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Auditing Process Safety Management

 

Did you participate in the writing of your Process Safety Management program? Or did someone stop by your control room and drop off a couple of books, while saying, "Okay, it's done. It's in those books over there." Or perhaps your system is below the threshold of 10,000 lbs of ammonia in which case a formal PSM program isn't required, although I still recommend undertaking PSM, regardless. Any covered site is required to undergo paragraph (o) Compliance Audits every three years or more often, or sooner if the system is modified.

OSHA records show that the number one reason for injuries (or worse) is operator error. Error can creep in for a whole host of reasons, not the least of which is a lack of adequate training. Accidents while draining oil pots or oil from thermosiphon oil coolers tops the list. These two tasks are radically different from one another and vary depending upon what valves are installed (or not installed) to aid in the oil drain process and to undertake these tasks safely. A clearly delineated, step-by-step process can reduce any operator error to a minimum.

Does your Process Hazard Analysis (PHA) clearly indicate each risk in operating and maintaining an ammonia refrigeration system? Risk is never 'zero' - it may be minimal or something more. For example, we run a risk every time we cross the street - that risk being do we get hit? Ordinarily this risk, while not zero, is certainly low (except in the Windy City Loop on Friday afternoons during rush hour ;-). The "R" Risk Matrix may be used to qualitatively identify and rate risks - this scale weighs increasing likelihood of an accident against increasing severity or outcome. The resulting risks run from a D (lowest) up to an A (highest). If you'd like further information on the R Risk Matrix, contact me.

Should you need some input along the lines of Process Safety Management, its implementation or auditing, please contact me. If you'd like to download Process Safety Management to obtain a copy of OSHA 29CFR 1910.119, click here.

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