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BASF risk Management and PSM
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Title:
Process Safety Management and Risk Management Plan
Freeport Site Function: Ecology & Safety Standard No.: BCF020.033 Page: Page 1 of 45
Reviewed: 6/14 Effective: 08/24/10 Supersedes: 06/98 Preparer: Owner: Approver: EHS Team Leader or Designee Director, Environ, Health & Safety SVP & General Manager
RECORD OF REVISIONS
Date Rev. # Details of Change 06/5/14 6 • added index for G-R-PRS-040 Documentation for Process Safety
• updated PSI, Site, #2 to show SDS terminology and to reflect the change to backup SDS accessibility based on the corporate SDS service provider changes
• added Dispersions as a covered process 08/01/13 5 • title corrections because of titles, roles, and responsibilities changes since
the last revision • PHA, #7, added “/redone in accordance to the PSM/RMP Guide” to comply
with changes made previously to the PSM/RMP Guide • added Excel version as an option
10/04/12 4 • updated titles to reflect ICON job descriptions • minor content updates in PSI and MI sections
05/15/12 3 • updated responsible person in the EHS Information & Mechanical Integrity section based on ICON changes
• updated Mechanical Integrity to reflect current standards and document locations
07/31/10 2 • minor edits for clarity; revised manager roles from “E&M Mech. Group Manager and Pressure Vessel Group Manager to new role and title “E&M MSG Group Manager;” revised “Loveland” to “INtools” database and/ or SAP
• revised references to related procedures such as but not limited to NP-EI-105, NP-MC-105, etc., and to related programs like SAP, electronic CAD, website, E&M, etc.
• added that PSSR should be filed with Job Books and in EHS Change Manager database
• added responsibilities for Area I/E Engineer in Element 8 • revised Document locations to reflect electronic locations (E&M, EHS web
pages) • updated information to include databases (MSDS, Change Manager,
AIMS) 05/31/07 1 This standard is being revised to bring it into compliance with the template and
formatting of the Corporate Safety Procedures. No major changes have been made. There are minor word revisions to accommodate the format.
Title:
Process Safety Management and Risk Management Plan
Freeport Site Function: Ecology & Safety Standard No.: BCF020.033 Page: Page 2 of 45 Reviewed: 11/09 Effective: 08/24/2010 Supersedes: 06/98 Preparer: Owner: Approver: Team Member, Freeport Hub Manager, EHS VP & General Manager
INTRODUCTION
OSHA’s Process Safety Management (PSM) standard became effective on May 26, 1992. The EPA’s Risk Management Plan became effective on June 21, 1999. These standards require that covered processes implement management practices to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals and to protect the public health and environment.
The following document on PSM and RMP outline a roadmap of where programs are found, who the owners of the programs are for accountability, and those responsible for maintaining the programs.
Within each element are blanks that each unit with PSM/RMP processes must answer to show where program accountability and responsibilities are for the unit. The filled in document will be maintained electronically on the unit’s web page or copied and placed in a unit PSM/RMP notebook. If a hardcopy notebook is kept, it will be located in the control room
Many PSM/RMP requirements reference another section of the Loss Control Manual, Maintenance Practices Manual, etc., because these programs existed before regulatory requirements went into effect. While all PSM requirements apply to RMP covered units, not all PSM units are covered by RMP. Additional RMP requirements are shown in a separate block in each element.
Senior Production Managers/Directors are overall accountable for implementation and maintaining of unit PSM/RMP programs. Operational Directors / VPs are accountable for providing support and resources for implementation and maintenance of required programs.
This document also serves as the index of the process safety documentation required by BASF global standard G-R-PRS-040 Documentation for Process Safety.
Click here for the Excel version of the PSM/RMP roadmap.
Below is a list of plants that fall under OSHA PSM and EPA’s RMP at Freeport
PSM RMP and PSM
Acrylic Acid II Acrylic Acid II
Acrylic Acid III Acrylic Acid III
Oxo Oxo
PolyAlcohols PolyAlcohols
Caprolactam I Caprolactam I
Caprolactam II Caprolactam II
SAP
Cyclohexanone I Cyclohexanone I
Cyclohexanone II Cyclohexanone II
Hydroxylamine II Hydroxylamine II
Ammonia Terminal Ammonia Terminal
Butyl Acrylate
2-Ethylhexyl Acrylate
Dispersions Dispersions
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #1 – EMPLOYEE PARTICIPATION UNIT: ______________ DATE: ______________ Reference: OSHA 1910.119 (c) and EPA 40 CFR 68.83
SITE PROGRAM Accountable for
Requirement Location of
Documentation References/ Comments
1. Safety Organization - Develop a written plan of action regarding employee’s participation. EHS Manager Loss Control Manual BCF020.028
UNIT LEVEL REQUIREMENTS
Responsible for Requirement
Location of Documentation
References/ Comments
1. Consult with employees on the conduct and development of Process Hazard Analyses. • Employees included on PHA team
__________________
________________
Participant List in Unit PSM/RMP PHA documentation
2. Consult with employees on the other elements of Process Safety Management.
___________________ Unit Safety and UST Meetings Job Books -Process Safety Reviews info.
Safety Standards Review/ Process Safety Reviews
3. Provide employees access to PHAs __________________
________________ Unit PSM documentation
4. Provide access to all other information required by OSHA PSM. See each section. __________________ ________________ Unit PSM/RMP documentation
RMP-Specific 40 CFR 5. Provide access to the RM plan, which contains the RMP worst case scenarios and the five-year
accident history. EHS Team Leader Office of EHS
Specialist for Technology and Environmental web page
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #2 - PROCESS SAFETY INFORMATION UNIT: ______________ DATE: ______________ Reference: OSHA 1910.119 (d) and EPA 40 CFR 68.67 SITE REQUIREMENTS Accountable for
Requirement Location of Documentation References/Comments
1. Any new chemical to be used on site must be approved through the process outlined in BCF020.036 Management of Change (Attachment B). This reviews the reactivity, safety, industrial hygiene, and ecology factors of the chemical.
Sr. Production Mgr./ Dir. & Site
Lab Mgr.
2 Each Unit’s EHS representative is responsible to help maintain MSDS/SDS information. MSDSs/SDSs for new or changed chemicals shall be provided to the Unit’s EHS representative for electronic maintenance.
EHS Mgr./Sr. Production Mgr./Dir.
Computer database BCF020.050: Hazard Communications
Unit Level Requirement Responsible for
Requirement Location of Documentation References/Comments
1 Written process safety information, as described in 2 and 3 below is compiled before performing a process hazard analysis.
PHA leader Technology Specialist
See locations in 2 and 3 below.
PHA leader is responsible for compiling process safety information prior to a PHA.
2 Information on the hazards of PSM-regulated chemicals in the process, including the information listed below, is available. a. toxicity information b. permissible exposure limits c. physical data d. reactivity data e. corrosivity data f. thermal & chemical stability g. hazardous effects of inadvertent mixing that could foreseeably occur.
a.______________ b.______________ c.______________ d.______________ e.______________ f._______________ g.______________
a.______________________ b.______________________ c.______________________ d.______________________ e.______________________ f.______________________ g.______________________
MSDS’s may be used to satisfy these requirements, to the extent that they contain the required information.
3 Information on the technology of the process, including at least the following information, is available. a. Block flow diagram or simplified process flow diagram b. Process chemistry c. Maximum intended inventory d. Safe upper and lower limits for such items as temperatures, pressures,
flows, compositions e. MOC, PSSRs and Incident Reports to be considered in the PHA or Revalidation
activities. f. An evaluation of consequences of deviations, including those affecting the safety and health of employees g. Facility Siting and Human Factors
a.______________ b.______________ c.______________ d.______________ e.______________ f. ______________ g.______________
a.______________________ b.______________________ c.______________________ d.______________________ e. EHS databases (Change Manager & AIMs) f. ______________________ g.______________________
Operator training information may be used to satisfy these requirements, to the extent that they contain the required information.
