2nd Lec.- PG 5-7 Flashcards
- Obtain and evaluate information
regarding the contract employer’s safety performance and programs. - Employer also must inform contract employers of the known potential fire, explosion, or toxic release hazards related to the contractor’s work and the process;
Explain to contract employers the
applicable provisions of the emergency action plan; - Develop and implement safe work
practices to control the presence,
entrance, and exit of contract employers and contract employees in covered process areas; - Evaluate periodically the performance of contract employers in fulfilling their obligations; and
- Maintain a contract employee injury
and illness log related to the - Contract Employer Responsibilities
Employer Responsibilities
The contract employer must:
- Ensure that contract employees are trained in the work practices necessary to perform their job safely;
- Ensure that contract employees are instructed in the known potential fire, explosion, or toxic release hazards related to their job and the process, and in the applicable provisions of the
emergency action plan; - Document that each contract employee has received and understood the training required by the standard by preparing a record that contains the identity of the contract employee, the date of training, and the means used to
verify that the employee understood the training; - Ensure that each contract employee follows the safety rules of the facility including the required safe work practices required in the operating procedures section of the standard; and
- Advise the employer of any unique
hazards presented by the contrad:
employer’s work
- a safety review takes place before any highly hazardous chemical is
introduced into a process.
*PSM, therefore, requires the employer to perform a pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information
Pre-Startup Safety Review
The pre-startup safety review must confirm that the following:
- Construction and equipment are in accordance with design specifications;
- Safety, operating, maintenance, and emergency procedures are in place and are adequate;
- A process hazard analysis has been performed for new facilities and recommendations have been resolved or implemented before startup, and modified facilities meet the management of change requirements, and
- Training of each employee involved in operating a process has been completed.
MECHANICAL INTEGRITY
PSM mechanical integrity requirements apply to the following equipment:
- Pressure vessels and storage tanks;
- Piping systems (including piping
components such as valves): - Relief and vent systems and devices;
- Emergency shutdown systems;
- Controls (including monitoring devices and sensors, alarms, and interlocks); and
- Pumps.
MECHANICAL INTEGRITY
PSM mechanical integrity requirements apply to the following equipment: (bullet)
- Employer must establish and implement written procedures to maintain the ongoing integrity of process equipment.
- Proper training of maintenance
personnel
Inspection and testing (Good
Engineering Practice) - Equipment deficiencies outside the acceptable limits defined by the process safety information must be corrected before further use
- For new plants and equipment,
employer ensures that fabrication specs are suitable to intended use. - New equipment should be installed correctly and adhere to manufacturer’s instructions
- Spare parts should also be available and suitable to use.
- A permit must be issued for hot work operations conducted on or near a covered process.
- The permit must document that the fire prevention and protection requirements in OSHA regulations have been implemented prior to beginning the hot work operations; it must indicate the date(s) authorized for hot work; and
identify the object on which hot work is to be performed. - The permit must be kept on file until completion of the hot work
Hot Work Permit
Management of Change
- OSHA believes that contemplated
changes to a process must be
thoroughly evaluated to fully assess
their impact on employee safety and health and to determine needed changes to operating procedures. - To this end, the standard contains a section on procedures for managing changes to processes. Written procedures to manage changes (except
for replacements in kind*) to process chemicals, technology, equipment, and procedures, and change to facilities that affect a covered process, must be
established and implemented.
These written procedures must ensure that the following considerations are addressed
prior to any change:
-The technical basis for the proposed change,
- Impact of the change on employee
safety and health,
- Modifications to operating procedures,
- Necessary time period for the change, and
- Authorization requirements for the proposed change.
- Employees who operate a process and maintenance and contract employees whose job tasks will be affected by a change in the process must be informed of, and trained in, the change prior to startup of the process or startup of the affected part of the process.
- If a change covered by these procedures results in a change in the required process safety information, such information also must be updated accordingly.
- If a change covered by these procedures changes the required operating procedures or practices, they also must be updated.
- A crucial part of the process safety
management program is a thorough investigation of incidents to identify the chain of events and causes so that corrective measures can be developed and implemented. - Accordingly, PSM requires the
investigation of each incident that
resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical in the workplace. - Such an _________ __________ investigation must be initiated as promptly as possible, but not later than 48 hours following the incident.
- The investigation must be by a team consisting of at least one person knowledgeable in the process involved, including a contract employee if the
incident involved the work of a
contractor, and other persons with
appropriate knowledge and experience to investigate and analyze the incident thoroughly.
- A crucial part of the process safety
management program is a thorough investigation of incidents to identify the chain of events and causes so that corrective measures can be developed and implemented. - Accordingly, PSM requires the
investigation of each incident that
resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical in the workplace. - Such an incident investigation must be initiated as promptly as possible, but not later than 48 hours following the incident.
- The investigation must be by a team consisting of at least one person knowledgeable in the process involved, including a contract employee if the
incident involved the work of a
contractor, and other persons with
appropriate knowledge and experience to investigate and analyze the incident thoroughly.
An investigation report must be prepared including at least:
- Date of incident,
- Date investigation began,
- Description of the incident,
- Factors that contributed to the incident, and
- Recommendations resulting from the investigation.
Compliance Audit
* To be certain process safety
management is effective, employers
must certify that they have evaluated compliance with the provisions of PSM at least every three years
* This will verify that the procedures and practices developed under the standard are adequate and are being followed.
* The _________ ______ must be
conducted by at least one person
knowledgeable in the process and a
report of the findings of the audit must be developed and documented noting
deficiencies that have been corrected.
* The two most recent _________ ______ reports must be kept on file.
Compliance Audit
*Employers must make available all
information necessary do comply with
* PSM to those persons responsible for compiling the process safety
information, those developing the
process hazard analysis, those
responsible for developing the
operating procedures, and those
performing incident investigations,
emergency planning and response, and compliance audits, without regard to the possible trade secret status of such information.
* Nothing in PSM, however, precludes the employer from requiring those persons to enter into confidentiality agreements not to disclose the information.
Trade Secret
