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Process Safety Code

Responsible Care ® Code of Management Practices

Code Responsible Care ® Code of Management Practices Making progress toward our vision of NO INJURIES

Making progress toward our vision of

NO INJURIES
NO INJURIES

NO ACCIDENTS

&

no harm to the environment

NOTICE

This Guide was prepared by JBF Associates, Inc. (JBFA) as an account of work sponsored by the American Chemistry Council. Neither JBFA, the Council, nor any of their employees, subcontractors, consultants, or other assigns makes any warranty, expressed or implied, or assumes any liability or responsibility for any use, or the results of such use, of any information, product, or process disclosed in this Guide, or represents that its use would not infringe privately owned rights.

This work is protected by copyright. The American Chemistry Council, which is the owner of the copyright, hereby grants a nonexclusive royalty-free license to reproduce and distribute this Guide, subject to the following limitations:

1. The work must be reproduced in its entirety, without alterations.

2. All copies of the work must include a cover page bearing the Council’s notice of copyright and this notice.

Copies of the work made under the authority of this license may not be sold.

1

ACKNOWLEDGE

The Process Safety Code of Management Practices was developed by the Safe Plant

Operations Task Group under the auspices of the Engineering and Operations

Committee of the American Chemistry Council. This Resource Guide was written by Steve Arendt of JBF

Associates, Inc. He distilled the information compiled by the Task Group during the

Code's development. At this Guide's publication, the Task Group had the following

membership:

Ray Olsen, Chairman Exxon Chemical Company

Percy Kavasmaneck Union Carbide Chemicals and Plastics Company

Brynn Aurelius Shell Chemical Company

Vincent Boyen Monsanto Company

Harry Calsing The B. F Goodrich Company

Joseph Caporossi American Cyanamid Company

Larry Csengery Shell Oil Company

Kerian Fitzpatrick ARCO Chemical Company

Theodore F Henken Chevron Chemical Company

William Jordan First Chemical Corporation

2

Michael McCready Union Carbide Chemicals and Plastics Company

John Oldner The Dow Chemical Company

Hermann Ortega Air Products and Chemicals, Inc.

Win Person Henkel Corporation

Philip Rasch Hoechst Celanese Corporation

Carl Rensink First Chemical Corporation

Lee Schaller Du Pont Company

MacGregor Scott ARCO Chemical Company

Adrian Sepeda Occidental Chemical Corporation

Loren Wassell Monsanto Company

Their technical insights, experiences, and suggestions were essential to the development of this Guide. The author also acknowledges the contributions of the following members of the American Chemistry Council Staff: Stephanie Bowen, Jayne Davis, Dave Hastings, Kyle Olson and Bob Ondocsin.

The author also wishes to recognize the groundbreaking work done by many other process safety professionals who, over the past few years, created much of the original thinking that this guide is based upon. In particular, the author extensively uses material from the Center for Chemical Process Safety's Guidelines for Technical Management of Chemical Process Safety, the Organization Resources Counselors, Inc.'s report Recommendations for Process Hazards Management of Substances with Catastrophic Potential and the American Petroleum Institute's Guidelines for Management of Process Hazards - Recommended Practice 750.

The author is also indebted to the reviewers of this Guide at JBF Associates, Inc.: Don Lorenzo, Mike Roberts and Curt Rogers. And he wants to thank Karen Fisher, Coco Everett and Tom Williams for their skill and craftsmanship in preparing this document.

4

Active participation in the Responsible Care initiative is an obligation of membership in the American Chemistry Council. A member's obligation to Responsible Care applies to all of its chemical businesses covered by the American Chemistry Council dues base. Each member company is expected to make a commitment to Responsible Care by:

Signing the Guiding Principles

Communicating the commitment to Responsible Care to employees

Making good-faith efforts to implement the Codes of Management Practices, participating in the self-evaluation process and meeting the expectations of the Responsible Care Program

Using the Responsible Care name and logo according to the terms and conditions as set forth in the Guidelines for the Use of the Responsible Care Service Mark

The Process Safety Code is one of six currently planned Codes of Management Practices. The Code identifies Management Practices that member companies should view as goals. This Resource Guide illustrates possible options for implementing the Process Safety Code. However, this Guide is not an exclusive, mandatory prescription, and the advice contained herein is not obligatory. Rather, it provides suggestions for consideration in your company's efforts to continually improve process safety. Moreover, adherence to this Code may not be future process safety related regulations.

5

TABLE OF CONTENTS

Notice

1

Acknowledgments

2

List of Acronyms and Initials

9

Glossary

10

THE PROCESS SAFETY CODE

14

INTRODUCTION

17

Background

17

Scope

22

Overview and Comparison of the Process Safety Code

22

How to Use This Resource Guide

23

IMPLEMENTING THE CODE IN YOUR COMPANY

28

MANAGEMENT LEADERSHIP IN PROCESS SAFETY

30

Management Practice 1 – Commitment

31

Management Practice 2 – Accountability

34

Management Practice 3 - Performance Measurement

36

Management Practice 4 - Incident Investigation

37

Management Practice 5 - Information Sharing

39

Management Practice 6 - CAER Integration

51

PROCESS SAFETY MANAGEMENT OF TECHNOLOGY

42

Management Practice 7 - Design Documentation

43

Management Practice 8 - Process Hazards Information

45

Management Practice 9 - Process Hazard Analysis

46

Management Practice 10 - Management of Change

48

6

PROCESS SAFETY MANAGEMENT OF FACILITIES

50

Management Practice 11 – Siting

51

Management Practice 12 - Codes and Standards

53

Management Practice 13 - Safety Reviews

54

Management Practice 14 - Maintenance and Inspection

56

Management Practice 15 - Multiple Safeguards

57

Management Practice 16 - Emergency Management

59

MANAGING PERSONNEL FOR PROCESS SAFETY

60

Management Practice 17 - Job Skills

61

Management Practice 18 - Safe Work Practices

62

Management Practice 19 - Initial Training

64

Management Practice 20 - Employee Proficiency

65

Management Practice 21 - Fitness for Duty

66

Management Practice 22 – Contractors

67

IMPROVING PROCESS SAFETY PERFORMANCE

69

BIBLIOGRAPHY

70

APPENDIX.

73

Questions and Answers

73

Comments/Suggestions

78

7

LIST OF TABLES

Table Description

1 Responsible Care Program Elements

2 Guiding Principles for Responsible Care

3 Summary of the Process Safety Code of Management Practices

4 Comparison of Process Safety Management Systems

8

Page

LIST OF ACRONYMS AND INITIALS

AIChE

American Institute of Chemical Engineers

AIHA

American Industrial Hygiene Association

ANSI

American National Standards Institute

API

American Petroleum Institute

ASME

American Society of Mechanical Engineers

ASTM

American Society of Testing and Materials

CCPA

Canadian Chemical Producers Association

CCPS

Center for Chemical Process Safety

CGA

Compressed Gas Association

CAA

Clean Air Act

CAER

Community Awareness and Emergency Response

DOT

Department of Transportation

DIERS

Design Institute for Emergency Relief Systems

DIPPR

Design Institute for Physical Property Data

EOC

Engineering and Operations Committee

EPA

Environmental Protection Agency

FMEA

Failure Modes and Effects Analysis

FTA

Fault 73ree Analysis

HAZOP

Hazard and Operability Analysis

ISA

Instrument Society of America

LEPC

Local Emergency Planning Committee

MP

Management Practice

MSDS

Material Safety Data Sheet

NAM

National Association of Manufacturers

NFPA

National Fire Protection Association

NIOSH

National Institute for Occupational Safety and Health

NJ-DEP

New Jersey Department of Environmental Protection

ORC

Organization Resources Counselors

OSHA

Occupational Safety and Health Administration

P&ID

Piping and Instrument Diagram

PFD

Process Flow Diagram

PSM

Process Safety Management

RMPP

Risk Management and Prevention Plan

SPOTG

Safe Plant Operations Task Group

TCPA

Toxic Catastrophe Prevention Act

TEMA

Tubular Heat Exchanger Manufacturers Association

9

GLOSSARY

This Code uses key terms in a context that may be different than their associated regulatory definitions. However, adherence to this code does not relieve a company of the obligation to meet federal, state and local regulatory requirements.

Accident

An unplanned, specific combination of events or

A program begun by the American Chemistry Council in 1985 and

Accidental chemical release

circumstances that leads to an undesirable consequence An unplanned, sudden release of chemical(s) from manufacturing, processing, handling and on-site

Acute hazard

storage facilities to the air, water or land. It does not include permitted or other releases The potential for injury or damage to occur as a

Community Awareness and Emergency Response (CAER)

result of an instantaneous or short duration exposure to the effects of an accident

enhanced in 1989 when turned into a Code. It involves building communication channels between industry and the

Chronic hazard

public, and creating emergency response planning mechanisms within companies The potential for injury or damage to occur as a

Code

result of prolonged exposure to an undesirable condition

Consequence

A set of management practices that Council members must make a good-faith effort to implement to meet their Responsible Care commitment The cumulative, undesirable result of an accident, usually measured in health/safety effects, environ mental impacts, loss of property and business costs

Consequence analysis

The analysis of the expected effects of an accident, independent of its likelihood

Dispersion models

Mathematical models that characterize the transport of toxic-flammable materials released to the air, soil and/or the water

10

Element

A group of management practices within this code

Event tree

A logic model that graphically portrays the

Failure modes and effects analysis (FMEA) Fault tree

combinations of events and circumstances in an accident A systematic, tabular method for evaluating the causes and effects of component failures A logic model that graphically portrays the

Hazard

combinations of failures that can lead to a particular system failure or accident of interest The inherent chemical or physical potential of a

Hazard and operability analysis (HAZOP)

material or activity to harm people, property or the environment A systematic, qualitative brainstorming approach for hazard evaluation that studies deviations from normal

Human factors

process conditions A discipline concerned with designing machines,

Incident

operations and work environments so that they match human capabilities, limitations and needs. Includes any technical work (engineering, procedure writing, worker training, worker selection, etc.) related to the human factor in operator-machine systems An unplanned event or series of events and

Likelihood

circumstances usually involving equipment failures and human errors resulting in an undesired consequence. If the outcome is severe, it is usually called an accident An estimate of the expected frequency or probability

Management practice

of occurrence of an event The basic component of a code. It represents goals and objectives rather than prescriptive absolute or quantitative standards

11

Material safety data sheet

Near miss

Process hazard analysis Process hazard evaluation Process hazard review

Process safety

Process safety activity

Process safety management

Quantitative risk assessment

Continual Improvement

A compilation of the toxicity, flammability, stability and reactivity hazards of a chemical. It is a legal document, required

by OSHA's Hazard Communication Standard

An incident whose consequence would have been severe enough to have been classified as an accident, if not for a fortuitous event or if slightly different circumstances existed

An organized effort to identify and analyze hazards associated with chemical processes and operations so that they can be controlled It normally involves the use of qualitative techniques to identify and assess the significance of hazards and develop conclusions and recommendations. Occasionally, quantitative methods may be used to help prioritize risk reduction alternatives

A discipline that focuses on prevention of fires, explosions and accidental chemical releases at chemical process facilities.

Excludes classic worker health and safety issues involving working surfaces, ladders, personal protective equipment and

so forth

An example of a policy, program, tool or system that, if instituted, will help a company implement a management practice

A program or activity involving the application of management principles and analytical techniques to ensure the process

safety of chemical facilities. Focuses on preventing major accidents rather than dealing with classic worker health and

safety issues

The systematic development of numerical estimates of the expected frequency and/or consequence of potential accidents that are then used to make decisions concerning the level of safety associated with a facility or operation

12

Risk

An estimate of human injury or economic loss in terms of both the accident likelihood and the magnitude of the loss or injury. The combination of the expected frequency (events/year) and consequence (effects/event) of a single accident or a group of accidents

Risk assessment

The systematic evaluation of the risk associated with potential accidents at complex facilities or operations

Risk management

The systematic application of management policies, procedures and practices to the tasks of analyzing, assessing and controlling risk in order to protect employees, the general public and the environment as well as company assets, while avoiding business interruptions. Includes decisions to use appropriate engineering and administrative controls for reducing risk

Safety critical jobs

Jobs, activities and tasks that, if improperly per formed,. have the potential to significantly increase the risk of a fire, explosion or accidental chemical release

Sound engineering practice

The application of mandatory codes and standards supplemented by the use of voluntary codes, standards and guidelines, tempered by professional judgment

What If Analysis

A qualitative examination of a process or operation conducted by asking questions that begin with "What if" concerning possible failures or errors

13

PURPOSE

THE PROCESS SAFETY CODE

The Process Safety Code of Management Practices is designed to prevent fires, explosions and accidental chemical releases. The Code is comprised of a series of Management Practices that reflect this goal, with the expectation of continuous performance improvement for each Management Practice. The Practices are based on the principle that facilities will be safe if they are designed according to sound engineering practices; built, operated and maintained properly; and periodically reviewed for conformance.

