacturer's recommendation and good engineering practice? Are inspections and tests performed more frequently if determined necessary by operating experience? [Criteria Reference .119 (j)(4)(iii)] 7. Is there documentation of each inspection and test that has been performed including all of the following: [Criteria Reference .119(j)(4)(iv)] * Date of the inspection or test? * Name of person performing the procedure? * Serial number or other identifier of equipment on which procedure was performed? * Description of inspection or test performed? * Results of inspection or test? 8. Are deficiencies in equipment that are outside limits (as defined in process safety information) corrected before further use or in a safe and timely manner when necessary means are taken to assure safe operation? [Criteria Reference .119(j)(5)] 9. In the construction of new plants and equipment, does the employer assure that equipment as it is fabricated is suitable for the process for which it will be used? [Criteria Reference .119(j)(6)(i)] 10. Have appropriate checks and inspections been made to assure equipment is installed properly and consistent with design specifications and manufacturer's instructions? [Criteria Reference .119(j)(6)(ii)] (Include contractor supplied equipment.) 11. Does the employer assure that maintenance materials, spare parts, and equipment are suitable for the process application for which they are used? [Criteria Reference .119(j)(6)(iii)] (Include contractor supplied equipment.) B. On-site Conditions 1. Do observations of a representative sample of process equipment indicate deficiencies outside acceptable limits? [Criteria Reference .119(j)(5)] (Compare process safety information criteria with the conditions of the equipment found in the process.) 2. If new plants or equipment are being constructed, do observations indicate that the equipment as it is fabricated is suitable for the process application? [Criteria Reference .119(j)(6)(i)] 3. Do observations of a representative sample of maintenance materials, spare parts, and equipment indicate that they are suitable for the process application for which they will be used? [Criteria Reference .119(j)(6)(iii)] C. Interviews Engineers (if any; or other qualified persons capable of providing the information requested; see NOTE, p. A-2): 1. Based on interviews with a representative number of engineers, have procedures to maintain the on-going integrity of the process equipment been implemented for: [Criteria Reference .119(j)(2)] * Pressure vessels and storage tanks? * Piping systems and components such as valves? * Relief and vent systems and devices? * Emergency shutdown systems? * Controls (including monitoring devices and sensors, alarms and interlocks)? * Pumps? (Ask about the possibility of safety critical equipment being inadvertently rendered inoperative. For example, a relief device might be isolated by closing an upstream valve.) 2. Based on interviews with a representative number of engineers, do the inspection and testing procedures follow recognized and generally accepted good engineering practice? Has prior operating experience indicated a need for a more frequent test and inspection schedule than has been implemented? [Criteria Reference .119(j)(4)] 3. Based on interviews with a representative number of engineers, are equipment deficiencies corrected before use when they are outside the acceptable limits? If not, are the deficiencies corrected in a timely manner and are necessary means taken to assure safe operation? [Criteria Reference .119(j)(5)] 4. Based on interviews with a representative number of engineers, has the employer assured that, for new plants and equipment, the equipment as it is fabricated is suitable for the process application? Are appropriate checks and inspections made to assure equipment is installed properly and consistent with design specifications and manufacturer's instructions? Are maintenance materials, spare parts, and equipment suitable for the process application for which they will be used? [Criteria Reference .119(j)(6)] (Ask about contractor supplied items.) Maintenance: 5. Based on interviews with a representative number of maintenance employees (and, where applicable, contractor maintenance employees), have the written procedures for maintaining the on-going integrity of process equipment been implemented? [Criteria Reference .119(j)(2)] 6. Based on interviews with a representative number of employees and contractor employees involved in maintaining the on-going integrity of the process, have they been trained to assure they can perform their tasks in a safe manner? Did the training include an overview of the process, its hazards, and procedures applicable to the job? [Criteria Reference .119(j)(3)] (Determine if certification, specialized training, or unique qualifications are required.) 7. Based on interviews with a representative number of maintenance employees, do test and inspection procedures follow recognized and generally accepted good engineering practices? Is the frequency of inspections and tests consistent with applicable manufacturer's recommendations and good engineering practices? Are more frequent inspections and tests necessary due as indicated by prior operating experience? [Criteria Reference .119(j)(4)] 8. Based on interviews with a representative number of maintenance employees, are equipment deficiencies that are outside acceptable limits corrected before further use? If not, are corrections made in a timely manner and are necessary means taken to assure operation? [Criteria Reference .119(j)(5)] 9. Based on interviews with a representative number of maintenance employees, are maintenance materials, spare parts and equipment suitable for the process application for which they are intended? [Criteria Reference .119(j)(6)] (Ask about availability and use of substitutes.) For additional information on Mechanical Integrity, see Appendix D, reference: 9.; 18.; 19.; 20.; 21.; 22.; 23.; 27.; 28.; 29.; and 34.
I. PROGRAM SUMMARY The intent of this paragraph is to require employers to control, in a consistent manner, nonroutine work conducted in process areas. Specifically, this subparagraph is concerned with the permitting of hot work operations associated with welding and cutting in process areas. Minimum requirements include: that the employer issue a hot work permit for hot work operations conducted on or near a covered process and that hot work permits shall document compliance with the fire prevention and protection requirements of 29 CFR 1910.252(a). II. QUALITY CRITERIA REFERENCES
III. VERIFICATION OF PROGRAM ELEMENTS A. Records Review 1. Have hot work permits been issued for all hot work operations conducted on or near a process covered by this standard? [Criteria Reference .119(k)(1)] 2. Do the hot work permits indicate the date(s) authorized for hot work performed? [Criteria Reference .119(k)(2)] 3. Do the hot work permits describe the object on which the hot work is to be performed? [Criteria Reference .119(k)(2)] 4. Have the hot work permits been kept on file until the hot work operations were complete? [Criteria Reference .119(k)(2)] 5. Have the hot work permits identified openings, cracks and holes where sparks may drop to combustible materials below? [Criteria Reference .252(a)(2)(i)] 6. Have the hot work permits described the fire extinguisher required to handle any emergencies? [Criteria Reference .252(a)(2)(ii)] 7. Have the hot work permits assigned fire watchers whenever welding is performed in locations where other than a minor fire might develop? [Criteria Reference .252(a)(2)(iii)] 8. Are the hot work permits being authorized, preferably in writing, by the "individual" responsible for all welding and cutting operations? Is authorization preceded by site & inspection and designation of appropriate precautions? [Criteria Reference .252(a)(2)(iv) & .252(a)(2)(xiii)(A)] 9. Have the hot work permits described precautions associated with combustible materials on floors or floors, walls, partitions, ceilings or roofs of combustible construction? [Criteria Reference .252(a)(2)(v) & .252(a)(2)(ix] 10. Has hot work permitting been successful in prohibiting welding in unauthorized areas, in sprinklered buildings while such protection is impaired, in the presence of explosive atmospheres, and in storage areas for large quantities of readily ignitable materials? [Criteria Reference .252(a)(2)(vi)] 11. Have the hot work permits required relocation of combustibles where practicable and covering with flameproofed covers where not practicable? [Criteria Reference .252(a)(2)(vii)] 12. Have hot work permits identified for shutdown any ducts or conveyors systems that may convey sparks to distant combustibles? [Criteria Reference .252(a)(2)(viii)] 13. Have hot work permits required precautions whenever welding on components (e.g., steel members, pipes, etc,) that could transmit heat by radiation or conduction to unobserved combustibles? [Criteria Reference .252(a)(2)(x) & .252(a)(2)(xii)] 14. Have hot work permits identified hazards associated with welding on walls, partitions, ceilings or roofs with combustible coverings or welding on walls or panels of sandwich-type construction? [Criteria Reference .252(a)(2)(xi)] 15. Has management established areas and procedures for safe welding and cutting based on fire potential? [Criteria Reference .252(a)(2)(xiii)] 16. Has management designated the "individual" responsible for authorizing cutting and welding