Washington Administrative Code › Title 296 - Labor and Industries, Department of › Chapter 296-67 - Safety standards for process safety management of highly hazardous chemicals › Part A › Section 296-67-291 - Appendix C - Compliance guidelines and recommendations for process safety management (nonmandatory)

Current through Register Vol. 24-14, July 15, 2024
This appendix serves as a nonmandatory guideline to assist
				  employers and employees in complying with the requirements of this section, as
				  well as provides other helpful recommendations and information. Examples
				  presented in this appendix are not the only means of achieving the performance
				  goals in the standard. This appendix neither adds nor detracts from the
				  requirements of the standard.
(1)
				Introduction to process safety management. The major objective of process
				safety management of highly hazardous chemicals is to prevent unwanted releases
				of hazardous chemicals especially into locations which could expose employees
				and others to serious hazards. An effective process safety management program
				requires a systematic approach to evaluating the whole process. Using this
				approach the process design, process technology, operational and maintenance
				activities and procedures, nonroutine activities and procedures, emergency
				preparedness plans and procedures, training programs, and other elements which
				impact the process are all considered in the evaluation. The various lines of
				defense that have been incorporated into the design and operation of the
				process to prevent or mitigate the release of hazardous chemicals need to be
				evaluated and strengthened to assure their effectiveness at each level. Process
				safety management is the proactive identification, evaluation and mitigation or
				prevention of chemical releases that could occur as a result of failures in
				process, procedures, or equipment. The process safety management standard
				targets highly hazardous chemicals that have the potential to cause a
				catastrophic incident. This standard as a whole is to aid employers in their
				efforts to prevent or mitigate episodic chemical releases that could lead to a
				catastrophe in the workplace and possibly to the surrounding community. To
				control these types of hazards, employers need to develop the necessary
				expertise, experiences, judgment, and proactive initiative within their
				workforce to properly implement and maintain an effective process safety
				management program as envisioned in the WISHA standard. This WISHA standard is
				required by the Clean Air Act amendments as is the Environmental Protection
				Agency's Risk Management Plan. Employers, who merge the two sets of
				requirements into their process safety management program, will better assure
				full compliance with each as well as enhancing their relationship with the
				local community. While WISHA believes process safety management will have a
				positive effect on the safety of employees in workplaces and also offers other
				potential benefits to employers (increased productivity), smaller businesses
				which may have limited resources available to them at this time, might consider
				alternative avenues of decreasing the risks associated with highly hazardous
				chemicals at their workplaces. One method which might be considered is the
				reduction in the inventory of the highly hazardous chemical. This reduction in
				inventory will result in a reduction of the risk or potential for a
				catastrophic incident. Also, employers including small employers may be able to
				establish more efficient inventory control by reducing the quantities of highly
				hazardous chemicals on site below the established threshold quantities. This
				reduction can be accomplished by ordering smaller shipments and maintaining the
				minimum inventory necessary for efficient and safe operation. When reduced
				inventory is not feasible, then the employer might consider dispersing
				inventory to several locations on site. Dispersing storage into locations where
				a release in one location will not cause a release in another location is a
				practical method to also reduce the risk or potential for catastrophic
				incidents.
(2) Employee involvement
				in process safety management. Section 304 of the Clean Air Act amendments
				states that employers are to consult with their employees and their
				representatives regarding the employers efforts in the development and
				implementation of the process safety management program elements and hazard
				assessments. Section 304 also requires employers to train and educate their
				employees and to inform affected employees of the findings from incident
				investigations required by the process safety management program. Many
				employers, under their safety and health programs, have already established
				means and methods to keep employees and their representatives informed about
				relevant safety and health issues and employers may be able to adapt these
				practices and procedures to meet their obligations under this standard.
				Employers who have not implemented an occupational safety and health program
				may wish to form a safety and health committee of employees and management
				representatives to help the employer meet the obligations specified by this
				standard. These committees can become a significant ally in helping the
				employer to implement and maintain an effective process safety management
				program for all employees.
(3)
				Process safety information. Complete and accurate written information
				concerning process chemicals, process technology, and process equipment is
				essential to an effective process safety management program and to a process
				hazards analysis. The compiled information will be a necessary resource to a
				variety of users including the team that will perform the process hazards
				analysis as required under WAC
				296-67-017; those developing the
				training programs and the operating procedures; contractors whose employees
				will be working with the process; those conducting the prestartup reviews;
				local emergency preparedness planners; and incurrence and enforcement
				officials. The information to be compiled about the chemicals, including
				process intermediates, needs to be comprehensive enough for an accurate
				assessment of the fire and explosion characteristics, reactivity hazards, the
				safety and health hazards to workers, and the corrosion and erosion effects on
				the process equipment and monitoring tools. Current safety data sheet (SDS)
				information can be used to help meet this requirement which must be
				supplemented with process chemistry information including runaway reaction and
				over pressure hazards if applicable. Process technology information will be a
				part of the process safety information package and it is expected that it will
				include diagrams of the type shown in WAC
				296-67-289, Appendix B of this
				part as well as employer established criteria for maximum inventory levels for
				process chemicals; limits beyond which would be considered upset conditions;
				and a qualitative estimate of the consequences or results of deviation that
				could occur if operating beyond the established process limits. Employers are
				encouraged to use diagrams which will help users understand the process. A
				block flow diagram is used to show the major process equipment and
				interconnecting process flow lines and show flow rates, stream composition,
				temperatures, and pressures when necessary for clarity. The block flow diagram
				is a simplified diagram. Process flow diagrams are more complex and will show
				all main flow streams including valves to enhance the understanding of the
				process, as well as pressures and temperatures on all feed and product lines
				within all major vessels, in and out of headers and heat exchangers, and points
				of pressure and temperature control. Also, materials of construction
				information, pump capacities and pressure heads, compressor horsepower and
				vessel design pressures and temperatures are shown when necessary for clarity.
