Guidelines for Performing Effective Pre-Startup Safety Reviews E-Book

• Herausgeber: John Wiley & Sons
• Kategorie: Fachliteratur
• Sprache: Englisch

Seitenzahl: 188

Veröffentlichungsjahr: 2011

Beschreibung

This book provides guidance to those with responsibility for scheduling and executing a Pre-Startup Safety Review (PSSR). It outlines a protocol and tool for use by project or turnaround teams, to effectively and efficiently schedule and execute a PSSR. * Integrates PSSR throughout the project/turnaround phases, with a verification check at the traditional PSSR step * Supports a "right first time" and "check only once" project philosophy to eliminate surprises * Features how-to checklists, hazard assessment, batch and continuous processes, validation, and documentation * Includes a CD with PSSR checklists and PSSR management system examples. Note: CD-ROM/DVD and other supplementary materials are not included as part of eBook file.

Leseprobe

Contents

Cover

Half Title page

Title page

Copyright page

List of Tables

List of Figures

Items on the CD Accompanying This Book

Acronyms and Abbreviations

Glossary

Acknowledgements

Preface

Chapter 1: Introduction

1.1 What are the Benefits of Performing Pre-Startup Safety Reviews?

1.2 How PSSR Relates to Other Process Safety Elements

1.3 An Overview of the Risk-Based Approach to PSSR

1.4 What is the Scope of a PSSR? Process Safety, Environmental, Quality and Personnel Safety Considerations

1.5 This Guideline’s Audience

1.6 How to Use this Guideline

1.7 References

Chapter 2: What is a Pre-Startup Safety Review?

2.1 The Basics of Pre-Startup Safety Review

2.2 What is a Risk-Based Approach to PSSR?

2.3 The Role of Training in Pre-Startup Safety Review

2.4 Scheduling Considerations

2.5 References

Chapter 3: Regulatory Issues

3.1 An Overview of PSSR Industry Guidelines and Regulations

3.2 Best Practices for PSSR

3.3 Environmental Considerations

3.4 General Safety, Security, and Occupational Health Considerations

3.5 References

Chapter 4: A Risk-Based Approach to Pre-Startup Safety Review

4.1 Using Risk Analysis Techniques to Select the Level of Detail for a PSSR

4.2 A Decision Guideline for Designing a PSSR

4.3 Typical Considerations for All Pre-Startup Safety Reviews

4.4 An Example Risk-Based Questionnaire

4.5 Two Examples of Using a Risk-Based Approach to PSSR Design

4.6 References

Chapter 5: The Pre-Startup Safety Review Work Process

5.1 Defining the PSSR System

5.2 PSSR Sub-Elements

5.3 Designing and Implementing an Initial PSSR Program

5.4 Preparing to Perform a Pre-Statup Safety Review

5.5 Follow Pre-Startup Safety Review Action Items

5.6 Approve the Pre-Startup Safety Review Report

5.7 References

Chapter 6: Methodologies for Compiling and Using A PSSR Checklist

6.1 Building Your Facility’s Database of Questions

6.2 Various Approaches: Electronic Versus Hardcopy

6.3 An Example Electronic Checklist

Chapter 7: Continuous Improvement

7.1 Diagnosing PSSR System Issues

7.2 Training and Communication

7.3 Examine Excesses as well as Deficiencies

7.4 Why Refine, Improve, Upgrade, or Redesign?

7.5 Upgrading the System

7.6 Example PSSR Performance and Efficiency Metrics

7.7 Audit Frequency

7.8 Qualification Considerations for PSSR Auditors

7.9 Sample PSSR Audit Protocols

7.10 Addressing Audit Results

7.11 Summary

7.12 References

Appendix A – PSSR Checklist Examples

Appendix B – Industry References

Appendix C – Regulatory References

Index

GUIDELINES FOR PERFORMING EFFECTIVE PRE-STARTUP SAFETY REVIEWS

This book is one in a series of process safety guideline and concept books published by the Center for Chemical Process Safety (CCPS). Please go to www.wiley.com/go/ccps to see the full list of titles.

Copyright © 2007 by American Institute of Chemical Engineers. All rights reserved.

A Joint Publication of the Center for Chemical Process Safety of the American Institute of Chemical Engineers and John Wiley & Sons, Inc.

Published by John Wiley & Sons. Inc., Hoboken, New Jersey.Published simultaneously in Canada.