Process safety is an interdisciplinary effort. Consequently, the Code is divided into the following four elements:

management leadership, technology, facilities and personnel. Each element is composed of Management Practices. Individually, each Practice describes an activity or approach important to preventing fires, explosions and accidental chemical releases. Collectively, the Practices encompass process safety from the design stage through operation, maintenance and training. The scope of this Code includes manufacturing, processing, handling and on-site storage of chemicals. This Code must be implemented with full recognition of the community's interest, expectations and participation in achieving safe operations.

The process safety management program in each facility is complemented by workplace health and safety programs, as well as waste and release reduction programs which address and minimize releases and waste generation. These three programs, and others, will help assure that American Chemistry Council member facilities are operated in a manner that protects the environment and the health and safety of personnel and the public.

RELATIONSHLP TO GUIDING PRINCIPLES

The Code helps achieve several of the Responsible Care Guiding Principles:

• To recognize and respond to community concerns about chemicals and our operations

• To make health, safety and environmental considerations a priority in our planning for all existing and new plants and processes

• To operate our plants and processes in a manner that protects the environment and the health and safety of our employees and the public

14

MANAGEMENT PRACTICES

Each member company shall have an ongoing process safety program which includes:

Management Leadership

1. Leadership by senior management through policy, participation, communications and resource commitments in achieving continuous improvement of performance

2. Clear accountability for performance against specific goals for continuous improvement

3. Measurement of performance, audits for compliance and implementation of corrective actions

4. Investigation, reporting, appropriate corrective action and follow-up of each incident which results or could have resulted in a fire, explosion or accidental chemical release

5. Sharing of relevant safety knowledge and lessons learned from such incidents with industry, government and the community

6. Use of the Community Awareness and Emergency Response (CAER) process to assure public comments and concerns are considered in design and implementation of the facility's process safety systems

Technology

7.

Current, complete documentation of process design and operating parameters and procedures

8.

Current, complete documentation of information relating to the hazards of materials and process technology

9.

Periodic assessment and documentation of process hazards, and implementation of actions to minimize risks associated with chemical operations, including the possibility of human error

10.

Management of changes to chemical operations to maintain or enhance the safety originally designed into the

facility

15

Facilities

11. Consideration and mitigation of the potential safety effects of expansions, modifications and new sites on the community, environment and personnel

12. Facility design, construction and maintenance using sound engineering practices consistent with recognized codes and standards

13. Safety reviews on all new and modified facilities during design and prior to start-up

14. Documented maintenance and inspection programs that ensure facility integrity

15. Sufficient layers of protection through technology, facilities and personnel to prevent escalation from a single failure to a catastrophic event

16. Provision for control of processes and equipment during emergencies resulting from natural events, utility disruptions and other external conditions

Personnel

17. Identification of the skills and knowledge necessary to perform each job

18. Establishment of procedures and work practices for safe operating and maintenance activities

19. Training for all employees to reach and maintain proficiency in safe work practices and the skills and knowledge necessary to perform their job

20. Demonstrations and documentation of skill proficiency prior to assignment to independent work, and periodically thereafter

21. Programs designed to assure that employees in safety critical jobs are fit for duty and are not compromised by external influences, including alcohol and drug abuse

22. Provisions that contractors either have programs for their own employees consistent with applicable sections of this Code or be included in the member company's program, or some combination of the two.

16

BACKGROUND

INTRODUCTION

The chemical process industry (CPI) in the U.S. is extremely diverse. It produces a multitude of chemical compounds during the manufacture of commercial goods including fuels, plastics, foods, pharmaceuticals, pesticides, textiles, metals and other important commodities. The thousands of chemicals involved range from innocuous materials to those posing various potential risks to safety, health and the environment. Considering that there are now tens of thousands of facilities handling hazardous chemicals, the occasional occurrence of accidents cannot be avoided entirely. But, many process accidents should be anticipated and actions to prevent them or mitigate their effects can be taken.

In 1988, the U.S. chemical industry publicly declared its support for a continuous effort to improve the industry's responsible management of chemicals. Through the American Chemistry Council, the industry energized this declaration by establishing the Responsible Care initiative and its 10 Guiding Principles. Moreover, Responsible Care was made an obligation of Council membership, and now, all Council members have pledged their support, and implementation is underway. Table 1 presents an overview of the Responsible Care initiative.

Using Codes of Management Practices to specify qualitative performance guidelines for member companies is one of the important features of the Responsible Care initiative. Initially, five groups of codes have been defined by the Responsible Care Coordinating Group. Each group of codes provides a framework that member companies can use to satisfy their obligation of making a good-faith effort toward achieving the Guiding Principles of Responsible Care. The codes are developed by working groups composed of technical experts from member companies.

17

Responsible Care Program Elements

Guiding Principles

A statement of the philosophy and commitment by each member company regarding environmental, health and safety

responsibilities in the management of chemicals. The Executive Contact of each member company signs a pledge

committing the company to operating its facilities according to the 10 Guiding Principles

Codes of Management Practices

Codes focus on Management Practices in specific areas of chemical manufacturing, transportation and handling. Specific objectives are outlined to help companies satisfy the spirit of the Guiding Principles. Member companies are to make good-faith efforts to achieve these qualitative performance goals and continually improve performance

Public Advisory Panel

A group of environmental, health and safety professionals, along with members from various public sectors, assists the

industry in identifying and developing programs and actions that are responsive to public concerns

Member Self-Evaluations

Reports, measurements and other demonstrations of program implementation document progress toward improved environmental, health and safety performance in the responsible management of chemicals

Executive Leadership Groups

In periodic regional meetings, senior industry representatives review Codes of Management Practices under development,

discuss progress on implementing existing codes, and identify areas where assistance from the Council or other companies is needed

Obligation of Membership

Bylaws obligate member companies to abide by the Guiding Principles, to participate in the development of the codes and programs and to make good-faith efforts to implement the program elements of the Responsible Care initiative

One of the five groups of codes is the Safe Plant Operations Code. This code is made up of two component codes:

the Process Safety Code and the Employee Health and Safety Code. The Process Safety Code of Management Practices is designed to prevent fires, explosions and accidental releases of chemicals. The management practices defined in the Code are statements of goals based on the principle that facilities will be safe if they are designed according to sound engineering practices; built, operated and maintained properly; and periodically reviewed for conformance to the Code.

The Employee Health and Safety Code is directed at the day-to-day, classic worker health and safety issues such as the proper use of personal protective equipment, hot work permits, confined space entry procedures, occupational exposure, medical surveillance and so forth. Together these two codes define the management practices necessary to satisfy the Responsible Care Guiding Principles relating to the safe and healthful operation of chemical manufacturing facilities.

18

SCOPE

While the Process Safety Code forms the foundation for industry's pursuit of the goal of accident-free chemical operations, no one can guarantee such an end result. Nonetheless, this Code, and the Responsible Care initiative in general, is dedicated in spirit to the goal of "zero accidents" and is committed to the continual improvement of process safety performance in an effort to reach that goal.

The Process Safety Code prescribes Management Practices designed to prevent major process accidents and to help achieve several of the Responsible Care Guiding Principles. (The primary principles that this Code addresses are highlighted in the list of Guiding Principles presented in Table 2.) Collectively, these practices address process safety issues throughout the life cycle of a process - from conception and design, through construction and start-up, and continuing with long-term operation of the facility. The scope of this Code includes all phases of on-site operation:

• Manufacturing

• Storage

• Processing

• Handling

Moreover, these management practices deal with a variety of activities, including normal operation, maintenance, training, process modifications and capital improvements.

19

Guiding Principles for Responsible Care

To recognize and respond to community concerns about chemicals and our operations

• To develop and produce chemicals that can be manufactured, transported, used and disposed of safely

To make health, safety and environmental considerations a priority in o r planning for all existing and new products and processes

• To report promptly to officials, employees, customers and the public, information on chemical-related health or environmental hazards and to recommend protective measures

• To counsel customers on the safe use, transportation and disposal of chemical products

To operate our plants and facilities in a manner that the environment and the health and safety of our employees and the public

• To extend knowledge by conducting or supporting research on the health, safety and environmental effects of our products, processes and waste materials

• To work with others to resolve problems created by past handling and disposal of hazardous substances

• To participate with government and others in creating responsible laws, regulations and standards to safeguard the community, workplace and environment

• To promote the principles and practices of Responsible Care by sharing experiences and offering assistance to others who produce, handle, use, transport or dispose of chemicals

Figure 1 illustrates the relationship of the companion codes of Responsible Care and provides a basis for discussing the limits of the scope of the Process Safety Code. Three code groups (Safe Plant Operations; Distribution; and Release Reduction and Waste Management) comprise the main thrust of responsible care of chemicals. The CAER code group plays a unique role in unifying all of the public communication activities under its existing community outreach network. The Product Stewardship code group provides the glue that ties all of the others together; it addresses potential concerns both in the development stage and once products are "out on the shelf." Each of these groups of codes is undergoing development and the relationships of one code group to another may change with time as the Responsible Care initiative matures. The following are brief descriptions of the five codes (other than the Process Safety Code).

Dirtribution - This Code seeks to reduce the risk that transportation and off site storage of chemicals poses to the public, to carriers, to contractor and company employees and to the environment. It applies to all modes of transportation (i.e., pipeline, barge, truck, ship and rail) and to distribution activities (e.g., storage, transfer and repackaging) occurring while chemicals are in transit between member companies and their suppliers and customers. The Distribution Code contains Management Practices on the following topics:

• Distribution risk management

• Compliance review and training

• Carrier safety fitness

• Chemical handling and storage

• Distribution emergency response and public preparedness

20

Waste and Release Reduction and Waste Management - This Code consists of two parts: the Waste and Release Reduction Code (the WARR Code was approved in April 1990) and the Waste Management Code (scheduled for approval in the fall of 1991). The WARR Code is designed to achieve ongoing reductions in the amount of all contaminants and pollutants released and in the amount of wastes generated at facilities. The Waste Management Code will address the handling of remaining pollutants after the implementation of the WARR Code.

When combined, the WARR Code and Waste Management Code will contain Management Practices on the following topics:

• Commitment

• Inventory releases and wastes

• Evaluation of risks

• Communication of risks and attention to public concerns (using the CAER Code)

• Establishment of reduction priorities and goals

• Implementation of reduction plans

• Measurement of progress

• Communication of progress for feedback (using the CAER Code)

• Integration with business plans

• Research and development

• Outreach to industry, customers and suppliers

• Protection of the environment

• Mitigation of past handling and disposal problems

When examined in conjunction with the Process Safety Code, the Waste and Release Reduction and Waste Management Codes address the release and waste generation factors during the design/redesign of manufacturing and other processes. They also guide the handling, decommissioning, and disposal of process equipment.

Employee Health and Safety - This Code addresses traditional worker health and occupational safety issues. It contains Management Practices on the following topics:

• Administration

• Prevention and control

• Analysis • Training and communication

The employee safety topics covered under this Code are distinctly different from the process safety concerns addressed in the Process Safety Code. Together with the Process Safety Code, these two codes make up the Safe Plant Operations Code.

CAER - This Code is the focal point for all code activities that involve communication with the public. It also includes those activities involving emergency response following an accident. The CAER Code contains Management Practices relating to community outreach and emergency response on the following topics:

• Employee education

• Communications training

• Public education

• Outreach program

• Policy

• Effectiveness evaluation

• Two-way dialogue with employees and community

• Incident recovery • Risk assessment • Emergency response plan • Response training • Emergency exercises • Facility tours • Information sharing

The Process Safety Code complements the CAER Code in the area of communication of relevant process safety information.

21

Product Stewardship - This Code focuses on the proper management of products at each stage in their life cycle. The goal is to design, develop, manufacture, transport, use and dispose of products safely and with minimal environmental impact. It involves a number of functional areas within the member company organization (R&D, manufacturing, distribution and sales and marketing) as well as suppliers, outside contractors, distributors and customers.

OVERYIEWAND COMPARISON OF THE PROCESS SAFETY CODE

The Process Safety Code is divided into four elements:

• Management leadership

• Facilities

• Technology

• Personnel

Each of these elements characterizes a particular aspect of chemical process safety assurance, and each element is composed of management practices. Table 3 lists each of the 22 Management Practices defined by this Code.

