Course Material 1.Overview of Process Safety 2.Compliance with Standards 3.Process Hazard Analysis 4.Standard Operating Procedures 5.Safe Work Procedures 6.Mechanical Integrity 7.Management of Change 8.Auditing Process Safety Systems 9.Emergency Response Procedures

8. Auditing Process Safety Management Systems Process Safety Management for Biofuels This material was produced under grant SH F-36 from the Occupational Safety and Health Administration, U.S. Department of Labor. It does not necessarily reflect the views or policies of the U.S. Department of Labor, nor does mention of trade names, commercial products, or organizations imply endorsement by the U.S. Government. 29 CFR (o)

Explosion at Esso Longford Plant September 25, 1998

Longford, Australia Explosion Cost of Industry Disruptions A$ 1,300,000,000 Ref.: (Royal Commission 1999, International Petroleum Encyclopedia 1999)

Longford, Australia Explosion Corporate PSM Audit

Longford, Australia Explosion PSM Deficiencies 1. Risk identification 2. Training 3. Operating Procedures 4. PSM documentation 5. Communications

Definition 1.PSM Systems Audit 2.PSM Process Audit Reference: Guidelines for Risk Based Process Safety, 2007, CCPS/AIChE, p.600

Audit Benefits 1.Verify procedures 2.Determine improvements 3.Measure effectiveness 4.Enhance safety awareness Reference: Guidelines for Process Safety Documentation, 1995, CCPS/AIChE, p.245

1. Assemble an audit team Familiar with the process to be audited Experienced in PSM

Audit team composition Team leader – Independent Subject matter experts (SMEs)

Audit team composition Area supervisor of the area being audited Lead operator of the area being audited Reference: Plant Guidelines for Technical Management of Chemical Process Safety, Revised Edition, 1992, CCPS/AIChE

2. Determine the audit timing and scope 1. Employee Participation 2. Process Safety Information 3. Process Hazard Analyses 4. Operating Procedures 5. Training 6. Contractors 7. Safe work procedures

OSHA PSM Elements 8. Mechanical Integrity 9. Hot work permit 10. Management of Change 11. Incident Investigation 12. Emergency Response 13. Compliance auditing 14. Trade Secrets

OSHA PSM Website 29CFR Part Number: 1910 Part Title: Occupational Safety and Health Standards Subpart:H Subpart Title:Hazardous Materials Standard Number: Title:Process safety management of highly hazardous chemicalsProcess safety management Appendix:A, B, C, D

PSM Audit Guidance Appendix C to § Compliance Guidelines and Recommendations for Process Safety Management (Nonmandatory)

3. Written Audit Protocol Audit Protocol Audit Checklist

Prepare for the audit Audit team Scope Timing Audit protocol

4. Pre-audit information required 1. Description of processes (PFDs) 2. Process Controls (P&IDs) 3. Organizational structure 4. PSM program description

4. Pre-audit information required 5. Past audit reports & resolution of recommendations 6. Summary of local regulations

5. Plan onsite activities

6. Kick-off Meeting Closeout Meeting

6. Conducting the Audit 1. Record reviews 2. Direct observations 3. Interviews

6. Conducting the audit Record reviews 1. Employee participation 2. Process Safety Info 3. PHAs

6. Conducting the audit Record reviews 4. Operating Procedures 5. Training 8. Mechanical Integrity 13. Compliance auditing

13. Compliance Auditing Requirements Every 3 years Keep past 2 audits Informal audits

6. Conducting the audit Direct Observations 6. Contractors 7. Safe work procedures 9. Hot work permit

6. Conducting the audit Interviews 10. Management of Change 11. Incident investigations 12. Emergency response plan

Element 12 - Emergency Response Plan

Element 14 Trade Secrets 14. Trade secrets Process Safety Information Process Hazard Analysis Operating Procedures Incident Investigations Emergency Response Compliance Audits

6. Conducting the audit Immediately inform facility management of imminent hazards

6. Conducting the audit Daily share preliminary findings and observations

6. Conducting the Audit Audit Protocol Focus on the written protocol

Close-out Meeting Closeout Meeting

7. Document the audit Draft report Feedback Final report

8. Address audit findings and recommendations

9. Monitor completion of audit recommendations Final Audit Report

Monitor PSM maturation over time for each facility

Share best practices

Remaining Course Material 1.Overview of Process Safety 2.Compliance with standards 3.Process Hazard Analysis 4.Standard Operating Procedures 5.Safe Work Procedures 6.Mechanical Integrity 7.Management of Change 8.Auditing Process Safety systems 9.Emergency response procedures