BCF020.033 Process Safety Management and Risk Management Plan
Reference: OSHA 1910.119 (d) and EPA 68.67 Unit Level Requirement Responsible for
Requirement Location of Documentation References/Comments
4 Information pertaining to equipment in the process, including the following information, is available. a. Materials of construction b. Piping and Instrument Diagrams (P&ID’s) c. Electrical area classification d. Relief system design, design basis and MAWPs of equip. e. Building ventilation system design f. Design codes & standards employed g. Material & energy balances (for processes built after May 26, 1992) h. 1. Interlock documentation h. 2. Fire detection / protection system documentation h. 3. Gas/vapor detection system documentation h. 4. Backup power supply (UPS) documentation h. 5. Alarms (as part of site wide alarm system, i.e. emergency horns) h. 6. Breathing air systems
a. See Element 8 b. Production Technologist c. See Element 8 d. See Element 8 e. Engineering Design Mgr f. See Element 8 g.______________ h.1. See Elem. 8 h.2._____________ h.3._____________ h.4. See Elem. 8 h.5._____________ h.6. See Safety Standard BCF020.013
a. See Element 8 b. Master P&ID’s available in control room. c. See Element 8 d. See Element 8 e.______________________ f. See Element 8 g.______________________ h.1. See Element 8 h.2.____________________ h.3.____________________ h.4. See Element 8 h.5.____________________ h.6. See Safety Standard BCF020.013, “Respiratory Protection”.
* Refers to “PSM Element 8, Mechanical Integrity” section of this document. • All those who make
changes to the process are responsible for updating master P&ID’s. See Safety Standard BCF020.36, “Management of Change” in the Loss Control Manual. The Production Technologist coordinates updates of the Master P&IDs with CAD.
• The procedure for identification and marking of PSM items on P&ID’s is Section 7.4 of the “Procedures & Guidelines for Engineers” manual.
• Fire detection / suppression systems are addressed in BCF020.016 in the Loss Control Manual.
• Hand-held Gas / vapor detection systems are addressed in the Loss Control Manual.
• Site wide alarms are addressed in the Loss Control Manual.
Reference: OSHA 1910.119 (d) and EPA 68.67 Unit Level Requirement Responsible for
Requirement Location of Documentation References/Comments
5 Equipment complies with recognized and generally accepted good engineering See Element 8 See Element 8 * Refers to “PSM Element
BCF020.033 Process Safety Management and Risk Management Plan
Reference: OSHA 1910.119 (d) and EPA 68.67 Unit Level Requirement Responsible for
Requirement Location of Documentation References/Comments
practices.
8, Mechanical Integrity” section of this document.
6 Equipment designed and constructed to codes, standards, etc no longer in use is designed, maintained, inspected, tested and operated in a safe manner.
See Element 8 See Element 8 Refers to “PSM Element 8, Mechanical Integrity” section of this document.
RMP-Specific Requirements
Unit Specific Requirements Responsible for Requirement
Location of Document References/Comments
Determine RMP Boundaries for: • Flammables – Determine Processes that:
1. Have a 1% De Minimus Concentration and 2. Meets NFPA 4 Criteria for Flammability (Count entire mixture to threshold amount)
• Toxic’s – Determine Processes that:
1. Have a 1% De Minimus Concentration and 2. Have a partial pressure of 10mmHg or greater (Count only toxic component in Mixture)
Document boundary determination.
____________
PSM/RMP PHA Unit documentation
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #3 – PROCESS HAZARD ANALYSIS UNIT: ______________
DATE: ______________ Reference: OSHA 1910.119 (e) and EPA 68.67
SITE PROGRAM Accountable for
Requirement Location of Documentation References/Comments
1
Site Program EHS Manager In accordance with Process Safety Management & Risk
Management Program Guide on Process Safety Web Page.
UNIT PROGRAM Responsible for
Requirement Location of Documentation References /Comments
1 A schedule should exist to show to completion date of initial hazard analyses and scheduled and completed Revalidation dates.
________________ _______________________
2 The schedule mentioned above should have documentation that describes the rational for the prioritization of the PHAs. The factors to be considered in the prioritization are: • the extent of process hazards • number of potentially affected employees • age of process • operating history
________________
_______________________
3 The Process Hazard Analysis (PHA) will be conducted in accordance to the Process Safety Management & Risk Management Program Guide.
Technology Specialist/TL
PSM/RMP PHA documentation
4 The hazard analysis method used should address specific areas such as: • process hazards • previous incidents with likely potential for catastrophic consequences • consequences of failure of engineering and administrative controls • the applicability of engineering and administrative controls to the hazards • facility surroundings • human factors • an evaluation of possible safety and health effects of failure of controls on
employees in the workplace
PHA Leader
_______________________
5 The hazard analysis team members must include individuals with the following qualifications: • expertise in engineering • expertise process operations • experience and knowledge specific to the process being evaluated and
Technology Specialist/TL
Procedures & Guidelines Manual for Engineers
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #3 – PROCESS HAZARD ANALYSIS UNIT: ______________ DATE: ______________ Reference: OSHA 1910.119 (e) and EPA 68.67
knowledge of the specific PHA methodology being used Reference: OSHA 1910.119 (e) and EPA 68.67 UNIT PROGRAM Responsible for
Requirement Location of Documentation References /Comments
6 A system must be in place to promptly address the team’s findings and recommendations. This system must: • Assure that the recommendations are resolved and documented in a timely
manner, • Document actions to be taken, • Ensure that actions are completed as soon as possible, • Develop a written schedule of when actions are to be completed, • And communicate the actions to operating, maintenance and other employees
whose work assignments are in the process and who may be affected by the recommendations or actions.
________________
_______________________
Target dates and completion dates can be reviewed in the unit PHA documentation
7 The PHA’s must be updated and revalidated/redone in accordance to the PSM/RMP Guide by a PHA team at least every five years to assure that the process hazard analysis is consistent with the current process.
________________
_______________________
8 The initial PHA’s updates or revalidations and documented resolutions of recommendations must be kept for the life of the process. • Most recent PHA and action items • Previous PHAs and action items.
________________ ________________
_______________________ _______________________
Unit PSM Manual may contain all PHAs or just most recent updates/ re-validations.
RMP-Specific Requirements UNIT PROGRAM Responsible for
Requirement Location of Documentation References /Comments
1. The owner or operator shall perform an initial process hazard analysis (hazard evaluation) before start-up of new RMP covered processes. For new processes under PSM because of the RMP rule, the priority on which the analysis will be conducted will be based on the potential for off-site consequences. Process analyses completed to comply with 1910.119(e) are acceptable initial process hazard analyses (these do not have to be re-prioritized based on off-site consequences). The prioritization shall be located in the PSM/RMP PHA documentation. Items 4-8 above must also be met for RMP hazard analysis. These PHA’s must be re-evaluated every 5 years.
_______________
_______________________
2. PHAs conducted on RMP processes must include a qualitative evaluation of the off-site consequences. See the Corp. Process Safety PSM/RMP Guide for standard phrasing.
_______________
_______________________
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #4 - OPERATING PROCEDURES UNIT: ______________ DATE: ______________ Reference: OSHA 1910.119 (f) SITE PROGRAM Accountable for
Requirement Location of Documentation References /Comments
1 Site Program for Written Job Instructions EHS Manager Loss Control Manual BCF020.017 2 Safe work practices must be developed and implemented for employees and
contractors to control hazards during operations such as: • Lock out/tag out. • Confined space entry. • Opening process equipment or piping. • Personal Protective Equipment (PPE) • Hot Work
Control over entrance into a facility by maintenance, contractor, laboratory or other support personnel.
a. Development b. Implementation
a. EHS Manager b. Production Execution Manager
a. Loss Control Manual b. See Permits
BCF020.012 BCF020.002 BCF020.039 BCF020.019 BCF020.023
BCF500.001 BCF020.001
Unit Level Requirement Responsible for
Requirement Location of Documentation References /Comments
1 a. There must be written operating procedures for each covered process that provides clear instructions for conducting activities safely.
b. Operating instructions must address, as a minimum, steps for each operating phase, including: 1. Initial start-up. 2. Normal operations. 3. Temporary operations. 4. Emergency shutdowns. * Conditions requiring emergency shutdown. * Assignment of shutdown responsibility to qualified operators. 5. Emergency operations. 6. Normal shutdown.
Start-ups following a turnaround or emergency shutdown. c. Operating procedures must include operating limits that outline
consequences of process deviation and steps required to correct or avoid deviations.
Safety and health considerations must be included in the operating procedures that include at a minimum:
a. _____________ b1. _____________ b2. _____________ b3. _____________ b4. _____________ b5. _____________ b6. _____________ c. _____________ d. _____________
a. _____________ b1. _____________ b2. _____________ b3. _____________ b4. _____________ b5. _____________ b6. _____________ c. _____________ d. _____________
BCF020.017: Written Job Instructions
BCF020.033 Process Safety Management and Risk Management Plan
Reference: OSHA 1910.119 (f) Unit Level Requirement Responsible for
Requirement Location of Documentation References /Comments
• Properties of, and hazards presented by, chemicals used in the process.
• Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment.
• Control measures to be taken if physical contact or airborne exposure occurs.
• Quality control for raw materials and control of hazardous chemical inventory levels.
