Lesson 2 Contractors, Mechanical Integrity, Management of Chain, And Emergency Planning

7/26/2019 Lesson 2 Contractors, Mechanical Integrity, Management of Chain, And Emergency Planning

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ontractors

pplication

here are diferent categories o contract labor. This includes

ose with specialized knowledge or skills who are hired to

perate the acility or perorm a particular aspect o a job, thos

ho are hired or a short time period to perorm turnaround

perations or maintenance, and those who provide incidental

ervice, such as janitorial, ood, or laundry services. PS providpecial provisions or contractors and all o their employees,

mphasizing the importance o protecting those employees wh

ay work or another employer. !owever, PS standards need

ot speci"cally apply to contractors providing incidental service

hose work does not in#uence process saety

xemption

S does not apply to contractors providing minor services tha

o not afect process saety, such as janitorial, ood and drink,

undry, delivery, or other supply services. $t only applies to

ontractors perorming maintenance or repair, turnaround, maj

novation, or specialty work on or adjacent to a covered proce


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mployer Responsibilities

hen selecting a contractor the employer operating the acilityhich PS applies is re&uired to obtain and evaluate inormatio

garding the prospective contract employer's saety

erormance and programs. $t is the operating employer's

sponsibility to(

$norm the contract employers about potential "re, e)plosio

or to)ic release hazards related to the contractors work or

process.

*)plain the provisions o the emergency action plan to the

contract employer.

+evelop and implement sae work practices to control the

presence, entrance, and e)it o contract employers and

contract employees in covered process areas. Periodically evaluate the perormance o contract employer

in ul"lling their obligations.

aintain a contract employee injury and illness log related

the contractor's work in the process areas.


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ontract Employer Responsibilitieshe contract employer must(

ssure that contract employees are trained in the work

practices necessary to perorm their job saely.

ssure that contract employees are instructed in the known

potential "re, e)plosion, or to)ic release hazards related to

their job and the process, and in the applicable provisions o

the emergency action plan.

+ocument that each contract employee has individually

received and understood the training re&uired under the

standard by preparing a record that contains the identity o

the contract employee, the date o training, and the means

used to veriy that the employee understood the training

ssure that each contract employee ollows the saety rule

o the acility, including the sae work practices re&uired in

the operating procedures section o the standard.

dvise the operating employer o any uni&ue hazards

presented by or ound during the contract employer's work


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re-Startup Safety Review

is mandatory that a saety review take place beore the

troduction o any highly hazardous chemical into the process

he PS re&uires the employer to perorm a saety review or

ew acilities and or modi"ed acilities. -eore the introduction

highly hazardous chemical to a process, the prestartup saetview must con"rm the ollowing(

/onstruction and e&uipment are in accordance with design

speci"cations.

Saety, operating, maintenance, and emergency procedure

are in place and are ade&uate.

process hazard analysis has been perormed or newacilities and recommendations have been resolved or

implemented beore startup, and modi"ed acilities meet th

management o change re&uirements which are delineated

this section ollowing !ot %ork Permits.

Training o each employee involved in operating a process

has been completed.


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Mechanical Integrity

S! believes that the mechanical integrity o the critical

rocess e&uipment is assured through proper installation,

esign, and operation. PS mechanical integrity re&uirementspply to the ollowing e&uipment(

Pressure vessels and storage tanks

Piping systems 1including piping components such as

valves2

3elie and vent systems and devices *mergency shutdown systems

/ontrols 1including monitoring devices and sensors, alarms

and interlocks2

Pumps

o maintain the ongoing integrity o the process e&uipment, the

perating employer must establish and implement written

rocedures. *mployees responsible or maintaining the integrit

process e&uipment should be trained in an overview o the


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rocess and the procedures applicable to the employee's job

sks

mployees must be well aware o the hazards involved

oo! Engineering Practices

ocedures that ollow recognized and accepted good

ngineering practices should be used or the inspection and

sting o process e&uipment. $nspections and tests must beheduled in accordance with the manuacturer's

commendations, good engineering practices, and prior

perating e)perience. *ach test and inspection must be

ocumented. The documentation should include(

The date on which the inspection or test was conducted

The inspector's or tester's name

The serial number or any other identi"er o the e&uipment

on which the inspection or test was conducted

description o the inspection or test

The results o the inspection or test

"uipment #e$ciencies

&uipment de"ciencies outside the acceptable limits de"ned by

e process saety inormation must be corrected beore urthe


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se. s long as the de"ciencies are corrected in a sae and

mely manner, they may not necessarily need to be corrected

eore urther use so long as other su4cient, necessary saety

easures are in place.

hen constructing new plants and e&uipment, the operating

mployer must assure that the e&uipment as it is abricated is

uitable or the desired process. /hecks and inspections must

e perormed to assure proper installation and consistency with

oth design speci"cations and manuacturer's instructions

he suitability o maintenance material, spare parts, and the

&uipment or which they will be used must be ensured by the

mployer.

