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Is Your Process Safety Documentation

Don't wait for a safety audit or OSHA inspection to find out.
By Brian J. Kingsley and David E. Kaelin, Sr., Chilworth Global
Feb 07, 2012
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Process documentation and other process safety information (PSI) play a key role in process safety
management (PSM). Nearly every governing authority, including the US Occupational Safety and Health
Administration (OSHA), and the National Fire Protection Association, as well as insurance providers
require process safety documentation.
While requirements differ slightly among industries, the key documents common to most include:
process description;
process flow diagram;
piping and instrumentation drawing (P&ID);
electrical area classification drawing;
process hazard analysis (PHA);
material safety data sheets (MSDS);
design basis for emergency systems and devices;
startup/shutdown operating procedures;
normal operating procedures;
emergency procedures;
management-of-change procedure; and
maintenance records.
Supporting documents may include:
material and energy balance;
process chemistry;
materials of construction;
equipment arrangement;
plot plant;
ventilation design;
emergency planning;
upper and lower control limits;
consequence of process deviation; and
accident/incident investigation reports.

Need a break? Check out our Comical Processing Cartoon Gallery. Dozens of cartoons based on the
chemical processing industry are made complete with captions from your peers.
Additionally, a site should carefully maintain and periodically update or revalidate documents
pertaining to life safety and building structural design.
Of course, the challenge is ensuring the information you have is adequate and remains that way. So, in
this article we'll discuss how to assess and address process documentation.
You should start with the fundamentals. Firstly, senior management should prepare a safety mission
statement and safety policy that commits them to the safety of employees and their work environment.
Secondly, form a safety committee to manage the diverse aspects of overseeing collection of data and
the creation of required documentation. Members should include representatives from management;
health, safety and environmental; engineering; maintenance; manufacturing; quality control; and any other
departments important to your processes. Thirdly, the safety committee should create a "basis of safety"
document as a roadmap for your approach to the design and management of the safety system, ensuring
your operations meet the intent of your company's safety policy.
The best approach for any large undertaking is to segment it into manageable pieces. The safety
committee should delegate individual document ownership to appropriate departments. When resources
are limited, outsourcing the technical drawings to a local engineering firm is a common approach.
However, you must start the process internally because no one knows your operation better than your
own people. Prepare a list of documents currently available, even if they're old or outdated. Perform a gap
analysis to define which documents are missing.
If the resources for document preparation (in terms of time or cost) are a factor, select a smaller
"boutique" engineering firm that can perform the work part time at a reduced cost. Alternatively, consider
contacting a local university about participating in a cooperative program for third- and fourth-year
engineering students. Ensure the students are well supervised to make the most of their four to six
months with you.
Once you've got current versions of all the documents needed, store them in a centralized secure location
where they are accessible to those who need them. Many companies maintain their documents
electronically with date stamps and expiration notices to ensure only the latest information is utilized. The
requirement for "as built" documentation is time critical not only for process troubleshooting but also for
process hazard assessment, management of change, and capital project implementation. Managers and
engineers can spend hours looking for missing documents and, unfortunately, sometimes inadvertently
use outdated documents, leading to lost time and potential rework. The role of a document control
coordinator is much underappreciated and often is critical to minimizing mistakes and lost efficiencies.
To illustrate what's involved in developing appropriate documentation, let's look at a PHA.

Spreadsheet-like worksheets alone don't suffice to meet OSHA PSM requirements for covered processes
or good engineering practice for noncovered ones, as detailed by the American Institute of Chemical
Engineers' Center for Chemical Process Safety (CCPS).
The PHA is a key part of the overall PSI of a process. Unfortunately, the OSHA PSM regulation doesn't
specify the need for or format of a formal PHA report but does require documentation of the effort. In
addition, under RAGAGEP (Recognized and Generally Accepted Good Engineering Practices) OSHA
may interpret the quality of documentation against the CCPS recommendations.
The OSHA PSM regulation requires a plant to keep the PHA and subsequent revalidations for the life of
the process. In addition, the site must document all follow-up activities stemming from PHA
recommendations and retain the documentation. These retention practices make sense for non-OSHA
processes as well. Such retention is important to the periodic PHA revalidation process and management
of process changes to ensure that new un-assessed hazards aren't introduced.
The PHA report must contain a number of elements.
Facility siting. OSHA PSM requires PHA reports to include a description of how facility siting was
considered, safety-critical findings and recommendations for follow-up activities. Siting checklists such as
those of the CCPS are good tools for siting considerations but the checklists alone may not provide
enough detail about findings. It's possible that some highly hazardous materials will require additional
efforts such as consequence analysis and risk analysis and their results documented or referenced in the
PHA report; we recommend including dedicated paragraphs on these.
OSHA expects a plant to specifically address hazards associated with the location of buildings and
employees as well as the discharge from emergency relief equipment. Regardless of hazard assessment
method applied, the report must indicate where these hazards exist and how they are managed.
Human factors. Discussion of these is another OSHA-PSM-required element; like facility siting, human
factors often are covered by a specific checklist. In addition, a site should specifically consider human
factors in the PHA worksheets for process safety hazard scenarios regardless of how a scenario is
identified. Consistently use phrases such as "human error of omission" or "human error of commission"
throughout the worksheet (in the "cause" column) to demonstrate and document consideration of these
human factors for operators, mechanics, engineers, management and others. Also, consider hazard and
operability studies (HAZOPs) and job safety analysis to uncover potential hazard scenarios caused by
human factors. These studies could be follow-up activities recommended by the initial PHA study.