Any special or unique hazards. e. Safety systems and their functions must be included in the operating
procedures. f. The operating instructions must be consistent with the process safety
information. g. The operating procedures must be readily accessible to employees who
work in or maintain a process.
e. _____________ f. _____________ g. _____________
e. _____________ f. _____________ g. _____________
2 The operating procedures must be reviewed as often as necessary to assure that they reflect current operating practice. At a minimum they must be certified annually and must reflect changes resulting from changes in: • Process chemicals • Technology • Equipment • Facilities
_______________
On cover page of each procedure. (In manuals or online)
Reference; OSHA 1910.119 (f) RMP Specific 40 CFR 68.69 Unit Level Requirement Responsible for
Requirement Location of Documentation References /Comments
1. The consequences of deviation evaluation for Operating procedures for RMP processes must consider the potential off-site impacts to human health and the environment. If deviations could produce off-site impacts to human health and the environment, this will be noted in the procedure. The steps to correct or avoid the deviation must be explained.
_______________
_____________________
Unit Operating Procedures
2. Operating procedures must include: Discharge or release control, containment, and recovery procedures
________________
_____________________
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #5 – TRAINING UNIT: ______________ DATE: ______________ Reference: OSHA 1910.119 (g) and EPA 40 CFR 68.71
SITE PROGRAM Accountable for
Requirement Location of
Documentation References/ Comments
1. Technician Training Program Site Training Coordinator Employee Training Files and/or Mockingbird Online Database (MBO)
Unit Level Requirement Responsible for
Requirement Location of
Documentation References/ Comments
1. Employees shall be trained in an overview of the process and in the operating procedures as specific in OSHA PSM. Training shall include emphasis on the specific safety and health hazards, emergency operations and safe work practices applicable to the employees’ job task.
_________________
______________
2. In lieu of initial training for those employees already involved in an operating process on May 26, 1992, an employer may certify, in writing, that the employee has the required knowledge, skills and abilities to safely carry out the duties and responsibilities, as specified in the operating procedures. This documentation is kept in each employees training file.
_________________
Employee Training Files and/or MBO
3. Refresher training shall be provided at least every three years, and more often if necessary, to each employee involved in an operating process to assure that the employee understands and adheres to the current operating procedures of a process. Unit Training Procedures
__________________
______________
4. The employer shall ascertain that each employee involved in an operating process has received and understands the training required by OSHA PSM. The Verification Process is defined by the unit training program.
__________________
______________
5. A record shall be kept which contains the identity of the employee, the date of training, and the means to verify that the employee understood the training. This is kept in the employee’s training file.
__________________
Employee’s Training Files and/or MBO
RMP-Specific 40 CFR 68.71
Unit Level Requirement Responsible for Requirement
Location of Documentation
References/ Comments
Training requirements are the same as PSM for verification, retraining requirements, and documentation.
Same as above Same as above
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #6 - CONTRACTORS UNIT: ______________ DATE: ______________ Reference: OSHA 1910.119 (h)
SITE PROGRAM Accountable for
Requirement Location of
Documentation References/ Comments
1. Contractor Safety Program EHS Manager LCM - Contractor Safety
2. Site Program - Site Specific/Block Orientation EHS Manager Security Policy # 5
3. Documentation of employee’s site specific orientation
EHS Manager Documentation at ABC Contractor Safety Council
4. Obtain and evaluate information regarding the contract employer’s safety performance and programs. a. Annual Review b. Document Storage c. Monthly Performance Review
a. PIC (Contractor Pre-entry Auditors) b. Procurement SM c. MAT
a. PIC Website b. PIC Website c. MAT files, Safety Dept.
BC032.002: Contractor/Agency EHS Qualifications & Oversight RCMS Work Process
5. Develop and implement safe work practices consistent to control the entrance, presence and exit of contract employers and employees.
EHS Manager
Security Proc. BCF500.001, and Contractor Safety #1,2,&4
6. Periodically evaluate the performance of contract employees in fulfilling their obligations in Process Safety Management. a. Conduct annual 7-Element audits of on-site contractors b. Conduct random audit of other contractors, based on activity data from units/safety observations.
a. EHS Annual Management Reviews/Safety Team Member - contractors b. EHS
a. Safety Dept. MAT files b. Safety Dept. files
7. Maintain a contractor employee injury/illness log related to the contractor’s work in process areas.
EHS Manager Safety Dept. files
BCF020.033 Process Safety Management and Risk Management Plan PSM ELEMENT #6 - CONTRACTORS UNIT: ______________ DATE: ______________ Reference: OSHA 1910.119 (h)
Reference: OSHA 1910.119 (h)
UNIT LEVEL REQUIREMENTS Responsible for Requirement
Location of Documentation
References/ Comments
1. Inform contract employers of the known potential fire, explosion, or toxic release hazards related to the contractors work and the process. a. Unit Program - Block Orientation b. Documentation of employees attending block orientation for
1. Alliance Contractors 2. All other Contractors
a. ________________ b1. Contractor Supt. b2. _______________
a. _____________ b1. On-Site Contr. Office b2.____________
2. Explain to contract employees the applicable provisions of the emergency action plan. a. Site Specific orientation b. Block Orientation c. Safe Work Permit
a. See Item #1 b. See Item #1 c. Permit Issuers/ Permit Receivers
a. See Item #1 b. See Item #1 c. LCM - BCF020.001
RMP Specific 40 CFR 68.87
UNIT LEVEL REQUIREMENTS
Responsible for Requirement
Location of Documentation
References/ Comments
Requirements for Contractors under RMP are the Same as PSM See above See above
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #7 - PRE-STARTUP SAFETY REVIEW UNIT: ______________ DATE: _____________ Reference OSHA 1910/119 (i)
SITE PROGRAMS Accountable for Requirement
Location of Documentation References/Comments
1. 95% Review (Pre-Startup Program) for Capital Projects and large maintenance jobs.
EHS Manager BCF020.025 In accordance with Process Safety Management & Risk Management Program Guide on Process Safety Web Page.
Unit Level Requirement Responsible for
Requirement Location of Documentation References/Comments
1. A pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information.
________________
_______________________
Documentation is kept with Project Files (Job Books) and on the EHS Change Manager Database
2. The pre-startup safety review shall confirm that prior to the introduction of highly hazardous chemicals to a process: a. Construction and equipment is in accordance with design specifications; b. Safety, operation, maintenance and emergency procedures are in place
and are adequate; c. For new facilities, a process hazard analysis has been performed and
recommendations have been resolved or implemented before startup d. Modified facilities have been subject to management of change process e. Training of each employee involved in operating a process has been
completed.
a. _____________ b. _____________ c. See Element #3 and #10 d. See Element #10 e. _____________
a. ____________________ b. ____________________ c. See Element #3 & #10 d. See Element #10 e. See Element #10 (EHS Change Manager Database)
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #7 - PRE-STARTUP SAFETY REVIEW UNIT: ______________ DATE: _____________ Reference: OSHA 1910.119 (i)
RMP-Specific 40 CFR 68.75 Unit Level Requirement Responsible for
Requirement Location of Documentation References/Comments
The RM Plan shall be reviewed, revised, and updated as listed below. The Unit is responsible to notify the Environmental Department when changes below occur and initiate an RM Plan update. a) Within five years of its initial submission or most recent update, whichever is
later, b) No later than three years after a newly regulated substance is first listed by
EPA, c) No later than the date on which a regulated substance is first present in an
already covered process above a threshold quantity, d) No later than the date on which a regulated substance is first present above a
threshold quantity in a new process, e) Within six months of a change that requires a revised PHA or hazard review, f) Within six months of a change that requires a revised offsite consequence
analysis, (see 40 CFR 68.36, when quantities of stored material may increase or decrease the distance to the endpoint by a factor of 2 or more)
g) When a unit is no longer subject to RMP requirements a revised registration must submitted with six months.
Technology Specialist/TL
Project Files and EHS Change Manager Database
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #8 - MECHANICAL INTEGRITY UNIT: ______________ DATE: _____________ Reference: OSHA 1910.119 (j)
SITE PROGRAM Accountable for Requirement
Location of Documentation References/Comments
1. Establish and implement written procedures to maintain the ongoing integrity of process equipment. a. Pressure vessels b. Storage tanks b. Piping systems & components c. Relief and vent systems and devices d. Emergency shutdown systems e. Controls (including monitoring devices and sensors, alarms and
interlocks) and f. Pumps
EHS Manager
Maintenance Director
Loss Control Manual BASF Technical Rules Web Page
Freeport Mechanical Integrity Program - BCF020.031
2. Technician training program for employees involved in maintaining the ongoing integrity of process equipment.
E&M L&D Coordinator
Employee’s Training Files and/ or MBO
3. In the construction of new plants and equipment, the employer shall ensure that equipment, as it is fabricated, is suitable for the process application for which they will be used.