No part of this publication may be reproduced, stored in a retrieva, system, or transmitted in any form or by any means, electronic, mechanical, photocopying, recording, scanning, or otherwise, except as permitted under Section 107 or 108 of the 1976 United States Copyright Act, without either the prior written permission of the Publisher, or authorization through payment of the appropriate per-copy fee to the Copyright Clearance Center, Inc., 222 Rosewood Drive, Danvers, MA 01923, [phone], fax [phone], or on the web at www.copyright.com. Requests to the Publisher for permission should be addressed to the Permissions Department, John Wiley & Sons. Inc., 111 River Street, Hoboken, NJ 07030, [phone], fax [phone], or online at http://www.wiley.com/go/permission.

Limit of Liability/Disclaimer of Warranty: While the publisher and author have used their best efforts in preparing this book, they make no representations or warranties with respect to the accuracy or completeness of the contents of this book and specifically disclaim any implied warranties of merchantability or fitness for a particular purpose. No warranty may be created or extended by sales representatives or written sales materials. The advice and strategies contained herem may not be suitable for your situation. You should consult with a professional where appropriate. Neither the publisher nor author shall be liable for any loss of profit or any other commercial damages, including but not limited to special, incidental, consequential, or other damages.

For general information on our other products and services or for technical support, please contact our Customer Care Department within the United States at [phone], outside the United States at [phone] or fax [phone].

Wiley also publishes its books in a variety of electronic formats. Some content that appears in print may not be available in electronic format. For information about Wiley products, visit our web site at www.wiley.com.

Library of Congress Cataloging-in-Publication Data is available.

ISBN 978-0-470-13403-0

It is sincerely hoped that the information presented in this document will lead to an even more impressive safety record for the entire industry, however, neither the American Institute of Chemical Engineers, its consultants. CCPS Technical Steering Committee and Subcommittee members, their employers, their employers officers and directors, nor AntiEntropics. Incorporated and its employees warrant or represent, expressly or by implication, the correctness or accuracy of the content of the information presented in this document As between (1) American Institute of Chemical Engineers, its consultants, CCPS Technical Steering Committee and Subcommittee members, their employers, their employers officers and directors, and AntiEntropics, Inc., and its employees, and (2) the user of this document, the user accepts any legal liability or responsibility whatsoever for the consequence of its use or misuse.

LIST OF TABLES

TABLE 1-1  How PSSR Typically Interfaces with Other PSM Elements

TABLE 3-1  Global Examples of Pre-startup Safety Review Related Documents

TABLE 4-1  Typical Risk-based Decision Making Steps in a PSM PSSR Procedure

TABLE 4-2  Example short form for lower risk / simple PSSR

TABLE 4-3  Example long form for higher risk / complex PSSR

TABLE 4-4  Example completed short form PSSR

TABLE 4-5  Example long form PSSR in progress

TABLE 5-1  An example integrated PSM/RMP compliance plan and management system

TABLE 5-2  Example pre-startup safety review administrative procedure

TABLE 6-1  Example of collapsing an electronic PSSR checklist

TABLE 6-2  Example expansion of an electronic PSSR checklist in progress

TABLE 7-1  Typical PSSR issues from formal or informal audits

TABLE 7-2  Example guideline wording for a PSSR element audit protocol

TABLE 7-3  Excerpted PSSR language from OSHA CPL 2-2.45A CH-1

LIST OF FIGURES

FIGURE 2-1 Basic PSSR work flow chart.

FIGURE 4-1 An example risk matrix chart

ITEMS ON THE CD ACCOMPANYING THIS BOOK

The text of the book

Example PSSR checklists

An example PSSR management system procedure

An Excel spreadsheet of basic PSSR checklist items in an expandable format

ACRONYMS AND ABBREVIATIONS

ACCAmerican Chemistry CouncilAIChEAmerican Institute of Chemical EngineersAPIAmerican Petroleum InstituteASMEAmerican Society of Mechanical Engineers  CCPSCenter for Chemical Process SafetyCFRCode of Federal RegulationsCPIchemical process industries  DOTDepartment of Transportation  EPAEnvironmental Protection AgencyESDemergency shutdown  HAZMAThazardous materialHAZOPhazard and operability study  ISOInternational Organization for Standardization  MOCmanagement of changeMSDSmaterial safety data sheet(s)  NDTnondestructive testingNECNational Electric CodeNFPANational Fire Protection Association  OSHAOccupational Safety and Health Administration  P&IDpiping and instrumentation diagramPHAprocess hazard analysisPMpreventive maintenancePPEpersonal protective equipmentPSMprocess safety managementPSSRpre-startup safety reviewPSVpressure safety valve  QAquality assurance  RAGAGEP  recognized and generally accepted good engineering practiceRMPrisk management program  SCBAself-contained breathing apparatusSISsafety instrumented systemSMEsubject matter expert  ULUnderwriters Laboratories Inc.