Table 3 Summary of the Process Safety Code of Management Practices

MANAGEMENT LEADERSHIP Commitment Accountability Performance Measurement Incident Investigation Information Sharing CAER Integration

FACILITIES Siting Codes and Standards Safety Reviews Maintenance and Inspection Multiple Safeguards Emergency Management

TECHNOLOGY Design Documentation Process Hazards Information Process Hazard Analysis Management of Change

PERSONNEL Job Skills Safe Work Practices Initial 71; wining Employee Proficiency Fitness for Duty Contractors

22

past two years, much effort has been expended defining appropriate activities for what is now called Process Safety Management. In 1

ation

Resources

Counselors

published

a

report,

later

provided

to

the

U.S.

Occupational

Safety

and

Health

Administration,

endations for Process Hazards Management of Substances with Catastrophic Potential. The Center for Chemical Process Safety of the A of Chemical Engineers published guidelines for Technical Management of Chemical Process Safety. More recently, the American Pe published a recommended practice entitled Management of Process Hazards.

ublications have many features in common. Many of the management systems and safety assurance activities are the same - albeit or ly. Some have different activities to meet the special needs of the particular focus group. Table 4 is a comparison of the basic components systems, including this Process Safety Code.

ular, this Process Safety Code embraces all of the key aspects of the three other PSM systems listed in Table 4. The main extension of the other PSM systems are: (1) the emphasis placed on management leadership, (2) the use of the CAER process to share relevan ion with industry and the public and (3) the pioneering effort to characterize a company's role in assuring that employees in safety critical uty. Enthusiastic management support is already recognized and accepted as the primary catalyst for companies to be successful in con ng process safety. On the other hand, sharing experience and assuring fitness for duty are crucial elements that may be difficult to achieve.

O USE THIS RESOURCE GUIDE

source Guide is designed to equip you with a thorough understanding of the Process Safety Code of Management Practices so that you c elp your company meet its Responsible Care obligations. However, this Guide is not a "how to" manual for executing specific technical anagement activities. Instead, this Guide provides an interpretation of the Code's Management Practices, describes the scope of the to other Responsible Care segments and provides advice on how you can help achieve continual process safety improvement.

ion designated by Tab 3 describes the general tasks that may have to be performed in implementing this code in your company and d

s for prioritizing code activities. The sections of this Guide designated by Tabs 4-7 describe each of the 22 Management Pracdca that c

elements of the Process Safety Code. For each practice, process safety codes are provided that may be useful in your quest for continual

mprovement. Not all of these activities are appropriate for every company or for every facility or division within a company. You should , and perhaps add others, that fit your company's needs and culture. Secondly, cuwnples are given for each activity to illustrate how compa ve successfully implemented them. Finally, pitfaffs and considcmnons are discussed so that you will be better equipped to meet future hallenges. Space is provided for you to take notes and to personalize this guide with ideas that you think may help your company or facil

e Guide may be updated periodically; please feel free to use the form provided at the rear of the Guide to compile your comments and sug ubmit them to the American Chemistry Council.

to consider when assessing process safety performance and when completing the self-evaluation portion of the Responsible Care initia

d in the section designated by Tab 8. The Bibliography (Tab 9) section provides an extensive list of authoritative references that compan

eful in creating effective process safety management programs. The Appendix (Tab 10) provides a list of typical questions that arose du

rocess for this Code. The answers may help clarify the intention of the Management Practices.

23

Comparison of Process Safety Management Systems

ment Leadership

itment

ntability

mance Measurement

nt Investigation

ation Sharing

Integration

ogy

n Documentation

ss Hazards Information

ss Hazard Analysis gement of Change

s

and Standards Reviews enance and Inspection ple Safeguards ency Management

el

kills

Work Practices

Training

yee Proficiency

s for Duty

actors

AMERICAN CHEMISTRY COUNCIL RESPONSIBLE CARE

24

CENTER FOR CHEMICAL PROCESS SAFETY

ability

Knowledge and

mentation

Reviews and Design dures

nagement

ment of Change

Equipment Integrity

Investigation

and Performance

Factors

s, Codes and Laws

nd Corrective Actions

ment of Process Safety ledge

25

IZATION RESOURCES COUNSELORS

Safety Information

Hazards Analysis

ment of Change in

s 'Ibchnology

g

Procedures

Related Incident

gation

ent Quality Assurance

ical Integrity

up Safety Review

ment of Change in

 

ies

cy Response and

l

o

Information

26

CAN PETROLEUM INSTITUTE

Safety Information

Hazards Analysis

ment of Change

g Procedures

rk Practices

Equipment and Mechanical Integrity

up Safety Review

cy Response and

l

Related Incident

gation

of PHM Systems

27

Creating a process safety management program from scratch and implementing the Responsible Care Process Safety Code is an imposing challenge. Fortunately, many companies have implemented at least some of the provisions of this Code. The following are some basic tasks that you may consider performing in your company's good-faith effort to implement the Code and to satisfy your Responsible Care commitment.

1. Develop a thorough understanding of the Process Safety Code and its relationship to other Responsible Care codes.

This Resource Guide should be a good start in helping you understand the scope of the Process Safety Code. As other codes and resource guides are developed, the scope definition and relationship of the codes will evolve. The American Chemistry Council is planning training seminars to aid member companies in implementing Responsible Care. Take advantage of these courses and attend Responsible Care information meetings to share your experiences with other companies.

2. Identify current company activities related to proem safety management

Most companies are already doing many of the activities discussed in the Management Practices. However, these activities may be highly decentralized. Perform a thorough survey of corporate and plant engineering activities. Create an inventory listing of departments and people responsible for performing process safety work.

3. Compare the Process Safety Code of Management Practices and examples of process safety activities to the process safety management inventory at your company and facility.

Identify gaps in programs at both the corporate and local plant levels. Determine departments and people best suited to make the necessary adjustments.

4. Determine priorities for implementing new process safety management activities.

Making some adjustments may be easy, such as extending an existing vessel inspection program to cover a forgotten class of equipment at a plant. Other improvements may be more difficult to make - it may take a long time to develop the in-house resources to do the job. Each company must evaluate its priorities based the risk of its operations, the exposure created by having an incomplete process safety management program and the available resources for implementing new programs.

5. Develop a program plan for fully implementing the Management Practices of the Process Safety Code.

Write a detailed plan outlining schedule, resources needed and individual responsibilities for implementing each new activity. Update the plan periodically (e.g., quarterly) - this will aid you in performing the self-evaluation of your company's performance.

6. Execute the process safety improvements.

Be deliberate and start with small steps. Early successes will spur interest and support. Attend American Chemistry Council sponsored Responsible Care meetings to share your experience with others and learn better ways to implement your programs.

The way you implement this Code in your company will be influenced by many factors. Company size will play a role. Large companies may already be doing much of what is required in the Management Practices, and they will probably have the necessary resources to satisfy the Code in a reasonable amount of time. Small companies, on the other hand, may have more limited resources for implementing new programs. But, through mutual aid arrangements with large companies, small companies can efficiently implement the Code. Moreover, smaller operations may not be hampered as much by geographical or organizational impediments.

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The evolving regulatory climate will also affect how companies choose to implement the management practices of the Process Safety Code. Several states have already passed laws requiring companies to perform tasks that will satisfy many of the Process Safety Code obligations. OSHA has proposed a new rule (29 CFR 1910.119) mandating that companies have programs in place to manage process hazards. Also, the 1990 Clean Air Act contains a number of features requiring companies to do more to prevent major chemical accidents. The requirements of applicable state and federal regulations relating to process safety management will certainly affect the priority and speed with which you may ultimately implement the Process Safety Code. However, adherence to the Process Safety Code may not guarantee regulatory compliance, now or in the future.

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MANAGEMENT LEADERSHIP IN PROCESS SAFETY

The foundation of any effort to improve process safety has to be management leadership. Although leadership and initiative are needed throughout all levels of an organization, it is crucial that senior management provide visible support and encouragement. Words alone are never enough; true commitment to continual improvement of process safety must be evidenced by management actions that reinforce a company's safety policies and goals.

The goal of the Management Leadership element is to ensure that process safety goals and objectives are defined and communicated throughout a company, and that responsibility and accountability for results are assigned. Six Management Practices (MPs) have been defined as essential components of process safety management leadership. The following sections discuss each practice. First, process safety activities are defined that may be useful in your quest for continual process safety improvement. Not all of these activities are appropriate for every company or for every facility within a company. You should choose the ones, and perhaps add others, that fit your company's needs and culture. Secondly, examples are given for each activity to illustrate how companies like yours have successfully implemented them. Finally, pitfalls and considerations are discussed so that you will be better equipped to meet future process safety challenges. Space is provided for you to take notes and to personalize this Guide with ideas that you think may help your company or facility.

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Management Practice 1: Commitment

Leadership by senior management through policy, participation, communications and resource commitments in achieving continuous improvement of performance

Clear definition and communication of process safety goals and objectives are critical to achieving long-term safe plant operation. Company management is responsible for establishing a corporate culture that places high value on safety. To be effective, a proper mind set must be developed, nurtured and rewarded in a continual, visible fashion.

PROCESS SAFETY ACTIVITIES

1.1 Establish a formal corporate process safety policy.

Collect information on other companies' process safety policies.

Compose a written statement that describes your company's process safety philosophy. Distribute and display it with other important company policies.

Publicize formal adoption of the policy by the corporate board of directors.

Develop guidelines to help each business group or corporate functional area implement the policy.

Establish a mechanism for senior management to solicit candid employee feedback about the process safety policy during its development and implementation. This can be done during plant visits, safety reviews and inspections.

1.2

Define corporate and line management organizations for implementing process safety initiatives.

• Form committees or task forces, where appropriate, to suggest structural changes that promote process safety.

• Provide an organization chart.

• Clearly define process safety responsibilities in job descriptions.

• Establish levels of authority for making process safety-related decisions.

• Emphasize hiring professionals with process safety expertise.

13.

Commit adequate resources to sustain continual improvement of process safety-

• Establish budget items, as necessary, for specific process safety development programs.

• Provide incentives and recognition (e.g., special awards, compensation) to employees who demonstrate extraordinary initiative in pursuing process safety.

• Acquire necessary equipment, tools, software and facilities (e.g., computer software for emergency relief system design and release prediction).

• Provide training and instruction to employees. Develop process safety training programs and materials. Use outside specialists as necessary to supplement internal expertise.

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1.4

Personally participate in an open, active manner in activities that visibly demonstrate process safety commitment.

Regularly attend process safety committee meetings.

Discuss process safety incidents at staff meetings.

Chair steering groups for company process safety committees.

Participate in plant inspections.

Generate a high profile for process safety by being active in process safety groups (e.g., Responsible Care, CAER, CCPS, NAM, local emergency planning committees).

Write articles for the company newsletter and issue pertinent process safety statements for the local media.

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PITFALLS AND CONSIDERATIONS

Inconsistent management leadership (or a lack of management leadership principles) will undermine the credibility of process safety policies. Employees watch management to see if their actions bear out verbal and written commitment to the company process safety policy. The minute one ignores even a minor safety infraction (e.g., even though it's company policy, someone decides not to wear a hardhat and safety glasses to go to the lunchroom because they'll be outside for only a minute), management credibility evaporates and others may mimic "the boss's" performance. Long-term commitment as evidenced by consistent enforcement of company safety policies is essential to the success of process safety management programs.

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PROCESS SAFETY ACTIVITIES

Management Practice 2- Accountability

Clear accountability for performance against specific goals for continual improvement

Everyone who has process safety responsibilities, from senior management to process operators, must exercise appropriate authority and judgment and understand and submit to being accountable for their process safety performance.

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Establish specific process safety related goals to use in determining whether continual improvement is being made.

• Use industry information to establish injury and incident rate targets. Include process-related fatalities.

• Use company experience to set targets for reducing the frequency of process safety-related accidents, incidents, near misses, reportable releases, etc. Develop incentives and systems to encourage complete reporting.

• Define goals (i.e., short- and long-term) for reducing accidental releases, property losses and business interruption.

2.2

Uniformly enforce codes, standards and procedures that promote process safety.

• Provide resources to stay informed of the evolving legal and regulatory climate relating to process safety.

• Ensure that company standards are followed and that any exceptions are properly authorized.

• Verify compliance with applicable consensus standards (e.g., ASME, NFPA, ANSI, AS'1'M) through a project safety review program (MP13).

2.3

Define a mechanism for reviewing management accountability for process safety.

• Include specific process safety goals in yearly personal objectives. Ensure that there is a performance rating inspection during periodic performance appraisals.

• Encourage creative goal setting methods in promoting personal achievement in continual improvement of process safety.

• Provide incentives to encourage individuals to make the correct "safetyfirst" decisions in the face of production or other competing needs.