EHS Manager
VP Tech Engr Svc
Loss Control Manual BASF Technical Rules Web Page
Freeport Mechanical Integrity Program
4. The employee shall ensure that maintenance materials, spare parts and equipment are suitable for the process application for which they will be used.
EHS Manager
Maintenance Director
Loss Control Manual BASF Technical Rules Web Page
Freeport Mechanical Integrity Program
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #8 - MECHANICAL INTEGRITY UNIT: ______________ DATE: _____________ Reference: OSHA 1910.119 (j)
Unit Level Requirement Responsible for Requirement
Location of Documentation References /Comments
TRAINING 1. Train each employee involved in maintaining the ongoing integrity of process
equipment in an overview of that process and its hazards. Area Maintenance Mgr
_______________________
Production & E&M L&D Coordinators also supports
2. Train each BASF employee involved in maintaining the ongoing integrity of process equipment in the procedures applicable to the employee’s job task, to ensure that the employee can perform the job tasks in a safe manner.
Maintenance Supervisors
_______________________
E&M L&D Coordinator also supports
3. Train each contractor employee involved in maintaining the ongoing integrity of process equipment in the procedures applicable to the employee’s job task, to ensure that the employee can perform the job tasks in a safe manner.
Contractor Supervision
Contractor-Maintained Records
Reference: OSHA 1910.119 (j)
QUALITY ASSURANCE 1. Appropriate checks and inspections shall be performed to assure that
equipment is installed properly and consistent with design specifications and the manufacturer’s instructions. • During installations
• 95% Review (Pre-Startup)
• Non-Capital Projects
Project Manager
Project Manager
E&M
_______________________
See PSM Element #7 & #9
Equipment Files
Maintenance and Reliability Engineers need to be involved
BCF020.033 Process Safety Management and Risk Management Plan PSM ELEMENT #8 - MECHANICAL INTEGRITY UNIT: ______________ DATE: _____________ Reference: OSHA 1910.119 (j)
Unit Level Requirement Responsible for Requirement
Location of Documentation References /Comments
MECHANICAL INTEGRITY 1. Listing of PSM-affected PRESSURE VESSELS is maintained, in the
following format: (indicate the system chosen to maintain up-to-date list ) ____a. Unit-generated list or database ____b. P&ID’s
a. Mechanical
Services Group (MSG)
b. Technology Specialist
a. B-611 MSG b. Master Stick in the Control Room
2. Equipment files for Pressure Vessels are maintained. ____a. Inspection records ____b. Operations equipment files
a. Mech. Svcs. Mgr. b. Maintenance Supervisor
a. B-611 MSG b. _________________
See FP-P-ME-02, “Equipment Files” in the Maintenance Procedures Manual.
3. The design basis / requirements for existing Pressure Vessels are available. These are kept in : (indicate all that apply) ____a. Job books ____b. Equipment specifications ____c. Equipment files ____d. BASF Technical Standards
a. Technology Specialist b. Technology Specialist c. Maintenance Supervisor d. VP Tech Engr. Svcs.
a. _____________________ b. _____________________ c. _____________________ d. BASF Technical Rules
Web Page
4. The required inspections and inspection frequencies are identified for individual Pressure Vessels. (Record the “keeper” and location of the monthly printout here.)
Mech. Svcs. Mgr.
SAP Inspection types and frequencies are recorded by the E&M MSG and produced on monthly printouts
5. Procedures are available for obtaining / scheduling inspections of Pressure Vessels. (Record the “keeper” and location of the Maintenance Policies & Procedures Manual here.)
MSG Manager BASF Technical Rules Web Page
• N-G-MC-105, “Risk Based Inspection”
• Procedures are in N-P-MC-105, “Equipment Inspection Procedures” in the Maintenance Policies & TJA’s. North America Procedures and Guidelines Section
BCF020.033 Process Safety Management and Risk Management Plan PSM ELEMENT #8 - MECHANICAL INTEGRITY UNIT: ______________ DATE: _____________ Reference: OSHA 1910.119 (j)
Unit Level Requirement Responsible for Requirement
Location of Documentation References/Comments
6. Pressure Vessel inspections follow good engineering practice Mech. Svcs. Mgr. See site BCF020.031: Mechanical Integrity Program (Freeport EHS web page - LCM)
• Inspection / E&Mt procedures are based on the API-510 Code, and operating / inspection experience.
• E&Mt methods are based upon ASNT-TC-1A.
7. Acceptance criteria for Pressure Vessel inspections are established.
Mech. Svcs. Mgr. See site BCF020.031: Mechanical Integrity Program (Freeport EHS web page - LCM)
The principles of the ASME Code and the National Board Inspection Code (NBIC) shall be used to determine fitness for service.
8. Procedures for Pressure Vessel repair or alteration follow good engineering practice.
Mech. Svcs. Mgr. See site BCF020.031: Mechanical Integrity Program (Freeport EHS web page - LCM)
Procedures are based upon the API-510 Code and the NBIC, and repair / alteration experience.
9. Documentation of Pressure Vessels: a. inspections, b. repairs c. alterations Is maintained in equipment files.
a. Mech. Svcs. Mgr. b._____________ c._____________
a. MSG Files b. Equip. Files in plant c. __________________
Official Inspection records are maintained in the MSG files. All others are the responsibility of the Owner.
10. A list of Storage Tanks is maintained. Mech. Svcs. Mgr. Maint. Equipment files/E&M MSG files
Official inspection records for registered Storage Tanks are maintained in the Mech. Group Files. Owners are responsible for all others.
11.
Equipment files for Storage Tanks are maintained. a. inspections, b. repairs c. alterations Is maintained in equipment files.
a. Mech. Svcs. Mgr. b._____________ c._____________
a. MSG Files b. Equip. Files in plant c. __________________
See FP-P-ME-02, “Equipment Files” in the Maintenance Procedures Manual.
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #8 - MECHANICAL INTEGRITY UNIT: ______________ DATE: _____________ Reference: OSHA 1910.119 (j)
Unit Level Requirement Responsible for Requirement
Location of Documentation References/Comments
12. The design basis / requirements for existing Storage Tanks are available. These are kept in : (indicate all that apply) ____a. Job books ____b. Equipment specifications ____c. Equipment files ____d. BASF Technical Standards
a. Technology Specialist b. Technology Specialist c. Maintenance Supervisor d. VP Tech Engr. Svcs.
a. _____________________ b. _____________________ c. _____________________ d. BASF Technical Rules Web Page
13. The required inspections and inspection frequencies are identified for individual Storage Tanks. (Record the “keeper” and location of the monthly printout here.)
MSG
SAP
Inspection types and frequencies are by the MSG, and produced on monthly printouts.
14. Procedures are available for obtaining / scheduling inspections of Storage Tanks. (Record the “keeper” and location of the Maintenance Policies & Procedures Manual here.)
MSG
Freeport E&M Web Page, Procedures and Guidelines
Procedures are in FP-P-MC-08 in the Maintenance Policies & Procedures Manual. Information for Pressure Vessels also applies to Storage Tanks.
15. Storage Tank inspections follow good engineering practice.
Mech. Svcs. Mgr. See site BCF020.031: Mechanical Integrity Program (Freeport EHS web page - LCM)
• Inspection / test procedures are based on the API-653 standard, and operating / inspection experience.
• Test methods are based upon ASNT-TC-1A.
16. Acceptance criteria for Storage Tank inspections are established.
Mech. Svcs. Mgr. See site BCF020.031: Mechanical Integrity Program (Freeport EHS web page - LCM)
The principles of the applicable API standard (12D, 12F, 650,
620, etc.) are used to determine if repairs are needed.
17. Procedures for Storage Tank repair or alteration follow good engineering practice.
Mech. Svcs. Mgr. See site BCF020.031: Mechanical Integrity Program (Freeport EHS web page - LCM)
Procedures are based upon the API-653 standard, and repair / alteration experience.