operations in process areas? [Criteria Reference .252(a)(2)(xiii)(B)] 17. Has management ensured that welders, cutters and supervisors are trained in the safe operation of their equipment? [Criteria Reference .252(a)(2)(xiii)(C)] 18. Has management advised outside contractors working on their site about all hot work permitting programs? [Criteria Reference .252(a)(2)(xiii)(D)] 19. Has the Supervisor determined if combustibles are being protected from ignition prior to welding by moving them, shielding them, or scheduling welding around their production? [Criteria Reference .252(a)(2)(xiv)(A)(B) & (C)] 20. Has the Supervisor, prior to welding, secured authorization from the responsible "individual" designated by management? [Criteria Reference .252(a)(2)(xiv)(D] B. On-Site Conditions 1. Conduct checks of current welding and cutting operations to ensure compliance with the requirements of 1910.119(k) and 1910.252(a). The twenty items listed above in "Records Review" may serve as an audit checklist. A management representative, the "individual" responsible for welding operations and the supervisor should all be invited to participate in this on-site check. [Criteria Reference .119(k) & .252(a)] C. Interviews - Employees and Contractors 1. Based on interviews with a representative number of maintenance and contractor employees, has the Supervisor visited welding work operations to verify that: [Criteria Reference .252(a)(2)(xiv)(E),(F) & (G)]
2. Based on interviews with a representative number of maintenance and contractor employees, have hot work permits been issued for all hot work operations conducted on or near a process covered by this standard? [Criteria Reference .119(k)(1)] 3. Based on interviews with a representative number of maintenance and contractor employees, have the hot work permits been kept on file until the hot work operations were complete? [Criteria Reference .119(k)(2)] 4. Based on interviews with a representative number of maintenance and contractor employees, have the hot work permits identified openings, cracks and holes where sparks may drop to combustible materials below? [Criteria Reference .252(a)(2)(i)] 5. Based on interviews with a representative number of maintenance and contractor employees, have the hot work permits assigned fire watchers whenever welding is performed in locations where other than a minor fire might develop? [Criteria Reference .252(a)(2)(iii)] 6. Based on interviews with a representative number of maintenance and contractor employees, are the hot work permits being authorized, preferably in writing, by the "individual" responsible for all welding and cutting operations? Is authorization preceded by site inspection and designation of appropriate precautions? [Criteria Reference .252(a)(2)(iv) & .252(a)(2)(xiii)(A)] 7. Based on interviews with a representative number of maintenance and contractor employees, have the hot work permits described precautions associated with combustible materials on floors or floors, walls, partitions, ceilings or roofs of combustible construction? [Criteria Reference .252(a)(2)(v) & .252(a)(2)(ix)] 8. Based on interviews with a representative number of maintenance and contractor employees, has hot work permitting been successful in prohibiting welding in: [Criteria Reference .252(a)(2)(vi)] * Unauthorized areas? * Sprinklered buildings while such protection is impaired? * The presence of explosive atmospheres? * Storage areas for large quantities of readily ignitable materials? 9. Based on interviews with a representative number of maintenance and contractor employees, have the hot work permits required relocation of combustibles where practicable and covering with flameproofed covers where not practicable? [Criteria Reference .252(a)(2)(vii)] 10. Based on interviews with a representative number of maintenance and contractor employees, have hot work permits identified for shutdown any ducts or conveyors systems that may convey sparks to distant combustibles? [Criteria Reference .252(a)(2)(viii)] 11. Based on interviews with a representative number of maintenance and contractor employees, have hot work permits required precautions whenever welding on components (e.g., steel members, pipes, etc.) that could transmit heat by radiation or conduction to unobserved combustibles? [Criteria Reference .252(a)(2)(x) & .252(a)(2)(xii)] 12. Based on interviews with a representative number of maintenance and contractor employees, have hot work permits identified hazards associated with welding on walls, partitions, ceilings or roofs with combustible coverings or welding on walls or panels of sandwich-type construction? [Criteria Reference .252(a)(2)(xi)] 13. Based on interviews with a representative number of maintenance and contractor employees, has management established areas and procedures for safe welding and cutting based on fire potential? [Criteria Reference .252(a)(2)(xiii)] 14. Based on interviews with a representative number of maintenance and contractor employees, has management designated the "individual" responsible for authorizing cutting and welding operations in process areas? [Criteria Reference .252(a)(2)(xiii)(B)] 15. Based on interviews with a representative number of maintenance and contractor employees, has management ensured that welders, cutters and supervisors are trained in the safe operation of their equipment? [Criteria Reference .252(a)(2)(xiii)(C)] 16. Based on interviews with contractors and contractor employees, has management advised outside contractors working on the site about all hot work permitting programs? [Criteria Reference .252(a)(2)(xiii)(D)] 17. Based on interviews with a representative number of maintenance and contractor employees, has the supervisor determined if combustibles are being protected from ignition prior to welding by moving them, shielding them, or scheduling welding around their production? [Criteria Reference .252(a)(2)(xiv)(A)(B) & (C)]
I. PROGRAM SUMMARY The intent of this paragraph is to require management of all modifications to equipment, procedures, raw materials and processing conditions other than "replacement in kind" by identifying and reviewing them prior to implementation of the change. Minimum requirements for management of change include: establishing written procedures to manage change; addressing the technical basis, impact on safety and health, modification to operating procedures, necessary time period, and authorizations required; informing and training employees affected; and updating process safety information and operating procedures or practices. II. QUALITY CRITERIA REFERENCES
III. VERIFICATION OF PROGRAM ELEMENTS A. Records Review 1. Are there written procedures for managing changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures and changes to facilities that affect a covered process? [Criteria Reference .119(l)(1)] (Review procedures that address responsibilities, steps for assessing risks and approving changes, requirements for reviewing designs for temporary and permanent changes, steps needed to verify that modifications have been made as designed, variance procedures, time limit authorizations for temporary changes, and steps required to return the process to status quo after temporary changes.) 2. Do the procedures assure that the technical basis for the proposed change is addressed prior to any change? [Criteria Reference .119(l)(2)(i)] 3. Do the procedures assure that the impact of the change on safety and health is addressed prior to any change? [Criteria Reference .119(l)(2)(ii)] 4. Do the procedures assure that modifications to operating procedures is addressed prior to any change? [Criteria Reference .119(l)(2)(iii)] 5. Do the procedures assure that the necessary time period for the change is addressed prior to any change? [Criteria Reference .119(l)(2)(iv)] 6. Do the procedures assure that the authorization requirements for the proposed change are addressed prior to any change? [Criteria Reference .119(l)(2)(v)] 7. Are employees involved in operating a process, and maintenance and contract employees whose job tasks will be affected by change informed of, and trained in, the change prior to start-up of process or affected part of process? [Criteria Reference .119(l)(3)] 8. Is the process safety information required by paragraph (d) updated if changed? [Criteria Reference .119(l)(4)] 9. Are the operating procedures or practices required by paragraph (f) updated if changed? [Criteria Reference .119(l)(5)] B. On-site Conditions 1. Do observations of new or recently modified process chemicals, technology, equipment, or procedures (except "replacement in kind") indicate that the Management of Change procedures have been implemented? [Criteria Reference .119(l)(1)] (Determine if records are available to support the procedures for new or revised processes found in the facility.) C. Interviews Operator, Maintenance, and Contractor Employees: 1. Based on interviews with operators, maintenance employees and contractor employees, are procedures implemented to manage changes to existing process chemicals, technology, equipment, facilities, and procedures? [Criteria Reference .119(l)(1)] 2. Based on interviews with operators, maintenance employees and contractor employees, is training in process changes provided to employees whose job tasks will be affected by the changes prior to start-up? [Criteria Reference .119(l)(3)] For additional information on Management of Change, see Appendix D, reference 9., Chapter 7.