2.4

Establish a management system to ensure compliance with the Process Safety Code of Management Practices.

• Define a plan for verifying that the commitment to process safety through the Responsible Care program is being met.

• Establish management criteria for periodic review of conformance with these Management Practices.

• Identify deficiencies and develop strategies and plans for expeditiously correcting them.

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PITFALLS AND CONSIDERATIONS

Specific process safety goals are difficult to define. Avoid vague prescriptions in performance goals, such as "operate unit safely." Instead, start deliberately by choosing a few very specific, measurable targets (e.g., complete annual process safety audit of five facilities per month, achieve 90% attendance at shift process safety seminar, implement/ resolve all recommendations from the last periodic process hazard review of the facility). React appropriately (e.g., recognition, promotion, letters of reprimand) to improved/ inadequate process safety performance.

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Management Practice 3: Performance Measurement

Measurement of performance, audits of compliance, and implementation of corrective actions.

Accountability for one's commitment (or lack thereof) to the Guiding Principles of Responsible Care that address process safety cannot be achieved unless management measures and reacts to the process safety performance of the affected individuals. Once measurement systems are in place, management can perform periodic audits, prescribe corrective actions for areas that need improvement and support awards for people who have achieved their performance goals. (See Tab 8 for more information on process safety performance evaluations.)

PROCESS SAFETY ACTIVITIES

3.1 Establish a program to verify operating facilities' compliance with proem safety objectives.

• Define the physical and organizational scope of the program.

• Commit adequate personnel for performing audits.

• Coordinate Process Safety Code audits with other regular audits (e.g., loss prevention, boiler, environmental) to avoid duplication.

• Establish a system to measure the effectiveness of the audit program.

• Develop lists of corrective measures.

3.2 Verify that corrective actions have been implemented in a timely fashion.

• Assign specific responsibilities for correcting identified deficiencies.

• Establish target completion dates along with a resource plan.

• Require documentation of actions that resolve audit recommendations.

• Establish a system to track corrective action efforts. For example, how many were completed last quarter? How many are in progress? How many are behind schedule? How many are under study?

• Establish a priority authorization system for approving resources (i.e., capital items, staff, etc.) for process safety-related items.

PITFALLS AND CONSIDERATIONS

Measurement systems ultimately fail when the gathered data do not match reality. Management must ensure that audits are not carried out in a perfunctory manner. Another pitfall is that of inadequate follow-up. Once an audit is complete, resolution of all items must be vigorously pursued. The importance of establishing appropriate process safety priorities must be promulgated throughout the company and then reinforced in performance appraisals. Just as company accountants monitor accounts payable, so too must process safety specialists track the status of corrective actions to improve process safety performance.

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Management Practice 4: Incident Investigation

Investigation, reporting, appropriate corrective action and follow-up of each incident that results or could have resulted in

a fire, explosion or accidental chemical release

Process safety-related incidents are unplanned events that result in undesired consequences such as fires, explosions or releases of toxic/hazardous materials. Incidents of interest include not only those that propagate to a fully developed catastrophic result, but also precursor events, those near misses that by circumstance or design were terminated before a more severe consequence resulted.

Major incidents may recur in the same unit, at the same facility, within the same company and within the industry unless forceful measures are taken to prevent them. Thus, in order to continually improve process safety performance, a company should have an aggressive and persistent program for investigating incidents, ferreting out causes, and determining effective corrective measures. Periodically reviewing the circumstances of previous accidents and determining whether similar circumstances have evolved again is an especially effective process safety assurance activity.

PROCESS SAFETY ACIVITIES

4.1 Establish an incident investigation policy.

• Define internally reportable incidents and develop reporting criteria.

• Develop an environment where employees feel empowered and obligated to report incidents, and feel safe from retribution.

• Create an incident review committee or other structure, with senior management involvement, to ensure incident reports are acted upon by the company. Highlight recommendations from previous incidents that have yet to be implemented.

• Plan for dealing with incidents in advance. This will help maximize the safety benefits of lessons learned.

• Define lines of authority and priorities when dealing with incidents (e.g., securing the site to prevent further harm, site preservation for collection of data and evidence, cleanup and reconstruction). Ensure proper coordination with emergency response personnel

42 Develop an incident investigation program.

• Create incident investigation guidelines.

• Establish investigation team criteria and lists of company resources and sources of special expertise.

• Provide the necessary tools and guidance for team members.

• Establish a mechanism for tracking incident reports. Ensure that it follows the life cycle of incidents as they occur, as they are investigated and as results are acted upon.

• Provide criteria for intracompany involvement. Define appropriate roles for legal, public relations and labor relations departments. Sometimes it will be appropriate to perform an investigation under attorney-client privilege.

• Provide resources for enlisting third-party participation by outside experts and specialists needed because of unavailability of company personnel.

• Perform company wide incident drills to test mobilization abilities and investigate how emergency response was performed during actual incidents.

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• Ensure the separation of the investigation activity (e.g., data gathering) from follow-on efforts (e.g., disciplining of employees).

4.3 Communicate lessons learned to all appropriate company groups.

• Maintain an incident log and frequency monitoring system. Ensure that incident investigation reports become a part of the process hazards information package (MP8).

• Provide guidelines for writing investigation reports, having them reviewed for other considerations (e.g., legal and public relations) and distributing them to appropriate personnel within the company.

• Develop recommended actions from the results of an investigation. Assign responsibilities and schedules for implementing corrective measures.

• Provide results and lessons learned (MP5) to appropriate authorities and to other company divisions that could be affected (e.g., other company units with similar processes). Coordinate information sharing using CAER outreach

(MT6).

• Provide feedback, from the investigation program, on ways to improve company response to incidents. Periodically review the results from past investigations with new employees.

PITFALLS AND CONSIDERATIONS

Lack of adequate planning is a major cause of failure to properly investigate and learn from incidents. Local responsibility must be assigned for site preservation. Ultimately, the success of a company's program is dependent upon how thoroughly and quickly the results are communicated and acted upon within operating facilities. If legal issues and boundaries have not been agreed upon in advance, then the information flow is stymied and valuable time may be lost.

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Management Practice 5: Information Sharing

Sharing of relevant safety knowledge and lessons learned from such indents with industry, government and the community.

Communicating important process safety information to other companies may help prevent accidents and save lives. Responsible sharing of information can be an important factor in maintaining credibility with the local government and communities surrounding a facility.

PROCESS SAFETY ACTIVITIES

5.1 Establish a formal policy for timely publication of process safety related information.

• Prepare a written internal clearance procedure involving appropriate corporate departments (e.g., legal, public relations, technical).

• Encourage in-house legal counsel to establish prerelease approval criteria for generic information, protecting confidential/proprietary data.

• Identify communication media with which information should be routinely shared.

• Encourage publication of process safety papers and presentation of talks to process safety-related conferences and industry groups.

5.2 Establish a formal policy for employee participation with outside groups to foster information sharing-

Identify local groups that should receive company information and support.

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5.3

Coordinate information sharing policies with tent investigation practices (MP4) and emergency management (MP16) for publication of accurate information during prolonged emergency situations.

• Designate a room with a telephone for the media to use during an emergency.

• Designate specific plant personnel to interact with local media until corporate staff support arrives.

PITFALLS AND CONSIDERATIONS

Companies that perfunctorily restrict sharing of information hurt themselves and the industry in the long-run. An uninformed public promotes suspicion, not trust. Companies should proactively encourage sharing of appropriate information that could improve industry's overall process safety performance. However, special training of company technical spokespersons may be required for "media" events. Plants must be prepared to supply facts and cooperate with the media during emergencies to avoid incorrect and damaging speculation that inevitably occurs in the absence of timely information sharing. Technical papers or press releases should be reviewed to prevent disclosure of inaccurate or inflammatory information.

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Management Practice 6: CAER Integration

Use of the CAM process to assure that public comments and concerns are considered in design and implementation of the facility's process safety system

The CAER Code of Management Practices provides for reliable emergency response to facility events that could have "beyond-the-fenceline" effects and promotes public dialogue through outreach to responsible community organizations. The Process Safety Code of Management Practices supports the objectives of the CAER Code; companies should use the process already set up through CAER to consider public concerns in the safe operation of process facilities. Companies should take advantage of opportunities to share appropriate technical information and relevant results from internal process hazard reviews with Local Emergency Planning Committees (LEPC).

PROCESS SAFETY ACTIVITIES

6.1 Implement the proactive features of CAER that relate to process safety outreach to the public.

• Review the commitment stated in the CAER Code.

• Establish coordination between company CAER representatives and those responsible for process safety issues.

• Use existing CAER outreach mechanisms to advise the public of company development and process expansion plans.

• Use the CAER process to open a dialogue with the community to receive their concerns about plant activities connected with process safety.

• Act on the community's advice and provide feedback concerning company decisions and their impact on process safety to the community within a reasonable time.

• Encourage company employees to be process safety ambassadors within the community (e.g., giving talks and distributing information concerning process safety provisions that exist to limit community risk, being a member of an LEPC).

• Use opinion surveys to perform periodic evaluations of the effectiveness of process safety outreach.

PITFALLS AND CONSIDERATIONS

Don't attempt to implement this Management Practice without coordinating it with the existing CAER framework set up within your company. Carefully select information that is appropriately presented for layperson review - don't just distribute lengthy technical reports. On the other hand, don't overly restrict the furnishing of pertinent process safety data because you think it's too complex for the public to understand. Try to avoid the appearance of hearing, but not listening; respond to public concerns in a timely fashion.

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PROCESS SAFETY MANAGEMENT OF TECHNOLOGY

Management leadership can focus on several areas to improve process safety. One general area is Technology. Managing process safety through technology involves making the inherent design and operating characteristics of a new process as free as possible from major hazards. This is achieved through proper process design; retention of important process information concerning potential hazards; and examination of the possible causes, effects and significance of equipment failures, instrument and software malfunctions and human errors. In addition, programs should be established to identify and control changes to process technology and operation so that new hazards are not inadvertently introduced.

The goal of the Process Safety Technology element is to ensure that chemical processes are designed and operated with a level of risk that is acceptable to the company, and ultimately to the regulators and the public. Four Management Practices (MPs) have been defined as essential components of process safety technology. The following sections discuss each practice. First, process safety activities are defined that may be useful in your quest for continual process safety improvement. Not all of these activities are appropriate for every company or for every facility within a company. You should choose the ones, and perhaps add others, that fit your company's needs and culture. Secondly, examples are given for each activity to illustrate how companies like yours have successfully implemented them. Finally, pitfalls and considerations are discussed so that you will be better equipped to meet future process safety challenges. Space is provided for you to take notes and to personalize this guide with ideas that you think may help your company or facility.

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Management Practice 7: Design Documentation

Current, complete documentation of process design and operating parameters and procedures

The long-term safe operation of a process facility depends on company personnel having a thorough knowledge of the design bases for the processes. Maintaining current, complete design documentation for mature processes is not easy, but it is essential for process safety success. If "upto-date" information is not available when a process change is considered, designers could make the wrong choice in specifying equipment size, materials of construction, new operating limits and so forth. Preserving this institutional memory along with process hazards information (MP8) forms the foundation for process hazard evaluations (MP9) and the plant's management of change process (MP10). Efficient management of design documentation helps improve a company's ability to manage the risk of chemical operations.

PROCESS SAFETY ACTIVITIES

7.1 Develop a system for retaining an archive of current design information and a history of significant revisions.

• Develop and retain process description, chemistry and reaction data.

• Develop and retain process flow sheets, P&)Ds and interlock logic diagrams (e.g., use computer-aided drawing system).

• Develop and retain equipment fabrication data sheets and inspection records.

Develop and retain design bases for process equipment, especially safety systems (e.g., assumptions for relief valve sizing, rationale for interlocks and safety-related alarm setpoints).

Determine criteria for deciding how frequently (e.g., yearly, every five years or only when significant changes occur) to formally update the design information archive. Dovetail with the management of change system (MP 10).

7.2 Update safe operating ranges for key process variables.

Define safe operating limits based on current process feeds and recipes.

List limiting conditions for continuous process operation (e.g., Should operations be allowed to continue without the emergency shutdown system in service? For how long?).

Establish limits for operating ranges and procedures for dealing with equipment failures or abnormal process parameters.

Explain the consequences of exceeding stated safety limits.

7.3 Procedures for normal operations and for dealing with pros upsets and emergencies must be current

Provide dated copies of procedures in control rooms.

Periodically review procedures with operators on the job. Verify that actual practice is reflected in procedures.

Create a mechanism to solicit and review operator suggestions for procedure changes.

Consider storing all procedures in a computer data base, so the current procedure can be printed out when needed.