				In addition, major components of control loops are usually shown along with key
				utilities on process flow diagrams. Piping and instrument diagrams (P&IDs)
				may be the more appropriate type of diagrams to show some of the above details
				and to display the information for the piping designer and engineering staff.
				The P&Ids are to be used to describe the relationships between equipment
				and instrumentation as well as other relevant information that will enhance
				clarity. Computer software programs which do P&Ids or other diagrams useful
				to the information package, may be used to help meet this requirement. The
				information pertaining to process equipment design must be documented. In other
				words, what were the codes and standards relied on to establish good
				engineering practice. These codes and standards are published by such
				organizations as the American Society of Mechanical Engineers, American
				Petroleum Institute, American National Standards Institute, National Fire
				Protection Association, American Society for Testing and Materials, National
				Board of Boiler and Pressure Vessel Inspectors, National Association of
				Corrosion Engineers, American Society of Exchange Manufacturers Association,
				and model building code groups. In addition, various engineering societies
				issue technical reports which impact process design. For example, the American
				Institute of Chemical Engineers has published technical reports on topics such
				as two phase flow for venting devices. This type of technically recognized
				report would constitute good engineering practice. For existing equipment
				designed and constructed many years ago in accordance with the codes and
				standards available at that time and no longer in general use today, the
				employer must document which codes and standards were used and that the design
				and construction along with the testing, inspection and operation are still
				suitable for the intended use. Where the process technology requires a design
				which departs from the applicable codes and standards, the employer must
				document that the design and construction is suitable for the intended
				purpose.
(4) Process hazard
				analysis. A process hazard analysis (PHA), sometimes called a process hazard
				evaluation, is one of the most important elements of the process safety
				management program. A PHA is an organized and systematic effort to identify and
				analyze the significance of potential hazards associated with the processing or
				handling of highly hazardous chemicals. A PHA provides information which will
				assist employers and employees in making decisions for improving safety and
				reducing the consequences of unwanted or unplanned releases of hazardous
				chemicals. A PHA is directed toward analyzing potential causes and consequences
				of fires, explosions, releases of toxic or flammable chemicals and major spills
				of hazardous chemicals. The PHA focuses on equipment, instrumentation,
				utilities, human actions (routine and nonroutine), and external factors that
				might impact the process. These considerations assist in determining the
				hazards and potential failure points or failure modes in a process. The
				selection of a PHA methodology or technique will be influenced by many factors
				including the amount of existing knowledge about the process. Is it a process
				that has been operated for a long period of time with little or no innovation
				and extensive experience has been generated with its use? Or, is it a new
				process or one which has been changed frequently by the inclusion of innovative
				features? Also, the size and complexity of the process will influence the
				decision as to the appropriate PHA methodology to use. All PHA methodologies
				are subject to certain limitations. For example, the checklist methodology
				works well when the process is very stable and no changes are made, but it is
				not as effective when the process has undergone extensive change. The checklist
				may miss the most recent changes and consequently the changes would not be
				evaluated. Another limitation to be considered concerns the assumptions made by
				the team or analyst. The PHA is dependent on good judgment and the assumptions
				made during the study need to be documented and understood by the team and
				reviewer and kept for a future PHA. The team conducting the PHA need to
				understand the methodology that is going to be used. A PHA team can vary in
				size from two people to a number of people with varied operational and
				technical backgrounds. Some team members may only be a part of the team for a
				limited time. The team leader needs to be fully knowledgeable in the proper
				implementation of the PHA methodology that is to be used and should be
				impartial in the evaluation. The other full or part time team members need to
				provide the team with expertise in areas such as process technology, process
				design, operating procedures and practices, including how the work is actually
				performed, alarms, emergency procedures, instrumentation, maintenance
				procedures, both routine and non-routine tasks, including how the tasks are
				authorized, procurement of parts and supplies, safety and health, and any other
				relevant subject as the need dictates. At least one team member must be
				familiar with the process. The ideal team will have an intimate knowledge of
				the standards, codes, specifications and regulations applicable to the process
				being studied. The selected team members need to be compatible and the team
				leader needs to be able to manage the team, and the PHA study. The team needs
				to be able to work together while benefiting from the expertise of others on
				the team or outside the team, to resolve issues, and to forge a consensus on
				the findings of the study and recommendations. The application of a PHA to a
				process may involve the use of different methodologies for various parts of the
				process. For example, a process involving a series of unit operations of
				varying sizes, complexities, and ages may use different methodologies and team
				members for each operation. Then the conclusions can be integrated into one
				final study and evaluation. A more specific example is the use of a checklist
				PHA for a standard boiler or heat exchanger and the use of a hazard and
				operability PHA for the overall process. Also, for batch type processes like
				custom batch operations, a generic PHA of a representative batch may be used
				where there are only small changes of monomer or other ingredient ratios and
				the chemistry is documented for the full range and ratio of batch ingredients.
