6. DNA???
• Is SOP & Safety in your DNA?
• What was Blue’s SOP?
• Thrust
• Lift
• Drag
• Did he feel it in his heart or his head?
• Was he ready?
• Are you ready?
• Do you know your SOP’s?
7. Operating Procedures or Standard
Operating Procedures (SOP’s)
• Where Did This Methodology Come From?
• Answer: The Military
• Definition: A standard operating procedure is a set of instructions
having the force of a directive, covering those features of operations
that lend themselves to a definite or standardized procedure without
loss of effectiveness. Standard Operating Policies and Procedures can
be effective catalysts to drive performance improvement and
improving organizational results. Every good quality system is based
on its standard operating procedures (SOPs).
8. Operating Procedures (RMP)
40 CFR Part 68.52
(a) The owner or operator shall prepare written operating procedures that provide clear instructions or steps for safely
conducting activities associated with each covered process consistent with the safety information for that process.
Operating procedures or instructions provided by equipment manufacturers or developed by persons or organizations
knowledgeable about the process and equipment may be used as a basis for a stationary source's operating procedures.
(b) The procedures shall address the following:
(1) Initial startup;
(2) Normal operations;
(3) Temporary operations;
(4) Emergency shutdown and operations;
(5) Normal shutdown;
(6) Startup following a normal or emergency shutdown or a major change that requires a hazard review;
(7) Consequences of deviations and steps required to correct or avoid deviations; and
(8) Equipment inspections.
(c) The owner or operator shall ensure that the operating procedures are updated, if necessary, whenever a major change
occurs and prior to startup of the changed process.
9. Operating Procedures (PSM)
29 CFR 1910.119(f)
The Operating Procedures must consider the following.
• Initial start-up
• Normal operations
• Temporary operations
• Emergency shutdown
• Emergency operations
• Normal shutdown
• Start-up following turnaround
• Consequences of deviation
• Steps required to correct or avoid deviation
10. Operating Procedures
• The operating procedures addressing operating parameters will
contain operating instructions about:
• pressure limits
• temperature ranges
• flow rates…and
• what to do when an upset condition occurs
• what alarms and instruments are pertinent if an upset condition occurs, and
other subjects.
11. Operating Procedures –
Start Up…We Must
• Include Sections such as:
• Objectives
• Purpose
• Concerns
• Procedures
• Department
• Operator
• Equipment Involved
• Location
• Related Documents
Let’s Look at An Example…
12.
13.
14. APR’s aren’t Magic
Posted on October 14, 2016 by Brian Chapin
• It is believed the oil drain valve was initially clogged as the employee opened it a
full three turns before any ammonia came out. When liquid exited the valve and
struck the employee he fell face first on concrete in hallway. “Convulsions” were
observed by other employees and the operator was unable to self-rescue due to
lung spasms. The other employees had no access to PPE and could not assist the
victim.
21. Operating Procedures
• Must be Developed for Each Equipment Operation
in the Covered Process
• Refer to Block Diagrams
• Refer to P&ID
• Must Cover Normal Operating Conditions, Normal
Operating Parameters, i.e.. Pressure/Flow/Current/
etc.
• Must Follow Procedures & Recommendations in PHA’s
• Must Follow Form
22. Operating Procedures
• For Shut-down Procedures…Remember:
• Most operations must be shut down in a specific order!
• Failure to follow these shut down procedures could results in a catastrophic
release or system failure
25. Operating Procedures –
Hazards of the Process
• Operating Procedures
Must Identify the
Hazards of the Process
in All Phases:
• Start Up
• Normal Operating
Conditions
• Temporary Operating
Condition
• Emergency Shut-down
• Start-up following an
Emergency Shut-down
26. Operating Procedures –
Hazards of the Process
• Operating Procedures
Must Identify the
Operating Limits:
• Upper
• Lower
• Normal Operating Range
27. Now That We’ve Completed
the Operating Procedures
We Must Develop Safety Work Practices, Programs &
Procedures for Covered Processes
29. •Develop and implement safe work practices* to provide for the control
of hazards during operations such as:
–Lockout/tagout;
–Confined space entry;
–Linebreak - Line Opening process equipment or piping;
–Control over entrance into a facility by maintenance, contractor, or other support personnel
Safe Work Practices
*These safe work practices apply to contractor employees as well
30. Safe Work Practices
Safe Work Practices, Programs &
Procedures must:
Be specific to the Covered Process
Follow Procedures & Recommendations in the
PHA’s
Follow Procedures in the Operating Procedures
Must be Able to be Tracked
Follow Form
31. Safe Work Practices
• Lockout Tagout - One of the Most Important Procedures in PSM
• Must be Written Carefully & Follow all Procedures (PHA’s, Operating
Procedures)
• Must be Followed to the Letter!