GLOSSARY

Gantt Chart

A manner of depicting multiple, time-based project activities (usually on a bar chart with a horizontal time scale).

Hazard and operability (HAZOP) study

A systematic method in which process hazards and potential operating problems are identified using a series of guide words to investigate process deviations.

Management of change (MOC)

A management system for ensuring that changes to processes are properly analyzed (for example, for potential adverse impacts), documented, and communicated to affected personnel.

Mechanical integrity (MI)

A management system for ensuring the ongoing durability and functionality of equipment.

Nondestructive testing/examination (NDT/NDE)

Evaluation of an equipment item with the intention of measuring an equipment parameter without damaging or destroying the equipment item.

Performance measure

A metric used to monitor or evaluate the operation of a program activity or management system.

Pre-startup safety review (PSSR)

A final check, initiated by a trigger event, prior to the use or reuse of a new or changed aspect of a process. It is also the term for the OSHA PSM and EPA RMP element that defines a management system for ensuring that new or modified processes are ready for startup.

Process hazard analysis (PHA)

A systematic evaluation of process hazards with the purpose of ensuring that sufficient safeguards are in place to manage the inherent risks.

Process safety information (PSI)

A compilation of chemical hazard, technology, and equipment documentation needed to manage process safety.

Quality assurance (QA)

Activities to ensure that equipment is designed appropriately and to ensure that the design intent is not compromised throughout the equipment’s entire life cycle.

Recommended and generally accepted good engineering practice (RAGAGEP)

Document that provides guidance on engineering, operating, or maintenance activities based on an established code, standard, published technical report, or recommended practice (or a document of a similar name).

Replacement in kind

A replacement that satisfies the design specifications.

Risk

A measure of potential loss (for example, human injury, environmental insult, economic penalty) in terms of the magnitude of the loss and the likelihood that the loss will occur.

Risk analysis

The development of a qualitative and/or quantitative estimate of risk-based on engineering evaluation and mathematical techniques (quantitative only) for combining estimates of event consequences and frequencies.

Trigger event

Any change being made to an existing process, or any new facility being added to a process or facility, or any other activity a facility designates as needing a pre-startup safety review. One example of a non-change related trigger event is performing a PSSR before restart after an emergency shutdown.

Verification activity

A test, field observation, or other activity used to ensure that personnel have acquired necessary skills and knowledge following training.

ACKNOWLEDGEMENTS

The American Institute of Chemical Engineers (AIChE) wishes to thank the Center for Chemical Process Safety (CCPS) and those involved in its operation, including its many sponsors whose funding made this project possible, and the members of the Technical Steering Committee, who conceived of and supported this guideline project. The members of the Pre-startup Safety Review subcommittee who worked with AntiEntropics Inc. to produce this text deserve special recognition for their dedicated efforts, technical contributions, and overall enthusiasm for creating a useful addition to the process safety guideline series. CCPS also wishes to thank the subcommittee members’ respective companies for supporting their involvement in this project.

The chairman of the Pre-startup Safety Review subcommittee was Perry Morse of E.I. DuPont de Nemours and Company. The CCPS staff liaison was Dan Sliva. The members of the CCPS pre-startup safety review guideline subcommittee were:

Larry Bowler

GE Advanced Materials

Don Connolley

BP

Susan Cowher

ISP Technologies, Inc.

Jonathan Gast

Wyeth Pharmaceuticals

David M. Hawkins, CSP

Intel Corporation

John Herber

3M Company

Lisa Morrison

PPG Industries, Inc.

Steve Marwitz

Formosa Plastics

Glen Peters

Air Products

Cedric Pereira

BP

Michael Moriarty

Akzo Nobel Chemicals Inc.

Michael Rogers

Syncrude Canada Ltd.

James Slaugh

Basell North America Inc.

Robert J. Stankovich

Eli Lilly and Company

Angela Summers

SIS Tech Solutions LP

AntiEntropics, Inc. of New Market, Maryland, was the contractor for this project. Robert J. Walter was the principal author of the text and would like to recognize Sandra A. Baker and James M. Godwin for their expert editorial support.

CCPS also gratefully acknowledges the comments submitted by the following peer reviewers:

John Alderman

RRS Engineering

Helmut Bezecny

The Dow Chemical Company (ret.)

