Implementation Issues of PSM in a Fertilizer Plant: An Operations Engineer's Point of View

Abstract

In this article, guidelines are provided for implementation of the elements of process safety management (PSM) such as management of change (MOC), process hazard analysis (PHA), incident investigation, emergency planning, and response. The role of mechanical integrity, operating procedures, compliance audits, pre‐start‐up safety review, contractors, training, work permits, and process safety information for implementation of the PSM in a fertilizer plant are discussed. Implementation of MOC is an important step for the adoption of PSM standards and a necessary condition for internal and external audits of the plant. There are many issues linked with implementation of PHA like plant modifications, shut downs, and production losses as well as the behaviour of the design engineer whenever modifications are required. Consequence analysis, an evaluation of an incident in terms of its effects on environment, equipment, and people is of great help. Incident reporting for a company can be improved by ensuring confidentiality and not exposing the reporting person. Improvement in the operating procedures and preserving mechanical integrity of the process plant are necessary conditions for the implementation of the standards. Internal and external audits of the company are the most important part of the PSM implementation. In general, the PSM implementation requires much effort and time but pays off well if implemented fully. © 2013 American Institute of Chemical Engineers Process Saf Prog 32: 59–65, 2013

Interrelations between process safety management elements

“…Therefore, cross checking of information pertaining PSI, PHA, OP, TNG, MI, and MOC elements is essential as process conformation [3][4][5]17,21]. Rashid et al (2013) has emphasized that PSSR must be conducted before the installation of facility. If not, it becomes difficult to implement the PSSR recommendations after facility installation as the items have not been agreed upon at the time of contract.…”

“…Interrelations of PHA element[3][4][5]7,17]. resolution of recommendation should be informed to affected personnel PHA activities must be conducted by a PHA team with specific expertise PSI Up-to-date PSI is vital to conduct PHA in order to draw accurate conclusions about the present process hazards and risks…”

Process Safety Management (PSM) for managing contractors in process plant

“…46 full investigation reports from 1998 to 2008 of plant facility accidents published by U.S. Chemical Safety and Hazard Investigation Board (CSB) indicate that accidents have not decreased as expected (Rashid et al, 2013). Even as lately in 2010, there were at least 6 accidents reported involving contractors out of 40 accident reports submitted to the EU's Major Accidents Reporting System (eMARS).…”

“…Amongst the non-compliance issues with regards to the regulation stipulated within PSM that commonly arise include not providing mandatory personal protective equipment (PPE) to workers, not discussing hazards related to the workforce activities and improper control of non-routine activities during changes in shifts (Rashid, Ramzan, Iqbal, Yasin, & Yousaf, 2013). Even the most sophisticated operators find compliance to PSM challenging due to the broad scope and highly technical nature of the 14 elements (Cunio & Melhem, 2014).…”

Managing process safety information based on process safety management requirements

“…Also, good documentation is just beginning and proper utilization is again difficult . In general, the PSM implementation requires much effort and time but pays off well if implemented fully .…”