BCF020.033 Process Safety Management and Risk Management Plan PSM ELEMENT #8 - MECHANICAL INTEGRITY UNIT: ______________ DATE: _____________ Reference: OSHA 1910.119 (j)
Unit Level Requirement Responsible for Requirement
Location of Documentation References/Comments
18. Listing of PSM-affected PIPING SYSTEMS is maintained, in the following format: (indicate the system chosen to maintain up-to-date list ) ____a. Unit-generated list or database ____b. P&ID’s
a. Mech. Svcs. Mgr. b. Technology Specialist
a. 611 MSG Files b. Master Stick in Control Rooms
19. Equipment files for registered Piping Systems are maintained.
MSG SAP Procedures are in M-P-MC-105-Stationary Equipment and Piping Systems Inspection Procedure
20. The design basis/requirements for existing Piping Systems are available. These are kept in: (indicate all that apply) ____a. Job books ____b. Equipment files ____c. Unit Pipe Service Index ____d. BASF Technical Standards ____e. Unit Line List
a._______________ b._______________ c. Technology Specialist d. NCE Design Services Manager e.________________
a.________________ b.________________ c.________________ d. BASF Technical Rules Web Page e.________________
21. The required inspections and inspection frequencies are identified for individual Piping Systems. (Record the “keeper” and location of the monthly printout here.)
Mech. Svcs. Mgr. MSG Files Inspection types and frequencies are recorded by the MSG, and produced on monthly printouts
22. Procedures are available for obtaining / scheduling inspections of Piping Systems. (Record the “keeper” and location of the Maintenance Policies & Procedures Manual here.)
Mech. Svcs. Mgr. North America E&M Web Page
Inspection types and frequencies are recorded by the MSG, and produced on monthly printouts (N-P-MC-105)
23. PIPING SYSTEM inspections follow good engineering practice.
Mech. Svcs. Mgr. See site BCF020.031: Mechanical Integrity Program (Freeport EHS web page - LCM)
• Inspection / test procedures are based on the API-570 Code, BASF Technical Standards, and operating / inspection experience (N-P-MC-105).
• Test methods are based upon ASNT-TC-1A and BASF Technical Standards.
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #8 - MECHANICAL INTEGRITY UNIT: ______________ DATE: _____________ Reference: OSHA 1910.119 (j)
Unit Level Requirement Responsible for Requirement
Location of Documentation References/Comments
24. Acceptance criteria for Piping System inspections are established.
Mech. Svcs. Mgr. See site BCF020.031: Mechanical Integrity Program (Freeport EHS web page - LCM)
The principles of the applicable ASME/ANSI code (B31.1, B31.3, etc), as well as BASF Technical Standard requirements are used to determine if repairs are needed.
25. Procedures for Piping System repair or alteration follow good engineering practice.
Mech. Svcs. Mgr. See site BCF020.031: Mechanical Integrity Program (Freeport EHS web page - LCM)
Procedures are based upon the API-570 code, and repair / alteration experience (N-G-MC-100).
26. Documentation of Piping System: a. Inspections b. repairs c. alterations
a. Mech. Svcs. Mgr. b._______________ c._______________
a. MSG Files b._______________ c._______________
Procedures are in N-P-MC-105-Stationary Equipment and Piping Systems Inspection Procedure. Are maintained in equipment files
27. A program for hose and hose fitting selection, maintenance and inspection is in place. Unit Process Hose Selection Chart
EHS Manager _______________
EHS web page Loss Control Manual _____________________
See BCF020.007, Hose and Hose Fittings
28. Listing of PSM-affected INSTRUMENTS is maintained, in the following format; (indicate the system chosen to maintain up-to-date list) Unit-generated list or database (INtools) ____
Area I&E Maintenance Engineer
INTools Identification for typical PSM instrumentation is in N-P-EI-105: Instrument PM/PdM Procedure (for example, the Safety Critical instruments of Risk Class B, C, D )
29. The design basis / requirements for existing Instruments are available. These are kept in : (indicate all that apply) ____a. Job books ____b. Equipment specifications ____c. Equipment files ____d. BASF Technical Standards
a. _____ b. Area I&E Supervisor c. Area I&E Supervisor d. NCE Design Services Director
a. _____________________ b. INTools c. _____________ d. BASF Technical Rules Web Page
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #8 – MECHANICAL INTEGRITY UNIT: ______________ DATE: _____________ Reference: OSHA 1910.119 (j)
Unit Level Requirement Responsible for Requirement
Location of Documentation References/Comments
30. The required inspections and inspection frequencies are identified for individual Instruments, in the following format; (indicate all that apply) ____a. Unit critical instrument program ____ b. Safety instrumented systems _____c. I&E Asset management tool
a. Area Maint. Engr. & Area I&E Supervisor b. SIS Responsible Engr. & Area I&E Supervisor c. Area I&E Maint. Engr. & Area I&E Supervisor
a. INtools b.INtools c. ____________________
Procedures for typical inspection methods and inspection frequencies are in N-P-EI-105
31. Instrument inspections follow good engineering practice, utilizing the following; (indicate all that apply) __X_a. N-P-EI-105 ____b. Manufacturer’s instruction manuals ____c. Other procedures
a. NCE Instrument & Control CoE b. I/E Techs c. I/E Techs
a. BASF Technical Rules Web Page b. I/E files c. I/E files
• In-line or in-vessel Instruments shall be tested for containment per the Piping System inspection requirements.
• Function tests shall be in accordance with BASF G-P-EI-201M guidelines and manufacturer’s instruction manuals.
32. Acceptance criteria for Instrument inspections are established. NCE Instrument & Control CoE
Same as above. • In-line or in-vessel Instruments shall use Piping System acceptance criteria.
• For function testing, the manufacturer’s instruction manual, G-P-EI-201M guidelines or other test procedures will determine acceptance criteria.
33. Procedures for Instrument repair or alteration follow good engineering practice.
NCE Instrument & Control CoE
See site BCF020.031: Mechanical Integrity Program (Freeport EHS web page - LCM)
Equipment will be repaired using manufacturer’s instruction manuals / recommendations.
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #8 – MECHANICAL INTEGRITY UNIT: ______________ DATE: _____________ Reference: OSHA 1910.119 (j)
Unit Level Requirement Responsible for Requirement
Location of Documentation References/Comments
34. Documentation of Instrument inspections, repairs and alterations is maintained in ; (indicate all that apply) ____a. Equipment files ____b. INtools database ____c. SAP
a. I/E Techs b.______________ c.______________
a. _____________________ b.______________________ c.______________________
35. Electrical classification drawings are maintained. ____a. Drawings ____b. Chemical list that forms the basis for the drawings ____c. Written description of justifications followed
Area I/E Maintenance Engineer
a. E&M CAD files b. _____________ c. _____________
N-G-EI-902: Electrical Area Classification Guidelines for Drawings and Documents on BASF Technical Rules Web Page and NFPA 497
36. Ground grid drawings and test documentation are maintained. Area I&E Maintenance Engineer
E&M CAD files Procedure is in N-G-EI-903- Facilities Grounding Drawings and Documents BASF Technical Rules Web Page
37. Safety interlock and shutdown system descriptions and test procedures are maintained.
Area I&E Maintenance Engineer
_______________
38. UPS systems are maintained. Area I&E Supervisor ______________ Typically, system maintenance is performed by outside contractors. Scheduling of system maintenance is a BASF responsibility.
39. UPS system design basis is documented. Area I&E Maintenance Engr.
_____________
40. Listing of PSM-affected PUMPS AND ROTATING/RECIPROCATING EQUIPMENT is maintained, in the following format: (indicate the system chosen to maintain up-to-date list ) ____a. P&ID’s (Master Stick) ____b. Rotating Equipment List (SAP)
a. Production Technologist b. Area Mechanical Maint. Engr.
a. Control Room b. SAP
41. A Rotating Equipment List with pertinent reference information is maintained.
Area Mechanical Maint. Engr.
SAP
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #8 – MECHANICAL INTEGRITY UNIT: ______________ DATE: _____________ Reference: OSHA 1910.119 (j)
Unit Level Requirement Responsible for Requirement
Location of Documentation References/Comments
42. Equipment files are maintained for Pumps and Rotating / Reciprocating Equipment. (repair checksheets and other maintenance repair documents)
Area Rotating Equipment Supervisor
_______________________ Procedure is in N-G-MC-005: Guideline Mechanical/ Equipment Equipment Files ” on the BASF Technical Rules web page
43. The design basis / requirements for existing Pumps and Rotating / Reciprocating Equipment are available. These are kept in : (indicate all that apply) ____a. Equipment files ____b. Job books ____c. Equipment specifications ____d. BASF Technical Standards
a. Area Rotating Equipment Supervisor b. Technology Specialist c. ___________ d. NCE Design Services Director
a. _____________________ b. _____________________ c. ______________ d. BASF Technical Rules Web Page
c. reference N-P-PM-503:
Project Job Files and Job Books on BASF Technical Rules Web Page
44. Predictive and/or preventive maintenance inspections are performed on Pumps and Rotating / Reciprocating Equipment.
Area Rotating Equipment Supervisor
Equipment Files (per N-G-MC-5)
Inspection / test frequencies are determined by manufacturer’s recommendations, operating / inspection experience, repair frequency reports and repair history information.