				Another process that might consider using a generic type of PHA is a gas plant.
				Often these plants are simply moved from site to site and therefore, a generic
				PHA may be used for these movable plants. Also, when an employer has several
				similar size gas plants and no sour gas is being processed at the site, then a
				generic PHA is feasible as long as the variations of the individual sites are
				accounted for in the PHA. Finally, when an employer has a large continuous
				process which has several control rooms for different portions of the process
				such as for a distillation tower and a blending operation, the employer may
				wish to do each segment separately and then integrate the final results.
				Additionally, small businesses which are covered by this rule, will often have
				processes that have less storage volume, less capacity, and less complicated
				than processes at a large facility. Therefore, WISHA would anticipate that the
				less complex methodologies would be used to meet the process hazard analysis
				criteria in the standard. These process hazard analyses can be done in less
				time and with a few people being involved. A less complex process generally
				means that less data, P&Ids, and process information is needed to perform a
				process hazard analysis. Many small businesses have processes that are not
				unique, such as cold storage lockers or water treatment facilities. Where
				employer associations have a number of members with such facilities, a generic
				PHA, evolved from a checklist or what-if questions, could be developed and used
				by each employer effectively to reflect his/her particular process; this would
				simplify compliance for them. When the employer has a number of processes which
				require a PHA, the employer must set up a priority system of which PHAs to
				conduct first. A preliminary or gross hazard analysis may be useful in
				prioritizing the processes that the employer has determined are subject to
				coverage by the process safety management standard. Consideration should first
				be given to those processes with the potential of adversely affecting the
				largest number of employees. This prioritizing should consider the potential
				severity of a chemical release, the number of potentially affected employees,
				the operating history of the process such as the frequency of chemical
				releases, the age of the process and any other relevant factors. These factors
				would suggest a ranking order and would suggest either using a weighing factor
				system or a systematic ranking method. The use of a preliminary hazard analysis
				would assist an employer in determining which process should be of the highest
				priority and thereby the employer would obtain the greatest improvement in
				safety at the facility. Detailed guidance on the content and application of
				process hazard analysis methodologies is available from the American Institute
				of Chemical Engineers' Center for Chemical Process Safety (see WAC
				296-67-293, Appendix
				D).
(5) Operating procedures and
				practices. Operating procedures describe tasks to be performed, data to be
				recorded, operating conditions to be maintained, samples to be collected, and
				safety and health precautions to be taken. The procedures need to be
				technically accurate, understandable to employees, and revised periodically to
				ensure that they reflect current operations. The process safety information
				package is to be used as a resource to better assure that the operating
				procedures and practices are consistent with the known hazards of the chemicals
				in the process and that the operating parameters are accurate. Operating
				procedures should be reviewed by engineering staff and operating personnel to
				ensure that they are accurate and provide practical instructions on how to
				actually carry out job duties safely. Operating procedures will include
				specific instructions or details on what steps are to be taken or followed in
				carrying out the stated procedures. These operating instructions for each
				procedure should include the applicable safety precautions and should contain
				appropriate information on safety implications. For example, the operating
				procedures addressing operating parameters will contain operating instructions
				about pressure limits, temperature ranges, flow rates, what to do when an upset
				condition occurs, what alarms and instruments are pertinent if an upset
				condition occurs, and other subjects. Another example of using operating
				instructions to properly implement operating procedures is in starting up or
				shutting down the process. In these cases, different parameters will be
				required from those of normal operation. These operating instructions need to
				clearly indicate the distinctions between startup and normal operations such as
				the appropriate allowances for heating up a unit to reach the normal operating
				parameters. Also the operating instructions need to describe the proper method
				for increasing the temperature of the unit until the normal operating
				temperature parameters are achieved. Computerized process control systems add
				complexity to operating instructions. These operating instructions need to
				describe the logic of the software as well as the relationship between the
				equipment and the control system; otherwise, it may not be apparent to the
				operator. Operating procedures and instructions are important for training
				operating personnel. The operating procedures are often viewed as the standard
				operating practices (SOPs) for operations. Control room personnel and operating
				staff, in general, need to have a full understanding of operating procedures.
				If workers are not fluent in English then procedures and instructions need to
				be prepared in a second language understood by the workers. In addition,
				operating procedures need to be changed when there is a change in the process
				as a result of the management of change procedures. The consequences of
				operating procedure changes need to be fully evaluated and the information
				conveyed to the personnel. For example, mechanical changes to the process made
				by the maintenance department (like changing a valve from steel to brass or
				other subtle changes) need to be evaluated to determine if operating procedures
				and practices also need to be changed. All management of change actions must be
				coordinated and integrated with current operating procedures and operating
				personnel must be oriented to the changes in procedures before the change is
				made. When the process is shut down in order to make a change, then the
				operating procedures must be updated before startup of the process. Training in
				how to handle upset conditions must be accomplished as well as what operating
				personnel are to do in emergencies such as when a pump seal fails or a pipeline
				ruptures. Communication between operating personnel and workers performing work
				within the process area, such as nonroutine tasks, also must be maintained. The
				hazards of the tasks are to be conveyed to operating personnel in accordance
				with established procedures and to those performing the actual tasks. When the
				work is completed, operating personnel should be informed to provide closure on
				the job.