I. PROGRAM SUMMARY The employer is required to investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemical in the workplace. An investigation shall be initiated no later than 48 hours following the incident. An investigation team shall be established and a report prepared which includes: 1) Date of incident 2) Date investigation began 3) Description of incident 4) Factors that contributed to the incident 5) Recommendations from the investigation. The employer is required to establish a system to promptly address the incident report findings and recommendations, documenting all resolutions and corrective actions. Incident reports shall be reviewed with all affected personnel whose job tasks are relevant to the investigation and retained for five years. II. QUALITY CRITERIA REFERENCES
III. VERIFICATION OF PROGRAM ELEMENTS A. Records Review 1. Has each incident been investigated which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemicals in the workplace? [Criteria Reference .119(m)(1)] 2. Have incident investigations been initiated as promptly as possible, but not later than 48 hours following the incident? [Criteria Reference .119(m)(2)] 3. Have incident investigation teams been established? Do the teams contain at least one person knowledgeable in the process involved in the incident, and other members with appropriate knowledge and experience to thoroughly investigate and analyze the incident? Has a contractor employee been included in the team if the incident involved work of the contractor? [Criteria Reference .119(m)(3)] 4. Have incident investigation reports been prepared at the conclusion of the investigation which include at minimum: [Criteria Reference .119(m)(4)] * Date of the incident? * Date the inspection began? * A description of the incident? * The factors that contributed to the incident? * Any recommendations resulting from the investigation? 5. Has a system been established to promptly address and resolve the incident investigation report findings and recommendations? [Criteria Reference .119(m)(5)] 6. Have resolutions and corrective actions from the incident investigation reports been documented? [Criteria Reference .119(m)(5)] 7. Have incident investigation reports been reviewed with all affected personnel whose job tasks are relevant to the incident findings including contract employees, where applicable? [Criteria Reference .119(m)(6)] 8. Are incident investigation reports retained for five years? [Criteria Reference .119(m)(7)] B. On-site Conditions 1. Do observations of a representative sample of process components involved in incident investigations indicate that recommendations have been resolved? [Criteria Reference .119(m)(5)] (Compare the corrective actions outlined in the investigation documentation with the actual equipment, procedures, material use, etc.) C. Interviews 1. Based on interviews with a representative number of operators, maintenance employees and contractor employees, have all incidents that resulted in or could reasonably have resulted in a catastrophic release of highly hazardous chemicals in the workplace, been investigated? [Criteria Reference .119(m)(1)] 2. Based on interviews with a representative number of the members of past investigation teams, do the teams contain at least one person knowledgeable in the process involved in the incident, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident? Was a contractor employee included in the team if the incident involved work of the contractor? [Criteria Reference .119(m)(3)] 3. Based on interviews with a representative number of employees whose job tasks are relevant to the past incident investigation findings, have the investigation reports been reviewed with the affected personnel? [Criteria Reference .119(m)(6)] For additional information on Incident Investigations, see Appendix D, references 9. and 24.
I. PROGRAM SUMMARY The intent of this paragraph is to require the employer to address what actions employees are to take when there is an unwanted release of highly hazardous chemicals. The employer must establish and implement an emergency action plan in accordance with the provisions of 29 CFR 1910.38(a) and include procedure. for handling small releases. Certain provisions of the hazardous waste and emergency response standard, 29 CFR 1910.120(a), (p), and (q), may also apply. [NOTE: 1910.120(a) addresses scope, application, and definitions for the entire standard. 1910.120(p) addresses treatment, storage, and disposal (TSD) facilities under the Resource Conservation and Recovery Act (RCRA). 1910.120(q) addresses requirements for facilities that are not RCRA TSD's, where there is the potential for an emergency incident involving hazardous substances. Cleanup operations--including corrective actions and post-emergency response cleanup--are covered by 1910.120(b) through (o). For further guidance, refer to the forthcoming directive on 29 CFR 1910.120.] II. QUALITY CRITERIA REFERENCES
III. VERIFICATION OF PROGRAM ELEMENTS A. Records Review 1. Has an emergency action plan been established and implemented for the entire plant in accordance with the requirements of 1910.38? Does the plan address the following: [Criteria Reference .119(n) or .38(a)(2)] * Escape procedures and routes? * Procedures for post-evacuation employee accounting? * Preferred means to report emergencies? * Duties and procedures of employees who:
2. Is the plan written if the facility has more than ten employees? [Criteria Reference .38(a)(1)] 3. Is there sufficient number of persons designated and trained to assist in the safe and orderly emergency evacuation of employees? [Criteria Reference .38(a)(5)(i)] 4. Is the plan reviewed with each employee covered by the plan: initially when the plan is developed; and whenever the employees' responsibilities or designated action under the plan change; and whenever the plan is changed? [Criteria Reference .38(a)(5)(ii)] 5. Does the emergency action plan cover procedures for handling small releases? [Criteria Reference .119(n)] 6. Is an alarm system established and implemented which complies with 1910.165? Are the alarms: [Criteria Reference .165(b-e)]
7. Does the written emergency response plan meet the requirements of 1910.120(a), (p), and (q), if appropriate? [Criteria Reference .120(a); 120(p); 120(q)] (See the NOTE at I., Program Summary. Clean-up operations required by a governmental body are addressed in .120(a); treatment, storage, and disposal (TSD) facilities under the Resource Conservation and Recovery Act are addressed in .120(p); and .120(q) addresses requirements for emergency response no matter where they occur, except that it does not cover employees engaged in operations at TSD facilities or hazardous waste sites.) 8. If employees are engaged in emergency response (except clean-up operations), does the plan address the following: [Criteria Reference .120(q)] * Coordination with outside parties? * Personnel roles, lines of authority, training, and communication? * Emergency recognition and prevention? * Safe distances and places of refuge? * Site security and control? * Evacuation routes and procedures? * Decontamination? * Emergency medical treatment and first aid? * Emergency alerting and response procedures? * Critique of response and followup? * PPE and emergency equipment? B. On-site Conditions 1. Do observations of a representative sample of alarm systems indicate that they comply with the requirements in .165(b-e)? Are the alarms: [Criteria Reference .165(b-e)] * Distinctive for each purpose of the alarm? * Capable of being perceived above ambient noise and light levels by all employees in the affected portions of the workplace? * Distinctive and recognizable as a signal to evacuate the work area or perform actions designated under the plan? * Maintained in operating condition? * Tested appropriately and restored to normal operating condition as soon as possible after test? (Be present for an alarm test if possible or review video if available.) * Tested no greater than every two months? * Serviced, maintained, and tested by appropriately trained persons? * Unobstructed, conspicuous and readily accessible, if they are manual alarm systems? 