45. Pump and Rotating / Reciprocating Equipment inspections follow good engineering and maintenance practices.
Area Mechanical Maint. & Reliability Engrs..
See site BCF020.031: Mechanical Integrity Program (Freeport EHS web page - LCM)
Inspection / test procedures are based on manufacturer’s recommendations, equipment check sheets, predictive & preventive maintenance procedures, BASF Technical Standards, and operating / inspection experience.
PSM ELEMENT #8 – MECHANICAL INTEGRITY UNIT: ______________ DATE: _____________
BCF020.033 Process Safety Management and Risk Management Plan
Reference: OSHA 1910.119 (j)
Unit Level Requirement Responsible for Requirement
Location of Documentation References/Comments
46. Pump and Rotating / Reciprocating Equipment inspection acceptance criteria follow good engineering and Maint.enance practices.
Area Mechanical Maint. & Reliability Engrs.
See site BCF020.031: Mechanical Integrity Program (Freeport EHS web page - LCM)
• Inspection / test acceptance criteria are based upon manufacturer’s instruction manuals, Mechanical TJA’s, and BASF Technical Standard requirements. Piping System acceptance criteria apply to flange and valve connections.
47. Checksheets for Pump and Rotating / Reciprocating Equipment repairs are available.
Area Rotating Equipment Supervisor
___________________ N-G-MC-005
48. Pump and Rotating /Reciprocating Equipment repairs and alterations follow good engineering and Maint.enance practices.
Area Mechanical Maint. & Reliability Engrs.
See site BCF020.031: Mechanical Integrity Program (Freeport EHS web page - LCM)
Equipment is repaired based on manufacturer’s specifications, BASF specifications, Maintenance procedures and TJA’s, established mechanical engineering / maintenance practices, and repair / alteration experience.
49. Documentation of Pump and Rotating / Reciprocating Equipment inspections, repairs and alterations is maintained in the following format; (check all that apply) ____a. Inspection / repair reports ____b. Checksheets ____c. Equipment files
a. Area Rotating Equipment Supervisor b. Area Rotating Equipment Supervisor c. Area Rotating Equipment Supervisor
a. _____________ b. _____________ c. _____________
N-G-MC-5
50. Listing of PSM-affected VENT AND RELIEF SYSTEMS is maintained, in the following format: (indicate the system chosen to maintain up-to-date list) ____a. SAP ____b. P&ID’s
a. Mech. Svcs. Mgr. b. Technology Specialist
a. SAP b. Control Room Master Stick
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #8 – MECHANICAL INTEGRITY UNIT: ______________ DATE: _____________ Reference: OSHA 1910.119 (j)
Unit Level Requirement Responsible for Requirement
Location of Documentation References/Comments
51. The design basis / requirements for existing Vent and Relief Systems are available. These are kept in : (indicate all that apply) ____a. Job books ____b. Equipment files ____c. Equipment specifications ____d. Unit relief device calculations
a. Technology Specialist b. Area Fixed Equipment Supervisor c. Technology Specialist d. Area Process Eng.
a. ________________ b. ________________ c. ________________ d. _________________
• Designs are per applicable codes (ASME Code, API RP520 & RP2000, NFPA Code, etc.), equipment specification sheets, manufacturer’s recommendations, and design / operation experience.
52. The required inspections and inspection frequencies are identified for Vent and Relief Systems. (Record the “keeper” and location of the monthly printout here.)
Mech. Svcs. Mgr. ____________________ • Inspection types and frequencies are recorded by the E&M MSG, and produced on monthly printouts.
53. Procedures are available for obtaining / scheduling inspections of Vent and Relief Systems. (Record the “keeper” and location of the Maintenance Policies & Procedures Manual here.)
Mech. Svcs. Mgr. BASF Technical Rules Web Page
Procedures are in N-G-MC-110: Relief and Flashback Protection Device Inspection, FP-P-MC-09: Relief Device Inspection and FP-P-MC-12: Relief Device Shop Testing and Repair Also refer to FP-P-MC-09 and FP-P- MC-12.
54. Vent and Relief System inspections follow good engineering practice. Mech. Svcs. Mgr. See site Mechanical Integrity Program document in the Loss Control Manual
Inspection / test procedures are based on the National Board Inspection Code (NBIC), API-510 Code, and operating / inspection experience. Consult references in 53.
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #8 – MECHANICAL INTEGRITY UNIT: ______________ DATE: _____________
Unit Level Requirement Responsible for Requirement
Location of Documentation References/Comments
55. Acceptance criteria for VENT AND RELIEF SYSTEM inspections are established.
Mech. Svcs. Mgr.
See site Mechanical Integrity Program document in the Loss Control Manual
Principles of the NBIC, repair shop procedures, manufacturer’s recommendations and BASF established practices are used to determine if repairs are needed FP-P-MC-09 and FP-P-MC-12.
56. Procedures for Vent or Relief System repair or alteration follow good engineering practice.
Mech. Svcs. Mgr. See site Mechanical Integrity Program document in the Loss Control Manual
Procedures are based on NBIC, Manufacturer’s recommendations, repair shop practices, and BASF established practices.
57. Documentation of Vent and Relief Systems: a. Inspections b. Repairs c. Alterations Are maintained in equipment files.
a. Technology Specialist b. Technology Specialist c. Maintenance Supervisor
a. ___________ b. ___________ c. ___________
RMP-Specific 40 CFR 68.73
UNIT LEVEL REQUIREMENTS Responsible for Requirement
Location of Documentation
References/ Comments
Requirements for Mechanical Integrity under RMP are the same as PSM See above See above
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #9 - HOT WORK PERMIT UNIT: ________________ DATE: ________________ Reference OSHA 1910.119(k) SITE PROGRAM Accountable for
Requirement Location of Documentation Reference/Comments
1. Safety Standard #BCF020.023: Hot Work EHS Manager Freeport EHS web page - LCM
BC032.016: Hot Work, 29 CFR 1910.252General Requirements for Welding, 29 CFR1910.119(k) Hot Work Permit, 40 CFR 68.85 Hot Work Permit (RMP)
Unit Level Requirement Responsible for
Requirement Location of Documentation References/Comments
1. The employer shall issue a hot work permit for hot work operations conducted on or near a covered process.
________________
_______________________
See Site Program above
2. The permit shall document that the fire prevention and protection requirements in 29 CFR 1910.252(a) have been implemented prior to beginning the hot work operations ‘It shall indicate the date(s) authorized for hot work’ and identify the object on which hot work is to be performed. The permit shall be kept on file until completion of the hot work operations and permit review.
_______________________
See Site Program above
RMP Specific 40 CFR 68.85
UNIT LEVEL REQUIREMENTS
Responsible for Requirement
Location of Documentation References/Comments
Requirements for Hot Work under RMP are the same as PSM See above See above
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #10 - MANAGEMENT OF CHANGE UNIT: _______________ DATE: _______________ Reference OSHA 1910.119(l) and EPA RMP 40 CFR 68.75 SITE REQUIREMENTS Accountable for
Requirement Location of Documentation References/Comments
1 BCF020.036, “Management of Change”
EHS Manager Freeport EHS web page - LCM
Process Safety PSM/RMP Guide III Management System Elements: Management of Change
Unit Level Requirement Responsible for Requirement
Location of Documentation References/Comments
1 Implementation of procedures for managing changes (except for “replacements in kind”) in the technology of manufacturing, process chemicals, and related equipment, or a change in the procedures of operating the process and related equipment outside of the established safe operating parameters.
Sr. Production Manager/Director
Freeport EHS web page - LCM
BCF020.036: Management of Change
2 A form or checklist is used which addresses the aspects of change management required by OSHA 1910.119 (l) including: The technical basis for the proposed change; Impact of change on safety and health; Modifications to operating procedures; Necessary time period for the change; and, Authorization requirements for the proposed change. Employees involved in operating a process and maintenance and contract employees whose job tasks will be affected by a change in the process shall be informed of, and trained in, the change prior to start-up of the process or affected part of the process.