(6) Employee training. All
				employees, including maintenance and contractor employees, involved with highly
				hazardous chemicals need to fully understand the safety and health hazards of
				the chemicals and processes they work with for the protection of themselves,
				their fellow employees and the citizens of nearby communities. Training
				conducted in compliance with WAC
				296-901-140, Hazard communication
				, will help employees to be more knowledgeable about the chemicals they work
				with as well as familiarize them with reading and understanding SDS. However,
				additional training in subjects such as operating procedures and safety work
				practices, emergency evacuation and response, safety procedures, routine and
				nonroutine work authorization activities, and other areas pertinent to process
				safety and health will need to be covered by an employer's training program. In
				establishing their training programs, employers must clearly define the
				employees to be trained and what subjects are to be covered in their training.
				Employers in setting up their training program will need to clearly establish
				the goals and objectives they wish to achieve with the training that they
				provide to their employees. The learning goals or objectives should be written
				in clear measurable terms before the training begins. These goals and
				objectives need to be tailored to each of the specific training modules or
				segments. Employers should describe the important actions and conditions under
				which the employee will demonstrate competence or knowledge as well as what is
				acceptable performance. Hands-on-training where employees are able to use their
				senses beyond listening, will enhance learning. For example, operating
				personnel, who will work in a control room or at control panels, would benefit
				by being trained at a simulated control panel or panels. Upset conditions of
				various types could be displayed on the simulator, and then the employee could
				go through the proper operating procedures to bring the simulator panel back to
				the normal operating parameters. A training environment could be created to
				help the trainee feel the full reality of the situation but, of course, under
				controlled conditions. This realistic type of training can be very effective in
				teaching employees correct procedures while allowing them to also see the
				consequences of what might happen if they do not follow established operating
				procedures. Other training techniques using videos or on-the-job training can
				also be very effective for teaching other job tasks, duties, or other important
				information. An effective training program will allow the employee to fully
				participate in the training process and to practice their skill or knowledge.
				Employers need to periodically evaluate their training programs to see if the
				necessary skills, knowledge, and routines are being properly understood and
				implemented by their trained employees. The means or methods for evaluating the
				training should be developed along with the training program goals and
				objectives. Training program evaluation will help employers to determine the
				amount of training their employees understood, and whether the desired results
				were obtained. If, after the evaluation, it appears that the trained employees
				are not at the level of knowledge and skill that was expected, the employer
				will need to revise the training program, provide retraining, or provide more
				frequent refresher training sessions until the deficiency is resolved. Those
				who conducted the training and those who received the training should also be
				consulted as to how best to improve the training process. If there is a
				language barrier, the language known to the trainees should be used to
				reinforce the training messages and information. Careful consideration must be
				given to assure that employees including maintenance and contract employees
				receive current and updated training. For example, if changes are made to a
				process, impacted employees must be trained in the changes and understand the
				effects of the changes on their job tasks (e.g., any new operating procedures
				pertinent to their tasks). Additionally, as already discussed the evaluation of
				the employee's absorption of training will certainly influence the need for
				training.
(7) Contractors.
				Employers who use contractors to perform work in and around processes that
				involve highly hazardous chemicals, will need to establish a screening process
				so that they hire and use contractors who accomplish the desired job tasks
				without compromising the safety and health of employees at a facility. For
				contractors, whose safety performance on the job is not known to the hiring
				employer, the employer will need to obtain information on injury and illness
				rates and experience and should obtain contractor references. Additionally, the
				employer must assure that the contractor has the appropriate job skills,
				knowledge and certifications (such as for pressure vessel welders). Contractor
				work methods and experiences should be evaluated. For example, does the
				contractor conducting demolition work swing loads over operating processes or
				does the contractor avoid such hazards? Maintaining a site injury and illness
				log for contractors is another method employers must use to track and maintain
				current knowledge of work activities involving contract employees working on or
				adjacent to covered processes. Injury and illness logs of both the employer's
				employees and contract employees allow an employer to have full knowledge of
				process injury and illness experience. This log will also contain information
				which will be of use to those auditing process safety management compliance and
				those involved in incident investigations. Contract employees must perform
				their work safely. Considering that contractors often perform very specialized
				and potentially hazardous tasks such as confined space entry activities and
				nonroutine repair activities it is quite important that their activities be
				controlled while they are working on or near a covered process. A permit system
				or work authorization system for these activities would also be helpful to all
				affected employers. The use of a work authorization system keeps an employer
				informed of contract employee activities, and as a benefit the employer will
				have better coordination and more management control over the work being
				performed in the process area. A well run and well maintained process where
				employee safety is fully recognized will benefit all of those who work in the
				facility whether they be contract employees or employees of the
				owner.
