Company Compliance Program

Information

Element:
Compliance Audits and Inspections
Document Number:
CHK-013-S004

Revision Date:
04/2014
Audit Title
Conducted on
Prepared by

EMPLOYEE PARTICIPATION 1910.119 (c)

The intent of this element is to require employers (operator) to involve employees at an elemental level of the PSM program. Minimum requirements for an Employee Participation Program for PSM must include a written plan of action for implementing employee consultation on the development of process hazard analyses and other elements of process hazard management contained within 1910.119. The employer must also provide ready access to all the information required to be developed under the standard.
Does the facility have a written plan for employee participation?
1910.119(c)(1)
Observation:
Recommendations:
Are employees consulted on PHA's and other elements of PSM program?
1910.119(c)(2)
Observation:
Recommendations:
Do employees (including contractor employees) have access to information required by the PSM regulation?
1910.119(c)(3)
Observation:
Recommendations:
Have all new employees been trained in the Employee Participation section of the PSM Manual? Does training include PSM CBT?
Best Work Practice
Observation:
Recommendations:
Does the facility cover one (1) PSM element at monthly safety meetings?
Best Work Practice
Observation:
Recommendations:
Does the facility have a PSM committee?
Best Work Practice
Observation:
Recommendations:
Is the PSM committee comprised of management and employee representatives?
Best Work Practice
Observation:
Recommendations:
Has responsibilities and accountabilities for the facility's PSM program development and upkeep been distributed to various employees?
Best Work Practice
Observation:
Recommendations:
What is the extent or your participation in the PSM program?
Interview Question
Observation:
Recommendations:
Tell me how the PSM program elements are communicated to you.
Interview Question
Observation:
Recommendations:
Have you been formally trained in all 14 elements of the PSM program?
Interview Question
Observation:
Recommendations:
Have you been given the responsibility or accountability of any of the PSM program elements?
Interview Question
Observation:
Recommendations:

PROCESS SAFETY INFORMATION

PROCESS SAFETY INFORMATION 1910.119(d)

The intent of this part is to provide complete and accurate information concerning the process, which is essential for an effective process safety management program, and for conducting process hazard analyses. Therefore in accordance with the schedule set forth in paragraph (e)(1) the employer is required to compile written process safety information on process chemicals, process technology, and process equipment before conducting any process hazard analysis.
Is the information available on process chemicals covering: toxicity; permissible exposure limits; physical data; reactivity data; corrosive data; thermal and chemical stability; and inadvertent mixing hazards?
1910.119(d)(1)
Observation:
Recommendations:
Does the following information on process technology cover the following:
1910.199(d)(2)(i)
Block Flow Diagrams (BFD) or Process Flow Diagrams (PFD)
1910.119(d)(2)(i)(A)
Observation:
Recommendations:
Process Chemistry?
1910.119(d)(2)(i)(B)
Observation:
Recommendations:
Does the information on process equipment cover the following:
1910.119(d)(3)
Piping and Instrumental Diagrams (P&IDs)
1910.119(d)(2)(i)(B)
Observation:
Recommendations:
Maximum intended inventories?
1910.119(d)(2)(i)(C)
Observation:
Recommendations:
Safe limits of flow, temperature & pressure?
1910.119(d)(2)(i)(D)
Observation:
Recommendations:
Consequences of deviation from design conditions?
1910.119(d)(2)(i)(E)
Observation:
Recommendations:
Where original technical information doesn't exist, has it been developed with PHA's?
1910.119(d)(2)(ii)
Observation:
Recommendations:
Does the information on process equipment cover the following:
1910.119(d)(3)(i)
Materials of construction?
1910.119(d)(3)(i)(A)
Observation:
Recommendations:
P&ID drawings?
1910.119(d)(3)(i)(B)
Observation:
Recommendations:
Electrical classification?
1910.119(d)(3)(i)(C)
Observation:
Recommendations:
Relief system design?
1910.119(d)(3)(i)(D)
Observation:
Recommendations:
Ventilation system design?
1910.119(d)(3)(i)(E)
Observation:
Recommendations:
Documentation of design codes and standards used?
1910.119(d)(3)(i)(F)
Observation:
Recommendations:
Material and energy balances for post 5/26/92 system?
1910.119(d)(3)(i)(G)
Observation:
Recommendations:
Safety systems (interlocks, detection or suppression systems)?
1910.119(d)(3)(i)(H)
Observation:
Recommendations:
Does the facility document that the equipment complies with good engineering practice?
1910.119(d)(3)(ii)
Observation:
Recommendations:
Does the facility document that all equipment is designed, operated, and maintained in a safe manner even if the original equipment design was based on code sum standards or practices that are no longer in general use?
1910.119(d)(3)(iii)
Observation:
Recommendations:
Does the facility have instrument loop diagrams?
Best Work Practice
Observation:
Recommendations:
If the facility has a flare, has the flare radiant circle been calculated and fenced?
Best Work Practice
Observation:
Recommendations:
Do you know where to locate the Material and Energy Balances?
Interview Question
Observation:
Recommendations:
Can you tell me where the redline P&ID drawings are located?
Interview Question
Observation:
Recommendations:
Do you know what "Area Classifications" are and so you know the restrictions they cause?
Interview Question
Observation:
Recommendations:

