1. PSM Audit Occurrences Randy Bentley

2. Topics: 1.Audits/Assessments 2.Violations of the OSHA Standard 1910.119, Process Safety Management. 3.Audit/Assessment Findings 4.Necessities for Successful Audits/Assessments

3. Audits/Assessments Why we do them: 1.OSHA PSM/EPA RMP, Compliance Audit requirements. 2.Recent OSHA/EPA Visit 3.Management Changes 4.Internal Improvement Exercises 5.Internal/Corporate Standards

4. PSM OSHA Citations 2012-Present* PSM Element# of Citations Employee Participation4 Process Safety Information71 Process Hazard Analysis73 Operating Procedures44 Training13 Pre-start Up Safety Review1 Mechanical Integrity60 *U.S. Department of Labor; Occupational Safety & Health Administration; 200 Constitution Ave., NW, Washington, DC 20210. Nov. 11, 2013.

5. PSM OSHA Citations, 2012-Present* PSM Element (cont.)# of Citations Hot Work Permit0 Management of Change18 Incident Investigation9 Emergency Planning and Response9 Compliance Audits24 Contractors0 Trade Secrets0 *U.S. Department of Labor; Occupational Safety & Health Administration; 200 Constitution Ave., NW, Washington, DC 20210. Nov. 11, 2013.

6. 1.Audits covered all triggers: Referral, NEP, Complaint, Accidents, etc. 2.Referrals were the most common trigger for audits. 3.Region 5 = $1,752,607 4.326 Citations; Avg. $5,376 Each 5.42 Organizations; Avg. 8 Citations per Audit More Statistics

7. Audit/Assessment Findings ElementAudit 1Audit 2Audit 3Audit 4Audit 5Totals Employee Participation 336 Process Safety Information 11334324 Process Hazard Analysis 72211 Operating Procedures 51410 Training 223310 Pre-start Up Safety Review 1124 Mechanical Integrity 9121718 Hot Work Permit 268 Management of Change 1157 Incident Investigation 1113 Emergency Planning and Response 24410 Compliance Audits 112 Contractors 167 Trade Secrets 0

8. OSHA Violation and Routine Audit Common Finding PSM ElementFinding Employee ParticipationWritten Plan/Consulting with Employees Process Safety Information Documenting Equipment Complies with RAGAGEP (recognized and generally accepted good engineering practices) Process Hazard AnalysisEstablished system for addressing findings and recommendations Operating ProceduresDeveloping and implementing operating procedures/Procedure reviews TrainingTraining in the process and operating procedures

9. GOLDEN GEARS POWERPOINT TEMPLATE PSM Element (cont.)Finding Hot Work PermitDates, Equipment, 1910.252a Management of ChangeEstablish and Implement written procedures to manage change Incident InvestigationInvestigate each incident which resulted OR COULD HAVE RESULTED Emergency Planning and Response Establish and Implement an Emergency Action Plan (EAP) IAW 1910.38 Compliance AuditsCertify, Report, Document Reponses Pre-startup Safety ReviewsPHA performed and findings resolved before startup Mechanical IntegrityInspection and Testing shall be performed OSHA VIOLATION AND ROUTINE AUDIT FINDING ( CONT. )

10. Necessities for Successful Audits /Assessments Management Support Site Support Program Documentation Program Implementation

11. Necessities for Successful Audits /Assessments Management Support Management-Driven Program Long-Term Support Corporate and Site Support

12. Necessities for Successful Audits /Assessments Management Support PSM is a Management-Driven Program Top-Down influence and implementation Dedicated Resources, both personnel and financial Long-Term Support PSM is a permanent body of regulation PSM program impact must be integrated to Cost/Earnings Forecasts A timetable of years, not business quarters Corporate and Site Support Support must come from all levels If a layer of support is missing, program will fail A successful program is one factor of site viability

13. Necessities for Successful Audits /Assessments Site Support Organization at the Site Personnel Requirements (Technical/Operations/Clerical)