2. Do observations of the evacuation routes indicate that they are not blocked, locked, or barricaded? [Criteria Reference .36(b)(4)] 3. Do observations of the evacuation routes indicate that there are readily visible signs for evacuation routes leading to safe locations? [Criteria Reference .36(b)(5)] 4. Do observations of a representative sample of the evacuation route signs during dark conditions indicate that they are adequately illuminated? [Criteria Reference .120(b)(6)] C. Interviews 1. Based on interviews with employees who have been identified as likely to discover releases or assigned other emergency response duties, are they provided training? Is the training based on the duties they are expected to perform? [Criteria Reference .120(q)(6)] 2. Based on interviews with employees who are likely to discover hazardous substance releases, can they demonstrate competency in the provisions listed in the first responder awareness level: [Criteria Reference .120(q)(6)(i)] * Understanding what hazardous substances are, and the risks associated with them in an incident? * Understanding potential outcomes associated with an emergency when hazardous substances are present? * Ability to recognize the presence of hazardous substances in an emergency? * Ability to identify the hazardous substances, if possible? * Understanding the role of the first responder awareness individual in the employer's emergency response plan, including site security and control and the U.S. Dept. of Transportation's Emergency Response Guidebook? * Ability to realize the need for additional resources, and make appropriate notifications to the communication center? 3. Based on interviews with employees who will take defensive action in containing and controlling a release as part of the response, can demonstrate the competencies for a first responder operations level: [Criteria Reference .120(q)(6)(ii)] * Knowledge of the basic hazard and risk assessment techniques? * Knowledge of how to select and use proper PPE provided to them? * Understanding of basic hazardous materials terms? * Knowledge of how to perform basic containment, confinement, and control operations within the capability of their unit? * Knowledge of how to implement basic decontamination procedures? * Knowledge of relevant standard operating procedures and termination procedures for a response? 4. Based on interviews with employees who will take offensive action in containing and controlling a release as part of the response, can they demonstrate the competencies for a hazardous materials (HAZMAT) technician: [Criteria Reference .120(q)(6)(iii)] * Knowledge of how to implement the employer's emergency response plan? * Knowledge of the classification, identification, and verification of known and unknown materials using field survey instruments and equipment? * Ability to function within an assigned role in the Incident Command System? * Knowledge of how to select and use proper Specialized chemical PPE provided to them? * Understanding of hazard and risk assessment techniques? * Ability to perform advanced control, containment, and/or confinement operations within the capability of their unit? * Understanding of how to implement decontamination procedures? * Understanding of termination procedures? * Understanding of basic chemical and toxicological terminology and behavior? 5. Based on interviews with a representative number of operator and maintenance employees, do they know the emergency action plan to protect themselves in an emergency? [Criteria Reference .38(a)]
I. PROGRAM SUMMARY The intent of this paragraph is to require employers to self-evaluate the effectiveness of their PSM program by identifying deficiencies and assuring corrective actions. Minimum requirements include: audits at least every three years; maintenance of audit reports for at least the last two audits; audits conducted by at least one person knowledgeable in the process; documentation of an appropriate response to each finding; documentation that the deficiencies found have been corrected. II. QUALITY CRITERIA REFERENCES
III. VERIFICATION OF PROGRAM ELEMENTS A. Records Review 1. Has the employer certified in writing that there has been an audit of compliance with PSM at least every three years? [Criteria Reference .119(o)(1)] 2. Do the audit reports include an evaluation of all the required paragraphs of the PSM standard? [Criteria Reference .119(o)(1)] 3. Was the compliance audit conducted by at least one person who was knowledgeable in the process? [Criteria Reference .119(o)(2)] 4. Has a report of the findings been developed for each audit? [Criteria Reference .119(o)(3)] 5. Has the employer promptly determined and documented and appropriate response to each of the findings? [Criteria Reference .119(o)(4)] 6. Does the employer document that deficiencies have been corrected? [Criteria Reference .119(o)(4)] 7. Has the employer retained the two most recent compliance audit reports? [Criteria Reference .119(o)(5)] B. On-site Conditions No observations are required; on-site Conditions will be cited under other paragraphs. [Criteria Reference .119(o)(4)] C. Interviews 1. Based on interviews with auditors, are they knowledgeable in processes? [Criteria Reference .119(o)(2)] 2. Based on interviews with a representative number of employees and their designated representatives, do they have access to compliance audit information? [Criteria Reference .119(o)(3)]
I. PROGRAM SUMMARY The intent of this paragraph is to require employers to provide all information necessary to comply with the standard to personnel developing paragraphs (d), (e), (f), (n) and (o) without regard to possible trade secrets. In addition, employees and their designated representatives shall have access to trade secret information contained within documents required to be developed by the standard. II. QUALITY CRITERIA REFERENCES
III. VERIFICATION OF PROGRAM ELEMENTS A. Records Review 1. Has all information necessary been provided to those persons responsible for compiling the process safety information (paragraph d), those assisting in development of the PHA (paragraph e), those responsible for developing the operating procedures (paragraph f), and those involved in incident investigations (paragraph m) and emergency planning and response (paragraph n), and compliance audits (paragraph o) been without regard to possible trade secret status of such information? [Criteria Reference .119(p)(1)] 2. Do employees and their designated representatives have access to trade secret information contained in the PHA and to other documents required to be developed by the standard, subject to the provisions set forth in 1910.1200(i)(1) through (i)(12)? [Criteria Reference .119(p)(3)] B. On-site Conditions Not applicable. C. Interviews Employees involved in specific duties: 1. Based on interviews with a representative number of employees involved in compiling the process safety information, developing PHA's, developing operating procedures, investigating incidents, planning and responding to emergencies, and auditing compliance, has all information necessary been provided to them without regard to possible trade secret status of such information? [Criteria Reference .119(p)(1)] Employees and Representives: 2. Based on interviews with a representative number of employees and their designated representatives, do they have access to trade secret information contained within the PHA and other documents required to be developed by the standard? [Criteria Reference .119(p)(3)] (Note that this access is subject to the provisions set forth in 1910.1200(i)(1).)
The guidance contained in this appendix is provided for compliance assistance. It shall be followed in interpreting the PSM standard for compliance purposes. Unless otherwise noted, all paragraph citations refer to 29 CFR 1910.119. This appendix contains clarifications agreed to in a settlement agreement dated April 5, 1993, between OSHA, the United Steelworkers of America, the Oil, Chemical and Atomic Workers International Union, and the Building and Construction Trades Department of the AFL-CIO. The settlement agreement clarifications reflect modifications jointly and cooperatively agreed to by the above parties and by the Chemical Manufacturers Association, the American Petroleum Institute, the Dow Chemical Company, and the National Petroleum Refiners Association. Where possible, clarifications and interpretations have been presented in a question-and-answer format. NOTE: OSHA plans to include additional clarifications and interpretations in this appendix through future page changes to this instruction.