PROCESS HAZARD ANALYSIS (PHA)

PROCESS HAZARD ANALYSIS (PHA) 1910.119(e)

The intent of this part is to require the employer to develop a thorough, orderly, systematic approach for identifying, evaluating and controlling processes involving highly hazardous chemicals. Minimum requirements include: (1) Setting a priority order and conducting analyses according to the required schedule; (2) Using an appropriate methodology to determine and evaluate the process hazards; (3) Addressing process hazards, previous incidents with catastrophic potential, engineering and administrative controls applicable to the hazards, consequences of failure of controls, facility siting, human factors and a qualitative evaluation of possible safety and health effects of failure of controls on employees; (4) Performing PHA by a team with expertise in engineering and process operations, the process being evaluated, and the PHA methodology used; (5) Establishing a system to promptly address OBSERVATION and recommendations, assure recommendations are resolved and documented, document action taken, develop a written schedule for completing actions, and communicate actions to operating, maintenance and other employees who work in the process or might be affected by actions; (6) Updating and revalidating PHA's at least every 5 years; and (7) Retaining PHA's and updates for the life of the process.
Has a complete compilation of written process safety information been made available prior to the PHA?
1910.119(e)(1)
Observation:
Recommendations:
Have initial PHA's been conducted where required?
1910.119(e)(1)
Observation:
Recommendations:
Does the selected PHA methodology meet the requirements of the PSM regulation?
1910.119(e)(2)
Observation:
Recommendations:
PHA records must be retained, does The Company's PSM Manual require PHA record retention? If so, how long is the retention time?
1910.119(e)(7)
Observation:
Recommendations:
Was the PHA performed by a team with expertise in:
1910.119(e)(4)
Engineering
Observation:
Recommendations:
Process Operations
Observation:
Recommendations:
At least one (1) employee who has experience and knowledge specific to the process being evaluated
Observation:
Recommendations:
One (1) member of the team must be knowledgeable in the specifics process hazard analysis methodology being used
Observation:
Recommendations:
Review PHA's to see if they take into account for:
1910.119(e)(3)
The hazards of the process
1910.119(e)(3)(i)
Observation:
Recommendations:
Identification of previous incidents which had a likely potential for catastrophic consequences in the workplace
1910.119(e)(3)(ii)
Observation:
Recommendations:
Engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases
1910.119(e)(3)(iii)
Observation:
Recommendations:
Consequences of failure of engineering and administrative controls
1910.119(e)(3)(iv)
Observation:
Recommendations:
Facility Siting
1910.119(e)(3)(v)
Observation:
Recommendations:
Human factors
1910.119(e)(3)(vi)
Observation:
Recommendations:
An evaluation of the possible safety and health effects of failure of controls on employees in the workplace
1910.119(e)(3)(vii)
Observation:
Recommendations:
Has the facility established a system to promptly address the PHA's observation and recommendations and assure that recommendations are resolved in a timely manner and documented?
1910.119(e)(5)
Observation:
Recommendations:
Are PHA's revalidated every five (5) years?
1910.119(e)(6)
Observation:
Recommendations:
Does the facility PSM program provide PHA's for new facilities?
Best Work Practice
Observation:
Recommendations:
Does the facility PHA program address RMP, potential off-site consequences of hazards?
Best Work Practice
Observation:
Recommendations:
Were you involved in a PHA, and what type PHA was it?
Interview Question
Observation:
Recommendations:
What does HAZOP stand for?
(Hazard and Operability) study
Interview Question
Observation:
Recommendations:
Are observation and recommendations from a PHA resolved in a timely manner and then communicated to you?
Interview Question
Observation:
Recommendations:

OPERATING PROCEDURES

OPERATING PROCEDURES 1910.119(f)

