Safety & SOPs

Doug Lillie, CIROBurris Logistics

Process Safety Management of Highly Hazardous & Explosive Chemicals

Operating Procedures, Safety Procedures & Training

SOPs and other acronyms

• SOP• TOS• MII• MOC• SRV

• PEL• IDLH• SCBA• APR• TWA

• DNA• EPA• RMP• OSHA• PSM

• NIOSH• DWP• MDMT

DNA???• Is SOP & Safety in your DNA?

DNA???• Is SOP & Safety in your DNA?• What was Blue’s SOP?

• Thrust• Lift• Drag

• Did he feel it in his heart or his head?• Was he ready?

• Are you ready?• Do you know your SOP’s?

Operating Procedures or Standard Operating Procedures (SOP’s)

• Where Did This Methodology Come From?

• Answer: The Military

• Definition: A standard operating procedure is a set of instructions having the force of a directive, covering those features of operations that lend themselves to a definite or standardized procedure without loss of effectiveness. Standard Operating Policies and Procedures can be effective catalysts to drive performance improvement and improving organizational results. Every good quality system is based on its standard operating procedures (SOPs).

Operating Procedures (RMP)

40 CFR Part 68.52 (a) The owner or operator shall prepare written operating procedures that provide clear instructions or steps for safely conducting activities associated with each covered process consistent with the safety information for that process. Operating procedures or instructions provided by equipment manufacturers or developed by persons or organizations knowledgeable about the process and equipment may be used as a basis for a stationary source's operating procedures.

(b) The procedures shall address the following:

(1) Initial startup;

(2) Normal operations;

(3) Temporary operations;

(4) Emergency shutdown and operations;

(5) Normal shutdown;

(6) Startup following a normal or emergency shutdown or a major change that requires a hazard review;

(7) Consequences of deviations and steps required to correct or avoid deviations; and

(8) Equipment inspections.

(c) The owner or operator shall ensure that the operating procedures are updated, if necessary, whenever a major change occurs and prior to startup of the changed process.

Operating Procedures (PSM)

29 CFR 1910.119(f)The Operating Procedures must consider the following.

• Initial start-up• Normal operations• Temporary operations• Emergency shutdown• Emergency operations• Normal shutdown • Start-up following turnaround• Consequences of deviation• Steps required to correct or avoid deviation

Operating Procedures• The operating procedures addressing operating parameters will

contain operating instructions about:• pressure limits• temperature ranges• flow rates…and • what to do when an upset condition occurs• what alarms and instruments are pertinent if an upset condition occurs, and

other subjects.

Operating Procedures – Start Up…We Must

• Include Sections such as:• Objectives• Purpose• Concerns• Procedures• Department• Operator• Equipment Involved• Location• Related Documents

Let’s Look at An Example…

APR’s aren’t MagicPosted on October 14, 2016 by Brian Chapin

• It is believed the oil drain valve was initially clogged as the employee opened it a full three turns before any ammonia came out. When liquid exited the valve and struck the employee he fell face first on concrete in hallway. “Convulsions” were observed by other employees and the operator was unable to self-rescue due to lung spasms. The other employees had no access to PPE and could not assist the victim.

Stopping Normalization of Deviance:

A Safety ProgramAstronaut Mike Mullane

Operating Procedures• Must be Developed for Each Equipment Operation

in the Covered Process• Refer to Block Diagrams• Refer to P&ID• Must Cover Normal Operating Conditions, Normal

Operating Parameters, i.e.. Pressure/Flow/Current/ etc.

• Must Follow Procedures & Recommendations in PHA’s• Must Follow Form

Operating Procedures • For Shut-down Procedures…Remember:

• Most operations must be shut down in a specific order!• Failure to follow these shut down procedures could results in a catastrophic

release or system failure

Ammonia Plant Explosion Caused by Improper Shut-down of Engine Room

Operating Procedures – Hazards of the Process

• Operating Procedures Must Identify the Hazards of the Process in All Phases:

• Start Up• Normal Operating

Conditions• Temporary Operating

Condition• Emergency Shut-down• Start-up following an

Emergency Shut-down

Operating Procedures – Hazards of the Process

• Operating Procedures Must Identify the Operating Limits:

• Upper• Lower• Normal Operating Range

Now That We’ve Completed the

Operating ProceduresWe Must Develop Safety Work Practices, Programs &

Procedures for Covered Processes

Safe Work Practices1910.119(f)(4)

• Develop and implement safe work practices* to provide for the control

of hazards during operations such as: – Lockout/tagout;

– Confined space entry;

– Linebreak - Line Opening process equipment or piping;

– Control over entrance into a facility by maintenance, contractor, or other support personnel

Safe Work Practices

*These safe work practices apply to contractor employees as well

Safe Work Practices

Safe Work Practices, Programs & Procedures must: Be specific to the Covered Process Follow Procedures & Recommendations in the

PHA’s Follow Procedures in the Operating Procedures Must be Able to be Tracked Follow Form

Safe Work Practices

• Lockout Tagout - One of the Most Important Procedures in PSM• Must be Written Carefully & Follow all Procedures (PHA’s, Operating

Procedures)• Must be Followed to the Letter!