(a) Registration Do covered establishments have to register with OSHA?
(a) Explosives--fireworks manufacture How does the PSM standard apply to pyrotechnics (fireworks) and explosives?
What is the role of the Bureau of Alcohol, Tobacco and Firearms (BATF) vis-a-vis the PSM standard and fireworks manufacture?
(a) Laboratories Does the PSM standard apply to laboratory and research operations?
(a) Flammable liquids Are processes involving flammable liquids (e.g., ethyl alcohol) covered by the standard?
(a)(1)(i) Hydrogen chloride (HCL) Does the PSM standard apply to muriatic (32% HCL) acid?
(a)(1)(i) Highly hazardous chemicals (HHCs) What is meant by "Formaldehyde (Formalin)" listed in Appendix A of the PSM standard?
Does the PSM standard apply to solutions of Dimethylamine?
(a)(1)(i) HHCs--mixtures Does the threshold quantity listed under Appendix A of the PSM standard apply to the quantity of the whole mixture or just the quantity of the component chemical, or to neither (i.e., does the threshold quantity apply only to quantities of pure chemical unless otherwise specified in the appendix)?
Does the PSM standard apply to an employer who uses cellulose nitrate in a concentration greater than 12.6% nitrogen to which water is added, producing a mixture containing greater than 23% water, which will not burn?
(a)(1)(i) and (b) Covered process--Hazardous waste operations Does the PSM standard apply to the EPA-regulated and permitted RCRA hazardous waste treatment, storage and disposal (TSD) facilities, when such facilities keep on-site in one location a hazardous waste chemical in a concentration and quantity which exceeds the applicable threshold quantity of Appendix A. If so, why? If not, why not?
(a)(1)(i) and (b) Covered process--dispersal of inventory Can an employer who keeps threshold quantities of highly hazardous chemicals listed in Appendix A to 29 CFR 1910.119, such as ammonia, separated into smaller lots and used and stored in separate systems or locations, be exempt from the requirements of the PSM standard?
The PSM standard's non-mandatory Appendix C suggests that, if reduced inventory of highly hazardous chemicals is not feasible, an employer might consider dispersing inventory to several locations on-site. When are such materials to be considered part of a single process?
What evaluation techniques are appropriate to determine adequate separation distances?
(a)(1)(ii) Application--55-gallon drums Would more than 10,000 pounds (4535.9 kg) of a flammable liquid stored together in 55-gallon (209-liter) drums be covered under the PSM standard?
(a)(1)(ii) Covered Process--Flammable gases For processes involving flammable gas mixtures, are the non flammable components in a flammable gas mixture included when determining the threshold quantity?
(a)(1)(ii) Covered process--Flammable liquids Does the PSM standard apply to processes in a paint manufacturing facility, which include the mixing and blending of flammable liquids with other raw materials, and which typically involve few or no chemical reactions? Typically, the flammable products are processed below their normal boiling points and that several large batch vessels are located near each other, with an aggregate weight above the threshold quantity of 10,000 pounds (4535.9 kilograms).
(a)(1)(ii)(A) Application--Exceptions--Hydrocarbon fuels Does the PSM standard apply to ceramic manufacturing facilities utilizing propane in amounts exceeding 10,000 pounds as the fuel for firing ceramic ware in a process which does not involve any other highly hazardous chemicals?
Does gasoline used as a fuel to test run inboard and outboard engines fall within the scope of the PSM standard?
Does the PSM standard apply to a plant that has more than 10,000 pounds of hydrocarbon fuel on site where the fuel is used solely as a fuel for a furnace used to melt glass?
(a)(1)(ii)(A) Tote tanks 350-gallon tote tanks containing flammable liquids are used at a facility to refuel vehicles. Are they covered by the standard?
(a)(1)(ii)(A) Fuels for heating Are flammable liquids and gases used as fuels for such items as heaters or exchanges contained in (covered) processes also included within the coverage of the standard?
(a)(1)(ii)(B) Tank farms Are flammable liquids stored in a tank farm covered under the standard?
(a)(1)(ii)(B) Flammable liquids Does 1910.119(a)(l)(ii)(B) exempt all flammable liquids stored or transferred which are kept below their normal boiling point without the benefit of chilling or refrigeration, including, but not limited to, flammable liquids in atmospheric tanks?
(a)(2)(i) Retail facilities What is the definition of "retail facilities" that are exempted from coverage by the PSM standard?
If an employer that would otherwise be covered by the PSM standard operates at several locations and the majority of its income comes from sales to end users, is the employer exempt as a "retail facility"?
Are facilities that fill propane tanks for "will call" type customers exempt from the PSM standard? Most of these facilities are under the aggregate quantity of 10,000 pounds (4535.9 kilograms), The majority of the business is transferring propane from the supply tank to small containers for barbecues and "RV" units.
(a)(2)(ii) Oil or gas well operations Are single well processing facilities with equipment including separators, heat-treaters and storage tanks used in gas production (from non-H2S containing petroleum fluids) operations exempt from coverage under 1910.119(a)(2)(ii), which excludes oil and gas well drilling and servicing operations?
(a)(2)(iii) Meaning of "facility" Can a facility contain more than one process?
(b) "Process" What are "aggregate threshold quantities"?
Is waste burning of covered solvents considered a process?
(b) "Hot work"
(b) "Normally unoccupied remote facility"
(c) Employee participation In implementing employee participation as required by 1910.119 (c) of the PSM standard, can an employer mandate that employees e.g., top operators of process units--provide the company with information such as step-by-step procedures for routine tasks performed on their operating units? Can the employer threaten disciplinary action for employees who do not cooperate?
(c)(2) Consultation What does consult mean? Can the employer simply inform the employees?
The standard requires employers to consult with "employees and their representatives." Is the term broad enough to include a representative of the international union? A consultant designated by the union local or international?
(c)(2) Consultation--contractors Must the employer consult with employees of contractors?
Host employers can consult with contractor employees and their representatives directly, or through the contractor employer. Contractor employers share responsibility for ensuring that there is consultation with their employees. (c)(3) Access What does "access" mean? Does this mean simply make it available at a central location? Does the employer have to make copies for employees if requested?
(c)(3) Equal access to information
(d) Retention of information How long must the employer maintain process safety information?
(d)(2)(ii) Original process safety information not present If process safety information on the original technology does not exist, what must the employer do?
(d)(3)(iii) Older codes--PSM standard deadlines For equipment based on old design codes, the employer must determine and document that the equipment is designed and operated safely. By what date must the employer do this? Specifically: * When must the employer determine adequacy of design based on old codes, and * How much time does the employer have to make corrections?
(e)(1) PHA priority What rationale must employers use to determine the priority for conducting the process hazard analyses? May the rationale include age, history, extent of employee exposure, etc.?
(e)(1) PHA priority--"as soon as possible"
(e)(1) PHA completion dates What is the time frame for completion of the initial PHAs and for updating and revalidating them?
(e)(1) PHAs--Required site-by-site? If a natural gas company has five sites with facilities performing the same process, does a separate PHA need to be performed for each site, for each facility at these sites, or for each process at each facility?
