Process Safety Management

Process Safety Management (PSM) and the Risk Management Program (RMP) are a management system that prevents or minimizes the release of toxic, reactive, flammable, or explosive chemicals at ANPI.

PSM is designed to keep employees and contractors safe from hazards/ releases on the plant. RMP is designed to protect the community, our neighbors, and the environment from releases that may leave the plant boundaries.

ANPI is using both PSM and RMP management plans, not only for preventing or minimizing the release of toxic, reactive, flammable, or explosive chemicals, but as a management tool for all activities at ANPI.

There are fourteen elements to PSM and thirteen elements for RMP. The management systems are very similar so practicing one requirement satisfies the other requirement.

The following is a summary of the PSM/RMP Elements:

• Employee Participation - Addresses that ANPI has a written plan to involve employees to participate in the elements of PSM/RMP and to ensure employees have access to the information developed.
• Process Safety Information (PSI) – ANPI must have information of the hazards, technology, and equipment of the processes. This PSI allows ANPI and employees to identify and understand the hazards posed by those processes.
• Process Hazard Analysis (PHA) – A hazard analysis is performed on the processes to identify, evaluate, and control the hazards in the process. Some of the items evaluated are the hazards of the process, previous incidents, and consequences of failure. ANPI must have a system to resolve recommendations that are developed from a PHA. All PHA’s are performed periodically and must be kept for the life of the process.
• Operating Procedures – Operating procedures provide clear instructions for safely conducting activities in the processes. Initial startup, normal operation, emergency shutdown, emergency operations, normal shutdown, Lock Out/ Tag Out, Hot Work permit, and confined space are some of the procedures used by operations. Procedures are reviewed annually for accuracy.
• Contractors – Contractors performing maintenance, repair, renovation, or specialty work at ANPI are evaluated for their safety performance and programs. The Contractors are informed of potential hazards of the process and of the provisions of the emergency action plan. The Contractor ensures their employees are trained in the work practices necessary to safely perform their job. The Contractor assures they will follow ANPI safety rules.
• Pre-Start-up Safety Review (PSSR) – A PSSR is performed when changes are made in the process or facility. The PSSR ensures construction and equipment is in accordance with the design specifications; safety, operating, maintenance and emergency procedures are written; a safety analysis has been performed and recommendations have been addressed; and training for each employee involved in operating the process has been completed.
• Mechanical Integrity (MI) – Mechanical Integrity deals with ensuring the equipment is inspected and tested. Procedures are written for inspection/testing and training is provided for employees involved in maintaining the equipment and an overview of the hazards of the process. Equipment deficiencies are corrected or safety considerations are addressed to assure safe operation. Construction of new equipment, as it is fabricated, is suitable for the process. Checks and inspections are performed to assure equipment is installed properly and that maintenance materials, spare parts, and equipment are suitable for their application.
• Management of Change (MOC) –Changes to process chemicals, technology, equipment, procedures, and facilities must be managed to ensure the change does not affect the safety and health of the employees and does not create a hazard. Employees are involved in the decision to make a change. Employees involved in operating the process are informed of and trained in the change prior to start-up of the process.
• Incident Investigation – ANPI must investigate incidents that resulted in or could have resulted in a catastrophic release of highly hazardous chemicals. The investigation must be started within 48 hours of the incident and must be conducted by a team. A report is prepared, a system is in place to address the corrective actions from the report, and the report is kept for five years.
• Hot Work Permits – A hot work permit is required when welding or other hot work is performed in any process. The permit must have a date, description of the work to be performed and the work area.
• Training – Employees involved in operating a process and before operating a new process must be trained in the Operating Procedures. The training includes specific safety and health hazards, emergency operations and safe work practices. Refresher training must be provided every three years and the training must be documented.
• Emergency Planning and Response – An emergency action plan has been developed for the entire facility and the surrounding area. The plan includes having an emergency response team that can respond to large and small releases, written procedures to handle small releases, and an evacuation plan for the plant and the surrounding area.
• Compliance Audit – An audit is performed every three years to verify procedures and practices are adequate and are being followed. A report is generated, recommendations are documented and tracked to completion and the last two audits must be kept on file.
• Trade Secrets – PSM addresses trade secrets, but RMP does not. ANPI can not withhold information they deem as trade secrets to employees involved in process safety information, process hazard analysis, operating procedures, incident investigations, emergency response, and compliance audits.