William L. Bobinger

E.I. DuPont de Nemours

Frederic Gil

BP Refining and Technology

Dennis Heavin

Eli Lilly and Company

Kevin Klein

Solutia Inc

Peter N. Lodal

Eastman Chemical Company

Randolph Matsushima

Suncor Energy U.S.A., Inc.

Victor J. Maggioli

Feltronics Corporation

Pike Prescott

Sun Chemicals Inc

William Ralph

BP Products North America

Sandra K. Schmitzer

GE Plastics

Casey R. Stephenson

Eli Lilly and Company

Angela Summers

SIS Tech Solutions LP

John C. Wincek

Croda USA

Their insights, comments, and suggestions helped ensure a balanced perspective for this guideline.

PREFACE

The American Institute of Chemical Engineers (AIChE) has been closely involved with process safety and loss control issues in the chemical and allied industries for more than four decades. Through its strong ties with process designers, constructors, operators, safety professionals, and members of academia, AIChE has enhanced communications and fostered continuous improvement of the industry’s high safety standards. AIChE publications and symposia have become information resources for those devoted to process safety and environmental protection.

AIChE created the Center for Chemical Process Safety (CCPS) in 1985 after the chemical disasters in Mexico City, Mexico, and Bhopal, India. The CCPS is chartered to develop and disseminate technical information for use in the prevention of major chemical accidents. The center is supported by more than 80 chemical process industries (CPI) sponsors who provide the necessary funding and professional guidance to its technical committees. The major product of CCPS activities has been a series of guidelines to assist those implementing various elements of a process safety and risk management system. This book is part of that series.

Pre-startup safety review (PSSR) is a fundamental element of successful process safety programs. However, facilities continue to be challenged to maintain successful PSSR programs in a way that improves total process safety over time. The CCPS Technical Steering Committee initiated the creation of these guidelines to assist facilities in meeting this challenge. This book contains approaches for designing, developing, implementing, and continually improving a pre-startup safety review system. The CD accompanying this book contains resource materials and support information.

CHAPTER 1

INTRODUCTION

The term pre-startup safety review (PSSR), in its simplest definition, means a final check prior to initiating the use of process equipment. When the term is used as a part of the overall process safety management program at a facility, it implies a management system within that program for ensuring that new or modified processes are ready for startup. This is accomplished by verifying that equipment is installed in a manner consistent with the design intent and that process safety management systems are in place. As each change, the associated risk, and the process in question may be unique, applying PSSR in a systematic way to your work processes simply represents a good business practice. Performing an effective pre-startup safety review is analogous to checking your math after performing a calculation or, for a more vivid analogy, checking your parachute before a jump.

In this book we examine the application of the practice of PSSR to the physical plant hardware, software, engineering, and management activities, and documentation associated with operating chemical processes. Although we focus on the chemical process industries (CPI) and specifically the associated process safety aspects, the concept of PSSR and its benefits apply to almost any human endeavor, especially in the manufacturing realm.

Since 1992, a major incentive for the chemical process industries (CPI) in the United States to make pre-startup safety review a part of day-to-day business practices has been the Occupational Safety and Health Administration’s (OSHA’s) process safety management (PSM) regulation (29 Code of Federal Regulations [CFR] 1910.119) (Reference 1-1). This regulation was followed by the Environmental Protection Agency’s (EPA’s) risk management program (RMP) rule (40 CFR 68) (Reference 1-2). These regulations are performance based and apply to facilities processing certain chemicals when present at or above specific threshold quantities. The term performance based means that each facility that falls under the regulation needs to meet certain minimum requirements, but how they meet those requirements is not prescriptive. A facility can build the PSSR program that best fits its risk levels, organizational culture, and resources.

However, other countries and industry organizations have recognized the importance of PSSR to process safety and have published similar rules or guidelines for using it. We will keep the general aspect of the concept of this "final check" in mind, address specific U.S. regulatory needs, but at the same time, give some specific examples of how global chemical processing companies apply pre-startup safety review to their operations to both comply with the applicable laws and enhance their manufacturing performance.

Whether implementing process safety management as a requirement or as a good practice, pre-startup safety review is essential to keeping the system alive and functioning properly to protect a facility against risk.

