It’s an all too common occurrence to receive a phone call that starts something like this:

I had some work performed by a contractor over the weekend. Do I need to fill out any paperwork for that?

Short answer, YES.

Long Answer: You should have done that AT THE TIME so now you might want to also consider an Incident Investigation to figure out how you managed to avoid your PSM program requirements on Hot Work, Line-Opening, SOPs, Management of Change, Pre-Startup Safety Review, etc…

These situations are humbling for all involved. It’s helpful to remember that Compliance is a goal we are always striving towards. Still, if we’ve been providing this information the same way for YEARS and it’s still not getting through, part of you begins to wonder if there isn’t a better way (cue the infomercials) to establish BASELINE awareness of these requirements. PSM programs have included guidance on ALL these requirements for decades, but it doesn’t seem to be translating into effective action.

Perhaps there is another way to jump-start that awareness? In an attempt to do just that, I created a simple little flowchart to give to Operators AND Contractor Service Technicians / Construction personnel.

To integrate this into the overall PSM/RMP program, this was placed in the Program Management System Written Plan in the first binder of the PSM program that (in my systems) is entitled “01 – EPA RMP.” The new section is directly after the “Implementation Policy: Management of Program Activities” section.

I also referenced this guidance where appropriate throughout the program. In the same Program Management System Written Plan’s “Implementation Policy: Management of Program Activities” section, the text was altered to point to this new guidance.

  • Activities Triggered by a Change: Certain PSM/RMP program activities are triggered when a change is made to the ammonia refrigeration system. See the “Implementation Policy: Management of Contractor / Operator Activities” for informative guidance and then consult the MOC/PSSR Written Plan to manage and track these activities.
  • Activities Triggered by Maintenance to the Systems: Maintenance to the system can trigger other PSM/RMP program policies / procedures. Examples include Lockout/Tagout, Line & Equipment Opening, and Hot Work permit procedures.  See the “Implementation Policy: Management of Contractor / Operator Activities” for informative guidance and then consult the Mechanical Integrity Written Plan to manage and track these activities.

It’s referenced in the Mechanical Integrity Written Plan in the “Implementation Policy: Quality Assurance” section which now ends with:

See the “Implementation Policy: Management of Contractor / Operator Activities” for additional informative guidance concerning operator and contractor work conducted on the system.

It’s also referenced in the Contractor Written Plan in the “Implementation Policy: Our Responsibilities concerning Affecting Contractors” and “Implementation Policy: Affecting Contractors responsibilities” sections which now end with:

See the “Implementation Policy: Management of Contractor / Operator Activities” for additional informative guidance concerning contractor work conducted on the system.