Emergency Preparedness and Response, Fire Safety, HazMat

Preparedness is Prevention: Six More Ways Process Safety Management Could Have Prevented This Fire

At the Arboris® plant in Newark, Ohio, workers were adding hexane to a process that produced sterols—a natural compound produced by pine trees—for use in foods such as spreads, bread, milk, and yogurt. Unfortunately, the employer’s process safety management (PSM) program failed at many points to identify and correct potentially disastrous issues with the process. As a result, a tank at the facility overpressurized and exploded, injuring four workers.

Yesterday, we looked at four areas where Arboris could have identified and corrected problems with the process before a disaster occurred. Today, we’ll look at six more. Examine your own PSM program for completeness in these areas.

Plan for Contractors

Two contractors were among those injured in the Arboris fire. The U.S. Occupational Safety and Health Administration (OSHA) alleges that Arboris had failed to develop safe work practices addressing contractors in violation of 29 CFR 1910.119(h). Arboris allegedly failed to what Contractor safe work practices must cover

  • The entrance, presence, and exit of contract employees in covered process areas.
  • The collection and evaluation of safety program and performance information on prospective contractors—for example, the collection and evaluation of the contractor’s OSHA 300 logs and safety programs.

Action items: Make sure that you have a plan in place for controlling the movement of contractors in covered process areas. For contractors who will be working on or near covered processes, have a procedure in place for checking their safety record before they come on-site.

Use Your Pre-Start-Up Safety Review

Employers must perform a pre-start-up safety review for new and modified facilities that confirms, before highly hazardous chemicals are added to a process, that everything is in place that is needed to ensure the safety of the process. Arboris allegedly failed to perform a pre-start-up safety review, in violation of 29 CFR 1910.119(i), by failing to ensure that safety, operating, maintenance and emergency procedures were in place.

This was a “bonus” citation of sorts, for OSHA: In failing to have these procedures in place as required at other points in its PSM program, Arboris also failed to have them available for its pre-start-up safety review.

Action item: Your pre-start-up safety review is your last chance to catch any potentially hazardous errors and omissions. Make sure that workers have a checklist to work through that will enable them to identify any problems.

Protect Your Mechanical Integrity

The mechanical integrity of any covered process is every bit as vital as the behavior of the chemicals in the system. OSHA alleges that Arboris failed to develop operational procedures to maintain the ongoing integrity of equipment, in violation of 29 CFR 1910.119(j). Specifically, Arboris allegedly did not:

  • Develop written procedures covering the inspection, testing, and maintenance of relief system components, piping system and valves, and process vessels in its covered process.
  • Update its computerized maintenance management system software for the covered process to the software system in use for the rest of the plant.
  • Establish quality assurance procedures to insure that equipment, maintenance materials, spare parts, and newly fabricated equipment were suitable for the process applications in which they would be used.
  • Ensure that appropriate checks and inspections were performed to ensure that equipment was installed properly and consistent with design specifications and manufacturer’s instructions.
  • Ensure that inspections and tests were being performed on pressure-relieving devices in the covered process.
  • Ensure that any identified equipment deficiencies are corrected in a timely fashion and before further use of the equipment.

Action items: Make sure that your mechanical integrity procedures are as complete and thorough as your PHA and safe operating procedures. If you’ve upgraded your management systems, make sure that the upgrade extends to your covered processes as appropriate. Check your inspection records to ensure that inspections are actually being performed and that any identified issues are being addressed.

Investigate Any Incidents

The PSM standard requires employers to fully investigate any incidents that occur in a covered process. The investigation reports should include the names of the members of the investigation team, the date the investigation began, a detailed description of the incident, a list of contributing factors, any recommendations arising out of the investigation, and documentation of how those recommendations were addressed.

Arboris had incident investigation reports for twenty different incidents involving its covered process—but, according to OSHA, all of those incident reports were missing one or more required elements, a violation of 29 CFR 1910.119(m).  Among Arboris’ alleged failings were a failure to include on its incident investigation team at least one representative of a contractor who was working on the process at the time of the incident, and failure to document the date that the inspection began.

Action item: Are your incident investigation reports complete—including documentation of how recommendations were addressed? If not, can you complete them?

Plan for Emergencies

The PSM standard stresses planning and preparation but recognizes that even with all that advance planning, pre-start-up review, and management of change, things can still go wrong. That’s why you also have to have a plan in place for handling emergencies under 29 CFR 1910.119(n), which references 29 CFR 1910.38, Emergency Action Plans, and portions of 29 CFR 1910.120, the Hazardous Waste Operations and Emergency Response (HAZWOPER) standard. Arboris allegedly violated this standard by failing to create procedures to be followed by workers who remain to operate critical plant equipment before evacuating.

Action item: If you are covered by the PSM standard, you are also covered by the Emergency Action Plans standard and may be covered by HAZWOPER. Make sure that you have done what you need to in order to comply with all three standards.

Need more information on setting up an effective PSM program? The resources at Safety.BLR.com can help you plan for all contingencies.