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Transcript
SOUTHWESTERN ELECTRICAL CO., INC.
NOVEMBER, 2008
FROM:
MANAGER
TO:
ALL EMPLOYEES
SUBJECT:
PROCESS SAFETY MANAGEMENT
INTRODUCTION:
Process Safety Management (PSM) is intended to protect workers, the public, and plants by
managing and controlling the hazards associated with the process of highly hazardous chemicals.
The standard mainly applies to manufacturing industries - particularly, those pertaining to
chemicals, transportation equipment and fabricated metal products. It also includes natural gas
liquids, farm product warehousing, electric, gas, sanitary service, and wholesale trade.
PSM has a direct effect on the maintenance of all the equipment used in these processes. This
includes the pipe lines that carry the products.
A process safety management program consists of 14 elements. These elements address the
management of the program.
ELEMENTS:
1. Employee participation
2. Process safety information
3. Process hazards analysis
4. Operating procedures
5. Training
6. Contractors
7. Pre-startup review
8. Mechanical integrity
9. Hot work permits
10. Management of change
11. Incident investigation
12. Emergency planning and response
13. A compliance audit
14. Trade secrets
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SWECO POLICY#__25__11/2008
(1) Employee participation - This element requires a written action plan for involving
employees in all PSM activities.
(2) Process safety information - This element requires that certain information about a process
be assembled and communicated to personnel. Process safety information includes system
diagrams, safe operating limits, and equipment information.
(3) Process hazards analysis - is a systematic approach used to identify, evaluate, and control
the hazards in a process. Process hazards analysis (PHA) can help determine where
problems may occur in a process, so that corrective action can be taken to make a safer
operation.
(4) Operating procedures - operating procedures must be written for all processes, this
includes startup, normal operation, normal shutdown and emergency shutdown. These
procedures must be communicated to all employees.
(5) Training - the training program must develop the knowledge, skills, and attitudes for
working safely, and it must include an overview of the process, its potential hazards,
relevant operating procedures and safe work practices. This element also requires initial
training and periodic refresher training.
(6) Contractors - this element involves the training of contractors
(7) Pre-startup review - is a review of key safety considerations and operator training that is
done before a new process is started up. A pre-startup review is also required for modified
processes that require a change in plant design or process safety information.
(8) Mechanical integrity, - ensures the ongoing integrity of process equipment. This element
requires testing and inspections to eliminate leaks that could cause the release of dangerous
materials, and potential sources of ignition that could lead to fires or explosions. It also
helps to ensure that equipment is designed, installed, maintained, and operated properly.
(9) Hot work permits - requires the use of hot work permits to certify that hot work, such as
welding can be done safely.
(10) Management of change - ensures that changes to process chemicals, echnology, equipment,
and facilities are analyzed for their impact on health and safety. The analysis of such
changes can then be used to determine necessary modifications to safety information,
procedures, and training.
(11) Incident investigation - requires the investigation of every incident that results in or could
have resulted in a catastrophic release. An investigation is necessary to identify the cause of
the incident and provide the basis for taking corrective actions.
(12) Emergency planning and response - requires a facility to establish and implement an
emergency action plan to deal with a release of highly hazardous chemicals. Operators and
other personnel should know exactly what to do to minimize the consequences of an
emergency.
(13) Compliance audit - helps to ensure that an effective process safety management system is
in place and is working. The compliance audit provides a systematic way of verifying
compliance with a process safety management program and identifying problems.
Employers are required to respond to the audit findings in a timely manner.
(14) Trade secrets - requires access to all necessary information for completing the other thirteen
elements of the standard without regard to trade secret status.
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SWECO POLICY#__25__11/2008
All elements are equally important, but some require more time than others. All elements must
be met to meet the requirements of the PSM program.
CONTRACTORS (6)
Contractors and their employees must be informed about the hazards associated with any process
that they are working on or near. They must also be properly trained to do their job safely and
according to the plant's safety regulations. Contractor employees must also be familiar with the
plant's emergency plan, so that they will know whom to contact and where to go if an emergency
occurs. The employer is responsible for providing this information and for keeping a contract
employee injury and illness log.