(8) Prestartup safety. For
				new processes, the employer will find a PHA helpful in improving the design and
				construction of the process from a reliability and quality point of view. The
				safe operation of the new process will be enhanced by making use of the PHA
				recommendations before final installations are completed. P&Ids are to be
				completed along with having the operating procedures in place and the operating
				staff trained to run the process before startup. The initial startup procedures
				and normal operating procedures need to be fully evaluated as part of the
				prestartup review to assure a safe transfer into the normal operating mode for
				meeting the process parameters. For existing processes that have been shutdown
				for turnaround, or modification, etc., the employer must assure that any
				changes other than "replacement in kind" made to the process during shutdown go
				through the management of change procedures. P&Ids will need to be updated
				as necessary, as well as operating procedures and instructions. If the changes
				made to the process during shutdown are significant and impact the training
				program, then operating personnel as well as employees engaged in routine and
				nonroutine work in the process area may need some refresher or additional
				training in light of the changes. Any incident investigation recommendations,
				compliance audits or PHA recommendations need to be reviewed as well to see
				what impacts they may have on the process before beginning the
				startup.
(9) Mechanical integrity.
				Employers will need to review their maintenance programs and schedules to see
				if there are areas where "breakdown" maintenance is used rather than an ongoing
				mechanical integrity program. Equipment used to process, store, or handle
				highly hazardous chemicals needs to be designed, constructed, installed, and
				maintained to minimize the risk of releases of such chemicals. This requires
				that a mechanical integrity program be in place to assure the continued
				integrity of process equipment. Elements of a mechanical integrity program
				include the identification and categorization of equipment and instrumentation,
				inspections and tests, testing and inspection frequencies, development of
				maintenance procedures, training of maintenance personnel, the establishment of
				criteria for acceptable test results, documentation of test and inspection
				results, and documentation of manufacturer recommendations as to meantime to
				failure for equipment and instrumentation. The first line of defense an
				employer has available is to operate and maintain the process as designed, and
				to keep the chemicals contained. This line of defense is backed up by the next
				line of defense which is the controlled release of chemicals through venting to
				scrubbers or flares, or to surge or overflow tanks which are designed to
				receive such chemicals, etc. These lines of defense are the primary lines of
				defense or means to prevent unwanted releases. The secondary lines of defense
				would include fixed fire protection systems like sprinklers, water spray, or
				deluge systems, monitor guns, etc., dikes, designed drainage systems, and other
				systems which would control or mitigate hazardous chemicals once an unwanted
				release occurs. These primary and secondary lines of defense are what the
				mechanical integrity program needs to protect and strengthen these primary and
				secondary lines of defenses where appropriate. The first step of an effective
				mechanical integrity program is to compile and categorize a list of process
				equipment and instrumentation for inclusion in the program. This list would
				include pressure vessels, storage tanks, process piping, relief and vent
				systems, fire protection system components, emergency shutdown systems, and
				alarms and interlocks and pumps. For the categorization of instrumentation and
				the listed equipment the employer would prioritize which pieces of equipment
				require closer scrutiny than others. Meantime to failure of various
				instrumentation and equipment parts would be known from the manufacturer's data
				or the employer's experience with the parts, which would then influence the
				inspection and testing frequency and associated procedures. Also, applicable
				codes and standards such as the National Board Inspection Code, or those from
				the American Society for Testing and Material, American Petroleum Institute,
				National Fire Protection Association, American National Standards Institute,
				American Society of Mechanical Engineers, and other groups, provide information
				to help establish an effective testing and inspection frequency, as well as
				appropriate methodologies. The applicable codes and standards provide criteria
				for external inspections for such items as foundation and supports, anchor
				bolts, concrete or steel supports, guy wires, nozzles and sprinklers, pipe
				hangers, grounding connections, protective coatings and insulation, and
				external metal surfaces of piping and vessels, etc. These codes and standards
				also provide information on methodologies for internal inspection, and a
				frequency formula based on the corrosion rate of the materials of construction.
				Also, erosion both internal and external needs to be considered along with
				corrosion effects for piping and valves. Where the corrosion rate is not known,
				a maximum inspection frequency is recommended, and methods of developing the
				corrosion rate are available in the codes. Internal inspections need to cover
				items such as vessel shell, bottom and head; metallic linings; nonmetallic
				linings; thickness measurements for vessels and piping; inspection for erosion,
				corrosion, cracking and bulges; internal equipment like trays, baffles,
				sensors, and screens for erosion, corrosion or cracking and other deficiencies.
				Some of these inspections may be performed by state or local government
				inspectors under state and local statutes. However, each employer needs to
				develop procedures to ensure that tests and inspections are conducted properly
				and that consistency is maintained even where different employees may be
				involved. Appropriate training is to be provided to maintenance personnel to
				ensure that they understand the preventive maintenance program procedures, safe
				practices, and the proper use and application of special equipment or unique
				tools that may be required. This training is part of the overall training
				program called for in the standard. A quality assurance system is needed to
				help ensure that the proper materials of construction are used, that
				fabrication and inspection procedures are proper, and that installation
				procedures recognize field installation concerns. The quality assurance program
				is an essential part of the mechanical integrity program and will help to
				maintain the primary and secondary lines of defense that have been designed
				into the process to prevent unwanted chemical releases or those which control
				or mitigate a release. "As built" drawings, together with certifications of
				coded vessels and other equipment, and materials of construction need to be
				verified and retained in the quality assurance documentation. Equipment
				installation jobs need to be properly inspected in the field for use of proper
				materials and procedures and to assure that qualified craftsmen are used to do
				the job. The use of appropriate gaskets, packing, bolts, valves, lubricants,
				and welding rods need to be verified in the field. Also procedures for
				installation of safety devices need to be verified, such as the torque on the
				bolts on ruptured disc installations, uniform torque on flange bolts, proper
				installation of pump seals, etc. If the quality of parts is a problem, it may
				be appropriate to conduct audits of the equipment supplier's facilities to
				better assure proper purchases of required equipment which is suitable for its
				intended service. Any changes in equipment that may become necessary will need
				to go through the management of change procedures.