Require all non-routine jobs to have written procedures that have been evaluated by the facility's management of change process (MP 10).

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PITFALLS AND CONSMERATIONS

Production pressure during the last stages of construction, maintenance turnaround and start-up may impair a company's abilities to keep their process design documentation up-to-date. Changes implemented with no formal review will allow the actual process design and operating practices to become different from the design of record. The key to maintaining "evergreen" documentation is to do it right once, and then, with the help of a good change control process (see MP10), to regularly update the design package throughout the process lifetime.

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Management Practice &Process Hazards Information

Current, complete documentation of information relating to the hazards of materials and process technology

The documentation of process hazards should cover all materials and operations used in a process. This information must be current and readily available to personnel, because maintaining a good understanding of the hazards that surround them leads to more deliberate and safer operations. Combined with accurate design documentation (MP7), this information is vital to long-term safe operation and regulatory compliance. Recent right-to-know regulations dictate that much of this information be made available to the public.

PROCESS SAFETY ACTIVITIES

8.1 Maintain current, accessible information on material characteristics (e.&, tarzicity, flammability, reactivity)

• Establish a data base for physical and chemical property data. Computerize, if possible, to improve accessibility.

• Maintain up-to-date MSDSs in all operating units.

• Maintain a company archive of hazards information that can be easily updated.

• Establish a purchasing system to ensure that essential hazards information for new materials is available when required (e.g., upon delivery or when drawn from the storeroom for use in the field).

8.2 Maintain a system for malting current process hazards information available to employees-

• Develop process hazards information articles for the plant newsletter.

• Maintain files of process hazards data in an accessible form (e.g., computer data base) that all affected personnel can use.

• Periodically review important process hazards data with the operating staff (e.g., monthly shift safety meetings).

• Provide a means for soliciting input from employees about ways to upgrade hazards information.

PITFALLS AND CONSIDERATIONS

There is a vast amount of material hazards information that must be kept current and available to employees. Many materials unknown to process hazards information managers can accumulate in a facility. Personnel can often use normal supply requisition procedures to order new materials to experiment with, and it is difficult to control these new materials. Purchasing controls must be established to ensure that any new materials used in the facility are logged into the process hazards information system and that data on these materials are made available in a timely fashion to potentially affected employees. It is especially difficult to control the use of "foreign" materials by outside contractors or sample materials provided by vendors who want you to try their products. Changes to existing process hazards information should be made through the management of change program (MP 10).

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Management Practice 9: Process Hazard Analysis

Periodic assessment and documentation of process hazards, and implementation of actions to minimize risks associated with chemical operations, including the possibility of human of error.

Process hazard analysis identifies and determines the significance of process safety-related hazards so that appropriate risk control measures can be implemented by management. Hazard reviews are held periodically throughout the life cycle of a process. These studies use the results from many other process safety activities and combine them with systematic approaches to evaluate the possible causes and effects of equipment failures, control and software malfunctions and human errors. Corporate policies and procedures should require thorough documentation not only of the hazard evaluation itself, but also of management's response to the study's findings and implementation of appropriate risk reduction measures.

A wide variety of hazard evaluation techniques are used in the chemical process industry. Some of these (e.g., What If, HAZOP) are purely qualitative and require modest training and expertise to use. Other approaches (e.g., fault trees, event trees, dispersion models) produce quantitative results, and are much more resource intensive. The most detailed of all hazard evaluation approaches is quantitative risk assessment. In this approach, various techniques are used to estimate the numerical frequencies and consequences of potential accident situations.

The results of process hazard analyses identify important weaknesses in design, control systems and procedures so that appropriate risk reduction measures can be applied. Generally, all of these analyses are performed by interdisciplinary teams.

PROCESS SAFETY ACTIVITIES

9.1 Develop a formal risk management program.

Consider using the CCPS program defined in Guidelines for Technical Management of Chemical Process Safety.

9.2

Integrate process hazard evaluations into the overall project management process.

• Include funding and schedule allowances in capital projects.

• Establish a formal requirement for design reviews.

• Provide results to management to determine when prestart-up reviews are necessary (1VIP13).

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Determine a priority for performing hazard evaluations of existing facilities.

• Identify requirements of federal and state regulations.

• Use appropriate industry standard.

• Perform risk screening/ranking studies to determine priorities.

9.4

Create a program for periodic reevaluation of facilities at established intervals.

• Apply timetables required in federal and state regulations.

• Use operating experience and capital expansion plans to help determine appropriate schedule.

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9.5

Provide the necessary specialized training to develop in-house expertise in hazard evaluation, or identify qualified

external resources.

• American Chemistry Council seminars and guides.

• AIChE continuing education courses.

• CCPS series of guidelines.

• Training courses from qualified consultants.

9.6 Develop a consistent corporate strategy for risk management (eg, process hazard review protocol, use of generic risk control measures, levels of risk acceptance).

9.7 Provide periodic auditing of the risk management process and risk control decision

PITFALLS AND CONSIDERATIONS

Unless adequate centralized guidance is provided, large companies with many facilities can find themselves with disparate applications of risk management strategies. Adopting vastly different risk control strategies at similar plants could leave the company vulnerable to regulatory citations or other legal liability based on a one-to-one comparison of these facilities. Risk management and process hazard analysis programs should be reviewed by in-house counsel to limit legal liability while preserving the ability to share essential process safety information with industry, regulators and the public.

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Design Documentation

Management Practice 10: Management of Change

Management of changes to chemical operations to maintain or enhance the safety originally designed into the facility.

Changes to complex chemical processing facilities inevitably occur over time. Many changes are good when they are well-planned, and they often result in increased productivity and safety. However, experience has shown that uncontrolled change can be a frequent contributor to accidents.

Company management should have systems in place to manage the changes that occur in organizations, procedures and processes. The purpose of this management practice is to establish management of change as a formal mechanism for ensuring that changes do not degrade the safety that was purposefully designed into the original process operation.

PROCESS SAFETY ACTIVITIES

Generally, three types of changes occur: (1) organizational, (2) physical and (3) procedural. The following activities may be pertinent to control of one or more of these types of changes.

10.1 Define change and establish a system to identify incipient changes before they are implemented.

• Have all work orders reviewed.

• Train operating, engineering, purchasing and maintenance personnel to recognize changes. Develop a timely, practical mechanism for alerting management of these changes.

• Provide guidelines illustrating how subtle changes can have serious process safety implications and which changes only represent "replacements in kind."

• Establish a test authorization procedure to manage temporary changes in facilities and procedures.

10.2 Establish a change review system.

• Require proposed changes to be documented.

• Subject all changes to process safety scrutiny through use of appropriate hazard review techniques.

• Specify who has the authority to approve changes.

• Provide a mechanism for timely approval of changes during peak workloads (e.g., maintenance turnarounds).

• Establish time limits for temporary changes, with specific renewal requirements.

10.3 Conduct periodic audits of management of change compliance.

• Verify that documentation updates have occurred in a timely fashion.

• Determine if training programs were modified to consider approved changes.

• Inspect operations through random walk throughs.

• Survey procedural changes by witnessing operator and maintenance personnel performing modified tasks.

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10.4 Consider the impact of organizational or policy changes on process safety

• Identify functional changes in corporate staff.

• Point out changes in local laboratory analysis support.

• Scrutinize changes in vacation scheduling

• Assess shift staffing policy.

PITFALLS AND CONSIDERATIONS

All changes must be identified and reviewed before implementation. However, at the same time, company personnel must have the flexibility to operate within the envelope of prescribed safe limits. Avoid overly complicated paperwork schemes. For management of change to really work, everyone must be educated about its importance.

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PROCESS SAFETY MANAGEMENT OF FACIL1TIES

Managing process safety in facilities involves operating processes with the goal of preventing fires, explosions and accidental releases of chemicals that, could affect employees, the public and the environment. This is achieved through prudently locating operations, constructing process facilities and fabricating equipment according to sound engineering practice, reviewing and learning from operating experience, properly maintaining and inspecting equipment throughout the life of a plant and managing the risk of operations prior to and during emergencies.

The Process Safety Management of Facilities element is closely allied to the Technology element in that the general process design is performed according to the practices in the Technology element, and the detailed design, construction and operation of processes is performed according to the practices specified in the Facilities element. This natural overlap should not be a cause for confusion; rather, having common features among Management Practices within the two elements helps ensure complete coverage of process safety throughout the life cycle of a process.

Six Management Practices (MPs) are defined as essential components of the Facilities element. The following sections discuss each practice. First, process safety activities are defined that may be useful in your quest for continual process safety improvement. Not all of these activities are appropriate for every company or for every facility within a company. You should choose the ones, and perhaps add others, that fit your company's needs and culture. Secondly, are given for each activity to illustrate how companies like yours have successfully implemented them. Finally, pitfalls and considerations are discussed so that you will be better equipped to meet future process safety challenges. Space is provided for you to take notes and to personalize this Guide with ideas that you think may help your company or facility.

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Management Practice 11: Siting

Consideration and mitigation of the potential safety effects of expansions, modifications and new sites on the community, environment and personnel

Selecting the location for a new process facility or a major unit expansion can have a significant effect on the potential safety and environmental risk of a facility. Sites for new construction should be selected taking into consideration a multitude of technical, regulatory and political factors. Space for expansion at a particular facility may be limited because of a lack of suitable land. Nevertheless, process safety issues should be foremost in the minds of facility planners because of the potential impacts that new or modified processes can have on existing communities and process facilities.

PROCESS SAFETY ACTIVITIES

11.1

Establish criteria for site selection and plot plan layout that include consideration of the potential impacts and benefits on neighbors, the community and access routes during all phases of a facility's life cycle (including construction impacts)-

Use an interdisciplinary approach to perform studies, reviews and risk assessments to determine the potential impacts and benefits of the proposed facility or expansion.

• Consider such factors as material flammability, toxicity, storage quantities, potential vapor cloud blast overpressures, prevailing wind direction, potential ignition sources and emergency flare thermal radiation patterns when locating plant population centers (e.g., control rooms, offices) within a facility.

• Mitigate potential adverse community impact by appropriate site selection and plot plan layout, consideration of buffer zones, location of units within the site, process storage unit separation and rail and entrance road layout.

• Make process safety considerations part of the siting decision-making package for management along with project cost, work force availability and other regional and local geographic and demographic factors.

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11.2

Utilizing GAER Code principles, establish a continuing dialogue with the community playing commission or an advisory board regarding community input on concerns, demographics, future growth projection and zoning.

11.3 Establish specific management responsibility for setting criteria for site selection and plot plan layout, and establish an approval process for consideration of deviations or exceptions.

PITFALLS AND CONSIDERATIONS

This management practice focuses primarily on minimizing the process safety impacts of facility operation through thoughtful siting. However, the shorter-term impacts of construction and major turnarounds also must be addressed. Unless sites are properly selected and controlled, construction and maintenance activities can also have a negative impact on the community. Employee and public relations can also be affected because of annoyance factors such as noise, odors, traffic and appearance during any phase of a facility life cycle.

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Management Practice 12: Codes & Standards

Facility design, construction and maintenance using sound engineering practices consistent with recognized codes and standards

Government regulations often include by reference certain codes and standards. These specifications form the minimum basis for responsible plant design, construction, operation and maintenance. Many states, municipalities and other government, bodies frequently adopt codes or issue regulations that may be more stringent than those mandated on a national level.

This management practice advocates the use of "sound engineering practices." Such practices frequently extend beyond mandatory codes and are generally known by experienced professionals in the design, construction and maintenance business. These practices typically manifest themselves in the internal engineering, design and installation standards that are compiled and maintained by responsible engineering and construction contractors, by many manufacturing firms and by insurers. Supplementing such internal standards, and sometimes incorporated within them, are the many voluntary and consensus codes and standards.

PROCESS SAFETY ACTIVITIES

12.1 Identify and comply with all pertinent government regulations and mandatory codes and standards relating to process safety.

12.2 Identify, use and comply with voluntary and consensus codes and standards that are related to process safety and are applicable to engineering, construction and maintenance activities. For example, contact the following groups:

AIChE

API

CGA

AIHA

ASTM

ISA

ANSI

ASME

NFPA

12.3

Where outside contractors are hired for engineering, design, construction or maintenance, select contractors who are familiar with and capable of complying with regulations and appropriate consensus codes and standards.

12.4

Ensure that construction is performed by qualified work crews and is supervised by capable individuals.

12.5

Establish a program of regular equipment inspection, testing and maintenance that complies with applicable code or regulatory requirements and is carried out by qualified individuals.

12.6 Audit compliance with applicable requirements, and implement timely corrective action as appropriate throughout the plant life cycle.

12.7 Assign responsibility and establish accountability at the local facility for compliance with the applicable requirements identified above.