The intent of this element is to provide clear instruction for conducting activities involved in covered processes that are consistent with the process safety information. The operating procedures must address steps for each operating phase, operating limits, safety and health considerations, and safety systems and their functions.
Are written operating procedures in place covering the following:
1910.119(f)(1)
Initial Startup
1910.119(f)(1)(i)(A)
Observation:
Recommendations:
Normal Operations
1910.119(f)(1)(i)(B)
Observation:
Recommendations:
Temporary Operations
1910.119(f)(1)(i)(C)
Observation:
Recommendations:
Emergency Shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibilities to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner.
1910.119(f)(1)(i)(D)
Observation:
Recommendations:
Emergency Operations
1910.119(f)(1)(i)(E)
Observation:
Recommendations:
Normal shutdown
1910.119(f)(1)(i)(F)
Observation:
Recommendations:
Startup following a turnaround, or after an emergency shutdown
1910.119(f)(1)(i)(G)
Observation:
Recommendations:
Do all operating procedures address the following:
1910.119(f)(1)(ii)
Consequences of deviation?
1910.119(f)(1)(ii)(A)
Observation:
Recommendations:
Steps to correct or avoid deviation?
1910.119(f)(1)(ii)(B)
Observation:
Recommendations:
Do all operating procedures consider the following safety and health considerations:
1910.119(f)(1)(iii)
Properties and hazards of the chemicals used in the process?
1910.119(f)(1)(iii)(A)
Observation:
Recommendations:
Exposure prevention measures?
1910.119(f)(1)(iii)(B)
Observation:
Recommendations:
Response to exposure?
1910.119(f)(1)(iii)(c)
Observation:
Recommendations:
Inventory levels and quality control for raw materials?
1910.119(f)(1)(iii)(D)
Observation:
Recommendations:
Any unique hazards not covered elsewhere?
1910.119(f)(1)(iii)(E)
Observation:
Recommendations:
Do the operating procedures address safety systems and their functions?
1910.119(f)(1)(iv)
Observation:
Recommendations:
Are operating procedures readily available to operations and maintenance personnel?
1910.119(f)(2)
Observation:
Recommendations:
Are operating procedures reviewed and re-certified annually to assure that they reflect current practice, including:
1910.119(f)(3)
Changes in process chemicals
Observation:
Recommendations:
Changes in technology
Observation:
Recommendations:
Changes in equipment
Observation:
Recommendations:
Changes in facilities?
Observation:
Recommendations:
Has the facility implemented the following safe work practices, such as:
1910.119(f)(4)
Lockout/tagout?
Observation:
Recommendations:
Confined space entry?
Observation:
Recommendations:
Opening process equipment or piping?
Observation:
Recommendations:
Control of entry into facilities?
Observation:
Recommendations:
Does the facility's operating procedures contain process operating limits?
Best Work Practice
Observation:
Recommendations:
Does the facility retain the annual verification? Specifically written certification annually it verify operating procedures are current and correct?
Best Work Practice
Observation:
Recommendations:
Have you been trained in safe work practices such as Lockout/tagout, hot work permits and confined space?
Interview Question
Observation:
Recommendations:
Do you know if the operating procedures are updated each year? And is this updating documented?
Interview Question
Observation:
Recommendations:
Does MOC program suffice as a system to keep operating procedures up-to-date?
Interview Question
Observation:
Recommendations:
Were you involved with writing or reviewing the operating procedures?
Interview Question
Observation:
Recommendations:

TRAINING

TRAINING 1910.119(g)

The intent of this element helps employees and contractor employees understand the nature and causes of problems arising from process operations, and increases employee awareness with respect to the hazards particular to a process. An effective training program significantly reduces the number and severity of incidents arising from process operations, and can be instrumental in preventing small problems from leading to catastrophic release. Minimum requirements for an effective training program include: Initial Training, Refresher Training, and Documentation.
Are all the following training requirements in place:
1910.119(g)
In reviewing the facility training program it was noticed that the facility is conducting training, however, no training needs analysis has been conducted and documented. Direction and prioritization needs to be provided and followed. In review of the training files no quality control is being conduct on the files prior to being put in the file drawer. Observation noticed that sign-in rosters did not correspond with verification conducted for the training. It was also noticed that the employee training spreadsheet is not being maintained of training completed.
Each employee involved in operating a process or operating a new process shall be trained in:
1910.119(g)(1)(i)
An overview of the process
Observation:
Recommendations:
And in the operating procedures of that process, and shall include:
Specific safety and health hazards
Observation:
Recommendations:
Emergency operations including shutdown
Observation:
Recommendations:
Safe work practices applicable to the employee's job tasks
Observation:
Recommendations:
Certification in lieu of initial training?
1910.119(g)(1)(ii)
Observation:
Recommendations:
Is refresher training performed every three (3) years?
1910.119(g)(2)
Observation:
Recommendations:
Does the following training documentation exist for each operator?
Identity of employee
Observation:
Recommendations:
Date of training
Observation:
Recommendations:
Means used to verify that employee understood training?
Observation:
Recommendations:
Have you been formally trained in the operating procedures of this facility?
Interview Question
Observation:
Recommendations:

CONTRACTORS

CONTRACTORS 1910.119(h)