1.1 WHAT ARE THE BENEFITS OF PERFORMING PRE-STARTUP SAFETY REVIEWS?

There are many benefits to be gained from performing pre-startup safety review for your processes. A simple list includes:

The change is more likely to operate as intended.The construction, maintenance, or programming work performed to build, install, or program the process change meets the design specifications originally intended.Pre-startup activities have been completed and post-startup activities are scheduled and tracked to help ensure that equipment is designed, fabricated, procured, installed, operated, and maintained in a manner appropriate for its intended application.New chemicals or materials used in the process are understood in regard to safety, health, environmental and material performance issues.Personnel assigned to inspect, test, maintain, procure, fabricate, install, or commission process equipment are appropriately trained and have access to current and up-to-date procedures and process safety information.In the event of an incident, a strong pre-startup safety review program documents corporate operational discipline and social responsibility.The safety systems are confirmed to be operating as designed.Engineering calculations and assumptions used for design and installation match recognized and generally accepted good engineering practices (RAGAGEP) which describe applicable codes and standards.Regulatory requirements for managing changes are met.Quality management system requirements for your company have been addressed.PSSR provides an opportunity for turnover of ownership from engineering or project managers to operations personnel

This book provides advice for developing a PSSR program that will assist organizations in achieving these benefits. Facilities should consider evaluating how they are doing in regard to reaping the benefits above. Chapter 7 – Continuous Improvement addresses this issue.

On a broader scale, effective PSSR supports any mature, well-designed PSM program by keeping the total program robust and vibrant in the face of change. The CCPS booklet The Business Case for Process Safety summarizes the benefits of process safety – and these same benefits are supported by performing effective pre-startup safety reviews:

“…methodically implementing process safety provides four benefits essential to any healthy business. Two of these benefits are qualitative and as a result are somewhat subjective. You can see them in the way the public, your shareholders, government bodies, and your customers relate to your company. The two remaining benefits are quantitative. These have measurable impact in terms of your bottom line and company performance. All four benefits, when realized together by adhering to a sound process safety system, combine to support the profitability, safety performance, quality, and environmental responsibility of your business.

Corporate Responsibility – Process safety is the embodiment of corporate responsibility and accountability. It helps your company display these characteristics through its actions. The heart of process safety lies in consistently planning to do the right things, then doing them right - consistently. Corporate responsibility leads to the second benefit…Business Flexibility – Corporate responsibility as demonstrated in your process safety management program leads to a greater range of business flexibility. When you openly display responsibility through implementing an effective process safety program, your company can achieve greater freedom and self-determination.Risk Reduction – Process safety provides unparalleled loss avoidance capability. A healthy process safety program significantly reduces the risk of catastrophic events and helps prevent the likelihood of human injury, environmental damage, and associated costs that arise from incidents. Although the essence of process safety focuses on preventing catastrophic incidents, the number of less severe incidents is also reduced.Sustained Value – Process safety relates directly to enhanced shareholder value. When properly implemented, it helps ensure reliable processes that can produce high quality products, on time, and at lower cost. This increases shareholder value.”

Pre-startup safety review provides a second level of protection to ensure operational readiness, which will drive continuous improvement in your process safety management system, and help your organization realize these four benefits.

1.2 HOW PSSR RELATES TO OTHER PROCESS SAFETY ELEMENTS

This guideline assumes the reader is already familiar with the fourteen basic elements of process safety as defined in the OSHA process safety management regulation and the EPA risk management program rule. These are:

1. Employee Participation

2. Process Safety Information

3. Process Hazard Analysis

4. Management of Change

5. Operating Procedures

6. Mechanical Integrity

7. Emergency Planning & Response

8. Training

9. Contractors

10. Hot Work Permit

11. Compliance Audits

12. Pre-Startup Safety Review

13. Incident Investigation

14. Trade Secrets

A well-designed PSSR program will fit within a facility’s existing process safety and risk management program as well as any other performance enhancement effort (for example, six sigma, total quality, environmental management, or profitability initiatives). Personnel charged with developing, implementing and upgrading the PSSR program can better achieve a higher level of overall process safety performance when they know how pre-startup safety review affects or is affected by the other elements of process safety. Table 1-1 illustrates how the other elements of PSM may relate to PSSR.

TABLE 1-1How PSSR Typically Interfaces with Other PSM Elements

PSM ElementPotential InterfaceEmployee Participation• Employees from various departments can have input into the PSSR program as developers, team leaders, team members, or interviewees during the reviews.• The PSSR procedure and PSSR checklist documentation provides clear evidence of how your organization encourages employee participation.Process Safety Information• PSSR assists in verifying that process safety information (PSI) for equipment, material hazards, and technology is updated in a timely fashion.Process Hazard Analysis (PHA)• PSSR assists in verifying any PHA action items required have been or will be addressed.Operating Procedures• PSSR provides a second check on whether the operating procedures affected by the change have been written or revised to properly reflect the change.Operator Training• PSSR checks to verify any changes to training related to the trigger event have been made and that training on the affected procedures has occurred as needed.Mechanical Integrity