The purpose of Process Safety Management (PSM) is to prevent or minimize the consequences of a catastrophic release of flammable, explosive, reactive or toxic chemicals. Refineries and many other facilities are subject to PSM for one or more processes.
Where contractors will work on or adjacent to a PSM covered process, contractor training is part of the facilities’ PSM compliance requirements. Specifically, contractor employees must be trained in work practices and informed of the known or potential fire, explosion or toxic release hazards, along with applicable portions of the facilities’ Emergency Action Plan. Receiving and understanding this training must be documented. The contractor must then make sure their employees follow the required safe work practices and are trained in the specific work practices needed to conduct their work. Also, the contractor must inform the facility of any unique hazards associated with the contractor’s work at the facility.
Host facility responsibilities
In order for contract employers (contractors) to provide the appropriate training for their employees, facilities must inform contractors of the known potential fire, explosion or toxic release hazards related to the contractor’s work and the process; explain to contractors the applicable provisions of the facility emergency action plan; and develop and implement safe work practices to control the presence, entrance and exit of contractors and contract employees in PSM covered process areas.
Host facilities can facilitate the transfer of information to contractors by providing copies of their pertinent safety policies and procedures, safe work practices, emergency procedures and PSM program.
Contractor strategies for preparing employees for PSM work
To more effectively train employees for working on or near a PSM process, a contractor can provide general PSM training prior to mobilizing to a customer’s facility. This greatly enhances the comprehension and retention of facility-specific orientation training on the PSM procedures in place at the facility.
Contractors should prepare a site-specific health and safety plan for the protection of their employees. This plan can incorporate the various facility PSM elements, such as evacuation signals and muster points, entrance and exit points, location of PSM processes, safe work practices, and a hazard assessment for the work to be conducted.
If a contractor already has strong safe work practices, uses standard operating procedures and has a robust health and safety training program, then their employees will have a good foundation of competency and an appreciation of the importance of the PSM program.
A health and safety professional can review facility documents and determine if there are differences from the contractor’s documents. Employees can then be trained on the different or additional facility program requirements prior to arrival at the facility.
Contractor PSM preparation should focus on training employees on the storage and handling of hazardous chemicals, hot work program, general work permit program, lockout/tagout, line breaking and standard operating procedures. Generally, the contractor will already have experience working with these programs and will have their own written policies and procedures for some, if not all, of these safe work practices.
The additional training emphasis for storage and handling of flammable and combustible liquids can include proper liquid transfer practices and grounding and bonding.
For hot work, employees should be trained, not only to the elements included in the OSHA standard but also various means and methods to control work conditions to minimize the hazards of hot work. This will tie into a facility general work permit system to identify any possible ignition sources associated with the contractor work.
Lockout/tagout training should include discussion of all potential energy sources and means to control those energy sources. Lockout/tagout training needs to include discussion of isolating storage tanks that have practices and controls that are not typically covered in a general lockout/tagout training program.
Line breaks, similar to tank isolation, have particular hazards and the need to coordinate with facility operations. Training should emphasize the coordination with operations and planning for the safe management of line contents.
Training for the preparation and use of a Job Safety Hazard Analysis (JSHA) provides critical task information to employees and helps prepare employees for working with facility general work permits. Since general work permits vary from facility to facility, the JSHA can help provide continuity for contractor employees whose work assignments rotate among facilities.
Site orientation training will include discussions of PSM processes and the facility practices related to PSM. With the pre-mobilization training, contractor employees should be able to recognize and retain information that is applicable to the specific work activities they will be performing.
Contractor supervisors and management can use the site orientation information to further refine a site-specific health and safety plan, safe work practices and standard operating procedures for conducting the work.
Ongoing reinforcement of skills and practices
The general work permit program, along with the JSHA, provides a strong daily foundation for conducting work safely. When identified, a confined space entry permit and/or hot work permit are also used to highlight the particular hazardous conditions associated with these confined spaces or hot work.
Regular informal and formal reviews and audits can identify areas for potential improvement to processes, practices and documentation. Where appropriate, these can add to current and future PSM training.
Routine annual training, such as an eight hour Hazardous Waste Operations and Emergency Response (HAZWOPER) update, can be weighted toward PSM safe work practices.
Protecting employees together
Contractors’ employees can arrive at a PSM facility with the tools and knowledge necessary to readily integrate into the facility PSM program upon receiving the site-specific orientation and training. The site-specific aspects are further reinforced through general work permits, JSHAs, daily safety tailgate meetings, participating in facility safety meetings, and conducting periodic safety stand-downs with intensive reviews of areas of interest. Together, these help meet a goal of everyone, facility and contractor employees alike, leaving at the end of the day in at least as good a condition as when they arrived.
For more information, contact STC EH&S Director John Kinsey at (803) 840-5331 or Industrial Hygienist Dave Comen at (864) 934-1243, or visit www.stcindustrial.com.