Safe Work Practices

• Lockout/Tagout in PSM• Why not Use Digital

Imaging in Your Procedures to Identify Critical Lockout /Tagout Positions

Safe Work Practices• Line Opening Permits

• Identify Procedures for Opening any Process Line in a Covered Process

• Must Include Hazards of the Line Opening

• PPE Required

Safe Work PracticesLine & Equipment Opening

A Hazard Review Must Be Completed for All Line/Equipment Hazards Including:

HAZARDOUS MATERIALS IN SYSTEM POTENTIAL PHYSICAL HAZARDS BARRICADING AS REQUIRED FIRST AID IF EXPOSED LOCATION OF SAFETY EQUIPMENT PPE REQUIRED FOR LINE OPENING

Safe Work Practices-Hot Work

A Program Must be Developed for the Covered Process That Requires:• A Hot Work Permit be Issued for ALL Hot Work Performed in the Plant by

Employees or Contractors• A Permit must be Posted at the Location of the Hot Work• A Fire Watch Is Required• A Fire Extinguisher or Other Appropriate Fire Fighting Equipment Must Be

Present, Fire Watch must be Trained in its use

Safe Work Practices

• Must be Specific for the Covered Process• May Require Additional Program other than Lockout Tagout, Line

Opening & Hot Work…such as Confined Space, Electrical Safe Work Practices, Combustible Dust

Now That We’ve Developed Safe Work

PracticesWe Have to Train

Training1910.119(g)

PSM 29CFR1910.119(g) Requires

(G) Training (Initial, Refresher, and Documentation) (paragraphs (g)(1), (g)(2), and (g)(3)).

• Paragraph (g)(1) requires employers to train employees operating dangerous process. Paragraph (g)(2) requires that the employer provide refresher training at least every three years. Paragraph (g)(3) requires the employer to prepare a record that contains the name of employee, the date of training, and the means used to verify that the employee understood the training

PSM Training• PSM Training Programs Must be Developed for:

• Affected Employees - Those not Directly Involved in the Process Operation• Authorized Employees - Those Directly Involved in the Process Operation• Contractors Who May Perform Work on a Covered Process• Vendors/Visitors who May Visit the Facility and May Potentially be Exposed to

the Covered Process

PSM Training• Training Must Be Performed as Follows:• Initial training

• Prior to work assignment• Waved for those already in a process

• Refresher training• Every three years

• All Training Must be Documented

PSM Training• Training Subjects Must Include at Least:

• Lockout Tagout• Hot Work• Line & Equipment Opening• Confined Space (if applicable)• Emergency Response

Examples of Training PSM training example including the means used to verify that the employee understood the training.

Let’s Use Hot Work Procedures

Safe Work Practices

Hot Work Program

EXAMPLES OF HOT WORK

Safe Work Practices Hot Work Burning, Welding, Grinding, Drilling, Cutting

Our Program Requires A Hot Work Permit be Issued for ALL Hot work

Performed in the Plant by Employees or Contractors

Permit must be Posted at the Location of the Hot Work

Fire Watch Is Required Fire Extinguisher Must Be Present, Fire Watch

must be Trained in its use

Safe Work PracticesHOT WORK

PERMIT MUST BE COMPLETED PRIOR TO BEGINNING WORK INVOLVIING ANY HOT WORK

PERMIT SHALL BE DISPLAYED AT THE LOCATION OF THE ACTUAL HOT WORK OPERATION

VERIFICATION OF UNDERSTANDING WORKSHEETHOT WORK

CIRCLE THE CORRECT ANSWER

1. A HOT WORK permit must be obtained prior to beginning HOT work by employees and contractors before beginning a job.

TRUE

2. A HOT WORK permit is not necessary if just drilling and grinding is being done on a job. FALSE

3. Contractors are not required to obtain HOT WORK permits. FALSE

4. The employee or contractor will obtain a HOT WORK permit from his supervisor and must determine if conditions are safe and have a fire watch if necessary.

TRUE

5. HOT WORK is permitted in explosive atmospheres, around hazardous tanks and equipment. FALSE

6. The following protective measures can be used: damp sand on floors, protective shields, or fire resistant coverings while Hot Work is taking place.

TRUE

7. 35 feet is a good safe distance for covered combustibles to be away from HOT WORK.

TRUE

8. Fully charged and operable fire extinguishers and/or hose lines shall be available and ready.

TRUE

9. The HOT WORK permit emergency information shall be posted at the job site.

TRUE

10. The fire watch does not have to be trained in fire extinguishing and is not responsible for sounding an alarm in the event of a fire.

FALSE

PSM Operating Procedures Summary

• You Must Develop and implement written operating procedures consistent with the process safety information and addresses at least the following elements:

• Initial start-up, normal and temporary operations

• Normal and emergency shut-down procedures

• Operating limits and consequences of deviation

• Hazards presented by the process

PSM Safe Work PracticesSummary

• Safe Work Practices, Programs & Procedures must:• Be specific to the Covered Process(s)• Follow Procedures & Recommendations in the PHA’s• Follow Procedures in the Operating Procedures• Must be Able to be Tracked• Follow Form

PSM Training Summary• PSM Training Programs Must be Developed for All Necessary Workers

and Contractors• Verification of Understanding is Required• Training Must Be Performed as Follows:• Initial training

• Prior to work assignment

• Refresher training• Every three years

• All Training Must be Documented

I will Survive!

Or

Will I Survive?

Questions?