Implementing Psm System Upgrade Post Nep Tcc Acit Ehs Rev 2
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Transcript of Implementing Psm System Upgrade Post Nep Tcc Acit Ehs Rev 2
A Practical Approach that Supports Operational Excellence
Authors:Robert Walter & Richard Foottit – AntiEntropics, Inc.
Brian Nelson – Suncor Energy (U.S.A.)
Human beings, who are almost uniqueh h b l lin having the ability to learn
from the experience of others,l k bl f hare also remarkable for their apparent
disinclination to do so. l dDouglas Adams
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P bli tt ti i t Public attention is greater now 2005 BP Texas City Incident (and recent others) have focused government & public attention on refinery g p yPSM performance
Good organizations are fallible The Baker report & CSB investigation were revealing The Baker report & CSB investigation were revealing (now almost 20 yrs since promulgation!)
Closer OSHA oversight is a necessary piece of the equationthe equation
Your PSM NEP inspection WILL focus on Your site’s implementation and enhancing overall i d f f l l dindustry performance from lessons learned
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OSHA b b d d t b I t t d OSHA web‐based database Integrated Management Information System (IMIS) is Very InformativeInformative Trending NEP citations as the program progresses Frequently cited OSHA standardsq y Industry profile for an OSHA standard
Of ~1644 NEP related citations – 27% are non‐PSM ( % i )PSM (was 31 % in 2009) Work on non‐PSM issues during waiting period 1008 PSM vs 447 Non PSM vs 189 deleted ~1008 PSM vs. ~447 Non‐PSM vs. 189 deleted
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U.S. Department of Labor - OSHA - Change in Citation Numbers 05/24/2011
447
189
1008447
Current PSM
Current Non‐PSM
Deleted Citations
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/ / D t / 8/ D t5/24/2011 Data 198 ‐Mechanical Integrity 178 ‐ Process Safety Information
68 O ti P d
2/28/2009 Data 100 ‐Operating Procedures 94 ‐Mechanical Integrity
86 P H d A l i 168 ‐Operating Procedures 166 ‐ Process Hazard Analysis 83 ‐Management of Change
72 Incident Investigation
86 ‐ Process Hazards Analysis 73 ‐ Process Safety Information 40 ‐Management Of Change
40 Incident Investigation 72 ‐ Incident Investigation 39 ‐Compliance Audit 28 ‐Contractors 27 Training
40 ‐ Incident Investigation 26 ‐Compliance Audit 14 ‐Training 13 Employee Participation 27 ‐Training
16 ‐ Emerg. Planning & Resp. 15 ‐ Employee Participation 11 Pre startup Safety Review
13 ‐ Employee Participation 13 ‐Contractors 9 ‐ Emerg. Planning & Resp. 7 Pre startup Safety Review 11 ‐ Pre‐startup Safety Review
7 ‐Hot Work 7 ‐ Pre‐startup Safety Review 4 ‐ Hot Work
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U S Department of Labor OSHA Citation Numbers
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200178
66 168
198
U.S. Department of Labor - OSHA - Citation Numbers05/24/2011
120
140
160
180 166 168
60
80
100
120
8372
0
20
4015
27 28
11 716
39
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EP PSI PHA OPER. PROC.
TRN CONT PSSR MI HOT WORK
MOC INC. INV.
EP&R COMP. AUDIT
U.S. Department of Labor - (OSHA) - Total Cost by PSM Element05/24/2011
$3,000,000 $2,798,448
05/24/2011
$2,000,000
$2,500,000
$1,500,000 $1,515,201
$1,173,471
$500,000
$1,000,000 $707,428
88 $83 000
$385,498 $215,958
$68 $127,410
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$‐EP PSI PHA OPER.
PROC.TRN CONT PSSR MI HOT
WORKMOC INC.
INV.EP&R COMP.
AUDIT
$47,550 $51,880 $83,000 $29,800 $21,650 $68,434
U.S. Department of Labor - (OSHA) - Average Cost of Citation05/24/2011
$14,000
$16,000 $15,722
$10,000
$12,000
$9,128
$6,000
$8,000
$4,211
$5,927
$4,645 $4,277
$2,000
$4,000 $3,170 $4,211
$1,921 $2,964 $2,709 $3,093 $2,999
$4, 77$3,267
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$0 EP PSI PHA OPER.
PROC.TRN CONT PSSR MI HOT
WORKMOC INC.