SOUTHWESTERN ELECTRICAL CO., INC. responsibilities:
1. Is responsible for the safety and health of its employees at the jobsite. SOUTHWESTERN
ELECTRICAL CO., INC. (jobsite foreman) will thoroughly familiarize himself with the Client’s
operations at the jobsite, including operations which may pose a personnel hazard. The jobsite
foreman will also thoroughly familiarize himself with the Client’s safety policies and with the
Client’s alarm system at the jobsite. The foreman will be responsible for conducting a thorough
examination of the jobsite prior to performing work. The foreman will complete the JOB SITE
SAFETY INSPECTION FORM. The jobsite must be safe for the proposed work before
commencing operations.
2. The foreman will advise the Client representative of any unique hazards presented by the
contract employee's work, or any hazards found by the employee's work.
3. Will provide the necessary protective equipment for its employees to complete the job in a
safe manner. Fire retardant clothing will be provided to employees as required. Example of this
would be working on equipment containing hydrocarbons, or hot tapping.
4. Is responsible for providing emergency medical and first aid care for its employees and for
follow-up care which may be necessary.
5. Will furnish the Client representative full reports of any accidents involving persons or
property on a Company jobsite. A "Near Miss" will be reported an investigation will be done.
The Client will be given a copy of a "Near Miss" report. A "Near Miss" is any incident that could
have caused serious injury or significant property damage as an accident.
6. The foreman will promptly report any fires on the Client’s property to the Client
representative.
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SWECO POLICY#__25__11/2008
7. Will conduct safety meetings at appropriate intervals to assure it employees are fully
informed of potential hazards. "Tail Gate" safety meeting will be conducted any time there is a
change in the work assignment or a new hazard is present.
8. Will ensure that its employees receive appropriate safety training regarding the potential
hazards of the job prior to commencement of work on a Clients=s jobsite. This training will be
documented on an Attendance Roster and filed at the office (SOUTHWESTERN ELECTRICAL
CO., INC.)
9. Will supply and be responsible for the condition and suitability of all equipment and tools
necessary to perform the work. The foreman is responsible for conducting an audit of all tools
and equipment prior to starting a job.
10. Will furnish only employees who are fit and physically and mentally qualified to perform the
work. Employees who have not had sufficient sleep, are unusually fatigued, or under the
influence or impaired by the use of alcohol, drugs or medicine are not considered to be fit.
11. Will provide its employees with energy lockout devices, i.e. lock to isolate all energy sources
to protect them from injury while working in, on or around equipment during repair or
maintenance due to an unexpected startup or energization. SOUTHWESTERN ELECTRICAL
CO., INC. will follow the Client’s LOCKOUT/TAGOUT procedure.
12. Will ensure that each of its employees has the ability to read and understand, hear and
understand, speak and be understood in English, as well as to write one's name in English when
assigned to "safety sensitive" work. Any Non-English speak person will not be assigned to a
"safety sensitive" job.
13. Will comply with local, state and federal occupational safety and health regulations and
maintain required records.
14. Meet federal and state occupational safety and health first aid requirements. We will have
sufficient number of trained first aiders at each job and adequate first aid supplies. The jobsite
foreman is responsible for ensuring these requirements are met.
15. The foreman is responsible for obtaining HOT WORK PERMITS from the relevant Client’s
personnel when using portable electric driven tools, welding, sand blasting, opening electrical
enclosures, etc., in an operating area or using any other equipment that might be a source of
ignition for combustible mixtures. This equipment shall be immediately shutdown in an
emergency or when requested by a Client’s representative.
16. The foreman is responsible for obtaining a Non-Permitted Confined Space Entry Permit prior
to entering a confined space.
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17. The foreman is responsible for obtaining any and all work permits that may be required for
each job.
18. Furnish a trained employee, with fire extinguishers in the work area for certain work as
required on a HOT WORK PERMIT, and remain on duty 30 minuets after the hot work is
completed. This employee must know how to sound the alarm in the event there is an
emergency.
19. The foreman is responsible for fire prevention in the work area.
20. Permit smoking only in designated areas.
21. Operate vehicles and other mobile equipment within the posted speed limits and only in areas
necessary to perform work.
22. Unattended vehicles will not be left running at any time.
23. The foreman will ensure that employees practice safe and orderly housekeeping in the work
areas at all times.