Numerous references describe formats that should be used for a technical report. The PHA report should
follow this general style because it covers a scientific method used to assess process hazards.
The key sections of a PHA report include:
General. The report must have a title page, table of contents and pertinent document-control identifiers
specific to site needs.
Executive summary. This section, which generally is limited to one or two pages, provides management
with an overview of the report, including scope, methodology, significant findings and the most important
recommendations. If the PHA uses risk ranking, this section is used to summarize those discovered
scenarios, if any, with the highest risk. The executive summary is where you will find the answers to basic
questions of who, what, where, when and how. In most cases, this section is written last.
Introduction. This begins with a description of what the report addresses, including a short process
description referencing pertinent detailed PSI such as the operating procedures, process flow diagrams,
P&IDs, and MSDS for the process chemicals. It then describes the content to follow.
Scope and objective. Here, detail the process scope and limitations as well as the study objectives, such
as meeting the requirements of the OSHA PSM regulation or corporate or site process safety standards
or goals. Note if this study targets multiple issues such as safety, environmental, business and operability
or only safety ones. Describe specific guidelines used to specify consequence levels and likelihood
ratings. Explain how safeguard reliability was evaluated. Refer, as appropriate, to process description
documentation in the appendices but specify scope limitations in this section. Consider including a
listing of the modes of operation covered, such as startup, shutdown, emergency shutdown, routine
operation and non-routine activities. Point out how utilities were considered because they are an
important source of common fault causes for process upset scenarios.
Methodology. This section most commonly contains "boiler-plate" text and covers the method(s) used to
analyze the process and identify hazards. It typically describes OSHA-approved methods such as
checklists, what-if, what-if/checklist, failure mode and effects analysis, and HAZOP. We recommend
including some discussion of why the method is applicable to this PHA with supporting references to the
PSI. Explain the risk assessment technique applied, including pertinent consequence descriptors and
likelihood levels. Detail the risk rankings as well as actions required for each risk ranking, such as action
time schedule allowances. Also, list the team participants with their experience and titles here.
Findings and conclusions. Detail all the most important team findings. Action items may include specific
follow-up assignments, most commonly for departments, although individuals may be specified. Tracking

of follow-up activities will be easier if the number of assigned groups or individuals is kept to a reasonable
number such as three or four. Stress the preliminary nature of findings and that the assigned activities will
lead to a risk management plan for follow-up and closure. Such a plan may include detailed consequence
analysis and release modeling, layers of protection analysis, or quantitative risk analysis. Export tables
from the PHA worksheets with the most critical recommendations. Categorize findings by major topic,
such as process node, unit operation or recommendation area (maintenance, operations, engineering,
etc.). If risk ranking is used, list intolerable level risks with associated action items. What is intolerable will
vary from company to company and generally is risk-matrix specific.
Appendices. These should include:
1. All PHA worksheets edited by the PHA leader and scribe and approved by the PHA team.
2. A complete action-item listing with enough detail to allow those responsible for closure to understand
each issue and make appropriate responses. Follow the independent reader (six month) rule: "include
enough detail in each recommendation so that you can grasp the issues after a time delay without
additional documentation study or conversations with team members."
3. PSI references (include date and version), such as
equipment files on items within the PHA scope;
MSDS for all process chemicals and utility materials;
process flow diagram and written process description;
standard operating procedures;
standard operating conditions;
P&IDs, if applicable to scope;
process material and energy balances; and
listing of study "nodes" or other process subdivisions.
In summary, PHA worksheets alone won't suffice. It's critical to have a formal PHA report that allows a
reader to easily grasp the important hazards associated with your process and understand the path
forward to ensure appropriate risk management. The pointers provided should enable you to develop a
report that stands the test of time, revalidation and auditing.
The resources required to consistently update and effectively manage all the documents and paperwork
related to process safety sometimes result in this work falling off the radar screen. Yet, industrial sites
handling and processing hazardous materials always must give process safety and, specifically, life
safety top priority. Furthermore, an auditor or a jurisdictional agency relies heavily on a review of available
documentation and records in evaluating the safety of your facility.

We can't sufficiently stress the importance of having your process safety documentation up-to-date and
readily accessible at all times. Even the largest companies often find gaps in their data due to a multitude
of reasons from office relocations to staff changes. The sooner you evaluate the current status of your
documentation, the earlier you'll be able to address any potential shortcomings.