Sr. Production Manager/Director
EHS Change Manager Database
BCF020.036: Management of Change
3 Management of change forms / checklists are retained in EHS Database: Change Manager and Change Manager Archive
EHS EHS Change Manager/ Change Manager Archive Databases
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #10 - MANAGEMENT OF CHANGE UNIT: _______________ DATE: ________________ Reference OSHA 1910.119(l) and EPA RMP 40 CFR 68.75
RMP Specific 40 CFR 68.75, 68.190
REQUIREMENTS Responsible for Requirement
Location of Documentation
References / Comments
1. The RM Plan shall be reviewed, revised, and updated as listed below. The Unit is responsible to notify the EHS when changes below occur and initiate update. a) Within five years of its initial submission or most recent update, whichever is
later, b) No later than three years after a newly regulated substance is first listed by
EPA, c) No later than the date on which a regulated substance is first present in an
already covered process above a threshold quantity, d) No later than the date on which a regulated substance is first present above a
threshold quantity in a new process, e) Within six months of a change that requires a revised PHA or hazard review, f) Within six months of a change that requires a revised offsite consequence
analysis, (see 68.36, when quantities of stored material may increase or decrease the distance to the endpoint by a factor of 2 or more)
g) When a unit is no longer subject to RMP requirements a revised registration must submitted with six months.
_____________
______________________
Freeport EHS web page – Environmental : Risk Management Program
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #11 - INCIDENT INVESTIGATION UNIT: ___________________ DATE: ___________________ Reference OSHA 1910.119(m) and EPA 40 CFR 68.81 SITE REQUIREMENTS Accountable for
Requirement Location of Documentation References / Comments
1 BC032.010 Incident Notification & Reporting BCF030.003 Environmental Response and Reporting Procedure
EHS Manager EHS Manager
Link on Freeport EHS web page – LCM and Freeport EHS web page - Environmental
2 Written procedures are implemented for investigation of incidents which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemicals.
EHS Manager BC032.010 Incident Notification & Reporting
Unit Level Requirement Responsible for
Requirement Location of Documentation References / Comments
1 Incident reports are developed which capture the incident information as required in OSHA 1910.119 (m).
Production Execution Manager
EHS Accident Incident Management System (AIMS) Database
2 Incident investigation reports for incidents involving or potentially involving PSM chemicals are retained for 5 years.
EHS
EHS AIMS and AIMS Archive Databases
Reference OSHA 1910.119(m) and EPA 40 CFR 68.81
RMP Specific 40 CFR 68.81 and 68.42 Unit Level Requirement Responsible for
Requirement Location of
Documentation References / Comments
1. Each Incident shall be investigated which resulted in, or could reasonably have resulted in a catastrophic release of an RMP regulated material as soon as possible but not later than 48 hours.
_____________
EHS AIMS Database
BC030.003 Environmental Response and Reporting Procedure
2. The incident investigation team shall consist of at least one person knowledgeable in the process, including a contract employee if the incident involved the work of a contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident.
Production Execution Manager
EHS AIMS Database
3. The report shall be reviewed with all affected personnel whose job tasks are relevant to the incident findings including contract employees where applicable.
Production Execution Manager
_____________________ BCF020.047: Safety Meeting and Emergency Drill (UST Requirements)
4. The investigation must include and document in addition to current required
BCF020.033 Process Safety Management and Risk Management Plan
information: a) The potential offsite impact to human health and the environment. b) Onsite impacts (injuries and significant property damage) c) Offsite impacts (injuries, evacuation, sheltering in place, property damage, and
environmental damage) d) If offsite responders were notified (fire, LEPC, i.e. Level 2 or 3) e) Duration of release, f) Weather Conditions (wind speed, wind direction, cloudy or clear, humidity,
rainfall amounts, temperature)
Production Execution Manager
EHS AIMS Database
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #12 - EMERGENCY PLANNING AND RESPONSE UNIT: ________________ DATE: ________________
Reference OSHA 1910.119(n) and EPA 40 CFR 68.95 Site Program
Accountable for
Requirement Location of
Documentation References/Comments
1 The employer shall establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38 (a).
EHS Manager Freeport EHS web page - Emergency Plans
Unit Level Requirement Responsible for Requirement
Location of Documentation References/Comments
1 The emergency action plan shall include procedures for handling small releases. Employees covered under this standard may also be subject to the hazardous waste and emergency response provisions contained in 29 CFR 1910.120 (a), (p) and (q).
_________________
_______________________
Freeport Site and Unit Emergency Plans
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #12 - EMERGENCY PLANNING AND RESPONSE UNIT: ________________ DATE: ________________ Reference OSHA 1910.119(n) and EPA 40 CFR 68.95
RMP Specific 40 CFR 68.95 Requirement Responsible for
Requirement Location of Documentation References/Comments
1 The emergency response program shall include procedures for the purpose of protecting the public health and environment. This plan shall contain the following: a) Procedures for informing the public and local emergency response
agencies about accidental releases b) Documentation of proper first aid and emergency medical treatment
necessary to treat accidental human exposures, c) Procedures and measures for emergency response after an accidental
release of a regulated substance, d) Procedures for the use of emergency response equipment and for its
inspection, testing, and maintenance, e) Training for all employees in relevant procedures f) Procedures to review and update, as appropriate, the emergency
response plan to reflect changes at the stationary source and ensure that employees are informed of changes
EHS Manager EHS Manager _________________ _________________ _________________ EHS Manager/ Production Execution Manager
Freeport EHS Web page - Emergency Plans Site Emergency Plan, BCF020.009: Site Safety Rules _______________________ _______________________ __________________
Site Emergency Plan Also, see Site Emergency Plan Also, see Site Emergency Plan Site Emergency Plan BCF020:036: Management of Change
2. Site Emergency Response Plan is coordinated with local emergency response officials.
EHS Manager Freeport EHS Web page - Emergency Plans
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #13 -COMPLIANCE AUDITS UNIT: ___________________ DATE: ___________________ Reference OSHA 1910.119(o)
SITE/UNIT PROGRAM Accountable for
Requirement Type/Location of Documentation
References/Comments
1 Employers shall certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed.
EHS Audit Leader/Sr. Production Manager/Director
______________________
This is the Units corporate audit report.
2 The compliance audit shall be conducted by at least one person knowledgeable in the process.
EHS Audit Leader/ Sr. Production Manager/Director
Same as above Unit Participation
3 A report of the findings of the audit shall be developed.
EHS Audit Leader/ Sr. Production Manager/Director
Same as above The Sr. Production Manager/Director is responsible to see that EHS Audit Leader returns report.
4 The employer shall promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected.
Sr. Production Manager/Director
Same as above
5 Employers shall retain the two most recent compliance audit reports.
Sr. Production Manager/Director
Same as above
RMP Specific 40 CFR 68.79
Requirements for Compliance Audits under RMP are the same as PSM See above See above
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #14 -TRADE SECRETS UNIT: ___________________ DATE: ___________________ Reference OSHA 1910.119(p)
Site Program
Accountable for
Requirement
Type/Location of Documentation
References/Comments
1 Employers shall make all information necessary to comply with the section available to those persons responsible for compiling the process safety information (required by paragraph (d) of this section), those responsible for developing the operating procedures (required by paragraph (f) of this section), and those involved in incident investigations (required by paragraph (m) of this section), emergency planning and response (paragraph (n) of this section) and compliance audits (paragraph (o) of this section ) without regard to possible trade secret status of such information.
Sr. Production Manager/Director
N/A See each of the proceeding sections and associated programs.
2 Nothing in this paragraph shall preclude the employer from requiring the persons to whom the information is made available under paragraph (p)(1) of this section to enter into confidentiality agreements not to disclose the information as set forth in 29 CFR 1910.1200.
Sr. Production Manager/Director
N/A Documentation is provided.
3 Subject to the rules and procedures set forth in 29 CFR 1910.1200 (i)(1) through 1910.1200(i)(12), employees and their designated representatives shall have access to trade secret information contained within the process hazard analysis and other documents required to be developed by this standard.
Sr. Production Manager/Director
N/A Documentation is provided.
BCF020.033 Process Safety Management and Risk Management Plan
PSM ELEMENT #14 -TRADE SECRETS UNIT: ___________________ DATE: ___________________ Reference OSHA 1910.119(p)
RMP Specific 40 CFR 68.79
Site Program
Accountable for
Requirement
Type/Location of Documentation
References/Comments
1 A written Risk Management (RM) program that meets requirements of 40 CFR 68.
EHS Manager Freeport EHS Web Page - LCM: BCF020.033 (this document) and Freeport Environmental website
2 Submit a RM Plan for each covered process prior to June 21, 1999 and submit updates every 5 years or sooner according to requirements under Management of Change above or 40 CFR part 68.36 and 68.190. This includes all requirements under Subpart G which includes, a) Submission b) Executive Summary c) Registration d) Offsite Consequence analysis e) Five-year accident history f) Prevention Program/program 3 g) Emergency response program h) Certification i) Updates And Subpart H which includes a) Record keeping b) Availability of information to the public c) Permit content and air permitting authority requirements d) Audits
EHS Manager
Freeport EHS web page – Environmental
3 Develop and implement a management system that: a) That ensures the implementation and continuance of an RM program b) Assign a qualified person for overall responsibility for the RM
program c) When responsibility for implementing individual requirements are
assigned to persons other than the person in (b) above list the names or positions and define the line of authority.