The intent of this element is to require employers who use contractors to perform work in and around processes that involve highly hazardous chemicals to establish a screening process so that they hire and use contractors who accomplish the desired job tasks without compromising the safety and health of employees at a facility. The contractor must assure that contract employees are trained on performing the job safely, with knowledge of the hazards related to the job, and applicable provisions of the emergency action plan.
Does the contractor responsibility apply to all contractors performing maintenance or repair, turnaround, major renovation or specialty work on or adjacent to a covered process?
1910.119(h)(1)
Observation:
Recommendations:
Operator Responsibility: Does the facility's contractor policy address the following?
1910.119(h)(2)
Evaluation of contractor's safety program and procedures?
1910.119(h)(2)(i)
Observation:
Recommendations:
Informs contractor of hazards in process?
1910.119(h)(2)(ii)
Observation:
Recommendations:
Explains emergency action plan to contractor?
1910.119(h)(2)(iii)
Observation:
Recommendations:
Development and implementation of facilities safe work practices to control entrance, presence, and exit of contact personnel?
1910.119(h)(2)(iv)
Observation:
Recommendations:
Performs periodic compliance checks on contractor?
1910.119(h)(2)(v)
Observation:
Recommendations:
Maintains contract employee injury log?
1910.119(h)(2)(vi)
Observation:
Recommendations:
Contractors Responsibility: are contractors fulfilling g the following PSM obligations:
1910.119(h)(3)
Assure that contract employees are trained in safe work practices?
1910.119(h)(3)(i)
Observation:
Recommendations:
Insure that each contract employee is instructed in the known potential fire, explosion, or toxic release hazards related to his/her job and the process, and the applicable provisions of the emergency action plan.
1910.119(h)(3)(ii)
Observation:
Recommendations:
Verify and document contract employee understanding of training.
1910.119(h)(3)(iii)
Observation:
Recommendations:
Assure contract employee follow safe rules of the facility including the safe work practices.
1910.119(h)(3)(iv)
Observation:
Recommendations:
The facility notifies the contractor of any unique hazards presented by the contractors or discovered by their work.
1910.119(h)(3)(v)
Observation:
Recommendations:
The facility must have documentation showing training and orientations provided to contractors
Best Work Practice
Observation:
Recommendations:
Ask a Contractor: Have you received the facility orientation and have you been trained in the safe work practices required to perform work on or around this process?
Interview Question
Observation:
Recommendations:

PRE START UP SAFETY REVIEW

PRE-START UP SAFETY REVIEW 1910.119(i)

The intent of this element is to make sure that, for new facilities and for modified facilities when the modification necessitates a change to process safety information, certain important considerations are addressed before any highly hazardous chemicals are introduced into the process. Minimum requirements include that the pre-startup safety review confirm the following: construction and equipment is in accordance with design specifications; safety, operating, maintenance, and emergency procedures are in place and adequate; for new facilities, a PHA has been performed and recommendations resolved or implemented; modified facilities meet the requirements of paragraph (1), management of change; and training of each employee involved in the process has been completed.
Are The Company's PSSR procedures and forms in place?
1910.119(i)
Observation:
Recommendations:
Does the facility perform pre-startup safety reviews for new or significantly modified equipment when there is a change in Process Safety Information?
1910.119(i)(1)
Observation:
Recommendations:
Does review determine that, prior to introduction of hazardous chemicals to the process that:
1910.119(i)(2)
Construction and equipment is per design specifications?
1910.119(i)(2)(i)
Observation:
Recommendations:
Safety, operating, maintenance and emergency procedures are in place and adequate?
1910.119(i)(2)(ii)
Observation:
Recommendations:
Has a PHA been performed on new facilities and has recommendations been resolved or implemented before startup?
1910.119(i)(2)(iii)
Observation:
Recommendations:
Has modified facilities meet the requirements of the management of change process?
1910.119(i)(2)(iii)
Observation:
Recommendations:
Have required employee training been completed?
1910.119(i)(2)(iv)
Observation:
Recommendations:
Are PSSR's completed prior to introduction of HHC into the process. The facility must maintain these records.
Best Work Practice
Observation:
Recommendations:
What is a PSSR used for?
Interview Question
Observation:
Recommendations:
Do you know where to locate a PSSR?
Interview Question
Observation:
Recommendations:

MECHANICAL INTEGRITY

MECHANICAL INTEGRITY 1910.119(j)