(10) Nonroutine work authorizations.
				Nonroutine work which is conducted in process areas needs to be controlled by
				the employer in a consistent manner. The hazards identified involving the work
				that is to be accomplished must be communicated to those doing the work, but
				also to those operating personnel whose work could affect the safety of the
				process. A work authorization notice or permit must have a procedure that
				describes the steps the maintenance supervisor, contractor representative or
				other person needs to follow to obtain the necessary clearance to get the job
				started. The work authorization procedures need to reference and coordinate, as
				applicable, lockout/tagout procedures, line breaking procedures, confined space
				entry procedures and hot work authorizations. This procedure also needs to
				provide clear steps to follow once the job is completed in order to provide
				closure for those that need to know the job is now completed and equipment can
				be returned to normal.
(11)
				Managing change. To properly manage changes to process chemicals, technology,
				equipment and facilities, one must define what is meant by change. In this
				process safety management standard, change includes all modifications to
				equipment, procedures, raw materials and processing conditions other than
				"replacement in kind." These changes need to be properly managed by identifying
				and reviewing them prior to implementation of the change. For example, the
				operating procedures contain the operating parameters (pressure limits,
				temperature ranges, flow rates, etc.) and the importance of operating within
				these limits. While the operator must have the flexibility to maintain safe
				operation within the established parameters, any operation outside of these
				parameters requires review and approval by a written management of change
				procedure. Management of change covers such as changes in process technology
				and changes to equipment and instrumentation. Changes in process technology can
				result from changes in production rates, raw materials, experimentation,
				equipment unavailability, new equipment, new product development, change in
				catalyst and changes in operating conditions to improve yield or quality.
				Equipment changes include among others change in materials of construction,
				equipment specifications, piping prearrangements, experimental equipment,
				computer program revisions and changes in alarms and interlocks. Employers need
				to establish means and methods to detect both technical changes and mechanical
				changes. Temporary changes have caused a number of catastrophes over the years,
				and employers need to establish ways to detect temporary changes as well as
				those that are permanent. It is important that a time limit for temporary
				changes be established and monitored since, without control, these changes may
				tend to become permanent. Temporary changes are subject to the management of
				change provisions. In addition, the management of change procedures are used to
				insure that the equipment and procedures are returned to their original or
				designed conditions at the end of the temporary change. Proper documentation
				and review of these changes is invaluable in assuring that the safety and
				health considerations are being incorporated into the operating procedures and
				the process. Employers may wish to develop a form or clearance sheet to
				facilitate the processing of changes through the management of change
				procedures. A typical change form may include a description and the purpose of
				the change, the technical basis for the change, safety and health
				considerations, documentation of changes for the operating procedures,
				maintenance procedures, inspection and testing, P&Ids, electrical
				classification, training and communications, prestartup inspection, duration if
				a temporary change, approvals and authorization. Where the impact of the change
				is minor and well understood, a check list reviewed by an authorized person
				with proper communication to others who are affected may be sufficient.
				However, for a more complex or significant design change, a hazard evaluation
				procedure with approvals by operations, maintenance, and safety departments may
				be appropriate. Changes in documents such as P&Ids, raw materials,
				operating procedures, mechanical integrity programs, electrical
				classifications, etc., need to be noted so that these revisions can be made
				permanent when the drawings and procedure manuals are updated. Copies of
				process changes need to be kept in an accessible location to ensure that design
				changes are available to operating personnel as well as to PHA team members
				when a PHA is being done or one is being updated.
(12) Investigation of incidents. Incident
				investigation is the process of identifying the underlying causes of incidents
				and implementing steps to prevent similar events from occurring. The intent of
				an incident investigation is for employers to learn from past experiences and
				thus avoid repeating past mistakes. The incidents for which WISHA expects
				employers to become aware and to investigate are the types of events which
				result in or could reasonably have resulted in a catastrophic release. Some of
				the events are sometimes referred to as "near misses," meaning that a serious
				consequence did not occur, but could have. Employers need to develop in-house
				capability to investigate incidents that occur in their facilities. A team
				needs to be assembled by the employer and trained in the techniques of
				investigation including how to conduct interviews of witnesses, needed
				documentation and report writing. A multidisciplinary team is better able to
				gather the facts of the event and to analyze them and develop plausible
				scenarios as to what happened, and why. Team members should be selected on the
				basis of their training, knowledge and ability to contribute to a team effort
				to fully investigate the incident. Employees in the process area where the
				incident occurred should be consulted, interviewed, or made a member of the
				team. Their knowledge of the events form a significant set of facts about the
				incident which occurred. The report, its findings and recommendations are to be
				shared with those who can benefit from the information. The cooperation of
				employees is essential to an effective incident investigation. The focus of the
				investigation should be to obtain facts, and not to place blame. The team and
				the investigation process should clearly deal with all involved individuals in
				a fair, open, and consistent manner.