EHS Manager Freeport EHS web page - LCM: BCF020.033: Process Safety Management and Risk Management Plan (this document)
BCF020.033 Process Safety Management and Risk Management Plan
G-R-PRS-040 ELEMENT EMPLOYEE PARTICIPATION UNIT: ___________________ DATE: ___________________ Reference G-R-PRS-040
Requirement Responsible for Requirement
Location of Documentation References/Comments
N/A G-R-PRS-040 ELEMENT PROCESS SAFETY INFORMATION Reference G-R-PRS-040, Section 6.1.1 – 6.1.4
Requirement Responsible for Requirement
Location of Documentation References/Comments
1. Process Safety documentation must be available to the Production, Maintenance and Emergency Response personnel at all times.
See this document
2. An index of the documentation shall be provided. See this document 3. Plant documentation listed under G-P-PRS-040, Section 6.1 shall be
‘As-Built’ following installation of a capital project or plant modification (MOC).
See this document
4. The documents shall be maintained in an up-to-date status and kept for the lifetime of the unit.
See this document
5. The following information shall be provided for all raw materials, products, intermediates and wastes: Material Safety Data Sheet (MSDS) for all materials that are or can be isolated.
See PSM/RMP PSI Site Requirement #2
6. Thermal Stability information, unless thermal hazard is negligible )If needed, determination of Thermal Stability / Reactivity significance
should be made together with Regional or Global Process Safety and/or BASF Safety Testing(.
See PSM/RMP PSI Unit Requirement #2f
7. Material Compatibility Information or Matrix See PSM/RMP PSI Unit Requirement #2g
8. Other relevant safety data that is not included on MSDS, e.g. ST (Staub=dust) class or Minimum ignition energy for solids
9. Process Description, including process chemistry See PSM/RMP PSI Unit Requirement #3b
10. Process Flow Diagrams (Material Flow and Energy Balance) – as applicable
See PSM/RMP PSI Unit Requirement 3a & 4g
11. Business Unit Process Safety Concept (if existing) 12. Piping and Instrumentation Diagrams (P&IDs) with equipment design
information See PSM/RMP PSI Unit
Requirement #4b. Details
BCF020.033 Process Safety Management and Risk Management Plan
of the minimum information to be included on P&IDs is provided in G-P-PRS-040, Section 6.2.
13. Site Map / Plot Plan Utilities/XA Asset Manager
Site Master Planning Files
14. Plant layout drawings 15. Equipment layout / arrangement drawings 16. Underground drawings (Piping, Electrical, Civil) 17. Operating permits issued by the Authorities 18. Calculations and drawings for fixed sprinkler and deluge systems 19. Location of underground firewater piping, hydrants, and monitors
G-R-PRS-040 PROCESS HAZARD ANALYSIS Reference G-R-PRS-040
Requirement Responsible for Requirement
Location of Documentation References/Comments
1. Plant SHE Protection Concept for all parts of the plant including related auxillary and infrastructure features.
a. SHE Step Review documentation (Steps 0, 1, 2, 3 (as applicable), and 4 = Pre-Start up Safety Review),
b. Hazard Assessments. All copies, including previous, historical versions shall be maintained for the life of the facility.
c. The scope of all High Hazard (Step 3 Review applicable) sections of the plant shall be documented for future reference. This scope shall be designated on the applicable P&IDs.
See PSM/RMP Process Hazard Analysis Requirements
G-R-PRS-040 OPERATING PROCEDURES Reference G-R-PRS-040
Requirement Responsible for Requirement
Location of Documentation References/Comments
1. Operating Procedures for all operating states See PSM/RMP Operating Procedures Unit Requirement 1
G-R-PRS-040 TRAINING
BCF020.033 Process Safety Management and Risk Management Plan
Reference G-R-PRS-040
Requirement Responsible for Requirement
Location of Documentation References/Comments
1. N/A G-R-PRS-040 CONTRACTORS Reference G-R-PRS-040
Requirement Responsible for Requirement
Location of Documentation References/Comments
1. N/A G-R-PRS-040 PRE-STARTUP SAFETY REVIEW Reference G-R-PRS-040
Requirement Responsible for Requirement
Location of Documentation References/Comments
1. N/A G-R-PRS-040 MECHANICAL INTEGRITY Reference G-R-PRS-040
Requirement Responsible for Requirement
Location of Documentation References/Comments
1. Interlock descriptions / logic diagrams / interlock trip limit settings See PSM/RMP Mechanical Integrity Site Requirement 1e & Unit Requirement 37
2. Testing documentation for instrumented devices See PSM/RMP Mechanical Integrity Unit Requirement 34
3. Mechanical Equipment drawings (e.g. vessel drawings) See PSM/RMP Mechanical Integrity Unit Requirement 2
4. Vessel Inventory and technical information See PSM/RMP
BCF020.033 Process Safety Management and Risk Management Plan
Vessel Inspection and Testing records (Mechanical Integrity program) Mechanical Integrity Unit Requirement 1-17
5. Piping systems a. Pipe Service Index b. Technical information, if applicable c. Inspection and testing records (Mechanical Integrity program) d. Temporary leakage treatments (e.g. piping clamps), including monitoring plans and records. (Recommended to document within MOC)
a. See PSM/RMP Mechanical Integrity Unit Requirement 20c b. & c. See PSM/RMP Mechanical Integrity Unit Requirement 18-26 d. See PSM/RMP Management of Change Requirements
6. Relief Device Inventory and technical information a. Relief Device Design Calculations including relief load calculations, PSV back pressure calculations, and documentation of all relevant relief scenarios. b. Documentation of the determination of safe discharge location, including dispersion modeling or other related input c. Relief Device Inspection and Testing Records (Mechanical Integrity program)
See PSM/RMP Mechanical Integrity Unit Requirement 50 & 51 a. See PSM/RMP Mechanical Integrity Unit Requirement 51d c. See PSM/RMP Mechanical Integrity Unit Requirement 52-57
7. Safety Instrumented Systems a. Classification of any Safety Instrumented Function (SIF) according to the requirements of G-P-EI 201M, Sections 5.2 and 6.18 b. Documentation and investigation of all failures of a Safety Instrumented Function, according to G-P-EI 201M, Section 7
a. See PSM/RMP Mechanical Integrity Unit Requirement 29& 37 b. See PSM/RMP Mechanical Integrity Unit Requirement 32
8. Motor Control schematics 9. Grounding and Bonding Diagrams; Lightning Protection concept
a. Testing and inspection of bonding and grounding systems (Mechanical Integrity program)
See PSM/RMP Mechanical Integrity Unit Requirement 36 a. See PSM/RMP Mechanical Integrity Unit Requirement 36
10. Hazardous Area Classification Drawings, Explosion Protection Document, or Ex-Zone Classification Drawings, Electrical Classification Drawings according to G-S-SF 100-4M; including determination of zone classifications both internal and external to process equipment.
See PSM/RMP Mechanical Integrity Unit Requirement 35
BCF020.033 Process Safety Management and Risk Management Plan
G-R-PRS-040 HOT WORK PERMIT Reference G-R-PRS-040
Requirement Responsible for Requirement
Location of Documentation References/Comments
N/A G-R-PRS-040 MANAGEMENT OF CHANGE Reference G-R-PRS-040
Requirement Responsible for Requirement
Location of Documentation References/Comments
1. Documentation of changes using Management of Change (MOC) See PSM/RMP Management of Change
2. Changes (technical and organizational) – G-P-PRS 040. All facilities described shall maintain documentation related to technical and organizational changes
See PSM/RMP Management of Change
G-R-PRS-040 INCIDENT INVESTIGATION Reference G-R-PRS-040
Requirement Responsible for Requirement
Location of Documentation References/Comments
1. Documentation of incident investigations, corrective actions and closure of investigations
See PSM/RMP Incident Investigation
G-R-PRS-040 EMERGENCY PLANNING AND RESPONSE Reference G-R-PRS-040
Requirement Responsible for Requirement
Location of Documentation References/Comments
1. Emergency response plan for each unit / facility See PSM/RMP Emergency Planning and Response
BCF020.033 Process Safety Management and Risk Management Plan
G-R-PRS-040 COMPLIANCE AUDITS Reference G-R-PRS-040
Requirement Responsible for Requirement
Location of Documentation References/Comments
N/A
G-R-PRS-040 TRADE SECRETS Reference G-R-PRS-040
Requirement Responsible for Requirement
Location of Documentation References/Comments
N/A