The intent of this element is to assure that equipment used to process, store, or handle highly hazardous chemicals is designed, constructed, installed, and maintained to minimize the risk of releases of such chemicals. This requires that a mechanical integrity program be in place to assure the continued integrity of the process equipment. The elements of a mechanical integrity program include the identification and categorization of equipment and instrumentation, development of written maintenance procedures, training for process maintenance activities, inspection and testing, correction of deficiencies in equipment that are outside acceptable limits defined by the process safety information, and development of a quality assurance program.
Had the following equipment been addressed:
1910.119(j)(1)
Pressure vessels and Storage Tanks:
Equipment files in place and contain minimum required information
1910.119(j)(1)(i)
Observation:
Recommendations:
Piping System and Components, including Heat Exchangers:
Equipment files in place and contain minimum required information
1910.119(j)(1)(ii)
Observation:
Recommendations:
Relief, Vent and Flare Systems:
Equipment files in place and contain minimum required information
PSV Study performed and copy available
Flare Study performed, radiation ring noted on Plot Plan
1910.119(j)(1)(iii)
Observation:
Recommendations:
Emergency Shutdown Systems:
ESD Matrix available and current
Annual testing documentation available
1910.119(j)(1)(iv)
Observation:
Recommendations:
Control Systems:
Instrument files in place and contain minimum required information
1910.119(j)(1)(v)
Observation:
Recommendations:
Pumps and Compressors:
Equipment files in place and contain minimum required information
1910.119(j)(1)(vi)
Observation:
Recommendations:
Are written procedures implemented to maintain Mechanical Integrity:
The facility has a current copy of The Company's Mechanical Integrity Program Manual
1910.119(j)(2)
Observation:
Recommendations:
Does the facility train each maintenance employee including applicable contract employees in:
1910.119(j)(3)
Overview of the process?
Training may be in the form of CBT, location specific training
Documentation of training exists for each employee
Observation:
Recommendations:
Process Hazards?
Training may be in the form of CBT, location specific training
Documentation of training exists for each employee
Observation:
Recommendations:
Maintenance procedures applicable to job tasks?
Training may be in the form of CBT, location specific training, Job Task Progression, O&M Procedures, OEM Procedures, Work Plans, PM Work Order procedures
Documentation of training exists for each employee
Observation:
Recommendations:
Does the Inspection and Testing Program address the following?
1910.119(j)(4)
Is it performed on covered process equipment as stated in the Company's Mechanical Integrity Program Manual?
1910.119(j)(4)(i)
Observation:
Recommendations:
Do procedures follow the Company's Mechanical Integrity Program Manual?
1910.119(j)(4)(i)
Observation:
Recommendations:
Are the frequency's consistent with the Mechanical Integrity Program Manual Inspections?
1910.119(j)(4)(ii)
Observation:
Recommendations:
Is Documentation of inspection and tests maintained?
Hard copy reports, inspection database, PM database, inventory lists, and equipment listsn are utilized to accomplish this
1910.119(j)(4)(iv)
Observation:
Recommendations:
Are the deficiencies in equipment outside of design limits corrected before further use or in a safe and timely manner when steps have been taken to ensure personnel safety?
Are deficiencies documented and tracked with the locations action list tracking system, including time intervals for completions
Temporary Operating Procedures, work plans may be utilized
1910.119(j)(5)
Observation:
Recommendations:
Is quality assurance of sufficient level to ensure Mechanical Integrity?
The Company's Mechanical Integrity Program Policy and Procedures followed?
1910.119(j)(6)
Observation:
Recommendations:
Is the equipment suitable for the process application?
Original and Current Design Specifications available on site
System in place to ensure correct material is used
1910.119(j)(6)(i)
Observation:
Recommendations:
Does the QA system ensure installation per design specifications?
The Company's Mechanical Integrity Program Policy and Procedures followed?
Management of Change followed to document correct materials used?
1910.119(j)(6)(ii)
Observation:
Recommendations:
Is a QA system in place that insures spare parts and materials are correct?
The Company's Mechanical Integrity Program Policy and Procedures followed?
The facility follows design specifications, OEM specifications as a minimum requirement.
1910.119(j)(6)(iii)
Observation:
Recommendations:
Does the facility MI Program document the following lists:
Pressure Vessels, Storage Tanks, Piping Systems, Instrumentation, Relief Valves, Pumps, and Compressors.
Is the minimum required information included with each list as required in The Company's MI Program Manual exhibits?
Are the Company's Mechanical Integrity Program Policy and Procedures followed?
Best Work Practice
Observation:
Recommendations:
Does the facility have written maintenance procedures for all routine and non-routine maintenance work?
This may be accomplished with OEM Manuals, O&M Procedures, Site specific work plans, PM Tasks
Best Work Practice
Observation:
Recommendations:
Does the facility utilize a written Preventative Maintenance system?
Empac, Access, Excel, MS Word, or hard paper system may be utilized to accomplish this.
Best Work Practice
Observation:
Recommendations:
Have you has formal training in the facility's maintenance procedures?
Interview Question
Observation:
Recommendations:
Do you know what the Company's "Quality Assurance Program" is?
Interview Question
Observation:
Recommendations:

HOT WORK PERMITS

HOT WORK PERMITS 1910.119(k)

The intent of this element is to require employers to control, in a consistent manner, non-routine work conducted in process areas. Specifically, this sub paragraph is concerned with the permitting of hot work operations associated with welding and cutting in process areas.