(13) Emergency preparedness. Each employer
				must address what actions employees are to take when there is an unwanted
				release of highly hazardous chemicals. Emergency preparedness or the employer's
				tertiary (third) lines of defense are those that will be relied on along with
				the secondary lines of defense when the primary lines of defense which are used
				to prevent an unwanted release fail to stop the release. Employers will need to
				decide if they want employees to handle and stop small or minor incidental
				releases. Whether they wish to mobilize the available resources at the plant
				and have them brought to bear on a more significant release. Or whether
				employers want their employees to evacuate the danger area and promptly escape
				to a preplanned safe zone area, and allow the local community emergency
				response organizations to handle the release. Or whether the employer wants to
				use some combination of these actions. Employers will need to select how many
				different emergency preparedness or tertiary lines of defense they plan to have
				and then develop the necessary plans and procedures, and appropriately train
				employees in their emergency duties and responsibilities and then implement
				these lines of defense. Employers at a minimum must have an emergency action
				plan which will facilitate the prompt evacuation of employees due to an
				unwanted release of a highly hazardous chemical. This means that the employer
				will have a plan that will be activated by an alarm system to alert employees
				when to evacuate and, that employees who are physically impaired, will have the
				necessary support and assistance to get them to the safe zone as well. The
				intent of these requirements is to alert and move employees to a safe zone
				quickly. Delaying alarms or confusing alarms are to be avoided. The use of
				process control centers or similar process buildings in the process area as
				safe areas is discouraged. Recent catastrophes have shown that a large life
				loss has occurred in these structures because of where they have been sited and
				because they are not necessarily designed to withstand over-pressures from
				shockwaves resulting from explosions in the process area. Unwanted incidental
				releases of highly hazardous chemicals in the process area must be addressed by
				the employer as to what actions employees are to take. If the employer wants
				employees to evacuate the area, then the emergency action plan will be
				activated. For outdoor processes where wind direction is important for
				selecting the safe route to a refuge area, the employer should place a wind
				direction indicator such as a wind sock or pennant at the highest point that
				can be seen throughout the process area. Employees can move in the direction of
				cross wind to upwind to gain safe access to the refuge area by knowing the wind
				direction. If the employer wants specific employees in the release area to
				control or stop the minor emergency or incidental release, these actions must
				be planned for in advance and procedures developed and implemented. Preplanning
				for handling incidental releases for minor emergencies in the process area
				needs to be done, appropriate equipment for the hazards must be provided, and
				training conducted for those employees who will perform the emergency work
				before they respond to handle an actual release. The employer's training
				program, including the hazard communication standard training is to address the
				training needs for employees who are expected to handle incidental or minor
				releases. Preplanning for releases that are more serious than incidental
				releases is another important line of defense to be used by the employer. When
				a serious release of a highly hazardous chemical occurs, the employer through
				preplanning will have determined in advance what actions employees are to take.
				The evacuation of the immediate release area and other areas as necessary would
				be accomplished under the emergency action plan. If the employer wishes to use
				plant personnel such as a fire brigade, spill control team, a hazardous
				materials team, or use employees to render aid to those in the immediate
				release area and control or mitigate the incident, these actions are covered by
				chapter 296-824 WAC, Emergency response to hazardous substance releases. If
				outside assistance is necessary, such as through mutual aid agreements between
				employers or local government emergency response organizations, these emergency
				responders are also covered by chapter 296-824 WAC. The safety and health
				protections required for emergency responders are the responsibility of their
				employers and of the on-scene incident commander. Responders may be working
				under very hazardous conditions and therefore the objective is to have them
				competently led by an on-scene incident commander and the commander's staff,
				properly equipped to do their assigned work safely, and fully trained to carry
				out their duties safely before they respond to an emergency. Drills, training
				exercises, or simulations with the local community emergency response planners
				and responder organizations is one means to obtain better preparedness. This
				close cooperation and coordination between plant and local community emergency
				preparedness managers will also aid the employer in complying with the
				Environmental Protection Agency's risk management plan criteria. One effective
				way for medium to large facilities to enhance coordination and communication
				during emergencies for on plant operations and with local community
				organizations is for employers to establish and equip an emergency control
				center. The emergency control center would be sited in a safe zone area so that
				it could be occupied throughout the duration of an emergency. The center would
				serve as the major communication link between the on-scene incident commander
				and plant or corporate management as well as with the local community
				officials. The communication equipment in the emergency control center should
				include a network to receive and transmit information by telephone, radio, or
				other means. It is important to have a backup communication network in case of
				power failure or one communication means fails. The center should also be
				equipped with the plant layout and community maps, utility drawings including
				fire water, emergency lighting, appropriate reference materials such as a
				government agency notification list, company personnel phone list, SARA Title
				III reports and safety data sheets, emergency plans and procedures manual, a
				listing with the location of emergency response equipment, mutual aid
				information, and access to meteorological or weather condition data and any
				dispersion modeling data.