24. Establish rope-off areas for excavations and overhead work and erect safety and caution signs
in cooperation with Client’s personnel and as deemed prudent.
25. Furnish personal protective equipment (PPE) for its employees, this includes hearing
protection in designated areas, hard hats and safety glasses with side shields on Client’s facilities.
Some jobs may require additional PPE i.e., goggles, face shields, gloves, etc.
26. Prohibit the possession of cameras, weapons or explosives on Client’s facilities.
27. Train personnel to understand and comply with emergency alarms and emergency
procedures. It is particularly important to understand the importance and necessity of shutting
down all sources of ignition and leaving the area immediately when an emergency alarm is
sounded.
28. Will train personnel to be aware of the hazards, characteristics and safety precautions
associated with hydrogen sulfide gas prior to beginning work at a Client’s facility containing
hydrogen sulfide. This training will be done annually and documented.
29. Provide personnel with appropriate respiratory equipment when performing work at a
Client’s facility containing hydrogen sulfide which could possibly release gas into the breathing
zone of the workers. Provide training and on the donning and duffing of this respiratory
protective equipment.
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SWECO POLICY#__25__11/2008
30. Require personnel to be clean shaven in the area of the face-to- respirator seal prior to
entering a Client’s facility that is designated as a respirator user facility.
31. Ensure that employees are confined to their assigned areas and prohibit loitering or
wandering into operating areas beyond the boundary of their work assignment.
32. Southwestern Electrical Co., Inc.’s safe work practices must be followed during operation
such as lockout/tagout, confined space entry, opening process equipment or piping and control
over entrance to facility.
EMERGENCY GUIDELINES
The following guidelines are provided in the event on an emergency on a Client’s facility.
Employees will be instructed on the hazards related to their jobs and potential fire, explosive or
toxic release hazards. The purpose of PSM is to prevent or minimize the consequence of releases
of toxic, reactive, flammable or explosive chemicals.
FIRE EMERGENCIES
1. If the attempt would not jeopardize personal safety, trained employees should attempt to
extinguish a fire in their work area during the incipient stages.
2. If the fire is too large or if attempts at extinguishing fail, employees should warn others in the
area and evacuate the danger area to an upwind position and assemble for headcount. If no place
of safe refuge has been identified by the Client, then the foreman will designate a place and take
a headcount of the employees. The foreman at the job site will have a roster of
SOUTHWESTERN ELECTRICAL CO., INC. employees. The office will also have a roster of
all employees that are assigned to a job site. The dispatcher will be informed in the event of an
emergency that requires employees to evacuate an area.
3. Immediately notify the Client representative of the situation.
NOTE: SOUTHWESTERN ELECTRICAL CO., INC. employees will not be expected to
perform duties relating directly to controlling a fire but may be called upon to provide support
services (hauling equipment, assisting injured personnel, etc.).
MAJOR GAS RELEASES:
1. Upon notification of a major release of flammable vapors, employees will shut down all
sources of ignition under their control.
2. All employees should immediately evacuate the danger area to an upwind position and
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assemble. The assemble point (place of safe refuge) should be far enough from the source release
to remain safe should the vapors ignite.
3. The foreman must immediately notify the Client representative of the situation.
4. Continue monitoring the wind direction and stay upwind at all times. All gas releases shall
be assumed to contain toxic gas.
5. Do not re-enter the danger zone until the emergency is under control and the Company
representative provides clearance to re-enter.
EMPLOYEE RESPONSIBILITIES:
SOUTHWESTERN ELECTRICAL CO., INC. employees are expected to follow all safety rules.
Employees are expected to maintain all equipment including all personal protective equipment in
a safe and sanitary condition. All accidents and near misses will be reported to the foreman as
soon as possible.
SOUTHWESTERN ELECTRICAL CO., INC. manager will ensure that all the requirements of
the PSM program is followed and assign responsibilities to supervisors, foreman and others as
needed. Our employees will be trained as required and employees are required to attend all
training sessions. Special skills, such and welders, crane operators, and electricians will be tested
or will have the proper certification.
Employees must respect the confidentiality of any "TRADE SECRET” information from
the release of process safety information to them.
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