INV.EP&R COMP.
AUDIT
L k t it ’ t li dit Look at your site’s past compliance audits. The same top four items from the PSM NEP citation hit parade will be likely be prominenthit parade will be likely be prominent
A small proposed penalty may belie a very large abatement cost (for example, operating procedures and P&IDs)
Each citation item has two abatement issuesS ifi b t t t i t ti f f d Specific abatement – strict correction of referenced items & sub‐items
Long term/plant wide abatement – to truly improve Long term/plant wide abatement to truly improve performance & avoid future FTAs & REPEATs
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f h lBefore everything else, getting ready is the secret to success.
dHenry Ford
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1 Perform a self analysis of those PSM NEP directive aspects of 1. Perform a self analysis of those PSM NEP directive aspects of your process safety management system that can be pre‐considered
2 Prepare your management technical staff & hourly employees 2. Prepare your management, technical staff, & hourly employees for the audit
3. Analyze the need for additional paralegal assistance & specific equipment to support the inspection & the refinery’s legal equipment to support the inspection & the refinery’s legal needs
4. Provide a suitable workspace for the OSHA inspection teamC d & l h i i h l i h OSHA 5. Create documents & tools that can assist in helping the OSHA inspectors and your organization track & respond to the team’s requests
6. Create a method for tracking each document request
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P f lf l i f th PSM NEP Perform a self analysis of those PSM NEP directive aspects of your process safety management system that can be pre‐management system that can be preconsidered. until the OSHA team selects the unit(s), specific , pactions are limited for many static questions & document requests
identify the best human resources for each question & identify the best human resources for each question & document request type. This is a useful preparation exercise as it prepares personnel for their roles in the OSHA ’ i iOSHA team’s inspection.
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P t t h i l t ff & h l l Prepare your management, technical staff, & hourly employees Educate them on an overview of the PSM NEP directive Educate them on their rights as workers in regard to an OSHA
inspection Prepare key people for the on boarding & opening conference Select & train your NEP response teamy p
▪ PSM group – safety experts – engineers – hourly PSM employee committee
▪ Escorts –Who will they be? What is expected▪ Security – Set strict procedures & adhere to them
Predetermine how you will efficiently support & escort the OSHA inspectors when they are on site▪ Safety orientation & employee interviews (other aspects?)
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f Analyze the need for: Additional paralegal assistance & Specific equipment to support the inspection & the refinery’s legal needs ▪ Bates stamping, ▪ High speed copyingHi h d i▪ High speed scanning
▪ Others things your site has thought of?
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f Provide a suitable workspace for the OSHA inspection team They will provide their basic needs, but consider:▪ Land line telephone▪ Independent Internet connection (not through site portal)
▪ Office furnitureOffice furniture▪ Other things?
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Create documents & tools that can assist in helping the OSHA inspectors & your
k d horganization track & respond to the team’s requests Document request and transmittal form Document request and transmittal log Escort Logs
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AEI NEP SUPPORT TEAM – Inspection Status Update - Document RequestsRevision 12
94 of 103 items prepared as of 10/6/08 (91%)92 of 103 items transmitted to OSHA (89%)Revision 12 92 of 103 items transmitted to OSHA (89%)
OSHA Reference and Date
Item no. Item Description – verbatim
[References]
Due Date
Primary Contact
Support Contacts
Status Date to Legal Date to OSHA Notes:
List 0 Letter 9/8/08
1 A list of all PSM (29 CFR 1910.119) covered process units with the date that the unit was put in service and the number of employees assigned to each unit per shift.
9/10/08 J. Doe J. Smith Finished 9/10/08 9/10/08
[REF: X.E.3.b./m.]
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h f h hIt is not the strongest of the species that survive, nor the most intelligent, but the ones most
hresponsive to change.Charles Darwin
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It is over:It is over: Document requests & personnel interviews have stopped OSHA has demobilized
Cl i f h b h ld Closing conference has been held Citations have been finalized & delivered Citation contest activity in accordance with OSHA protocol has been
completed (informal/formal) The site staff has recovered from PSM NEP fatigue.