(14)
				Compliance audits. Employers need to select a trained individual or assemble a
				trained team of people to audit the process safety management system and
				program. A small process or plant may need only one knowledgeable person to
				conduct an audit. The audit is to include an evaluation of the design and
				effectiveness of the process safety management system and a field inspection of
				the safety and health conditions and practices to verify that the employer's
				systems are effectively implemented. The audit should be conducted or led by a
				person knowledgeable in audit techniques and who is impartial towards the
				facility or area being audited. The essential elements of an audit program
				include planning, staffing, conducting the audit, evaluation and corrective
				action, follow-up and documentation. Planning in advance is essential to the
				success of the auditing process. Each employer needs to establish the format,
				staffing, scheduling, and verification methods prior to conducting the audit.
				The format should be designed to provide the lead auditor with a procedure or
				checklist which details the requirements of each section of the standard. The
				names of the audit team members should be listed as part of the format as well.
				The checklist, if properly designed, could serve as the verification sheet
				which provides the auditor with the necessary information to expedite the
				review and assure that no requirements of the standard are omitted. This
				verification sheet format could also identify those elements that will require
				evaluation or a response to correct deficiencies. This sheet could also be used
				for developing the follow-up and documentation requirements. The selection of
				effective audit team members is critical to the success of the program. Team
				members should be chosen for their experience, knowledge, and training and
				should be familiar with the processes and with auditing techniques, practices,
				and procedures. The size of the team will vary depending on the size and
				complexity of the process under consideration. For a large, complex, highly
				instrumented plant, it may be desirable to have team members with expertise in
				process engineering and design, process chemistry, instrumentation and computer
				controls, electrical hazards and classifications, safety and health
				disciplines, maintenance, emergency preparedness, warehousing or shipping, and
				process safety auditing. The team may use part-time members to provide for the
				depth of expertise required as well as for what is actually done or followed,
				compared to what is written. An effective audit includes a review of the
				relevant documentation and process safety information, inspection of the
				physical facilities, and interviews with all levels of plant personnel.
				Utilizing the audit procedure and checklist developed in the preplanning stage,
				the audit team can systematically analyze compliance with the provisions of the
				standard and any other corporate policies that are relevant. For example, the
				audit team will review all aspects of the training program as part of the
				overall audit. The team will review the written training program for adequacy
				of content, frequency of training, effectiveness of training in terms of its
				goals and objectives as well as to how it fits into meeting the standard's
				requirements, documentation, etc. Through interviews, the team can determine
				the employee's knowledge and awareness of the safety procedures, duties, rules,
				emergency response assignments, etc. During the inspection, the team can
				observe actual practices such as safety and health policies, procedures, and
				work authorization practices. This approach enables the team to identify
				deficiencies and determine where corrective actions or improvements are
				necessary. An audit is a technique used to gather sufficient facts and
				information, including statistical information, to verify compliance with
				standards. Auditors should select as part of their preplanning a sample size
				sufficient to give a degree of confidence that the audit reflects the level of
				compliance with the standard. The audit team, through this systematic analysis,
				should document areas which require corrective action as well as those areas
				where the process safety management system is effective and working in an
				effective manner. This provides a record of the audit procedures and findings,
				and serves as a baseline of operation data for future audits. It will assist
				future auditors in determining changes or trends from previous audits.
				Corrective action is one of the most important parts of the audit. It includes
				not only addressing the identified deficiencies, but also planning, followup,
				and documentation. The corrective action process normally begins with a
				management review of the audit findings. The purpose of this review is to
				determine what actions are appropriate, and to establish priorities,
				timetables, resource allocations, and requirements and responsibilities. In
				some cases, corrective action may involve a simple change in procedure or minor
				maintenance effort to remedy the concern. Management of change procedures need
				to be used, as appropriate, even for what may seem to be a minor change. Many
				of the deficiencies can be acted on promptly, while some may require
				engineering studies or indepth review of actual procedures and practices. There
				may be instances where no action is necessary and this is a valid response to
				an audit finding. All actions taken, including an explanation where no action
				is taken on a finding, needs to be documented as to what was done and why. It
				is important to assure that each deficiency identified is addressed, the
				corrective action to be taken noted, and the audit person or team responsible
				be properly documented by the employer. To control the corrective action
				process, the employer should consider the use of a tracking system. This
				tracking system might include periodic status reports shared with affected
				levels of management, specific reports such as completion of an engineering
				study, and a final implementation report to provide closure for audit findings
				that have been through management of change, if appropriate, and then shared
				with affected employees and management. This type of tracking system provides
				the employer with the status of the corrective action. It also provides the
				documentation required to verify that appropriate corrective actions were taken
				on deficiencies identified in the audit.
Statutory Authority:
					 RCW
					 49.17.010,
					 49.17.040,
					 49.17.050, and
					 49.17.060. 02-20-034, §
					 296-67-291, filed 9/24/02, effective 10/1/02. Statutory Authority:
					 RCW
					 49.17.010,
					 49.17.040, and
					 49.17.050. 01-11-038, §
					 296-67-291, filed 5/9/01, effective 9/1/01. Statutory Authority: Chapter 49.17
					 RCW. 93-21-075 (Order 93-06), § 296-67-291, filed 10/20/93, effective
					 12/1/93; 92-17-022 (Order 92-06), § 296-67-291, filed 8/10/92, effective
					 9/10/92.