32. Safe Work Practices
• Lockout/Tagout in PSM
• Why not Use Digital
Imaging in Your
Procedures to Identify
Critical Lockout /Tagout
Positions
33. Safe Work Practices
• Line Opening Permits
• Identify Procedures for Opening
any Process Line in a Covered
Process
• Must Include Hazards of the Line
Opening
• PPE Required
34. Safe Work Practices
Line & Equipment Opening
A Hazard Review Must Be Completed for All
Line/Equipment Hazards Including:
HAZARDOUS MATERIALS IN SYSTEM
POTENTIAL PHYSICAL HAZARDS
BARRICADING AS REQUIRED
FIRST AID IF EXPOSED
LOCATION OF SAFETY EQUIPMENT
PPE REQUIRED FOR LINE OPENING
35. Safe Work Practices-
Hot Work
A Program Must be Developed for the Covered Process That Requires:
• A Hot Work Permit be Issued for ALL Hot Work Performed in the Plant by
Employees or Contractors
• A Permit must be Posted at the Location of the Hot Work
• A Fire Watch Is Required
• A Fire Extinguisher or Other Appropriate Fire Fighting Equipment Must Be
Present, Fire Watch must be Trained in its use
36. Safe Work Practices
• Must be Specific for the Covered Process
• May Require Additional Program other than Lockout Tagout, Line
Opening & Hot Work…such as Confined Space, Electrical Safe Work
Practices, Combustible Dust
37. Now That We’ve Developed
Safe Work Practices
We Have to Train
39. PSM 29CFR1910.119(g) Requires
(G) Training (Initial, Refresher, and Documentation) (paragraphs (g)(1), (g)(2), and
(g)(3)).
• Paragraph (g)(1) requires employers to train employees operating dangerous
process. Paragraph (g)(2) requires that the employer provide refresher training at
least every three years. Paragraph (g)(3) requires the employer to prepare a
record that contains the name of employee, the date of training, and the means
used to verify that the employee understood the training
40. PSM Training
• PSM Training Programs Must be Developed for:
• Affected Employees - Those not Directly Involved in the Process Operation
• Authorized Employees - Those Directly Involved in the Process Operation
• Contractors Who May Perform Work on a Covered Process
• Vendors/Visitors who May Visit the Facility and May Potentially be Exposed to
the Covered Process
41. PSM Training
• Training Must Be Performed as Follows:
• Initial training
• Prior to work assignment
• Waved for those already in a process
• Refresher training
• Every three years
• All Training Must be Documented
42. PSM Training
• Training Subjects Must Include at Least:
• Lockout Tagout
• Hot Work
• Line & Equipment Opening
• Confined Space (if applicable)
• Emergency Response
43. Examples of Training
PSM training example including the means used to
verify that the employee understood the training.
47. Safe Work Practices
Hot Work
Burning, Welding, Grinding, Drilling, Cutting
Our Program Requires
A Hot Work Permit be Issued for ALL Hot work
Performed in the Plant by Employees or
Contractors
Permit must be Posted at the Location of the Hot
Work
Fire Watch Is Required
Fire Extinguisher Must Be Present, Fire Watch
must be Trained in its use
48. Safe Work Practices
HOT WORK
PERMIT MUST BE
COMPLETED PRIOR TO
BEGINNING WORK
INVOLVIING ANY HOT
WORK
PERMIT SHALL BE DISPLAYED
AT THE LOCATION OF THE
ACTUAL HOT WORK
OPERATION
49. VERIFICATION OF UNDERSTANDING WORKSHEET
HOT WORK
CIRCLE THE CORRECT ANSWER
1. A HOT WORK permit must be obtained prior to beginning HOT work by employees and contractors
before beginning a job.
TRUE
2. A HOT WORK permit is not necessary if just drilling and grinding is being done on a job.
FALSE
3. Contractors are not required to obtain HOT WORK permits.
FALSE
4. The employee or contractor will obtain a HOT WORK permit from his supervisor and must
determine if conditions are safe and have a fire watch if necessary.
TRUE
50. 5. HOT WORK is permitted in explosive atmospheres, around hazardous tanks and equipment.
FALSE
6. The following protective measures can be used: damp sand on floors, protective shields, or fire resistant
coverings while Hot Work is taking place.
TRUE
7. 35 feet is a good safe distance for covered combustibles to be away from HOT WORK.
TRUE
8. Fully charged and operable fire extinguishers and/or hose lines shall be available and ready.
TRUE
9. The HOT WORK permit emergency information shall be posted at the job site.
TRUE
10. The fire watch does not have to be trained in fire extinguishing and is not responsible for sounding an alarm
in the event of a fire.
FALSE
51. PSM Operating Procedures Summary
• You Must Develop and implement written operating procedures consistent with
the process safety information and addresses at least the following elements:
• Initial start-up, normal and temporary operations
• Normal and emergency shut-down procedures
• Operating limits and consequences of deviation
• Hazards presented by the process
52. PSM Safe Work Practices
Summary
• Safe Work Practices, Programs & Procedures must:
• Be specific to the Covered Process(s)
• Follow Procedures & Recommendations in the PHA’s
• Follow Procedures in the Operating Procedures
• Must be Able to be Tracked
• Follow Form
53. PSM Training Summary
• PSM Training Programs Must be Developed for All Necessary Workers
and Contractors
• Verification of Understanding is Required
• Training Must Be Performed as Follows:
• Initial training
• Prior to work assignment
• Refresher training
• Every three years
• All Training Must be Documented