Now the response begins:p g Specific citation abatement efforts take first priority Long term abatement plant‐wide is the real organizational opportunity If the PSM team succeeded in helping Mgmnt understand the business If the PSM team succeeded in helping Mgmnt understand the business
case for PSM, operational excellence can be enhanced long term
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The OSHA inspectors can assist in clarification of The OSHA inspectors can assist in clarification of the citations & discuss methods for closing the citations in a timely manner (FMOA)citations in a timely manner (FMOA)
See the example Gantt chart average of 26 citations seen in inspections completed to date (was 15 in average of 26 citations seen in inspections completed to date (was 15 in
2009) The period allowed for abatement is often only one to two months
Contest the following as appropriate Contest the following as appropriate Abatement date Proposed Penaltyp y Citation basis (reduce citation type)
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The basic tenets of PSM are rooted in good The basic tenets of PSM are rooted in good engineering & management practices Each site’s citations are unique historical inspection data can ID likely Each site s citations are unique, historical inspection data can ID likely
elements, Pre‐inspection self‐analysis & tracking document requests during the inspection period are helpful
Identify elements that received the most interest by the OSHA NEP Identify elements that received the most interest by the OSHA NEP inspectors
Identify the non‐PSM personnel safety issues raised & start addressing them ASAPthem ASAP
This displays a proactive, good faith effort concerning worker safety (& creates extra time later for more complex citation abatement activities)
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A l l i f l t d it t ll it f Apply learning from selected units to all units for elements like: Process Safety Information Process Safety Information Process Hazard Analysis Operating Proceduresp g Training Management of Change Pre‐startup Safety Review Mechanical IntegrityC Contractors
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E l t th t f PSM f d Evaluate three aspects of a PSM program for upgrade opportunities:
Administrative procedures These describe the programmatic approach to compliance
Work procedures Work procedures As indicated by a specific element’s needs (for example operating procedures, maintenance procedures, safe work practices, emergency response procedures
Documentation The evidence that the administrative & work procedures The evidence that the administrative & work procedures are being used.
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Document Number / Document TitlePSM RMP 01 PSM/RMP Compliance Manual DescriptionPSM‐RMP‐01 ‐ PSM/RMP Compliance Manual DescriptionPSM‐RMP‐02 ‐ Employee ParticipationPSM‐RMP‐03 ‐ Process Safety InformationPSM‐RMP‐04 ‐ Process Hazard Analysis
dPSM‐RMP‐05 ‐ PSM/RMP Procedure Program PSM‐RMP‐06 ‐ PSM/RMP Training ProgramPSM‐RMP‐07 ‐ContractorsPSM‐RMP‐08 ‐ Pre‐Startup Safety ReviewPSM‐RMP‐09 ‐Mechanical IntegrityPSM‐RMP‐10 ‐Hot Work PermitPSM‐RMP‐11 ‐Management Of ChangePSM‐RMP‐12 ‐ Incident InvestigationS c de t est gat oPSM‐RMP‐13 ‐ Emergency Planning & ResponsePSM‐RMP‐14 ‐Compliance AuditsPSM‐RMP‐15 ‐Trade SecretsPSM‐RMP‐16 ‐ RMP Management System
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PSM‐RMP‐16 ‐ RMP Management SystemPSM‐RMP‐17 ‐ RMP Executive SummaryPSM‐RMP‐18 ‐ Risk‐Based Process Safety Guidelines
F h PSM l h CCPS For each PSM element, the CCPS paper detailsB i i t t l f Basic requirements to analyze your program for based upon the regulation & citations to date Specific citations to date within each PSM Specific citations to date within each PSM element Vulnerable areas for the refining industry as g yindicated by targeted PSM requirements
A sample seed Gantt chart for an upgrade ff t f lleffort follows
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1. Industry gets a directed opportunity to improve overall PSM 1. Industry gets a directed opportunity to improve overall PSM performance Leveraging this requires an organizational culture of high
operational discipline operational discipline 2. High reliability organizations (HROs) must embrace PSM
upgrade to see sustainable growth & greater reliabilityO ti l di i li b tt t hi h l l f 3. Operational discipline can better support a high level of operational excellence
4. Valuing a holistic sense of quality supports business excellence5. OSHA inspectors & site management gain PSM expertise6. OSHA better able to help industry protect workforce7. Refining & chemical industries’ gain increased level of
catastrophic risk prevention
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Business ExcellenceBusiness ExcellenceThe Peak The Peak ‐‐ Both perceptual andBoth perceptual and
Operational ExcellenceOperational Excellencequantitative thingsquantitative things
ppThe The Path Path –– quantitative, business quantitative, business critical things (Procedures, Metrics, KPIs)critical things (Procedures, Metrics, KPIs)
Operational DisciplineOperational DisciplineThe The Power Power Cultural qualitative Cultural qualitative
