HOW CSTOP FULFILLS PSM

WAC 296-67-029 Contractors.

(1) Application. This section applies to contractors performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process. It does not apply to contractors providing incidental services which do not influence process safety, such as janitorial work, food and drink services, laundry, delivery, or other supply services.

(2) Employer (host facility) responsibilities.

(a) The employer, when selecting a contractor, shall obtain and evaluate information regarding the contract employer's safety performance and programs.

(b) The employer shall inform contract employers of the known potential fire, explosion, or toxic release hazards related to the contractor's work and the process. CSTOP does this for the host facility in the Petroleum Module.

EXAMPLE OF A PROCESS FLOW DIAGRAM

(c) The employer shall explain to contract employers the applicable provisions of the emergency action plan required by WAC 296-67-053.

(d) The employer shall develop and implement safe work practices consistent with WAC 296-67-021, to control the entrance, presence, and exit of contract employers and contract employees in covered process areas.

(e) The employer shall periodically evaluate the performance of contract employers in fulfilling their obligations as specified in subsection (3) of this section.

(f) The employer shall maintain a contract employee injury and illness log related to the contractor's work in process areas.

(3) Contract employer responsibilities.

(a) The contract employer shall assure that each contract employee is trained in the work practices necessary to safely perform his/her job. CSTOP does this for the contractor.

(b) The contract employer shall assure 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. CSTOP does this for the contractors in the petroleum module

(c) The contract employer shall document that each contract employee has received and understood the training required by this paragraph. The contract employer shall prepare a record which contains the identity of the contract employee, the date of training, and the means used to verify that the employee understood the training. CSTOP does this for the contractor.

(d) The contract employer shall assure that each contract employee follows the safety rules of the facility including the safe work practices required by WAC 296-67-021.

(e) The contract employer shall advise the employer of any unique hazards presented by the contract employer's work, or of any hazards found by the contract employer's work.

WAC 296-67-021 Operating procedures.

(1) The employer (host facility) shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements.

(a) Steps for each operating phase:

(i) Initial startup;

(ii) Normal operations;

(iii) Temporary operations;

(iv) Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner;

(v) Emergency operations;

(vi) Normal shutdown; and

(vii) Startup following a turnaround, or after an emergency shutdown.

(b) Operating limits:

(i) Consequences of deviation; and

(ii) Steps required to correct or avoid deviation.

(c) Safety and health considerations:

(i) Properties of, and hazards presented by, the chemicals used in the process;

(ii) Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment; CSTOP does this as the program addresses fire, safety and health topics around PSM covered processes

(iii) Control measures to be taken if physical contact or airborne exposure occurs;

(iv) Quality control for raw materials and control of hazardous chemical inventory levels; and

(v) Any special or unique hazards.

(d) Safety systems and their functions.

(2) Operating procedures shall be readily accessible to employees who work in or maintain a process.

(3) The operating procedures shall be reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities.

(4) The employer shall certify annually that these operating procedures are current and accurate.

(5) The employer shall develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. These safe work practices shall apply to employees and contractor employees. CSTOP does this.

Amended WAC 296-67-291 Appendix C

Compliance guidelines and recommendations for process safety management (non-mandatory).

Introduction to process safety management. The major objective of process safety management of highly hazardous chemicals is to prevent unwanted releases of hazardous chemicals especially into locations which could expose employees and others to serious hazards. An effective process safety management program requires a systematic approach to evaluating the whole process. Using this approach the process design, process technology, operational and maintenance activities and procedures, non-routine activities and procedures, emergency preparedness plans and procedures, training programs, and other elements which impact the process are all considered in the evaluation. The various lines of defense that have been incorporated into the design and operation of the process to prevent or mitigate the release of hazardous chemicals need to be evaluated and strengthened to assure their effectiveness at each level.

This WISHA standard is required by the Clean Air Act amendments as is the Environmental Protection Agency's Risk Management Plan.

2). Employers are encouraged to use diagrams which will help users understand the process. A block flow diagram is used to show the major process equipment and interconnecting process flow lines and show flow rates, stream composition, temperatures, and pressures when necessary for clarity. The block flow diagram is a simplified diagram. CSTOP does this in the Power Point Petroleum module. Process flow diagrams are more complex and will show all main flow streams including valves to enhance the understanding of the process, as well as pressures and temperatures on all feed and product lines within all major vessels, in and out of headers and heat exchangers, and points of pressure and temperature control.

(6) Employee training. All employees, including maintenance and contractor employees, involved with highly hazardous chemicals need to fully understand the safety and health hazards of the chemicals and processes they work with for the protection of themselves, their fellow employees and the citizens of nearby communities. Training conducted in compliance with WAC 296-800-170, chemical hazard communication program standard, will help employees to be more knowledgeable about the chemicals they work with as well as familiarize them with reading and understanding MSDS. (CSTOP does this) However, additional training in subjects such as operating procedures and safety work practices, emergency evacuation and response, safety procedures, routine and non-routine work authorization activities, and other areas pertinent to process safety and health will need to be covered by an employer's training program. (CSTOP does this) In establishing their training programs, employers must clearly define the employees to be trained and what subjects are to be covered in their training. (CSTOP does this, and relies on the advisory board for topics to be covered) Employers in setting up their training program will need to clearly establish the goals and objectives they wish to achieve with the training that they provide to their employees. The learning goals or objectives should be written in clear measurable terms before the training begins. These goals and objectives need to be tailored to each of the specific training modules or segments. (CSTOP does this for each module) Employers should describe the important actions and conditions under which the employee will demonstrate competence or knowledge as well as what is acceptable performance.

Training program evaluation will help employers to determine the amount of training their employees understood, and whether the desired results were obtained. If it appears that the trained employees are not at the level of knowledge and skill that was expected, the employer will need to revise the training program, provide retraining, or provide more frequent refresher training sessions until the deficiency is resolved (CSTOP is completed annually as prescribed by the advisory board). Those who conducted the training and those who received the training should also be consulted as to how best to improve the training process. CSTOP does this in train the trainer and in its audit process. If there is a language barrier, the language known to the trainees should be used to reinforce the training messages and information. CSTOP developed materials in Spanish. Careful consideration must be given to assure that employees including maintenance and contract employees receive current and updated training.

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