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Other Applications PSM

How might the PSM process be applied to other industries?

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, neither of which are regulated by OSHA’s PSM standard. However, how might the fundamentals of PSM be applied elsewhere to make all communities safer?

Employee Participation is important in a communal setting such as this market. The market is said to provide an income for over 20% of the local residents. Therefore, most everyone in town has a stake in the market. Getting the vendors and community involved in the safe planning of the market is imperative. Encouraging participation also gives the local community a greater sense of ownership into the operations, thereby increasing buy-in to the safety precautions put in place.

There needs to be a plan in place for dealing with Contractors, or in this case, market vendors. It was reported that the vendors were certified by the secretary of defense to sell their products commercially and that the vendors were checked to ensure compliance. Those are great steps to take. However, in talking to some of those involved, it was apparent that not all contractors/vendors followed the rules. In order to ensure a safe marketplace for all involved, those that do not follow the rules need to be removed immediately from the site, similar to contractors at an industrial site who do not follow safety rules and are removed from the facility immediately. Employee participation plays a role in helping to identify those vendors who are not following the rules. Others need to feel enough personal responsibility and ownership that they follow the “see something, say something” mantra.

The concepts of Mechanical Integrity also apply to a fireworks market. When designing the stalls, the risks of sparks and explosions need to be taken into consideration to design a robust area. The materials of construction need to be chosen with these risks in mind, and the integrity of the structures needs to be tested and demonstrated on a regular basis. Although the initial cost may be more expensive, having an explosion proof enclosure would allow for the remaining vendors to continue operation even if one vendor had an issue and had to close due to a fire.

Involving the buyers in the Operating Procedures would also make a difference. When it is established that the vendors have a large stake in the operations, they are then able to pass that sense of importance on to the clients to make sure the clients behave safely. The CNN report states that sometimes “it was the clients who ignored the safety precautions, asking to light certain fireworks to ensure they worked, an action expressly prohibited in the market.” When the vendors are invested and buy-in to the procedures because they were involved in their development, it makes enforcement much easier. The public will always try to bend rules to get what it wants, it is up to the vendors to make sure the rules are followed by everyone at every interaction.

PSM may be aimed at chemical manufacturers, however its concepts are relevant in many situations. How does PSM process apply to other industries or facets of your life?

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Categories
Other Applications PSM

PSM in Space Exploration?

FALCON 9 FIRST STAGE LAND LANDING (ORBCOMM 2 MISSION) Courtesy of SpaceX.com

FALCON 9 FIRST STAGE LAND LANDING (ORBCOMM 2 MISSION) Courtesy of SpaceX.com

On September 1, 2016 SpaceX attempted to launch a Falcon 9 rocket with payload and “during a standard pre-launch static fire test for the AMOS-6 mission, there was an anomaly at SpaceX’s Cape Canaveral Space Launch Complex 40 resulting in loss of the vehicle.” SpaceX has been grounded since then as they have worked to figure out what caused the anomaly.

Initially, they reported that Standard Operating Procedures were followed, which resulted in no personnel injuries. We are able to see from this how important it is to read Operating Procedures when they come across your desk for review. It is illustrated here how procedures play a role in preventing injuries. Imagine if the Operating Procedures did not specify that no personnel were to be in the vicinity of the launch pad during fueling operations. It may have resulted in a very different outcome.

They used Incident Investigation methods to thoroughly look at what happened so they were able to prevent it from happening again. They assembled a team of people from many agencies with a stake in the outcome to get a thorough understanding of the problem. They worked with the FAA, NASA, the US Air Force, and industry experts. They did not work in a bubble. They understood that it would take many eyes with many backgrounds to determine the root cause. They worked methodically through a fault tree analysis, one of many tools available in the Incident Investigation toolbox. Eventually, they concluded “that one of the three composite overwrapped pressure vessels (COPVs) inside the second stage liquid oxygen (LOX) tank failed. Specifically, the investigation team concluded the failure was likely due to the accumulation of oxygen between the COPV liner and overwrap in a void or a buckle in the liner, leading to ignition and the subsequent failure of the COPV.”

SpaceX was able to determine the root cause, and made changes in the configuration of the vessel along with modifying its operating procedures for fueling. They were successful in their launch on Saturday, January 14.

How have you used Operating Procedures and Incident Investigation to better your process?

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Other Applications PSM

PSM in Paper Mills?

Ah, the smell of Kraft mills…it is amazing that one type of plant has given an entire industry a bad name for its putrid smells. But that is a whole different blog post. Let’s take a look at how PSM may be applied in the Pulp & Paper industry.

Courtesy of  https://www.packagingcorp.com/deridder-containerboard-mill
Courtesy of https://www.packagingcorp.com/deridder-containerboard-mill

In early February, there was an explosion at the Packaging Corporation of America DeRidder Containerboard Mill in DeRidder, LA. The mill produces Kraft linerboard and corrugated medium. For those not familiar with the terms, linerboard is the outside layers of corrugated cardboard and the corrugated medium is the wavy center portion. Many paper mills are not covered by PSM, or only a small section of processes are covered, because they typically do not have a large number of the identified highly hazardous chemicals above the threshold quantities.

The Chemical Safety Board issued a statement as it was preparing to investigate the incident, in that statement, the CSB stated, “According to initial reports, the explosion took place while contractors performed welding on a tank during a facility shut down. The explosion was powerful enough to cause the tank to fly and land in a different area of the plant.” Although paper mills may not be fully PSM covered, the guidelines provide a great framework for any manufacturing facility.

The first PSM element that may have come into play in this incident is Hot Work. According to OSHA, “Hot work” means riveting, welding, flame cutting or other fire or spark-producing operation. Welding a tank would certainly fall under this definition. PSM requires that a hot work permit be issued for “hot work operations conducted on or near a covered process.” The regulation also requires the scope of work to be completed along with the fire prevention and protection measures that have been implemented prior to beginning the hot work operation. It is especially dangerous to weld on a tank as there is a possibility of flammable gasses getting trapped inside the (relatively) small area inside the tank. When preparing the hot work permit, the area outside the tank as well as inside the tank needs to be checked and free from any flammable materials. Many plants have designated locations where hot work is allowed without special permits, make sure those locations are well posted and everyone knows where they can and cannot perform work without a permit.

Another PSM element that would have played a factor is Contractors. It is important to treat contractors as more than second class citizens. Make sure they are trained in all plant safety policies and procedures. And check out the contractor policies to make sure they are in line with what has been implemented at the plant. It is important to have adequate oversight for contractors. Do not send them out to a job site and leave them alone all day. Make sure they know how to reach a representative in case of questions, and check in with them to make sure they are not making up their own answers.

How else might PSM play a role in the Paper Industry? Share your thoughts with us!