PITFALLS AND CONSIDERATIONS

Codes, standards, laws and regulations are recognized to be dynamic, complex, interlocking and under continual revision. For this reason, engaging properly trained, qualified professionals who are cognizant of pertinent codes and standards is of critical importance to all aspects of safe plant design, operation and maintenance. Local plant management should avail themselves of corporate staff resources as well as outside experts in an effort to stay up-to-date on applicable regulatory requirements.

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Management Practice 13: Safety Reviews

Safety reviews on all new and modified facilities during design and prior to start up

Safety reviews described in this management practice should focus on physical, on-site inspection during construction and commissioning of processes to ensure that new or modified facilities are built in accordance with intended design and are safe for start-up and operation. This management practice complements the process hazard evaluations performed during the design phase (MP9). A primary goal of the practice is to prevent surprises during start-up and initial operation.

Such safety reviews should be repeated whenever a facility is revised, expanded or otherwise modified in order to ensure that original safety built into the facility is not compromised. It should be recognized that any change in a facility, whether in hardware, procedures or operating conditions, if not monitored and controlled (W10), may represent a threat to safe operations.

PROCESS SAFETY ACTIVITIES

13.1 Establish an interdisciplinary safety review team (or teams for large, long-duration projects), which is essentially independent of those responsible for design and construction, to follow and evaluate the ,, construction and commissioning of a project.

13.2 Establish authority/responsibility for safety approval of all new projects and modifications.

13.3 Review projects during the design stage and/or participate in process hazard evaluations (MP9), and provide

appropriate safety related requirements to those responsible for design.

13.4 Perform periodic on-site inspections during the construction stage of a project to verify that installation is in accordance with design.

• Compare construction work to appropriate drawings (e.g., P&IDs, isometrics).

• Have a quality assurance program in place that includes inspection and verification of construction materials.

• Inspect and verify pipe and valve schedules.

• Verify electrical classification.

• Inspect electrical seal-offs.

• Verify maximum allowable working pressure.

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13.5

At mechanical completion, verify that critical checks and tests have been properly completed -

• Pressure test piping, equipment, seals, gaskets, etc. (hydrotest and/or leak detection as appropriate).

• Verify safety/relief valve settings (and test if necessary).

• Flush, clean or pickle piping and equipment as appropriate.

• Stroke all automatic or remote-controlled valves.

• Calibrate instruments.

• Proof test-electrical circuits, switches, computer interfaces and software.

• Check control logic, interlocks and emergency shutdown controls on an item-by-item and a system basis, as may be feasible.

13.6 Establish a formal system to develop punch lists; to document, communicate and deficiencies revealed at any stage of safety reviews; and to follow up, reinspect and retest as necessary.

13.7 Perform a prestart-up safety review of all new and modified facilities, including verification that operational and maintenance procedures are in place and operators are trained (see MP19), just prior to startup and initial operation.

13.8 In order to test system integrity and controls, use water or other non-hazardous materials (where feasible) to operate new processes prior to introducing hazardous materials or catalysts.

PITFALLS AND CONSIDERATIONS

Prestart-up safety reviews are usually performed under intense schedule pressures. They are usually the last hurdle before processes are released for production and the propensity for cutting corners must be avoided. Efforts to check out newly constructed or modified processes and those that have completed maintenance turnarounds should receive schedule priority.

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Management Price 14: Maintenance and Inspection

Documented maintenance and inspection programs that ensure facility integrity

Process equipment that is properly designed, fabricated, installed and operated should provide reliable service - if it is adequately inspected, tested and maintained over the life of the facility. A consistent preventive maintenance (PM) program that is designed to uncover hidden flaws will help ensure incident-free operation. Thorough, periodic inspection and testing helps detect incipient failures and latent defects that could defeat system integrity or function. Inspection, testing and maintenance activities should be documented so that an adequate audit trail exists to verify compliance with applicable program guidelines. These records are essential as a basis for reevaluating test and inspection frequencies and maintenance procedures.

PROCESS SAFETY ACTIVITIES

14.1 Develop written programs.

• Perform quality assurance inspection of vendor-supplied components.

• Construct, install and perform functional checks of new equipment.

• Establish a preventive maintenance management system for routinely servicing equipment.

• Develop a critical equipment checklist.

Perform regular inspection and non-destructive testing of major vessels, tanks and critical piping. Include general corrosion testing to confirm acceptable code allowances as well as for discovering special internal and external problems (e.g., pitting or stress cracking).

Regularly proof-test standby equipment, critical alarms, interlocks and safety systems.

14.2 Establish approved inspection procedures and methods for performing various maintenance and testing tasks.

• Define criteria for decisions concerning whether equipment is suitable for continued service or should be replaced.

14.3 Define appropriate maintenance and inspection frequencies for specific equipment.

14.4 Main personnel to use proper procedures and tools. Provide documentation as proof of training and qualification.

14.5 Create appropriate administrative controls to ensure that outside contractors and vendors use approved procedures

and methods and that personnel are qualified to perform the work.

14.6 Develop a documentation system for recording the results of all inspections and tests. Use this system to reevaluate

material selections, maintenance procedures and inspection frequencies.

P1TFALLS AND CONSIDERATIONS

Most companies have maintenance, inspection and testing programs. Documentation of these activities should be rigorously performed. Records management is important if these programs are to prove the pedigree of critical equipment over the lifetime of a facility. Also, be careful that PM programs not only address economic issues (e.g., cost of parts, repairs and process downtime), but also focus on discovering incipient failures to help ensure facility integrity.

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Management Practice 15: Multiple

Sufficient layers of protection through technology, facilities and personnel to prevent escalation from a single failure to a catastrophic event

Catastrophic accidents can occur either because of a lack of sufficient safety systems or because the existing redundant safety systems were defeated by a single common cause. The Multiple Safeguards management practice focuses on the

strategy of

providing diverse layers of protection (i.e., a defense-in-depth strategy) in a facility to limit the risk of

chemical accidents. It builds on the results of many of the activities outlined in the Process Safety Code. Properly applied,

diverse, multiple protection schemes can minimize the possibility that single failures can propagate into catastrophic accidents.

This Management Practice recommends the application of multiple layers of protection with the following hierarchy.

1. Technology - the first consideration should be, wherever feasible, to choose minimum hazard or inherently safer technology.

2. Faces - hardware safety is then applied in the form of design safety factors, emergency controls, fire control systems, back-up power supplies, etc.

3. Personnel - finally, protection layering is completed by proper training, emergency response procedures, etc.

This Multiple Safeguards management practice focuses on protection layers that can be designed into facilities.

PROCESS SAFETY ACTIVITIES

15.1 Analyze off-normal operation, emergency conditions and protection requirements in all process hazard evaluations

(MP9).

15.2 When feasible, apply adequate safety factors in equipment design to accommodate worst credible case, upset or emergency conditions.

15.3 Install secondary containment, flaring or in~neration (as opposed to relief to atmosphere) in the design of emergency relief systems for flammable or hazardous materials.

15.4 Use early leak detection systems (eg, flammable vapor analyzers, on-line chromatographs) tied into alarms or automatic emergency controls for vulnerable equipment (eg, rotary equipment seals).

15.5 Design equipment and piping with adequate lock-ouut devices (eg., isolation valves, line blinds, purge connections) to allow safe maintenance.

15.6 Provide release mitigation systems (eg, water curtains, foam systems, emergency scrubbers) for areas susceptible to major hazardous leaks.

15.7 Install meeting and/or explosion detection/suppression systems for equipment that contains flammable vapors or dusts.

15.8 Provide redundant process controls and/or back-up instrument power for critical operations-

15 .9 Use fire-proms automatic or remote-operated valves that can isolate critical equipment or process units.

15.10 Identify critical safeguards list for use in maintenance and inspection program (MP14).

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PITFALLS AND CONSIDERATIONS

There are two Achilles' heels for some supposedly redundant protection systems: (1) the systems are not truly independent, and they are subject to common causes of failure (e.g., electric power, instrument power, cooling water, fuel supply) and (2) the standby systems are not regularly proof tested to ensure operability in the event of an authentic demand. Process safety specialists should carefully scrutinize multiple layers of safety systems and use the strategy suggested for providing diversity and reliability in facility safeguards through technology, facilities and personnel.

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Management Practice 16: Emergency Management

Provision for control of processes and equipment during emergencies resulting from natural events, utility disruptions and other external conditions

Plant emergencies and events external to the process or facility can occur that may jeopardize the ability to adequately control equipment and processes within safe limits. For the purpose of this element, "external conditions" refers to those conditions or events that are beyond the control of the process operator, and as such can be outside the company's facility, or inside the facility but simply beyond the process battery limits. Some natural events, such as weather extremes, can be compensated for by control systems, and others, such as earthquakes, through design practices. Utility disruptions, such as partial or complete power failure, cooling water failure, etc., may require auxiliary back-up supply sources or initiation of an orderly and safe automatic shutdown of the equipment or process. Remote or automatic operation of shut-off valves may also be appropriate to isolate process units, tank farm storage, etc., during such emergencies. Redundant or emergency control systems should be independent of primary controls to be most effective.

PROCESS SAFETY ACT

16.1 Identify and consider possible abnormal weather and seismic phenomena (eg., extreme cold, high wind, flash floods and earthquakes) in equipment and facility design and operation. Identify and comply with local building codes and zoning regulations.

16.2 Identify and consider the potential effects of emergency conditions in neighboring plants and access routes while conducting facility design and plot plan layout.

16.3 As appropriate for hazardous processes, consider an emergency shutdown mode in the process control design to handle conditions where an orderly shutdown may not be possible.

16.4 Consider providing safe haven control rooms, backup communications systems, and spare emergency equipment when designing facilities.

16.5 Schedule emergency shutdown drills to practice response to external emergencies and process upsets. Involve appropriate outside organizations (e-g, Coast Guard, local fire departments, mutual aid groups). Use the CAER process to advise the public (1V1P6).

PITFALLS AND CONSIDERATIONS

Systems and procedures for managing plant process emergencies are essential to limiting the risk to employees and the public. However, unless contingency plans are tested in exercise drills, they (and the associated emergency equipment) may be ineffective when an actual emergency occurs.

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MANAGING PERSON FOR PROCESS SAFETY

Management of process safety through proper control of technology and facilities cannot be effective unless proper consideration is given to the safety contributions made by people. Personnel issues that affect process safety performance exist in all activities in a facility. Managing process safety through effective hiring, training and proficiency practices and human factors engineering can be the most important way of limiting the risk of chemical operations.

The Personnel element of this Process Safety Code recognizes that safe process operations are dependent upon the skills and knowledge of qualified employees. The goal of the Personnel element is to ensure that acceptable levels of competence are continuously maintained for workers in a facility - especially for those people in safety-critical jobs - including contractors. Six Management Practices (MPs) have been defined as essential components of the Personnel element. While these practices focus primarily on safe work activities of operating and maintenance personnel, some of the practices will be relevant to staff and management employees.

The following sections discuss each management practice. First, process safety activities are defined that may be useful in your quest for continual process safety improvement. Not all of these activities are appropriate for every company or for every facility within a company. You should choose the ones, and perhaps add others, that fit your company needs and culture. Secondly, examples are given for each activity to illustrate how companies like yours have successfully implemented them. Finally, pitfalls and considerations are discussed so that you will be better equipped to meet future process safety challenges. Space is provided for you to take notes and to personalize this Guide with ideas that you think may help your company or facility.

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Management Practice 17: Job Skills

Identification of the skills and knowledge necessary to perform each job

The physical and mental requirements of each job at a chemical process facility should be identified and understood. Human factors methods can be used to optimize the man-machine interfaces so that realistic expectations of reliable human performance can be established. These job descriptions and expectations should form the basis for hiring programs and job advancement decisions. Implementing this management practice should contribute to satisfactorily trained employees being placed in the appropriate work assignment to help ensure safe plant operations. These results can also help define the content for initial training programs (MP19) and establish criteria for employees to qualify for independent work (1VIP20).

PROCESS SAFETY ACTIVITIES

17.1 Analyze operating and maintenance job functions to determine which jobs can significantly affect process safety.

• Use human factors methods to identify individual job tasks.

• Integrate the results of process hazard reviews that have identified critical tasks and actions.

• Determine the knowledge and experience required of persons performing each task or set of tasks.

• Construct written descriptions that profile job requirements.

• Identify the safety criticality of jobs and tasks to provide input to training and retraining programs.