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The The Power Power –– Cultural, qualitative, Cultural, qualitative, perceptual, thingsperceptual, things
It i i t t tt f b h i l It i i t t tt f b h i l It is a consistent pattern of behavioral It is a consistent pattern of behavioral choices that choices that supports supports successsuccess A values based management style is based upon a A values‐based management style is based upon a shared set of values and principles▪ Not directly measurable, but perceived as important by all
In a world of change these fifteen characteristics In a world of change these fifteen characteristics are always valued when displayed in actions of:▪ Organizations▪ Teams▪ Individuals
When a high level of operational discipline is realized, all stakeholders benefit,
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Hold a sense of personal responsibility for their actions. Hold a sense of personal responsibility for their actions. Honor commitments to themselves and others. Honor commitments to themselves and others. Seek outcomeSeek outcome‐‐based results rather than activitybased results rather than activity‐‐based results. based results. View problem, setbacks, and mistakes as opportunities for improvement.View problem, setbacks, and mistakes as opportunities for improvement. Use time management techniques in achieving goals.Use time management techniques in achieving goals. Respect and attempt to understand others' ideas and worldviews.Respect and attempt to understand others' ideas and worldviews. Seek fairness in all exchanges.Seek fairness in all exchanges. Share recognition with others.Share recognition with others. Value their life & health & the lives & health of coValue their life & health & the lives & health of co‐‐workers & the community.workers & the community. Use active, twoUse active, two‐‐way communication so information is understandable to all parties.way communication so information is understandable to all parties. Seek to perform the duties & tasks required by their position.Seek to perform the duties & tasks required by their position. Desire to use informational, capital , and human resources efficiently.Desire to use informational, capital , and human resources efficiently. Assume a leadership role when needed , and conversely, follow when appropriate.Assume a leadership role when needed , and conversely, follow when appropriate. Use existing systems to achieve goals & seek to improve the systems when needed.Use existing systems to achieve goals & seek to improve the systems when needed. Trust that others are capable of a high level of operational discipline & treat them Trust that others are capable of a high level of operational discipline & treat them
accordingly.accordingly. 34
Catastrophic Incident
Prevention
QualityMust
ProfitabilitySafety & Health
Includeea
Operational Discipline
Operating Excellence
Environmental Responsibility
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Business Excellence
All All CompetenciesCompetencies , personal, team, or , personal, team, or organizational consist organizational consist of three partsof three partsgg f pf pKnowledgeKnowledge
the Cognitive domainthe Cognitive domain the Cognitive domainthe Cognitive domain Skills Skills
th P h t d ith P h t d i the Psychomotor domainthe Psychomotor domainAttitudeAttitude
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the Affective domainthe Affective domain
EvaluationDecision‐making
SynthesisCombines elements
Judging, selection
AnalysisSeparates whole into
Into new entity
Application
Separates whole into its parts
Comprehension
Uses information in new situation
Knowledge
ComprehensionInterpretTranslate
Performances that require knowledgeOr specific information
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KnowledgeRecognition and
Recall
p
NaturalizationCompletes skills with
ease and limited
ArticulationCombines multiple
ease and limited exertion
Precision
Combines multiple skills with harmony
Manipulation
Reproduces skill w/o original source
Imitation
ManipulationPerform skill to instruction
Skill performances that require manipulation oftools, supplies,
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ImitationObserves skill and
repeats
, pp ,or equipment
CharacterizingTotal behavior is
Organizing
Total behavior is consistent with
values internalized
OrganizingCommitted to a set
of values as displayed by
ValuingDisplays behavior consistent w/
behavior
Responding
attitude without forced compliance
Th f d i
Receiving
p gComplies
w/expectationsThe forgotten domainPerformance involves operational discipline
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ReceivingAware but passively attending to stimuli
p pdemonstrating values,attitudes, and feelings
Robert Walter & Richard FoottitRobert Walter & Richard FoottitAntiEntropics, IncorporatedAntiEntropics, IncorporatedP.O. Box 692P.O. Box 692New Market, MD 21774New Market, MD 21774
[email protected]@[email protected]@antientropics.com
For a copy of the full paper, contact Robert WalterFor a copy of the full paper, contact Robert Walter
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