SOUTHWESTERN ELECTRICAL CO., INC.
NOVEMBER, 2008
FROM: MANAGER
TO: ALL EMPLOYEES
SUBJECT: PROCESS SAFETY MANAGEMENT
INTRODUCTION:
Process Safety Management (PSM) is intended to protect workers, the public, and plants by managing and controlling the hazards associated with the process of highly hazardous chemicals.
The standard mainly applies to manufacturing industries particularly, those pertaining to chemicals, transportation equipment and fabricated metal products. It also includes natural gas liquids, farm product warehousing, electric, gas, sanitary service, and wholesale trade.
PSM has a direct effect on the maintenance of all the equipment used in these processes. This includes the pipe lines that carry the products.
A process safety management program consists of 14 elements. These elements address the management of the program.
ELEMENTS:
1. Employee participation
2. Process safety information
3. Process hazards analysis
4. Operating procedures
5. Training
6. Contractors
7. Prestartup review
8. Mechanical integrity
9. Hot work permits
10. Management of change
11. Incident investigation
12. Emergency planning and response
13. A compliance audit
14. Trade secrets
(1) Employee participation This element requires a written action plan for involving employees in all PSM activities.
(2) Process safety information This element requires that certain information about a process be assembled and communicated to personnel. Process safety information includes system diagrams, safe operating limits, and equipment information.
(3) Process hazards analysis is a systematic approach used to identify, evaluate, and control the hazards in a process. Process hazards analysis (PHA) can help determine where problems may occur in a process, so that corrective action can be taken to make a safer operation.
(4) Operating procedures operating procedures must be written for all processes, this includes startup, normal operation, normal shutdown and emergency shutdown. These procedures must be communicated to all employees.
(5) Training the training program must develop the knowledge, skills, and attitudes for working safely, and it must include an overview of the process, its potential hazards, relevant operating procedures and safe work practices. This element also requires initial training and periodic refresher training.
(6) Contractors this element involves the training of contractors
(7) Prestartup review is a review of key safety considerations and operator training that is done before a new process is started up. A prestartup review is also required for modified processes that require a change in plant design or process safety information.
(8) Mechanical integrity, ensures the ongoing integrity of process equipment. This element requires testing and inspections to eliminate leaks that could cause the release of dangerous materials, and potential sources of ignition that could lead to fires or explosions. It also helps to ensure that equipment is designed, installed, maintained, and operated properly.
(9) Hot work permits requires the use of hot work permits to certify that hot work, such as welding can be done safely.
(10) Management of change ensures that changes to process chemicals, echnology, equipment, and facilities are analyzed for their impact on health and safety. The analysis of such changes can then be used to determine necessary modifications to safety information, procedures, and training.
(11) Incident investigation requires the investigation of every incident that results in or could have resulted in a catastrophic release. An investigation is necessary to identify the cause of the incident and provide the basis for taking corrective actions.
(12) Emergency planning and response requires a facility to establish and implement an emergency action plan to deal with a release of highly hazardous chemicals. Operators and other personnel should know exactly what to do to minimize the consequences of an emergency.
(13) Compliance audit helps to ensure that an effective process safety management system is in place and is working. The compliance audit provides a systematic way of verifying compliance with a process safety management program and identifying problems. Employers are required to respond to the audit findings in a timely manner.
(14) Trade secrets requires access to all necessary information for completing the other thirteen elements of the standard without regard to trade secret status.
All elements are equally important, but some require more time than others. All elements must be met to meet the requirements of the PSM program.
CONTRACTORS (6)
Contractors and their employees must be informed about the hazards associated with any process that they are working on or near. They must also be properly trained to do their job safely and according to the plant's safety regulations. Contractor employees must also be familiar with the plant's emergency plan, so that they will know whom to contact and where to go if an emergency occurs. The employer is responsible for providing this information and for keeping a contract employee injury and illness log.