PITFALLS AND CONSIDERATIONS

An operator whose job it is to respond to a unit upset by activating a shutdown switch is in a critical safety position. However, many employees in a facility play a role in process safety assurance, even though the bulk of their job may be routine. For example, a clerk that inadvertently logs in and marks a brass thermowell as suitable for service in a hydrogen peroxide storage and feed system is making a big mistake that could have significant safety consequences. Employee job descriptions and safety rankings must not get bogged down by perfunctorily classifying most jobs in the facility as safety critical. They must instead distill those important tasks and highlight them for proper employee orientation and training.

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Management Practice 18: Safe Work Practices

Establishment of procedures and work practices for safe operating and maintenance activities

Concise, well-written, safe work practices and procedures equip knowledgeable personnel to manner. These practices and procedures bridge the gap between training and experience and offer employees critical guidance on how to protect themselves, other employees and the public from human error-induced accidents. The results from management programs are used to help develop and refine initial training programs and recurrent demonstration of competency.

PROCESS SAFETY ACTIVITIES

18.1 Using the results from job and task analyses (MPl'n, develop safe work practices for discrete tasks performed by operating and maintenance personnel.

• Develop and implement proper methods for taking laboratory analysis samples.

• Define the use of specialized tools and equipment.

• Define the use of personal protective equipment.

• Develop recognition of hazards and appropriate emergency actions through the use of techniques such as Job Safety Analysis.

• Describe the use of lockoutltagout procedures, hot work permits, heavy lifting permits, confined space entry procedures and special activity (e.g., line break) permits.

18.2 Develop clear, written procedures for normal operating and maintenance activities.

• Develop clear instructions and checklists for start-up, normal operation, standby, recirculation and normal shutdown actions. Include figures and illustrations for complicated tasks or refer to standard operating procedures for more information.

• Develop practical checklists for performing routine preventive maintenance on critical process equipment items.

• Develop procedures explicitly dealing with process upsets and emergencies (e.g., loss of containment events).

• Include essential safety equipment and personnel needed in routine and emergency maintenance activities.

18.3 Create a mechanism for employees to give fey on problems encountered in the use of established work practices and procedures.

• Conduct regular shift meetings to discuss problems.

• Conduct preventive maintenance and turnaround debriefings to share experiences and lessons learned.

• Appoint employee safety committees that review employee suggestions and make recommendations to company management.

• Maintain copies of current safe work practices and procedures in unit and shop locations. Consider using a computerized data base.

• Conduct periodic reviews of all work practices and procedures.

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PITFALLS AND CONSIDERATIONS

Written procedures and work practices that are not developed using employee input are likely to be inefficient and to fall into disuse. Minor changes in work practices accumulate over time, are passed down from veteran to new employees and must be reviewed and incorporated into a formal written program. Contractor work practices should be especially monitored for consistency with company practices (see MP 22).

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Management Practice 19: Initial Training

Training for all personnel to reach and maintain profit in safe work practices and in the skills and knowledge necessary to perform their job

Properly selected employees with skills matched for the job combine with standard work practices and procedures to give

a company the basics for safe human interaction with process equipment and facilities. To ensure that these skills and practices are properly applied, companies must provide thorough training. This training may include classroom, simulation and on-thejob activities and should be supplied by qualified instructors using consistent methods.

PROCESS SAFETY PRACTICES

19.1 Develop a formal program for initial training of new employees and employees placed in new positions or jobs.

• Acquire or develop training materials (e.g., notebooks, videos).

Select and develop qualified instructors.

• Include appropriate subject matter such as hazard recognition techniques, safe operating limits, MSDSs, start-up/shutdown/maintenance procedures and compliance requirements for applicable laws and regulations.

• Develop consistent training plans that combine classroom training with field simulations and on-the-job training. Include key elements and required proficiency levels.

• Use operating personnel to help develop the training program.

19.2 Provide means for evaluating employee proficiency with newly taught material, including tests and standard performance criteria.

19.3 Periodically assess the performance of training instructors and programs through competency checks, opinion surveys, etc.

19.4 Administer supplemental training to employees whenever changes are made to process designs or operating procedures.

PITFALLS AND CONSIDERATIONS

Sometimes, training programs don't use the right blend of classroom and field training. One-dimensional training programs can become stagnant, and instructors can become perfunctory and stale. Total reliance on on-the-job training by experienced operators may result in transfer of shortcuts, unsafe work practices and bad habits to new employees. Periodically changing training instructors and using newly "graduated" employees can help sustain training program interest and vigor.

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Management Practice 20: Employee Proficiency

Demonstrations and documentation of skill proficiency prior to assignment to independent work, and periodically thereafter

Once personnel have been selected based on their skills and are trained to use good work practices and procedures, periodic demonstration of competence is necessary to ensure long-term safe operation. Methods should be developed to ascertain competency and objective performance criteria should be developed to evaluate the effectiveness of on-going training. Also, as process designs and procedures change and as new people are transferred in or advance through the job ranks, undesired changes in work practices may occur. Programs for continual renewal of workforce skills should be coordinated with the facility's management of change process (MP10).

PROCESS SAFETY ACTIVITIES

20.1 Use performance evaluations at the end of training programs.

Develop written or computer-aided tests.

Create on-the-job proficiency tests.

20.2 Identify specific skill or knowledge deficiencies and provide remedial training.

• Create special recurrent training programs.

Establish a work-sharing or buddy system for matching inexperienced workers with veterans.

Identify temporary work positions for employees who fail to meet competency checks.

20.3 Maintain a written inventory of demonstrated skills and knowledge for each employee. Document the training,

testing and qualification criteria.

20.4 Provide opportunities for employees to practice their skills in handling abnormal situations.

• Arrange periodic emergency drills.

• Use process simulators to challenge operators to deal with recovery from upset conditions.

20.5 Periodically audit skill inventories and job assignments to ensure that no one is working in a position for which they are not qualified.

• Establish a system for ensuring adequate screening of vacation relief for normal shifts.

• Develop a pool of replacement employees that can substitute in several key positions.

• Review personnel assignments for maintenance turnarounds, vacation schedule relief, and contractors.

20.6 Periodically survey the performance of the incumbent workforce to determine compliance with practices and procedures.

P1TFALLS AND CONSIDERATIONS

Contractor assignments, vacation relief and turnaround scheduling can result in inadvertent substitution of inadequately trained employees.

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Management Practice 21: Fitness of Duty

Programs designed to assure that personnel in safety critical jobs are fit for duty and are not compromised by external influences, including alcohol and drug abuse

Knowledgeable, well-trained, veteran employees alone will not ensure safe operations that are free from human errors. Employees must also be physically able, mentally alert and capable of using good judgment to properly follow prescribed practices. Encourage employee involvement in the development and implementation of policies and programs to eliminate substance abuse.

PROCESS SAFETY ACTIVITIES

21.1 Have a plan for dealing with cases of suspected incapacity to perform jobs safely.

• Identify jobs considered as "safety critical" where incapacity might result in improper performance and lead to a significant process failure or incident.

Establish employment screening practices.

• Define appropriate facility security measures for search and seizure of contraband in accordance with legal requirements.

• Develop a policy that will be followed by management when incapacity is suspected.

• Establish appropriate rehabilitation/assistance programs for employees.

• Communicate the plan to employees.

21.2

Train supervisors to recognize the symptoms of physical or mental incapacitation and how to deal with it when suspected. The symptoms of drug and alcohol abuse should be given particular attention.

Identify pertinent federal and state regulations.

• Provide guidance to supervisors concerning how to protect the facility while respecting personal rights.

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Integrate "fitness for duty programs with existing human resource policies. Provide a mechanism for employee feedback.

21.4

Train employees to know their responsibilities and personal legal exposures relative to intervention with any employees suspected of performance-affecting incapacities that may affect safe job performance.

PITFALLS AND CONSIDERATIONS

This area raises many legal issues. All "fitness for duty" programs should be developed in concert with legal counsel. Companies across the industry have wide ranging policies with regard to employee assistance programs, second chances, etc.

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Management Practice 22 Contractors

Provisions that contractors either have programs for their own employees insistent with applicable sections of this Code or be included in the member compass program, or some combination of the two

Contractors can influence and be affected by fires, explosions and accidental chemical releases in the same way that member company employees can be. Sometimes, because their work activities are normally associated with plant areas undergoing a "change" of some kind (e.g., inspection, maintenance, construction), contractors may be exposed to particularly hazardous situations. The obligation of training contract employees remains with the contractor firm's management. However, companies should cooperate to the fullest extent possible to assure that the training is carried out by the contractor and should monitor jobsites to enforce applicable company safety policies and procedures.

PROCESS SAFETY ACTIVITIES

22.1 Develop a program for dealing with contractor safety issues.

• Identify types of contractor jobs that have a direct bearing on process safety.

• Establish in the purchasing organization a list of qualified bidders whose safety programs have been determined to be consistent with applicable sections of the Process Safety Code.

• Develop criteria for selecting contractors based on safety performance.

• Establish responsibility for ensuring contractor safety performance while on-site.

• Communicate the program to company employees.

22.2 Provide contractors with company safety program information relevant to the contractor's work and ensure that the contractor's program addresses these requirements.

• Establish contractual provisions that require contractors to acknowledge and adhere to company on-site safety requirements.

• Develop a contractor orientation program package to be supplied to contractors as a part of the purchasing process.

• Establish a procedure to review the contractor safety program, including inspecting written material, contractor facilities and lost-time injury records.

22.3 Provide appropriate safety orientation for contract workers.

• Classify possible contractor job assignments according to the potential for workers creating and/or being exposed to process hazards in the workplace.

• Develop a brief videotape presentation on the general hazards associated with your facility.

• Issue emergency response information cards as a reminder of the actions that on-site contract workers should take.

• Issue dated passes for contractors to document their participation in a safety orientation program.

• Provide periodic refresher orientation on the company's on-site safety requirements for contract workers.

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22.4 Develop a system for monitoring contractor work practices in the field, verifying compliance with company safety policies, and providing feedback to contractor management.

• Perform periodic safety audits of contractor work sites.

• Have contract workers attend appropriate company safety meetings-

• Review documentation associated with hot work permits and related programs to verify contractor use.

• Provide periodic reports to contractors concerning their workers' safety performance.

• Have company maintenance supervisors meet regularly with contractor supervision to discuss safe work practice topics pertinent to their planned activities.

• Develop a contractor recognition program to acknowledge good and improved safety performance of contractors.

• Interact with local contractor associations or councils to discuss common process safety-related issues.

PITFALLS AND CONSIDERATIONS

The bottom line on process safety relative to contractors is that a company should take reasonable measures to assure that contract workers are subject to safety policies, procedures and practices that are equivalent to safety requirements of member companies. Moreover, companies should consistently enforce their own safety rules regarding on-site contractor work activities. The program you employ to promote contractor safety should respect that contractors must retain and exercise the responsibility for training their own employees. However, it is incumbent on facilities that hire contract workers to take reasonable measures to provide adequate information, and to enforce existing safe company work practices in a consistent fashion.

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IMPROVING PROCESS SAFETY PERFORMANCE

The hallmark of the Process Safety Code is the goal of achieving “continual improvement of process safety." To reach this goal, companies must be able to objectively assess their process safety performance. A key question is, What is effective process safety management performance? Ultimately, it is the safe, reliable and environmentally sound operation of chemical facilities as manifested by accident-free experience accumulated over the lifetime of a facility.

At this time there is no technically rigorous method for assessing process safety performance by reliably predicting accident reduction on the basis of current information. The CCPS has embarked on a research program to define measurable process safety attributes and to develop robust methods for assessing a company's performance.

In the meantime, companies will have to rely on classic measures of safety performance such as data on accident rates, lost time injuries, quantities of chemicals released and so forth. But, the goal of continual improvement still remains, and American Chemistry Council members will still be required to perform self-evaluations of their process safety performance.

The self-evaluation is supposed to provide an indication of how well companies are doing at developing and implementing programs directed at satisfying their Process Safety Code commitment. The self-evaluation is not able to focus on the long-term effectiveness of a company's efforts. (That is what the CCPS's efforts are all about.) Rather, it only addresses the issue of compliance with the Management Practices in the Code. Nonetheless, even with this limitation, the self-evaluation is an important feature of the Responsible Care Program. Thus, you must strive for consistency in the manner in which you perform the self-evaluations so that comparison of several evaluations over the years will reveal the continual trend of improvement strived for by successful companies. To aid this effort, American Chemistry Council is planning to hold seminars on the self-evaluation element of the program.

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API-620 Recommended Rules for Design and Construction of Large, Welded Low Pressure Storage ?finks, Seventh Edition, American Petroleum Institute, Washington, DC, 1985.

31.

Guidelines for Vapor Release Mitigation, American Institute of Chemical Engineers, New York, NY, 1988.

32.