Minimum requirements include: that the employer issue a hot work permit for hot work operations conducted on or near a covered process and that hot work permits shall document compliance with the fire prevention and protection requirements of 29 CFR 1910.252(a).
Does the facility have a hot work permit system?
1910.119(k)(1)
Observation:
Recommendations:
Does the hot work permit document the following:
1910.119(k)(2)
Does the hot work permits indicate the date(s) authorized for hot work performed?
Observation:
Recommendations:
Does the hot work permits describe the object on which the hot work is to be performed?
Observation:
Recommendations:
Have the hot work permits been kept on file until the hot work operations were complete?
Observation:
Recommendations:
Have the hot work permits identified openings, cracks and holes where sparks may drop to combustible materials below?
252(a)(2)(i)
Observation:
Recommendations:
Have the hot work permits described the fire extinguisher required to handle any emergencies?
252(a)(2)(ii)
Observation:
Recommendations:
Have the hot work permits assigned fire watchers whenever welding is performed in locations where other than a minor fire might develop?
252(a)(2)(iii)
Observation:
Recommendations:
Are the hot work permits being authorized, preferably in writing, by the "individual" responsible for all welding and cutting operations? Is authorization preceded by site and inspection and designation of appropriate precautions?
252(a)(2)(iv) and 252(a)(2)(xiii)(A)
Observation:
Recommendations:
Have the hot work permits described precautions associated with combustible materials on floors or floors, walls, partitions, ceilings or roofs of combustible construction?
252(a)(2)(v) and 252(a)(2)(ix)
Observation:
Recommendations:
Has hot work permitting been successful in prohibiting welding in unauthorized areas, in sprinklered buildings while such protection is impaired, in the presence of explosive atmospheres, and in storage areas for large quantities of readily ignitable materials?
252(a)(2)(vi)
Observation:
Recommendations:
Have the hot work permits required relocation of combustibles where practicable and covering with flameproofed covers where not practicable?
252(a)(2)(vii)
Observation:
Recommendations:
Have hot work permits identified for shutdown any ducts or conveyors systems that may convey sparks to distant combustibles?
252(a)(2)(viii)
Observation:
Recommendations:
Have hot work permits required precautions whenever welding on components (e.g., steel members, pipes, etc.) that could transit heat by radiation or conduction to unobserved combustibles?
252(a)(2)(x) and 252(a)(2)(xii)
Observation:
Recommendations:
Have hot work permits identified hazards associated with welding on walls, partitions, ceilings or roofs with combustible coverings or welding on walls or panels of sandwich-type construction?
252(a)(2)(xi)
Observation:
Recommendations:
Has management established areas and procedures for safe welding and cutting based on fire potential?
252(a)(2)(xiii)
Observation:
Recommendations:
Has management designated the "individual" responsible for authorizing cutting and welding operations in process areas?
252(a)(2)(xiii)(B)
Observation:
Recommendations:
Has management ensured that welders, cutters and supervisors are trained in the safe operation of their equipment?
252(a)(2)(xiii)(C)
Observation:
Recommendations:
Has management advised outside contractors working on their site about all hot work permitting programs?
252(a)(2)(xiii)(D)
Observation:
Recommendations:
Has the Supervisor determined if combustibles are being protected from ignition prior to welding by moving them, shielding them, or scheduling welding around their production?
252(a)(2)(xiv)(A) (B) and (C)
Observation:
Recommendations:
Has the Supervisor, prior to welding, secured authorization from the responsible "individual" designated by management?
252(a)(2)(xiv)(D)
Observation:
Recommendations:
Does the facility retain copy of hot work permits for at least one (1) year from issue date?
Best Work Practice
Observation:
Recommendations:
Does the facility's MI testing and inspection program require periodic calibration of test equipment?
Best Work Practice
Observation:
Recommendations:
Have you filled out and issued a Hot Work Permit?
Interview Question
Observation:
Recommendations:
The Hot Work Permit asks if you have met the requirements of 1910.252a for welding and cutting. Do you know what the 1910.252a requires?
Interview Question
Observation:
Recommendations:
What do you do with the Hot Work Permit after the work has been completed?
Interview Question
Observation:
Recommendations:

MANAGEMENT OF CHANGE

MANAGEMENT OF CHANGE 1910.119(l)

