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Elements PSM

Spacing

Shortly before Christmas, there was a massive fire and explosion at a fireworks market on the northern outskirts of Mexico City with a death toll of at least 32 people. This is Mexico and the pyrotechnics industry, both of which are not regulated by OSHA’s PSM standard.

The investigation so far has shown that it was due to customers wanting to test fireworks at the stalls. What comes to mind from this incident is the spacing between the stalls. Were the stalls too close to provide the customers a full experience, or were safety processes not followed?

From this incident, the issue of spacing can be applied in your own site. Even with the understanding that many legacy sites were built years before these safety requirements were put in place, consideration needs to be made regarding what processes are able to impact other units. The analysis should be to look at what your critical processes are and how they can be impacted by nearby units.

I had a situation in a plant where two tanks were within seven feet of each other. One tank was an inlet tank to the site and loss of it would have caused some upset problems but not stopped the operation. The loss of the other tank would shut down the site as it was necessary for consistent feed to the process. So we analyzed the system to determine that we needed to protect the tanks from each other even though the tanks were built 30 years ago.

How has spacing played into your design?

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Elements PSM

Operability and HAZOPs

This week’s tip goes back to the old philosophy that knowledge is lost over time. Currently HAZOPs focus on only the hazards of the process. But think about the opportunity that you’re missing in that you have a room full of the best people from the unit and you’re not talking about operability problems. And by operability problems, I mean operational constriction points, physically difficult areas to operate, bad operating procedures, and just bad procedures.  HAZOPs are expensive to begin with, however we need to utilize all the personnel available to get the most value out of the study. It only takes a couple minutes to ask the operators these critical questions and to create action items to look into these issues. Doing this will enhance value for operations.

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Elements PSM

Corrosion/Erosion-Changes in pipe after catalyst beds

When inspecting your piping in vessels do you emphasize size changes in elbows after catalyst beds? My experience has shown that a momentum change happens to your process flow and a lot of erosion can occur in the post catalyst bed beads. The issue comes from bed beating, normally a silicone or ceramic structure, that is highly erosive and similar to sandpaper. These points of change of momentum, which are the changes in flow patterns such as expansion or direction, encourage your catalyst beads to impact the surface. This happened to me and I have used this thought to increase the inspection areas consistently throughout operations.

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Elements PSM

Audits-routine or valuable?

When choosing your audit format, be it checklist or open audit, how do you approach this? Although you may use a checklist to help ensure you are reviewing everything, you must look at the audit with an open mind every time. Even with the most skilled operator, a checklist can get only to the routine and not dive deep enough to get real value. We suggest you review your audits and work with operations or other personnel performing the audit to ensure that everyone is keeping an open mind and looking at all things.

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Elements PSM

How are you choosing Mechanical Integrity inspection points?

When defining mechanical integrity points are you picking these are the picking spots that correspond to the minimum changes or you picking random points helping you win the lottery of inspection and hit a place that issues can occur. Make sure you discuss this with a mechanical integrity engineer prior to going out and starting inspections and defining these points, because once you defined the points, you lose the historical value of those points.

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Elements PSM

Audits-don’t punish for failure

Have you consciously looked at the outcomes of your audits? If you reframe your outlook on audit findings not as a speeding ticket, but as a notice that you found something before it became a problem, it will encourage greater involvement and discourage cover-ups. Things that are not right are not a good thing for any plant, and identifying potential issues may be looked at by management as not doing due diligence. However, most people’s minds are set on operations and business and not on looking for problems. Those activities are limited to hazard assessments, audits, and investigations. This is when personnel have their minds open to find problems. Think about the opportunity to reward for finding potential problems before they became issues so the problems are able to be addressed. The alternative is to punish for having potential problems that exist and having personnel hide things because they do not want to be caught. Which environment would you rather be a part of?

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Elements PSM

Lost in Technology

Do operators read your procedures? Take a look at them and notice how long they are. Are they too long and cumbersome? Maybe it is time to review and revise them to a much more manageable length. Keep the extra information for a policy and keep your procedures to the point. It will help everyone involved!

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Elements PSM

When do you use a PSSR?

Most facilities I have seen only use a PSSR in conjunction with an MOC. While this is important, why are they not used every time a process gets re-started? When there is an emergency shut-down, are there important things that need to be checked before starting back up? That is what the PSSR is for! Or how about after a turnaround? Are you sure everything is lined up properly and you are ready to start the process? Use the tools you have to make sure! PSSR’s are good for more than only MOCs!

How do you use PSSRs at your facility?

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Elements PSM

Include Contractors in reviews

Along with the element of employee participation, contractors must be included. These embedded workers are as critical as direct employees. In many cases the use of contractors for maintenance activities has led to limited direct employee usage. Think about all the activities in which hazards in the worksite are being analyzed. Are contractors involved with JSAs, HAZOPs and LOTOs? A key piece of information may be missing if they are not!  Remember, every time a change occurs in the plant, the knowledge of the prior people who are in maintenance has been changed. Therefore contract personnel may have important information to help you be successful.

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Elements PSM

How high is your MOC pile?

MOCs are difficult to manage and most sites allow them to pile up as priorities shift in maintenance and operations. Many times, MOCs sit around collecting dust and not getting implemented. Think about if these changes are absolutely necessary. Sometimes, upon second review the MOC has hazards or benefits that were not covered initially. If you find the MOC is still valuable, schedule it for completion! However, if the MOC is found to not be as desirable as initially intended, the MOC needs to be eliminated. Keep in mind that an MOC associated with a PHA needs to be reevaluated by the PHA team, and not only the operational management team.