(e)(2) Process hazard analysis--"appropriate methodology" What type of methodology must employers use in the PHA in order to be sure it is "appropriate"?
(e)(3) Meaning of "control" The regulation requires that the PHA address the "control" of the hazards. What is meant by: "identification, evaluation, and control of process hazards"--?
(e)(3)(iv) Quantitative determination? Must the employer make a quantitative determination to determine the consequences of failure of the controls?
(e)(3)(v) Facility siting What does "facility siting" mean?
(e)(5) Abatement = shutdown? Hazards may be identified for which a recommended solution/action might be the shutdown of the process. For example, several processes might be located very close, and if fire were to occur a domino effect might result in a catastrophic release. The resolution may be to separate the processes, but there is no additional property on which to expand. What is required of the employer?
(e)(5) Timeliness Employers must "promptly" address the problems identified in the PHA in a "timely manner," and complete actions "as soon as possible." What time frame did OSHA intend here?
(e)(5) Addressing PHA team's findings and recommendations
(e)(7) Retention How long must the process hazard analyses, updates, and revalidations be retained?
(f)(1) Written operating procedures Many employers have computerized process control systems and safety interlock systems software. Can simplified loop diagrams or narrative descriptions be used to describe the logic of software and the relationship between the equipment and computerized process control systems, to meet the requirements for written operating procedures at 1910.119(f)(1)? Can system logic flow charts or narrative descriptions of the computerized safety interlock systems be used to meet these same requirements?
(f)(1)(iii)(c) "Control measures to be taken if physical contact or airborne exposure occurs" Does this mean first aid, or industrial hygiene services?
(g)(1)(i) Initial training
(g)(1)(ii) Initial training--"grandfathering" What is required in the employer's written certification regarding employees whose initial training is "grandfathered"?
(g)(2) Refresher training Employees have to be given refresher training at least every 3 years--measured from when?
Under what circumstances must refresher training be provided more often than every 3 years?
Is training under "management of change" considered to be refresher training?
(g)(3) Training documentation This paragraph requires the employer to make sure that operators "understand" the training provided to them under this section. Is some method of testing required?
(h) Scope of activities
(h) Scope of activities--construction work Do contractors performing construction work at a site covered by the PSM standard also have to comply with 29 CFR 1926 standards?
(h)(1) and (2) Contractors and subcontractors
(h)(2) Contractors--Employer responsibilities--Training How much of the burden of training contractor employees is placed on the employer?
(h)(2)(i) Contractors--Employer responsibilities--Selecting a contractor When selecting a contractor, an employer has to evaluate the potential contractor's safety performance and programs. Must the employer document this? If so, to what extent?
(h)(2)(vi) Contractors--Employer responsibilities--Contractor injury and illness log What type of injury and illness log does an employer have to maintain regarding contract employees?
(i)(2)(i) Pre-startup safety review--equipment in accordance with design specifications
(j)(1)(i) Application
(j)(2) Written Procedures
(j)(2) Written Procedures Do these written procedures need to be specific to each vessel, each type of vessel, or each group of equipment types listed?
(j)(3) Training for process maintenance activities
(j)(5) Equipment deficiencies If equipment is found to be operating outside acceptable limits, must the process be shut down and the equipment deficiencies corrected before further use?
(j)(6)(ii) Quality assurance If an installation is being done by contractors, does this require the employer to implement a quality assurance program to monitor the activities of these contractors?
(l) Management of change What does "change" encompass?
Do the management of change procedures apply to items such as gaskets?
(m)(5) Addressing team's findings
(o)(1) Compliance audits--required frequency?
(o)(4) Documenting actions based on compliance audit findings
1. OSHA Instruction CPL 2.45B, June 15, 1989, the Revised Field Operations Manual (FOM). 2. OSHA Instruction STP 2.22A, CH-2, January 29, 1990, State Plan Policies and Procedures Manual. 3. OSHA Instruction ADM 1-1.12B, December 29, 1989, Integrated Management Information System (IMIS) Forms Manual, Chapter 4. OSHA Instruction CPL 2.94, July 22, 1991, OSHA Response to Significant Events of Potentially Catastrophic Consequences. 5. "Safety and Health Program Management Guidelines," 1989; U.S. Department of Labor, Occupational Safety and Health Administration 6. "Safety and Health Guide for the Chemical Industry," 1986, (OSHA 3091); US.DOL, OSHA. 7. "Review of Emergency Systems," June 1988; U.S.E.P.A., Office of Solid Waste and Emergency Response, Washington, DC 20480. 8. "Guidelines for Hazard Evaluation Procedures," Center for Chemical Process Safety of the American Institute of Chemical Engineers; 345 East 47th Street, New York, NY 10017. 9. "Plant Guidelines for Technical Management of Chemical Process Safety," Center for Chemical Process Safety (CCPS) of The American Institute of Chemical Engineers (AICHE). 10. "Guidelines for Safe Storage and Handling of High Toxic Hazard Materials," AICHE, CCPS. 11. "Guidelines for Vapor Release Mitigation," AICHE, CCPS. 12. "Process Safety Management (Control of Acute Hazards)," Chemical Manufacturers Association (CMA). 13. "Evaluating Process Safety in the Chemical Industry," Chemical Manufacturers Association; 2501 M Street NW, Washington, DC 20037. 14. "Safe Warehousing of Chemicals," Chemical Manufacturers Association. 15. "A Managers Guide to Reducing Human Errors Improving Human Performance in the Chemical Industry," Chemical Manufacturers Association. 16. "Improving Owner and Contractor Safety Performance," API Recommended Practice 2220. 17. "Management of Process Hazards," American Petroleum Institute (API) Recommended Practice 750, First Edition, January 1990; 1220 L Street NW, Washington, DC 20005. 18. "Sizing, Selection, and Installation of Pressure Relieving Devices," Part 1, July 1990, API RP 520. 19. "Guide for Pressure relieving and Depressuring Systems," Nov. 1990, API RP 521. 20 "Avoiding Environmental Cracking in Amine Units," Aug. 1990, API RP 945. 21. "Pressure Vessel Inspection Code: Inspection, Rating, Repair, and Alteration," June 1989, API STD 510. 22. "Inspection of Piping, Tubing, Valves, and Fittings," API RP 574. 23. "Prevention of Brittle Fracture of Pressure Vessels," API RP 920. 24. "Accident Investigation * * * A New Approach," 1983, National Safety Council; 444 North Michigan Avenue, Chicago, IL 60611-3991. 25. "Fire & Explosion Index Hazard Classification Guide," 6th Edition, May 1987, Dow Chemical Company; Midland, Michigan 48674. 26. "Chemical Exposure Index," May 1988, Dow Chemical Co. 27. "Pressure Vessels, Section VIII," The American Society of Mechanical Engineers (ASME). 28. "Chemical Plant and Petroleum Refinery Piping," ASME B31.3. 29. "Personnel Qualification and Certification in Nondestructive Testing," American Society of Nondestructive Testing, Recommended Practice No. SNT-TC-1A. 30. "Prevention of Furnace Explosions/Implosions in Multiple Burner Boiler Furnaces," National Fire Protection Association, NFPA 85C. 31. "Purged and Pressurized Enclosures for Electrical Equipment," NFPA 496. 32. "Spacing of Facilities in Outdoor Chemical Plants," Factory Mutual Loss Prevention Data Sheet, 7-44. 33. "Chemical Process Control and Control Rooms," Factory Mutual Loss Prevention Data Sheet, 7-45. 34. "National Board Inspection Code, A Manual for Boiler and Pressure Vessel Inspectors," The National Board of Boiler and Pressure Vessel Inspectors, 1992. 35. Gideon, James A., and Thomas W. Carmody, "Process Safety Management: Resources from the American Institute of Chemical Engineers for Use by Industrial Hygienists," American Industrial Hygiene Association Journal (53), June 1992.
