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Qualification #2: Does your Mechanical Contractor Have In-House PSM Capabilities

By: Ryan Murphy, PSM Services Manager

Does your Mechanical Contractor have what it takes? There are three things to consider when choosing a Mechanical Contractor: safety, qualifications, and capabilities. To better serve you, we have created this series as a guide to help you identify the right Mechanical Contractors to fit your needs and get the job done right. Follow this series to make sure your Mechanical Contractor has what it takes?


In June 2017, we discussed NEP inspections and OSHA’s process safety management compliance expectations. “Luck of the Draw” – What Does a NEP Inspection Mean to Your Facility? Have you considered the integrity of your own program and where you may potentially have gaps in compliance? The task to bring your facility into compliance can 

seem daunting. Fortunately, by choosing a Mechanical Contractor with PSM

 capabilities on the forefront, you can save yourself the hardship, time, and costs involved in implementing compliance after the completion of your project.

What are the benefits of choosing a contractor with in-house PSM capabilities?

PSM requirements continue to evolve and it is the responsibility of each facility to ensure it remains in compliance. Facility managers often reach out to third-party PSM specialists for help, but it can be difficult to find a qualified third party to implement and maintain an effective PSM program. Hiring a mechanical contractor with an in-house PSM team to assist with your program can alleviate the burden on your facility.  By involving a contractor’s PSM personnel during the engineering and installation phases you have greater certainty that your program can prevent and mitigate the release of hazardous chemicals. The collaboration of PSM personnel throughout all phases of the project is key.

Your facility is one of a kind, so shouldn’t your PSM program be too? Choosing an independent third party at the completion of your project to implement your PSM program can accompany some risks. Many third-party PSM companies have general compliance programs that do not fit the individual needs of your facility and if they were not engaged at the onset of the project they are likely to miss important gaps in the compliance requirements specific to your facility. Those gaps leave you at greater risk for safety hazards, equipment failures, and OSHA fines for noncompliance. You should expect a program that incorporates your organization’s culture and addresses your unique needs, equipment, and processes. A tailored program is essential to ensure the safety of your employees, community, and brand.

What makes a PSM program effective?

An effective PSM program requires a methodical approach to developing and evaluating the following:

  • Standard Operating Procedures (SOP’s):  SOP’s provide instructions for all phases of operation and for each piece of equipment but should also include technical operating specifications, operating limits, consequences of deviation, safety and health considerations, personal protective equipment and first aid measures.  Maintaining and storing this documentation is also important, so ensuring your contractor can provide a PSM compliance management software is also a key to maintaining appropriate documentation.
  • Process Hazard Analysis (PHA): An initial PHA is required prior to system startup and the PHA revalidated every 5 years (or sooner based on major process changes).  This is an onsite study which analyzes the chemical process for potential release hazards, documents existing safety systems in place, and recommends improvement where deemed necessary.
  • Training Programs: Your contractor should offer comprehensive and detailed PSM and RMP training that is specifically tailored to your employees and managers. It’s crucial that training emphasizes the successful management and implementation of the PSM standards to those in your facility who play a role in your compliance.
  • Compliance Audits: Audits are required every 3 years. Compliance audits are required by the OSHA Process Safety Management regulation 29 CFR 1910.119 paragraph (o), as well as the EPA Clean Air Act Risk Management Program 40 CFR Part 68. This should include the development and delivery of a detailed compliance audit report.
  • Risk Management Plan (RMP): While PSM compliance is required by OSHA, RMP compliance is required by EPA in order to protect the environment and community, resulting from the Clean Air Act Amendments of 1990. RMP and PSM are meant to go hand in hand so you will notice they share many of the same requirements. However, there is not a complete overlap, so compliance with both PSM and RMP is mandatory and it is essential that your contractor can identify the gaps between the two to ensure your program is meeting the requirements of both.  An essential RMP program should address the following:
    • Create a hazard assessment that details the potential effects of an accidental release, an accident history of the last five years, and an evaluation of worst-case and alternative accidental releases including identification of public receptors, mapping and residential population estimation based on inventory calculations.
    • Prevention Program that includes safety precautions and maintenance, monitoring, and employee training measures (most of these programs overlap with the PSM required programs); and
    • Emergency response program that spells out emergency health care, employee training measures and procedures for informing the public and response agencies (e.g the fire department) should an accident occur
    • RMP plans are required to be revised and resubmitted to EPA at least every five years.
  • Emergency Preparedness: Requires facilities to have a written plan to respond to emergencies involving applicable processes.  The essential elements of an emergency action plan will cover evacuation and the degree of involvement of facility employees. OSHA specifies strict training requirements based on the degree of involvement of on-site personnel, whether the facility decides not to get involved in an incident and let local emergency response personnel handle it or participate in a response. Coordination with local emergency responders should be part of an effective program.
  • Process Safety Information:  Facilities are required to compile written process safety information (PSI) about highly hazardous chemicals and process equipment for all PSM covered processes. Complete and accurate compilation of PSI is critical to the effective implementation of all other aspects of the PSM standard and will help employers and employees involved in operating the process identify and understand the hazards involved in their processes. PSI must include information concerning the hazards of the covered process chemical, the technology of the process, and all the equipment used in the process.  PSI examples include: P&ID’s, Safety Data Sheets, maximum intended inventory calculations.

You know how important the safety of your people, plant, and product are. We know how devastating it could be if compliance is not followed. For the safety of your facility and your community, don’t take a risk on a contractor who can’t provide PSM guidance from the very beginning of your next project.

 

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