14. Necessities for Successful Audits /Assessments Site Support (“Moderate” Size; 300 People; 3 Processes) Site PSM-Programs Manager Site Champions for Each PSM Element (14 Element Model) Process Area Champions for Each Element (14 Element Model)

15. Necessities for Successful Audits /Assessments Site Support Site Champions for Each Element 14 Elements = 14 Champions (can vary per site size) Calculate the Personnel Needed (“Moderate” sized plant-site): (14 Elements) X (1 Person/2 Elements) X (0.25 Fraction of Person’s Time) = 1.75 Persons as Site Champions Call it “2 People” Typically Technical/Salaried Personnel Include technical and administrative requirements

16. Necessities for Successful Audits /Assessments Site Support Process Area Champions for Each Element Typically salaried personnel Skills driven by technical needs of the element Calculation of personnel is similar Assume three (3) process areas on-site One person handles several elements in less-demanding areas Calculate the personnel needed (“Moderate” sized plant-site): (14 Elements) X (1 Pers/2 Elem) X (0.1 Fraction of Person’s Time) X (3 Process Areas) = 2.1 Persons as Process Area Champion Call it “2 People”

17. Necessities for Successful Audits /Assessments Site Support (“Moderate” Size; 300 People; 3 Processes) Site PSM-Programs Support Personnel (Eng. Dept) “Reliability Engineer” Calculate the personnel needed (“Moderate” sized plant-site): (1 Person) X (0.25 Fraction of Person’s Time) X (3 Process Areas) = 0.75 Persons as Reliability Engineer Call it “1 Person” Process Area PSM-Programs Support Personnel (Tech. Eng.) “Process Engineer” Calculate the personnel needed (“Moderate” sized plant-site): (1 Person) X (0.25 Fraction of Person’s Time) X (3 Process Areas) = 0.75 Persons as Reliability Engineer Call it “1 Person”

18. Necessities for Successful Audits /Assessments Site Support (“Moderate” Size; 300 People; 3 Processes) Summary of Personnel Needs for PSM Programs 1 each – Site Programs Manager 2 each, equivalent – Site Element Champions 2 each, equivalent – Process Area Element Champions 1 each, equivalent – Site Engineering - Support 1 each, equivalent – Process Area Engineering – Support Above is for a long-term, continuing PSM program Approximately 1.5 dedicated persons for every $100 Million of Replacement Investment.

19. Necessities for Successful Audits /Assessments Program Documentation Specificity and a Requirement Goal: to provide a comprehensive audit trail so government regulators may feel assured that the facility is operating “Safely”.

20. Necessities for Successful Audits /Assessments Program Documentation Specificity and a Requirement Audit Trail Sampling… Technology: Documented PSI; Updated PHAs; Management of Change documents. Facilities: Operating Procedures; PSSRs; MI; QA. Personnel: Site governance documents, all elements; Contractor Safety Programs; Position Qualification Training Programs and Records; Self-auditing programs and protocols; Incident Investigations, records and analysis. Employees will be interviewed during a third-party audit.

21. Necessities for Successful Audits /Assessments Program Documentation Each regulatory reference requires some type of information This information must be captured by some type of form or information system The employer must maintain documentation and an audit trail that shows employer compliance with the various regulatory references Third-party auditors go directly to this audit trail to determine compliance Verbal comments and discussions do not constitute an audit trail; documents must be presented to verify an audit trail

22. Training of Co-Managed Elements All contract partners are affected Facility - maintain audit trail for contractors Contractor requirements can be audited Involvement of Workforce Employee PSM records will be audited Training records Certificates (Example – Welding Qualifications) Employees will be interviewed during an audit Evidence of employee involvement in PSM program Necessities for Successful Audits /Assessments Program Implementation

23. Questions?? 1.Audits/Assessments 2.Violations of the OSHA Standard 1910.119, Process Safety Management. 3.Audit/Assessment Findings 4.Necessities for Successful Audits/Assessments PSM Audit Occurrences