36. Institute of Makers of Explosives Safety Library Publications, 1120 19th Street, N.W., Suite 310, Washington, D.C. 20036:
37. Department of Defense (DOD) Standards:
DOD 4145.26M DOD Contractor's Safety Manual for Ammunition, Explosives and Related Dangerous Material 38. National Fire Protection Association (NFPA) Codes: NFPA 495 Code for the Manufacture, Transportation, Storage and Use of Explosive Materials NFPA 77 Static Electricity NFPA 78 Lightning Protection Code
39. Synthetic Organic Chemical Manufacturers Association (SOCMA) Level I Chemical Process Operator Certification Training Trainee Manual, May 1990; NUS Corporation, Fossil and Industrial Training Services Department, 910 Clopper Road, Gaithersburg, MD 20877-0962.
Recommended Guidelines for PQV Inspection Preparation (Nonmandatory) The following guidelines are suggested as background and preparation for a PQV inspection. These are suggested actions only, and shall in no case take precedence over the guidance presented elsewhere in this instruction. AREA OFFICE COORDINATION Coordination within the Area Office is absolutely essential in the orderly conduct of a PQV inspection. The Area Director and all those involved in a PQV inspection must commit the resources with the understanding that the project is long-term, possibly several weeks or months. It is imperative that team members complete all outstanding assignments prior to the PQV inspection. Equally important, team participants should not be directed or "asked" to do assignments while they are engaged in the PQV inspection. An obvious exception would be court hearings, over which the Area Office has little control. The Area Director should designate a contact person in the Area Office to coordinate and oversee all aspects of the inspection. The contact person should be a supervisor, safety or industrial hygiene (IH), who is familiar with the PQV concept. In addition to providing Area Office coordination, the contact person would review the entire case file/report. The team leader would communicate at least weekly with the contact supervisor, who would then brief the Area Director as appropriate. INSPECTION TEAM COMPOSITION By design, a PQV inspection is a large and complex undertaking, to be accomplished by a select, well-trained team. All members of the team must be experienced journey or senior level compliance officers who are familiar with the chemical industry and have taken the appropriate OSHA training. Newer compliance officers can be utilized in the inspections, but not as a substitute for regular team members. The team should consist of two safety compliance officers/engineers, two industrial hygiene compliance officers, an administrative support person and a construction specialist. The team leader could be from either discipline in the team, but preferably a safety specialist, due to the fact that most of the critical PSM and construction related hazards reside in the area of safety. The team leader should be a GS-12 Senior Compliance Officer with experience in large team inspections. He or she should have excellent organizational and communication skills, both oral and written. It would also be of benefit that the team leader be knowledgeable in word processing and data base management computer operations. Since the team leader will be the focal point during the conduct of the inspection, that person should also have demonstrated leadership abilities. The entire team, the company, employees/unions and other OSHA personnel will look to the team leader for direction and answers to the many questions that will arise during the course of the inspection. The team leader is responsible for the overall conduct of the inspection including planning, onsite activities and report preparation. The leader would assign the various inspection areas to team members in accordance with their expertise and abilities, and determine what, if any, special expertise is needed. Additional responsibilities include:
An administrative support person would greatly increase the overall efficiency of the inspection. This position would be ideal for an accommodated compliance officer with some computer skills and organizational abilities. The support person would answer directly to the team leader and would be responsible for organizing, labeling and filing the many documents that will become part of the case file. An accommodated CSHO could also review the documents and document requests to assure the request was properly fulfilled. In addition, an accommodated CSHO could assist the inspecting team members with the many interviews that will be conducted. The support person would also be responsible for the inspection supplies and equipment. Safety and IH team members are responsible for carrying out the PQV inspection activities under the direction of the team leader. They must keep the team leader apprised of their activities and potential problems when they arise. The construction specialist would work for the most part independently of the rest of the team, under the general direction of the team leader. Some crossover of inspection areas is to be expected, as many of the contractors and company responsibilities overlap. PRE-INSPECTION PREPARATION Effective planning and preparation is essential to the efficient implementation and successful completion of any large inspection, especially a PQV. Exhibit 1 provides an outline that can be used as a guide to plan and prepare for a PQV inspection. Establishment histories can be obtained and reviewed well in advance of the target date for the inspection. The inspection strategy and scheduling should be done after the team has been selected. A pre-inspection meeting with all members and the Area Office contact person should be held prior to entry. The case file begins in the planning and preparation stage. Any documents received, such as micro to host reports, citations and PSM-related findings (including PetroSEP) in other regions must be logged and identified to allow for easy retrieval. An activity log/diary should be started to record all pertinent actions taken. A computer data base management program is recommended to keep track of the document requests and to provide a ready index of the documents that have been obtained. With this type of system it would be easy to search for pertinent documents by using the OSHA identification number, topic of document, company identification number, date of request, etc., and to ensure that various members of the team do not duplicate requests for documents. The team should develop a weekly schedule of activities, taking into account travel days, holidays, start time, stop time, company briefings and internal briefings. Time should be allotted during the inspection week to complete necessary paperwork and documentation and tie up loose ends. DOCUMENTS PQV inspections will require compliance officers to review numerous company documents. Many of these documents will become part of the case file as documentation for potential citations or for documentation of the required PSM elements. It is imperative that these documents be organized and identified so that they may be readily referenced and reviewed. It is highly recommended that all requests for copies of company documents be in writing. A standard document request format should be established and should contain at least the following information:
It should be noted that there is no universal language used to identify documents. Different companies have different names for the same type of document. It is therefore essential to clearly communicate what information is needed and desired prior to writing the request. The document requests should be in duplicate: one copy for the company and the other to be retained in the case file. To avoid long discussions and legal department involvement, all documents obtained should be considered proprietary information. Prior to the documents actually being received, a filing system should be developed. The system should be secure, accessible to all team members and ensure that individual documents are easily retrievable. The administrative support person could manage the filing system to ensure its continued effectiveness. NOTE: Only appropriate documents should be maintained in the filing system; field notes, document "clips", and document review/evaluation notes should remain with the corresponding 1B's. Exhibit 2 contains a list of those documents most commonly requested. It is divided into two sections: Pre-Unit Selection and Unit-Specific Documents. INSPECTION FACILITIES The PQV team needs a suitable work area/command center from which the inspection can be conducted and coordinated. Except in the most unusual of circumstances, the company will provide the requisite onsite space. Almost any room will suffice, providing it meets some basic requirements. The work area must be secure 24 hours a day with access limited to the inspection team and those company officials who would respond in an emergency. This is important so as to preclude taking boxes of documents and equipment in and out each day. The room should have sufficient desks and/or tables for reviewing documents and writing the