SOUTHWESTERN ELECTRICAL CO., INC. responsibilities:
1. Is responsible for the safety and health of its employees at the jobsite. SOUTHWESTERN ELECTRICAL CO., INC. (jobsite foreman) will thoroughly familiarize himself with the Client’s operations at the jobsite, including operations which may pose a personnel hazard. The jobsite foreman will also thoroughly familiarize himself with the Client’s safety policies and with the Client’s alarm system at the jobsite. The foreman will be responsible for conducting a thorough examination of the jobsite prior to performing work. The foreman will complete the JOB SITE SAFETY INSPECTION FORM. The jobsite must be safe for the proposed work before commencing operations.
2. The foreman will advise the Client representative of any unique hazards presented by the contract employee's work, or any hazards found by the employee's work.
3. Will provide the necessary protective equipment for its employees to complete the job in a safe manner. Fire retardant clothing will be provided to employees as required. Example of this would be working on equipment containing hydrocarbons, or hot tapping.
4. Is responsible for providing emergency medical and first aid care for its employees and for followup care which may be necessary.
5. Will furnish the Client representative full reports of any accidents involving persons or property on a Company jobsite. A "Near Miss" will be reported an investigation will be done. The Client will be given a copy of a "Near Miss" report. A "Near Miss" is any incident that could have caused serious injury or significant property damage as an accident.
6. The foreman will promptly report any fires on the Client’s property to the Client representative.
7. Will conduct safety meetings at appropriate intervals to assure it employees are fully informed of potential hazards. "Tail Gate" safety meeting will be conducted any time there is a change in the work assignment or a new hazard is present.
8. Will ensure that its employees receive appropriate safety training regarding the potential hazards of the job prior to commencement of work on a Clients=s jobsite. This training will be documented on an Attendance Roster and filed at the office (SOUTHWESTERN ELECTRICAL CO., INC.)
9. Will supply and be responsible for the condition and suitability of all equipment and tools necessary to perform the work. The foreman is responsible for conducting an audit of all tools and equipment prior to starting a job.
10. Will furnish only employees who are fit and physically and mentally qualified to perform the work. Employees who have not had sufficient sleep, are unusually fatigued, or under the influence or impaired by the use of alcohol, drugs or medicine are not considered to be fit.
11. Will provide its employees with energy lockout devices, i.e. lock to isolate all energy sources to protect them from injury while working in, on or around equipment during repair or maintenance due to an unexpected startup or energization. SOUTHWESTERN ELECTRICAL CO., INC. will follow the Client’s LOCKOUT/TAGOUT procedure.
12. Will ensure that each of its employees has the ability to read and understand, hear and understand, speak and be understood in English, as well as to write one's name in English when assigned to "safety sensitive" work. Any NonEnglish speak person will not be assigned to a "safety sensitive" job.
13. Will comply with local, state and federal occupational safety and health regulations and maintain required records.
14. Meet federal and state occupational safety and health first aid requirements. We will have sufficient number of trained first aiders at each job and adequate first aid supplies. The jobsite foreman is responsible for ensuring these requirements are met.
15. The foreman is responsible for obtaining HOT WORK PERMITS from the relevant Client’s personnel when using portable electric driven tools, welding, sand blasting, opening electrical enclosures, etc., in an operating area or using any other equipment that might be a source of ignition for combustible mixtures. This equipment shall be immediately shutdown in an emergency or when requested by a Client’s representative.
16. The foreman is responsible for obtaining a NonPermitted Confined Space Entry Permit prior to entering a confined space.
17. The foreman is responsible for obtaining any and all work permits that may be required for each job.
18. Furnish a trained employee, with fire extinguishers in the work area for certain work as required on a HOT WORK PERMIT, and remain on duty 30 minuets after the hot work is completed. This employee must know how to sound the alarm in the event there is an emergency.
19. The foreman is responsible for fire prevention in the work area.
20. Permit smoking only in designated areas.
21. Operate vehicles and other mobile equipment within the posted speed limits and only in areas necessary to perform work.
22. Unattended vehicles will not be left running at any time.
23. The foreman will ensure that employees practice safe and orderly housekeeping in the work areas at all times.
24. Establish ropeoff areas for excavations and overhead work and erect safety and caution signs in cooperation with Client’s personnel and as deemed prudent.