ot &or' Permit

ot work permits are essential or hot work operationsonducted on or near a covered process. -eore starting hot

ork operations, the implementation o "re prevention and

rotection re&uirements must be documented on the hot work

ermit. The date1s2 authorized or hot work and the object on

hich the hot work is to be perormed must also be included on

e permit and the permit must be kept on "le until hot work is

ompleted

ase Stu!y


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n Explosion an! (ire Erupte! in the Storage )an's

a product re"nery, newly hired and old workers were perorming the

gular tasks. 5o warning signs or symbols were present on the highly

zardous chemicals storage tanks. Two workers who recently hadned the re"nery were welding pipes near the storage tanks. n

)plosion and "re erupted in storage tanks containing #ammable

ydrocarbons and wastewater.

ree workers were killed on the spot and seven were wounded

riously. Three workers died later as a result o their injuries

easons

%arning signs6labels were not present on the tanks' storage area.

%orkers did not know that tanks contained hazardous materials.

0ther workers did not tell them 1the victims2 not to weld in the

hazardous chemical storage area, which is severe negligence.

The workers were new and had not received any saety training or

education

anagement of Change

here is nothing permanent e)cept change7 thereore, written

rocedures to manage changes, e)cept or 8replacements innd8 1e.g., replacement o deective e&uipment with same

)act type which does not afect the operation or saety o the

rocess2 to process chemicals, e&uipment, and technology, or

ny other changes that could afect a covered process, must be


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stablished and implemented

hese written proce!ures must assure that the followingonsi!erations are a!!resse! prior to any change*

The technical basis or the proposed change

$mpact o the change on employee saety and health

odi"cations to operating procedures

5ecessary time period or the change uthorization re&uirements or the proposed change

hose employees who are involved in an operating process, or

ose whose tasks will be afected by a change in the process,

eed to be inormed and trained beore implementing any

hange in the process. $n addition, process saety inormation

nd operating procedures or practices must be updated inccordance with the process change and 0S! re&uirements

mergency Planning an! Response

mergency preplanning and training are vital to avoid

atastrophes in a workplace7 they enable employees to e)ecute

roper actions in case o emergencies. n emergency actionan must be developed and implemented in accordance with

e 0S! standards or the entire plant. 9urthermore, the

mergency action plan must include the procedure o handling


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mall releases o hazardous chemicals

nci!ent Investigationcident investigation standards re&uire the employer to

vestigate as soon as possible 1but no later than :; hours

ter2 incidents that did result or could have resulted in

atastrophic releases o covered chemicals. The investigation

am must include at least one person who is knowledgeable in

e process 1including a contract employee, i appropriate2 to

vestigate, analyze, and develop a written report on the

cident

n investigation report must inclu!e the following

oints* +ate o incident

+ate investigation began

+escription o the incident

9actors that contributed to the incident

3ecommendations resulting rom the investigation

mployers must address and document their responses to

port "ndings and recommendations and review "ndings with

fected employees and contractor employees


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eports must be retaine! for $ve years

ompliance Au!itorder to assess whether process saety management

andards are ade&uate and being ollowed, employers must

ertiy at least every three years that they have careully

pplied all the applicable provisions o the PS standards. The

ompliance audit must be conducted by at least one person

th knowledge o the process and standards re&uirement.

urthermore, it is auditor's responsibility to prepare a report

ased on the "ndings, noting any de"ciencies, and the

mployer's responsibility to determine and document any

sponses to the "ndings and to document any de"ciencies tha

ave been recti"ed.3emember< The last two compliance audit

ports must be kept on record

ra!e Secrets

is important that employers provi!e all

nformation necessary for compliance to the

ersons responsible for*

/ompiling the process saety inormation

+eveloping the operating procedures +eveloping the process hazard analysis

Perorming incident investigations


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*mergency planning and response

/ompliance audits

mployers must provide all the inormation without regard toossible trade secret status o such inormation. !owever, they

ay re&uire employees to sign con"dentiality agreements to

rotect those trade secrets

Summary

order to assess whether process saety management

andards are ade&uate and being ollowed, employers must

ertiy at least every three years that they have careully

pplied all the applicable provisions o the PS standards. The

ompliance audit must be conducted by at least one person

th knowledge o the process and standards re&uirement.

urthermore, it is the auditor's responsibility to prepare a reporased on the "ndings, noting any de"ciencies, and the

mployer's responsibility to determine and document any

sponses to the "ndings and any de"ciencies that have been

cti"ed. -ear in mind that PS only applies to contractors

erorming maintenance or repair, turnaround, major

novation, or specialty work on or adjacent to a covered

rocess


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Lesson 2 Contractors, Mechanical Integrity, Management of Chain, And Emergency Planning

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Transcript of Lesson 2 Contractors, Mechanical Integrity, Management of Chain, And Emergency Planning