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Hot work permit. A permit must be issued for hot work operations conducted on or near a covered process. The permit must document that the fire prevention and protection rules for welding, cutting, and brazing (29 CFR 1910.252(a)) have been implemented before beginning the hot work operations. It must also indicate the date(s) authorized for hot work and identify the object on which hot work is to be performed.
Management of change. Prepare written procedures to manage changes (except for “replacements in kind”) to process chemicals, technology, equipment, operating procedures, and facilities that affect a covered process. 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.
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Incident investigation. 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 OSHA expects employers to become aware and to investigate are the types of events that 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.
Emergency planning and response. Address what actions employees are to take when there is an unwanted release of highly hazardous chemicals. Select how many different emergency preparedness procedures or lines of defense you plan to have and then develop the necessary plans and procedures, appropriately train employees in their emergency duties and responsibilities, and then implement these lines of defense.
Compliance audit. Select a trained individual or assemble a trained team of people to audit the PSM 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 PSM 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 lead by a person knowledgeable in audit techniques and impartial toward 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.
Trade secrets. Include a policy statement concerning the disclosure of trade secret claims and your requirements for confidentiality agreements.
Training. Develop a written training program that ensures each employee presently involved in operating a process or a newly assigned process will be trained in an overview of the process and in its operating procedures. The training must include emphasis on specific safety and health hazards of the process, emergency operations including shutdown, and other safe work practices that apply to the employee’s job tasks.
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Contractors. Develop a written procedure for managing contractors that perform maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process. Such procedures will not apply to contractors providing incidental services that do not influence process safety, such as janitorial, food and drink, laundry, delivery, or other supply services. Ensure that each contract employee is trained in the work practices necessary to safely perform his or her job.
State requirements. California, Nevada, New York, and Utah have adopted PSM requirements that are stricter than the federal requirements. Check with your state to find out if stricter rules apply.
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