report. Provisions should be made for communications--one phone line as a minimum. Outgoing calls should be charged on the Area Office calling card. Where phone service is not provided, the team should have a portable cellular phone. Sufficient power outlets should be available for charging pumps, batteries and other inspection equipment. The inspection team will need copies of a number of documents. It is hoped that the company would provide copying services or the use of a copy machine. The administrative support person could make the copies should the company not provide these services. The team leader must determine as soon as possible, what--if any--of the necessary facilities the company will provide. If the company does not provide all of the necessary facilities voluntarily, or puts disruptive restrictions on their use, the ARA for Technical Support should be contacted as soon as possible so that alternate facilities can be arranged. This may result in the use of a rented copier(s) and office space. INSPECTION EQUIPMENT Upon entry to the site, the inspection team should be fully prepared with all necessary inspection equipment and personal protective equipment. Exhibit 3 contains a list of equipment that may be useful to prepare for the inspection. In addition, an inspection "kit" is outlined which can be used to set up the command center. Some of the items in the "kit" may appear to be trivial; however, all of these items will be needed at some time during the inspection. It may not be practical to go back and forth to the office or a store to get these items, particularly if the inspection site is in a remote location. The administrative support person would be responsible for maintaining adequate supplies throughout the inspection. CRITICAL INSPECTION AREAS It is essential that team members have specific subjects and areas to investigate. The team leader, with input from the team members, should assign the inspection areas prior to entry. This will help to avoid confusion and duplication of effort. In addition, the team members will be able to be better prepared for their individual tasks. As inspection subjects are completed, the information should be reviewed with the team leader before going on to the next assignment. The state of compliance or noncompliance within any given area may require the team leader to modify the assignment list so as to make the most of the resources available. CONTRACTORS Contractors are an integral part of any PSM inspection. There may be only a few contractors or dozens, with several hundred contract employees, depending on whether the facility is undergoing a shutdown or turnaround. It is imperative that, upon entry, the scope of the contractor activity be determined. The construction specialist on the team will have to formulate an inspection plan and set appropriate priorities. It is not the intent of the PQV inspection to inspect all outside contractors that are on-site, rather to inspect only those contractors who may be exposed to, or could cause or be affected by a catastrophic incident. Food service workers, certain janitorial employees and similar activities would not normally be inspected. Remote construction projects not associated with catastrophic potential would not necessarily be inspected. The term "contractor" is not limited to construction type activities. Many chemical facilities use contract maintenance workers, vessel and piping inspectors, vessel heat treating, cleaning, engineering and similar non-construction contractors who remain at the facility year round or are called in at regular intervals. They are used to supplement existing plant personnel for regular duties and for special projects. A shared responsibility for both contractors and company is quality assurance. It is essential that all materials and workmanship meet engineering standards. There should be sufficient checks to ensure that materials, such as the proper alloy or carbon steel pipe is used, and that the studs and/or bolts are of the proper size and grade. This is especially important in contractor supplied materials. CRITICAL EXPERTISE Situations may arise in a PQV inspection that are beyond the technical expertise of the team members. A list should be developed identifying OSHA personnel and/or private sector experts and how they may be contacted. Areas where this expertise may be needed are:
By no means is this list all-inclusive. It should be modified as needed to reflect current technology and hazards. DOCUMENTATION In order to withstand the probable legal challenges, all items must be thoroughly documented. Since the team will be made up of journey-and senior-level CSHOs, good documentation is to be expected. All OSHA-1B forms must be complete and legible. Shortcuts for employer knowledge such as "should have known" or "reasonable diligence" are not acceptable. Appropriate company documents, logs, procedures, permits, etc., should be referenced on the 1B for the particular violation. Photographic documentation, either still camera or videotape, should be reviewed as soon as practicable to ensure that the condition or violation is appropriately depicted. Retake any photos or videos that are not good quality. CASE FILE AND REPORT PREPARATION A PQV inspection will take weeks or months of onsite activity and will generate a large amount of paper, both in field notes and documents. It is essential that the paper flow be organized and well maintained. This will result not only in a more efficient onsite survey, but will greatly reduce the write-up time. A daily log, either manual or computer generated, should be maintained indicating the team members onsite, daily activities, meetings, problems, or other details, as necessary. All OSHA-1B forms should be completed as the violation is observed, documenting the employees exposed, the date, time, location and management representative who accompanied the CSHO. Each instance of a violation should have a separate 1B. Where multiple violations are noted on a form, the form should be photocopied and highlighted showing the appropriate instance and corresponding documentation. Alleged violation descriptions should be written as soon as practicable, while the hazard is fresh in the mind of the CSHO. Multi-employer policy citations must be coordinated with respect to exposing, controlling, correcting and creating employers' files. Case file structure and organization must begin prior to entry into the facility. All documents must be logged and an index (computer preferred) generated, indicating the subject matter, document identification number, file number and the location of the document (box number). This is essential, as these documents may have to be referenced or retrieved many times during the course of the inspection and the review process. A data base management program for the PC's would be extremely beneficial. Computer disks should be backed up daily, or more often as necessary. The photos and videotape taken during the inspection should be properly identified with photographer, date, roll or tape number and subject. They should be kept in a separate file. EXHIBIT 1 PRE-INSPECTION PREPARATION A. Previous OSHA history - nationwide search
B. EPA history 1. reportable releases 2. reports of any kind 3. complaints and pending actions C. Other Agency histories - local/State/Federal
D. Previous PetroSEP/PSM inspection results
E. Identify contact people -- other jurisdictions
F. Acquire necessary codes or standards
INSPECTION STRATEGY A. Identify critical needs and expertise B. Select team members C. Identify expertise within the team D. Identify critical inspection areas E. Assign areas according to expertise F. Identify areas lacking expertise
G. Develop a tracking system for documents H. Develop a daily log of on-site activities I. Identify known scheduling conflicts
J. Develop weekly schedule of activities
PLANNING AND SCHEDULING A. Create a Projected Time Line
B. Resource Scheduling
C. Equipment Acquisition
EXHIBIT 2 DOCUMENT REQUEST LIST I. PRE-UNIT-SELECTION
II. UNIT-SPECIFIC DOCUMENTS
EXHIBIT 3 INSPECTION EQUIPMENT I. PERSONAL PROTECTIVE EQUIPMENT
II. SAMPLING EQUIPMENT
III. TECHNICAL EQUIPMENT
INSPECTION KIT I. Office Supplies
II. Inspection Supplies
III. Command Center Equipment
IV. Library/Reference Material
Information about PSM-related inspection activity, as described at H. of this instruction, shall be recorded in IMIS following current instructions in the IMIS manual. These guidelines shall apply: 1. PQV Inspections. The identifier code "PSMPQV" shall be used for these inspections.
2. Unprogrammed PSM-related Inspections. All unprogrammed inspection activity relating to the PSM standard--as described at H.3. of this instruction--shall be coded as follows in Item 42, Optional Information of the OSHA-1 form:
3. Other Programmed Inspections: Screening for PSM Coverage. In all programmed safety and health inspections in general industry, a determination shall be made as to whether the establishment is covered by the PSM standard. The establishments shall be coded as follows in Item 42, Optional Information of the OSHA-1 form:
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