The intent of this element is to require management of all modifications to equipment, procedures, raw materials and processing conditions other the "replacement in kind" by identifying and reviewing them prior to implementation of the change. Minimum requirements for management of change include: establishing written procedures to manage change; addressing the technical basis, impact on safety and health, modification to operating procedures, necessary time period, and authorizations required; informing and training employees affected; and updating process safety information and operating procedures and practices.
Are management of change procedures written and available?
1910.119(l)(1)
Observation:
Recommendations:
Does the management of change system address the following items:
1910.199(l)(2)
Does the procedures assure the technical basis for the proposed change is addressed prior to any change?
1910.119(l)(2)(i)
Observation:
Recommendations:
Does the procedures assure that the impact of the change on safety and health is addresses prior to any change?
1910.119(l)(2)(ii)
Observation:
Recommendations:
Does the procedures assure that modifications to operating procedures is addressed prior to any change?
1910.119(l)(2)(iii)
Observation:
Recommendations:
Does the procedures assure that the necessary time period for the change is addressed prior to any change?
1910.119(l)(2)(iv)
Observation:
Recommendations:
Does the procedures assure that the authorization requirements for the proposed change are addressed prior to any change?
1910.119(l)(2)(v)
Observation:
Recommendations:
Are employees involved in operating a process, and maintenance and contract employees whose job tasks will be affected by change informed of, and trained in, the change prior to start-up of process or affected part of process?
1910.119(l)(3)
Observation:
Recommendations:
Is process safety information updated prior to startup, if required?
1910.119(l)(4)
Observation:
Recommendations:
Are procedures and practices required by change updated prior to startup?
1910.119(l)(5)
Observation:
Recommendations:
Does the facility have an MOC list which reviews and updates status of outstanding MOC monthly?
Best Work Practice
Observation:
Recommendations:
Are MOCs closed out prior to introducing hazards chemicals to process?
Best Work Practice
Observation:
Recommendations:
Does the facility include RMP considerations as part of MOC process?
Best Work Practice
Observation:
Recommendations:
Please explain the purpose of the MOC program.
Interview Question
Observation:
Recommendations:

INCIDENT INVESTIGATION

INCIDENT INVESTIGATION 19910.119(m)

The employer is required to investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemical in the workplace. An investigation shall be initiated no later than 48 hours following the incident. An investigation team shall be established and a report prepared which includes: 1) Date of incident 2) Date investigation began 3) Description of incident 4) Factors that contributed to the incident 5) Recommendations from the investigation. The employer is required to establish a system to promptly address the incident report OBSERVATION and recommendations, documenting all resolutions and corrective actions. Incident reports shall be reviewed with all affected personnel whose job tasks are relevant to the investigation and retained for five (5) years.
Is each incident that did or could have resulted in a release of hazardous chemical investigated? Including "Near Misses".
1910.119(m)(1)
Observation:
Recommendations:
Is each incident investigated ASAP but no later than 48 hours following incident?
1910.119(m)(2)
Observation:
Recommendations:
Does each incident include knowledgeable personnel and contract employees as required?
1910.119(m)(3)
Observation:
Recommendations:
Do the reports include: the date of incident; incident description; contributing factors; and resulting recommendation?
1910.119(m)(4)
Observation:
Recommendations:
Does system resolve and document all observation and corrective actions?
1910.119(m)(5)
Observation:
Recommendations:
Are final reports reviewed by all personnel involved, including contractors?
1910.119(m)(6)
Observation:
Recommendations:
Are all reports retained for five years?
1910.119(m)(7)
Observation:
Recommendations:
Does the facility consider RMP consequences as part of incident investigation?
Best Work Practice
Observation:
Recommendations:
Please explain what a near miss is.
Interview Question
Observation:
Recommendations:
Please explain to me when an Incident Investigation should occur.
Interview Question
Observation:
Recommendations:
If the objective of the incident investigation is not to be place blame, then what is the objective?
Interview Question
Observation:
Recommendations:

EMERGENCY PLANNING AND RESPONSE

EMERGENCY PLANNING AND RESPONSE 1910.119(n)

The intent of this element is to require the employer to address what actions employees are to take when there is an unwanted release of highly hazardous chemicals. The employer must establish and implement an emergency action plan in accordance with the provisions of 29 CFR 1910.38(a) and include procedures for handling small releases. Certain provisions of the hazardous waste and emergency response standard, 29 CFR 1910.120(a), (p), and (q), may also apply.
Does the facility have an established, site specific Emergency Action Plan?
1910.119(n)(1) and 1910.38(a)
Observation:
Recommendations:
Does the Emergency Action Plan include procedures for handling small releases?
1910.119(n)(1)
Observation:
Recommendations:
Are facility's employees trained in the level of HAZWOPER required by the Company's Emergency Action Plan?
1910.120
Observation:
Recommendations:
Is there sufficient number of persons designated and trained to assist in the safe and orderly emergency evacuation of employees?
38(a)(5)(i)
Observation:
Recommendations:
Is the plan reviewed with each employee covered by the plan: initially when the plan is developed; and whenever the employees' responsibilities or designated action under the plan change; and whenever the plan is changed?
38(a)(5)(ii)
Observation:
Recommendations:
Are mock drills performed annually according to the Company PSM Manual?
Best Work Practice
Observation:
Recommendations:
For facilities that employ 10 or more people, is a distinctive siren or alarming device in response of an emergency in place and tested every 2 months?
Best Work Practice and 1910.165
Observation:
Recommendations:
Do you know where to find the emergency phone numbers for the local emergency responders?
Interview Question
Observation:
Recommendations:
What level of HAZWOPER training have you had?
Interview Question
Observation:
Recommendations:

COMPLIANCE AUDITS

COMPLIANCE AUDITS 1910.119(o)

The intent of this element is to require employers to self-evaluate the effectiveness of their PSM program by identifying deficiencies and assuring corrective actions. Minimum requirements include: audits at least every three years; maintenance of audit reports for at least the last two audits; audits conducted by at least one person knowledgeable in the process; documentation of an appropriate response to each finding; documentation that the deficiencies found have been corrected.
Does the facility certify PSM compliance every three (3) years and verify that the compliance requirements are being followed?
1910.119(o)(1)
Observation:
Recommendations:
Do the audit reports include an evaluation of all the required paragraphs of the PSM standard?
1910.119(o)(1)
Observation:
Recommendations:
Is a compliance audit done by at least one (1) person knowledgeable in the process?
1910.119(o)(2)
Observation:
Recommendations:
Are written audit reports developed?
1910.119(o)(3)
Observation:
Recommendations:
Has a prompt response to audit OBSERVATION been determined and documented?
1910.119(o)(4)
Observation:
Recommendations:
Does the facility retain the two (2) most recent audit reports?
1910.119(o)(5)
Observation:
Recommendations:
Does the facility have written policies and procedures for audit review?
Best Work Practice
Observation:
Recommendations:
Do you know the purpose of the internal PSM Compliance audit?
Interview Question
Observation:
Recommendations:
How often are PSM compliance audits performed?
Interview Question
Observation:
Recommendations:

TRADE SECRETS

TRADE SECRETS 1910.119(p)

The intent of this element is to require employers to provide all information necessary to comply with the standard to personnel developing paragraphs (d), (e), (f), (n), and (o) without regard to possible trade secrets. In addition, employees and their designated representatives shall have access to trade secret information contained within documents required to be developed by the standard.
Is all information available to the following people without regard to secret status:
1910.119(p)(1)
Observation:
Recommendations:
Those compiling the process safety information?
Observation:
Recommendations:
Those assisting in the development of the PHAs?
Observation:
Recommendations:
Those responsible for developing operating procedures?
Observation:
Recommendations:
Those involved in incident investigations?
Observation:
Recommendations:
Those involved in emergency planning and response?
Observation:
Recommendations:
Those involved in compliance audits?
Observation:
Recommendations:
Does the facility demand signed confidentiality re: qualifying secrets?
1910.119(p)(2)
Observation:
Recommendations:
Do employees have access to trade secrets per 29 CFR 1200(i) 1 and 12?
1910.119(p)(3)
Observation:
Recommendations:

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EMPLOYEE PARTICIPATION 1910.119 (c)

PROCESS SAFETY INFORMATION 1910.119(d)

PROCESS HAZARD ANALYSIS (PHA) 1910.119(e)

OPERATING PROCEDURES 1910.119(f)

TRAINING 1910.119(g)

CONTRACTORS 1910.119(h)

PRE-START UP SAFETY REVIEW 1910.119(i)

MECHANICAL INTEGRITY 1910.119(j)

HOT WORK PERMITS 1910.119(k)

MANAGEMENT OF CHANGE 1910.119(l)

INCIDENT INVESTIGATION 19910.119(m)

EMERGENCY PLANNING AND RESPONSE 1910.119(n)

COMPLIANCE AUDITS 1910.119(o)

TRADE SECRETS 1910.119(p)

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EMPLOYEE PARTICIPATION 1910.119 (c)

PROCESS SAFETY INFORMATION 1910.119(d)

PROCESS HAZARD ANALYSIS (PHA) 1910.119(e)

OPERATING PROCEDURES 1910.119(f)

TRAINING 1910.119(g)

CONTRACTORS 1910.119(h)

PRE-START UP SAFETY REVIEW 1910.119(i)

MECHANICAL INTEGRITY 1910.119(j)

HOT WORK PERMITS 1910.119(k)

MANAGEMENT OF CHANGE 1910.119(l)

INCIDENT INVESTIGATION 19910.119(m)

EMERGENCY PLANNING AND RESPONSE 1910.119(n)

COMPLIANCE AUDITS 1910.119(o)

TRADE SECRETS 1910.119(p)

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