1. My Facility is PSM-Covered – Now What? A real-world introduction to PSM’s 14 Elements Moderator Host Speaker Sajjad Gul, Dir. Business Dev. Rob Bartlett, PSM Consultant Ameyra Rosales, Brand Mangr

2. About 360factors, Inc. Pareto Engineering & Management Consulting Rob Bartlett owns Pareto Engineering & Management Consulting. He uses his over 20 years of experience and partners with companies to create World Class Process Safety Systems.

3. 3 Offices in 3 Countries ABOUTUS INDUSTRY FOCUSED Oil & Gas Utilities Mining Manila, Philippines Karachi, Pakistan Austin, TX (US HQ) INDUSTRY FOCUSED $25M REVENUE 350+ EMPLOYEES GLOBAL PRESENCE

4. 1984 – Bhopal, India 2000+ fatalities. 170 injuries Why is PSM Needed? 2005 – Texas City 15 fatalities. 170 injuries 1974 – Flixborough, England 28 fatalities. unknown injuries 1984 – Mexico City 650 fatalities. unknown injuries 2014 – Texas City 4 fatalities. unknown injuries

5. Costs and Benefits of Good Safety Performance What we see Direct Costs of Injuries  Medical costs  Wage indemnity  Claims administration fees What we don’t see The Hidden Costs of Injuries  Damaged equipment, vehicles & goods  Lost production and quality  Process interruptions, yield losses  Replacement labor / Overtime  General liability costs  Litigation  Damage to customer relations & public image Direct Cost Indirect Cost 5X

6. Process Safety Management A real-world introduction to PSM’s 14 Elements My Facility is PSM-Covered Now What?

7. Process Safety Management Simple* Elements  Employee Participation  Training  Hot Work  Incident Investigation  Emergency Response  Compliance Audits  Trade Secrets *Relative to other elements

8. Process Safety Management Challenging Elements  Process Safety Information  Process Hazard Analyses  Operating Procedures  Contractor Management  Pre-Startup Safety Reviews  Mechanical Integrity  Management of Change

9. Process Safety Management Process Safety Information  Information pertaining to the hazards of the highly hazardous chemicals in the process  Toxicity information  Permissible exposure limits  Reactivity data  Corrosivity data  Information pertaining to the technology of the process

10. Process Safety Information Real World Advice  Most information exists in SDSs, literature, & plant and process documentation  Gather all PSI in one place – either electronic or paper  Be sure that PSI is updated as changes are made  Create an Action Item for annual review of the PSI

11. Process Safety Management Process Hazard Analysis  PHA shall be appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process  What if / What if Checklist  Hazard and Operability Study (HAZOP)  Failure Mode Effective Analysis (FMEA)  Fault Tree Analysis  Layer of Protection Analysis (LOPA)  Updated/Revalidated at least every five years

12. Process Hazard Analysis Real World Advice  Choose the right method, not every process needs a HAZOP.  Chose the right team – experience is the key.  PHA doesn’t end with a report - develop a system to review and manage PHA recommendations

13. Process Safety Management Operating Procedures  Develop and implement written operating procedures that provide clear instructions for safety conducting activities involved in each covered process  Steps for each operating phase  Operating Limit  Health & Safety consideration  Safety Systems  Develop procedures for LOTO, First Breaks, Confined Space, Facility Control

14. Operating Procedures Real World Advice  Electronic document system often easiest to maintain.  Do not try to put all the required information into one procedure – combine common information into one procedure  Be simple and direct – readability and understandability are vital

15. Process Safety Management Contractors  Applies to contractors performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process  Obtain and evaluate information regarding the contract employer's safety performance and programs  Inform contract employers of the known potential fire, explosion, or toxic release hazards  Control the entrance, presence and exit of contract employers and contract employees in covered process areas  Contract employer has specific responsibilities

16. Contractor Management Real World Advice  Develop an approval process for contractors  Allot adequate resources to maintaining contractor approval and training documentation  Ensure that contractor employees have the required training to complete

17. Process Safety Management Pre-Startup Safety Review  Perform a PSSR for new facilities and for modified facilities when the modification is significant enough to require a change in PSI  Construction and equipment is in accordance with design and specifications  Safety, operating, maintenance and emergency procedures are in place and adequate  PHA and MOC completed, if needed  Training employees involved in operating a process completed

18. Pre-Startup Safety Reviews Real World Advice  Involve the right people – experience counts  Don’t rely on memory - use checklists  Develop a system for managing post-startup actions from PSSR  Use the PSSR as opportunity to prove that process is safe to start – Document everything!

19. Process Safety Management Mechanical Integrity  Applies to:  Pressure Vessels and Storage Tanks  Piping Systems (including piping components such as valves)  Relief and vent systems and devices  Emergency shut down systems  Controls (including monitoring devices, sensors, alarms and interlocks)  Pumps

20. Process Safety Management Mechanical Integrity  Establish and implement written procedures to maintain the on-going integrity of process equipment  Train each employee involved in maintaining the on-going integrity of process equipment  Perform inspections and tests on process equipment following Recognized and Generally Accepted Good Engineering Practices (RAGAGEP)  Document inspections and correct deficiencies  Establish Quality Assurance procedures

21. Mechanical Integrity Real World Advice  RAGAGEP = 7 words = infinity of complexity  Use operations and maintenance manuals whenever possible (have them readily accessible)  Develop ITPM plan using CCPS MI book  Use a Computerized Maintaining System to schedule ITPM tasks and track deficiencies to closure  Become familiar with API, NFPA, ASME, and other RAGAGEP

22. Process Safety Management Management of Change  Establish and implement written procedures to manage changes to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process  Include :  Technical basis for the change  Impact of change on safety & health  Modifications to operating procedures  Necessary time period for the change  Authorizations req. for the change

23. Management of Change Real World Advice  There are very few ‘Replacement in Kind’  Be sure complete all pre- and post- change actions  Include personnel changes  Paper is ok, but electronic is far superior

24. My Facility is PSM-Covered – Now What?!?  Review OSHA 1910.119  Complete a Gap-Analysis for compliance of existing programs  Develop programs to address gaps

25. Success Factors  Use as many existing processes as possible  Hot Work, PSI, Operating Procedures  Use a cross-functional team  Include operators and mechanics  Continual training and auditing  Don’t assume the processes are working

26. Q&A At the end of the day, safety is all about care, saving lives, families, and the society we operate in.