In 1992, the Process Safety Management (PSM) Program was born. It's now been 28 years since the industry implemented the basic 14 PSM elements for maintaining a safe environment. Every element is important in its own regard and each is unique.
Since the initiation of PSM, facilities have developed programs to check all the boxes for a "good" PSM program, but many have since failed to stay in compliance. In a well-run organization, one key element that will keep the program current and in compliance is management of change (MOC). I often refer to this as the "management of compliance." No matter how well a facility's program is set up, if changes are not managed effectively, compliance will remain out of reach.
OSHA provided a great summary in "Appendix C to 1910.119 -- Compliance Guidelines and Recommendations for Process Safety Management (Nonmandatory)." Employers may wish to develop a form or clearance sheet to facilitate processing changes through the MOC procedures. A typical change form may include a description and purpose of the change; the technical basis for the change; safety and health considerations; documentation of changes for the operating and maintenance procedures, inspection and testing; P&IDs; electrical classification; training and communications; pre-startup inspection; duration; and approvals and authorizations.
Although Appendix C is nonmandatory, it provides a framework for understanding how important MOC truly is. In just one sentence, it references six different elements MOC can impact -- areas for potential deviations from the program if the element is not designed and maintained rigorously. Although MOC software provides a very structured and modernized method to initiate and track MOCs to completion, it can lead to a lack of communication.
Consider an MOC to install a 2-inch bypass line with a block valve around a control valve and all the potential elements affected by it:
- Process hazard analysis (PHA): The standard asks about the "impact of change on safety and health." The risk of the addition of the bypass line to the existing process must be evaluated. Regardless of the procedure used, the risks associated with the change must be reviewed and documented. Face-to-face discussions can be especially important to understand and evaluate the impact and potential risk.
- Operating procedures: Any change made to a process must be included in the operating procedures. This requires a review of all procedures, as the function of the new bypass line could impact each of the different operating phases: normal, shutdown, emergency and startup after emergency. Each procedure may need to be modified.
- Training: The standard requires that if changes are made to the operating procedures, all affected personnel must receive training on the new system. A modification to a procedure that doesn't highlight the change through training may be overlooked and not fully understood by operations personnel.
- Mechanical integrity (MI): Adding a new line and valve requires these elements to be added to the existing MI program to fulfill testing requirements. It is important to ensure the correct piping and valve are installed and comply with company equipment standards.
- Pre-startup safety review (PSSR): The addition of new pipe and valve requires a PSSR to be completed with all equipment in place prior to startup. PSSRs are often overlooked, but the PSM standard mandates that everything associated with the addition of a bypass is reconfirmed prior to startup, including verification of design, materials, installation, procedures and training. Another cautionary reminder on MOC software that incorporates PSSR generation is that it is best practice to maintain a paper copy of the PSSR. The requirement is that you must confirm multiple items, and the best way to ensure compliance is to physically check items off a list.
- Contractors: PSM requirements include making contractors aware of any PSM areas they are working in and associated hazards. If the installation of the bypass valve takes place in a PSM facility, any contractors involved would need to be informed.
- Process safety information (PSI): The bypass addition requires P&IDs to be revised, including changes required to safety systems as a result of a PHA study. Further, the addition of a bypass valve may impact downstream relief systems, so the relief systems may need to be reevaluated and the associated PSI documentation updated.
Including the MOC element, the addition of a 2-inch bypass line and valve potentially affects eight PSM elements. This emphasizes how important the MOC process is and how robust an in-place system must be to stay in compliance. MOC software can be a blessing and a curse. Removing the human element greatly improves tracking and monitoring, but it can lead to a lack of communication. Face-to-face communication is the best approach for ensuring everything in the MOC is completed.
For more information, visit www.smithburgess.com or call (713) 802-2647.