Guidelines for Safe Storage and Handling of High Toxic Hazard Materials, American Institute of Chemical Engineers, New York, NY, 1988.

33.

Guidelines for Use of Vapor Cloud Dispersion Models, American Institute of Chemical Engineers, New York, NY, 1987.

34.

DIERS Project Manual, American Institute of Chemical Engineers, New York, NY, 1988.

35.

C. G. Ramsey, R. Sylvester-Evans, and M. A. English, "Siting and Layout of Major Hazardous Installations;" I. Chem. E. Symposium Series No. 71, 1982.

36.

API-510 Pressure Vessel Inspection Code: Maintenance Inspection, Rating, Repair, and Alteration, Fourth Edition, American Petroleum Institute, Washington, DC, 1985.

37.

ASME Boiler and Pressure Vessel Code, Section VIII, Rules for Construction of Pressure Vessels, Division I, American Society of Mechanical Engineers, New York, 1983 Edition.

38.

Chemical Plant and Petroleum Refinery Piping - ANSI/ASME B31.3, American Society of Mechanical Engineers, New York, 1984.

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39.

Trevor A. Kletz, "The Prevention of Major Leaks - Better Inspection after Construction," presented at the 17th

AIChE Loss Prevention Symposium, Denver, CO, August 1983.

40.

T. Lowe and J. Maehin (eds.), New Perspectives in Management Control, New York, St. Martin's Press, 1983.

41.

Joseph A. Marciariello, Management Control Systems, Englewood Cliffs, NJ, Prentice-Hall, Inc., 1984.

42.

R. T. Martinott, "Maintenance Management Systems;' Chemical Week, March 9, 1988.

43.

Robert D. Merrick, "Materials Consideration in Loss Prevention," presented at the API Conference, Fundamental Applications of Loss Prevention, Houston, TX, October 1985.

44.

Guide for Inspection of Refinery Equipment, American Petroleum Institute, Washington, DC, 1957.

45.

W. H. Woolfulk and R. E. Sanders, "Dynamic Testing and Maintenance of Safety Relief Valves," Chemical Engineering, October 26, 1987.

46.

Steve Krivan, "Avoiding Catastrophic Loss: Technical Safety Audit and Process Safety Review;" Professional Safety, 31:2, 1986.

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QUESTIONS AND ANSWERS

The Process Safety Code of Management Practices is the third code developed for the Council’s Responsible Care initiative. During code development, the American Chemistry Council member companies had many opportunities to review and comment on the concepts and language in the Code. It was presented and discussed at two Responsible Care Coordinator workshops, at Public Advisory Panel meetings and at an open member forum prior to final approval by the American Chemistry Council board.

During this review and approval process a variety of questions surfaced about clarification of the intent of the Code language. The following is a list of the more common questions and answers, grouped according to the four Code elements.

MANAGEMENT LEADERSHIP

1. Q. How does one define senior management?

A. Senior management is that level that has the authority to establish policies and authorize expenditures to implement them. As used in this Code, senior management generally includes plant managers and above.

2. Q. What is meant by participation by senior management?

A. Participation in this context refers to activities that convey and reinforce commitment and leadership as well as support the implementation of policies and procedures.

3. Q. Is it necessary to have a writes process safety policy?

A.

Yes.

4. Q. what parameters can be used to measure process safety performance?

A. Each company should establish its own methods of measurement. Accident/ incident frequencies, property loss statistics, audit violations, permit violations, risk reviews and completion of training are a few examples.

5. Q. How should one define the type of incident that should be investigated?

A. There is no single standard that defines the type of incident or near-miss to investigate. Management should establish a formal procedure to investigate those uncontrolled events that have potentially serious consequences.

6. Q. 1What should be done after each incident or near-miss intmestw1im?

A. Corrective actions or method of follow-up should be identified, carried out and communicated as appropriate within the company.

7. Q. What kind of knowledge and lessons learned should be shared?

A. Knowledge and lessons learned that can benefit others because of their general applicability or novelty or unusualness. Member companies may establish procedures to promote sharing knowledge and lessons learned consistent with proprietary and legal considerations.

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8. Q. How much input do you envision our industry receiving from the public sector?

A. The American Chemistry Council fully supports the concepts of working with local communities to listen to community views and concerns and to consider them in plant safety systems. The intent is to discuss major process additions and new grass-roots construction as opposed to minor plant changes. Individual companies are responsible for the safe design and operation of facilities; that responsibility cannot be shared with the public. It is intended, however, that public concerns be considered in design and operation of the facility. The CAER network provides a useful vehicle to accomplish this.

TECHNOLOGY

9. Q.

What type of documentation of process desk and operating parameters should exist?

A. Each operating unit should have up-to-date safety-related information that contains the design basis and procedures (e.g., process flowsheets, piping and instrument diagrams or engineering flow diagrams, equipment drawings, critical operating parameters, electrical area classifications, safety valve capacity information and operating manuals). The documents will serve as the backbone for employee training, hazard evaluation and process modifications.

10. Q. Whatt is meant by operating parameters?

A. Operating parameters are the ranges of conditions (e.g., temperature, pressure and flow composition) within which a unit is designed to operate. Within that range, a unit is expected to operate without any safety problems. For example, a safe operating parameter for a reactor temperature at normal pressure might be -20 ° C minimum to 130 ° C maximum. Operating outside the range could cause instability in the reaction - runaway temperature if above, potential brittle fracture if below.

11. Q. What one some of the types of information needed to define the chemistry?

A. Each reactant and product should have a material safety data sheet. Chemical reaction kinetics and acute toxicity should be known and understood. Reactive chemical performance upon mixing various chemicals in different proportions should be documented. Waste streams should be included as well as reactants and products.

12. Q. What type of procedures should be maintained?

A. Generally, all routine jobs or tasks with process safety implications should have written, step-by-step instructions. These procedures should capture the experience base of the knowledgeable experts. The protective equipment and personnel concerns should be incorporated in the procedures. Also, emergency procedures must be clear and unequivocal.

13. What is the difference between documentation covered in MP7 versus that in MP8?

Q.

A. MP7 refers mainly to design and operating information, while MP8 specifically addresses the hazards associated with the unit being evaluated.

14. Does the reference to risk in the Code imply that we will be required to perform quantitative risk assessments on all our plants?

Q.

A. No. Qualitative analysis alone should be sufficient to satisfy process safety analysis objectives in most cases. In any case, qualitative analysis should be considered prior to performing numerical frequency or consequence calculations.

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15. Q.

fat does periodic assessment of process hazards mean in the Technology element?

A. Each member company should establish its own review frequency based on inherent hazards, operating experience, rate of technology change and other factors. Typical review frequencies range from three to seven years. Under very special circumstances, review frequency may be as short as one year.

16. Q. what is meant by 'management of change"?

A. "Management of change" means having management systems in place that ensure that the original safe design of the unit is maintained and all changes, including minor modifications, are properly reviewed, recorded and communicated.

17. Q. What chance should be coveted?

A. All changes except like-for-like substitutions. Examples include hardware, procedures, raw materials, operating conditions, throughput, personnel, software and control mode.

18. Q.

There does not seem to be a clear distinction between Technology and Facilities - shouldn't these two sections be combined?

A. While it is true that the two sections are closely related and interdependent, Technology (i.e., chemistry and know-how) and Facilities (i.e., equipment and hardware) each deserve an independent focus as related to process safety.

FACILITIES

19. Should the community be consulted when considering potential effects of a new site or new installation?

Q.

A. Yes, using principles of the CAER process.

20. Does thus mean the community has approval or rejection authority over our projects?

Q.

A. No. It means that we should identify and respond to community concerns.

21. Choosing a new plant site involves many complex considerations. Can we realistically expect to completely satisfy all interests?

Q

A. Possibly not, but the Responsible Care Guiding Principles require health, safety and the environment to be priority considerations and such issues must be adequately resolved.

22. Q. Does the Code cover concerns about sabotage or terrorism?

A. Such issues are not intended to be within the scope of the Code. However, good practice in site selection and planning will consider such general security issues as buffer zones, fencing, lighting, entrance gates and security surveillance. Also, mitigation and emergency response measures can help minimize consequences of hostile acts.

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23. Q.

Does "sound engineering price" extend beyond mandatory codes and gins?

A. In many cases, yes. While government codes and regulations may establish minimum legal requirements for plant design, operation and maintenance, member companies are expected to use qualified professionals to identify and apply other engineering practices (such as contained in many non-mandatory or consensus standards or codes) as may be necessary to fulfill our safety commitment to employees and the community.

24. Q.

MP9?

Are "Safety Reviews" as prescribed in MP13 dif fervent from "Process Hazard Evaluations” as prescribed in

A. Yes. "Process Hazard Evaluations" are done during the process design stage and periodically thereafter. They focus on the hazards inherent to the process and the measures taken to control these hazards. "Safety Reviews" use "Process Hazard Evaluations" as a starting point and focus on the physical installation to ensure that it is in accordance with design and is safe to start up and operate.

25. Q Shouldn't "Safety Reviews" go beyond simple field inspection?

A. Yes. "Safety Reviews" may include such things as testing equipment, controls, control logic, interlocks, "water runs;' etc., prior to operation with hazardous materials. In addition, such reviews should also confirm that process documentation and procedures are in place and that operators have been properly trained.

26. Q. Don't a "Preventive Maintenance Program" meet the anent of MP14?

A. To meet the intent of this code practice, the preventive maintenance (PM) program must go beyond operating reliability and economic considerations and address all potential failures that, while perhaps extremely unlikely, could impact process safety. A program to "ensure facility integrity" must search out hidden deterioration and flaws that can result in sudden and unexpected failures that can impact process safety.

27. Q.

WW are some examples of activities that could be included in a PM program to satisfy* MP14?

A. Some examples are: conducting metallurgical examinations for stress corrosion cracking, conducting nondestructive acoustic testing, monitoring compressor vibration, measuring thickness for erosion or corrosion on key parts of pressure vessels and pipelines, verifying quality of construction materials and determining reliability of critical instruments and verifying operability of relief devices.

28. Q. Shouldn't a hierarchy be considered in applying "layers of protection"?

A. Normally, technology should be applied first, choosing an inherently safer or less hazardous process whenever possible. Then, hardware, safety factors, redundant controls, failure detection systems, etc., should be applied. Finally, emergency procedures and personnel training should complement the process and the hardware design.

29. Q. How many layers constitute "sufficient layers of "?

A. There is no absolute answer to this question. The number of layers needed depends on the likelihood of an initial failure, the nature of the consequences and whether additional layers of protection will significantly improve safety. Layers of protection include more than redundant equipment. They may include process techniques, instrumentation and hardware, operating procedures and operator training.

30. Q. What is meant by "external conditions"?

A. By external conditions we mean anything that is beyond the direct and immediate control of the process operator (e.g., natural disasters). Another example might be a fire or toxic release from a neighboring plant, as well as an upset or incident in an adjoining process unit.

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PERSONNEL

31. Q.

We gain our employees thoroughly; why is it necessary to also demonstrate their profiency?

A. Even with the best employee training programs, people learn at different rates and comprehension. An actual demonstration is the only way of being sure that each individual has grasped essential concepts or skills. Demonstrations can involve written tests and/or having the trainee show a qualified observer how they would do a job. In addition, rarely performed procedures (e.g., emergency shutdown) must be practiced to ensure reliability.

32. Q. Do procedures and work practices have to be documented?

A. Generally, yes. Procedures typically require proper execution of several stages. Documented procedures help ensure that a critical action is not overlooked and that the procedure is carried out consistently by everyone.

33. Q. Does the Code require that employees be screened for alcohol and drag abuse?

A. No. The Code requires programs designed to determine fitness for duty.

34. Q. What kinds of jobs are safety-critical?

A. A position is safety-critical when it involves tasks that, if not performed properly, can significantly increase the likelihood of a fire, explosion or accidental chemical release.

35. Q. What is meant by “external influence”?

A. External influences include abuse of alcohol or drugs, but the term also refers to any factor that

might impair judgment, attention or general capacity to perform a job safely. Examples include physical impairment, emotional stress and stress from too much overtime work.

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PROCESS SAFETY CODE RESOURCE GUIDE

Commends and Suggestions

The Responsible Care initiative will evolve considerably over the next few years as member companies implement the various Codes of Management Practices. The American Chemistry Council wishes to capture and share this experience as you find ways to continually improve process safety through efficient implementation of process safety activities. It is also natural to expect that this Resource Guide will become outdated and need revision. Please feel free to use this form (and additional paper, if necessary) to summarize your comments and suggestions for improving this Resource Guide. Please send them to:

Daniel Roczniak, Director American Chemistry Council Responsible Care Team 1300 Wilson Boulevard Arlington, VA 22209

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