25. Furnish personal protective equipment (PPE) for its employees, this includes hearing protection in designated areas, hard hats and safety glasses with side shields on Client’s facilities. Some jobs may require additional PPE i.e., goggles, face shields, gloves, etc.
26. Prohibit the possession of cameras, weapons or explosives on Client’s facilities.
27. Train personnel to understand and comply with emergency alarms and emergency procedures. It is particularly important to understand the importance and necessity of shutting down all sources of ignition and leaving the area immediately when an emergency alarm is sounded.
28. Will train personnel to be aware of the hazards, characteristics and safety precautions associated with hydrogen sulfide gas prior to beginning work at a Client’s facility containing hydrogen sulfide. This training will be done annually and documented.
29. Provide personnel with appropriate respiratory equipment when performing work at a Client’s facility containing hydrogen sulfide which could possibly release gas into the breathing zone of the workers. Provide training and on the donning and duffing of this respiratory protective equipment.
30. Require personnel to be clean shaven in the area of the faceto respirator seal prior to entering a Client’s facility that is designated as a respirator user facility.
31. Ensure that employees are confined to their assigned areas and prohibit loitering or wandering into operating areas beyond the boundary of their work assignment.
32. Southwestern Electrical Co., Inc.’s safe work practices must be followed during operation such as lockout/tagout, confined space entry, opening process equipment or piping and control over entrance to facility.
EMERGENCY GUIDELINES
The following guidelines are provided in the event on an emergency on a Client’s facility. Employees will be instructed on the hazards related to their jobs and potential fire, explosive or toxic release hazards. The purpose of PSM is to prevent or minimize the consequence of releases of toxic, reactive, flammable or explosive chemicals.
FIRE EMERGENCIES
1. If the attempt would not jeopardize personal safety, trained employees should attempt to extinguish a fire in their work area during the incipient stages.
2. If the fire is too large or if attempts at extinguishing fail, employees should warn others in the area and evacuate the danger area to an upwind position and assemble for headcount. If no place of safe refuge has been identified by the Client, then the foreman will designate a place and take a headcount of the employees. The foreman at the job site will have a roster of SOUTHWESTERN ELECTRICAL CO., INC. employees. The office will also have a roster of all employees that are assigned to a job site. The dispatcher will be informed in the event of an emergency that requires employees to evacuate an area.
3. Immediately notify the Client representative of the situation.
NOTE: SOUTHWESTERN ELECTRICAL CO., INC. employees will not be expected to perform duties relating directly to controlling a fire but may be called upon to provide support services (hauling equipment, assisting injured personnel, etc.).
MAJOR GAS RELEASES:
1. Upon notification of a major release of flammable vapors, employees will shut down all sources of ignition under their control.
2. All employees should immediately evacuate the danger area to an upwind position and assemble. The assemble point (place of safe refuge) should be far enough from the source release to remain safe should the vapors ignite.
3. The foreman must immediately notify the Client representative of the situation.
4. Continue monitoring the wind direction and stay upwind at all times. All gas releases shall be assumed to contain toxic gas.
5. Do not reenter the danger zone until the emergency is under control and the Company representative provides clearance to re-enter.
EMPLOYEE RESPONSIBILITIES:
SOUTHWESTERN ELECTRICAL CO., INC. employees are expected to follow all safety rules. Employees are expected to maintain all equipment including all personal protective equipment in a safe and sanitary condition. All accidents and near misses will be reported to the foreman as soon as possible.
SOUTHWESTERN ELECTRICAL CO., INC. manager will ensure that all the requirements of the PSM program is followed and assign responsibilities to supervisors, foreman and others as needed. Our employees will be trained as required and employees are required to attend all training sessions. Special skills, such and welders, crane operators, and electricians will be tested or will have the proper certification.
Employees must respect the confidentiality of any "TRADE SECRET” information from
the release of process safety information to them.
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SWECO POLICY#__25__11/2008