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Hot Work – NFPA 51B–2019 and Magic Rooms

September 26, 2019 /

RAGAGEP is always changing and we have to ensure that our safety programs evolve to match the new / changed requirements. Tuesday I took a dive into NFPA 51B 2019, the standard for “Fire Prevention during Welding, Cutting, and Other Hot Work.” After reading through it, some changes were made to my base program. Here’s the section from my running “Change Log”

092419 – Updated both versions Hot Work Written Plans to deal with NFPA51B-2019.

  • Changed NFPA references to match new section numbers
  • Changed fire watch to 60-minute minimum per NFPA.
  • Updated master definitions file (in \01-RMP\ ) to include updated definition of Fire Watch and new definitions for Fire Protection System and Fire Monitoring.

To Implement:

  • Change out \01 – EPA RMP\Definitions – Glossary of Terms and Acronyms with 092419 version by using the appropriate MOC procedure.
  • Replace \09 – Hot Work\09 – Hot Work Permit Element Written Plan with 092419 version by using the appropriate MOC procedure.
  • Train all personnel involved in Hot Work about new 60-minute fire watch requirement. Document training per the written plan.

 

This is a fairly simple change. You may have noticed that there is a new section in the “Change Log” for each entry – a “To Implement” section that tells you how to modify your program if it was written based on the baseline templates. I’ve gone back through the last month’s changes and added this information. Time willing, I might do the same for the previous 100+ entries!

While we are on the subject of Hot Work though, I want to bring up another common issue: “Designated Areas.” This is a particularly “Hot” topic right now, because a recent large industrial fire was caused by Hot Work and some people are saying it was an oil fire caused by Hot Work done in a “shop.”

Designated Areas: Many plants have “Designated Areas” such as maintenance or welding shops where Hot Work is conducted without the use of a permit. It should be noted that nothing in the PSM/RMP or OSHA General Industry rules (as interpreted through 1910.119(k)) appear to support this. For this reason, we’ve always called these areas “Magic Rooms” because people seem to think that these rooms are exempt from OSHA rules. The custom actually comes from NFPA 51B:

In the 2019 version, it is section 5.3.2.1 which allows for areas to be classified as Designated Hot Work areas. These areas would allow Hot Work without the use of the written permit provided certain requirements are met:

  • The specific area designed or approved for Hot Work meets the requirements of 5.5.1*
  • The area is reviewed at least annually by the Permit Authorizing Individual
  • Signs are posted designating Hot Work Areas
  • Prior to the start of the Hot Work, the operator verifies the following:
    • The location is verified as fire resistant.
    • The requirements of 5.4.2(3) are met so that the area is essentially free of combustible and flammable contents.
    • Fire extinguishers are in working condition and readily available.
    • Ventilation is working properly.
    • Hot Work equipment is in working order.

* Section 5.5.1 is the list of requirements that have to be met before issuing a Hot Work Permit. Essentially, you are making sure that the Designated Area meets the requirements for issuing a Hot Work Permit without actually issuing one.

The acceptability of this custom is in question due to a statement made by OSHA in their PSM Preamble:

“…this proposed provision would not require a permit for Hot Work operations in a welding shop unless the welding shop was located in a process area covered by the standard. OSHA believes that such a location would not exist.” (OSHA, PSM Preamble, 1992)

OSHA was clearly thinking of Petroleum and Chemical plants in that quote, where such situations are usually not found. As of 2019, we are not aware of any Ammonia Refrigeration PSM-covered facility receiving a Hot Work citation for Designated Areas if they follow the requirements of NFPA 51B Section 5.3.2.1. Still, it would be far more defensible if you issued Hot Work permits for all Hot Work, even that work conducted in maintenance and welding shops.

 

Here’s a look at the Hot Work element Written Plan section dealing with Designated Hot Work Areas:

Note: Previous discussion on Hot Work at this link. You can read the 2019 version of NFPA-51B in its entirety at NFPA.org

 

Questions from the field: Who is responsible for the PSM/RMP duties?

September 18, 2019 /

From a legalistic perspective, we’ll first turn to the law. In this case, the EPA’s RMP rule…

68.15(a) The owner or operator of a stationary source with processes subject to Program 2 or Program 3 shall develop a management system to oversee the implementation of the risk management program elements.

68.15(b) The owner or operator shall assign a qualified person or position that has the overall responsibility for the development, implementation, and integration of the risk management program elements.

68.15(c) When responsibility for implementing individual requirements of this part is assigned to persons other than the person identified under paragraph (b) of this section, the names or positions of these people shall be documented and the lines of authority defined through an organization chart or similar document.

The short, legalistic answer is that the owner/operator is responsible. They must pick a qualified person who has overall responsibility for the program.

If the owner then chooses to break up the various requirements of the program to people other than that qualified person, they have to document all those people. In my programs, I call these people a “Responsible Person.”

 

Ok, but how does this actually work. Let’s imagine a small facility that is required to have a PSM/RMP program. They pick their Safety Manager, Sofía as their Process Safety coordinator, so she is now the person responsible under §68.15(b).

But, Sofía, while very knowledgeable in Safety and Environmental issues, is not as familiar with refrigeration or engineering. It’s unlikely she’ll be in the best position to manage most of the program elements on a day-to-day basis.  To address this issue, the facility decides to assign certain skilled people the responsibility for various program elements. They assign the Operating Procedure, Operator Training and Maintenance elements to Robert, their Maintenance Manager. They also decide to assign the Process Safety Information, Management of Change and Pre-Startup Safety Review elements to Jaylen, their Plant Engineer.  Because he usually manages them anyway, they assign Benny, the Lead Operator, the Contractor element. Of course, all these people are going to rely on the knowledge and experience of each other, the Facility Manager John, and the other operators, Tessa, Faraz, and Tiah.

This might be getting a little confusing at this point, which is why §68.15(c) wants us to document these assignments. For example:

Program Element Responsible Person
Overall PSM / RMP Management System PSM Coordinator
Risk Management Plan (RMP) PSM Coordinator
Process Safety Information Plant Engineer
Employee Participation PSM Coordinator
Process Hazard Analysis PSM Coordinator
Operating Procedures Maintenance Manager
Operator Training Maintenance Manager
Contractor Qualification and Safety Lead Operator
Pre-Startup Safety Review Plant Engineer
Hot Work Permit PSM Coordinator
Incident Investigation PSM Coordinator
Mechanical Integrity Maintenance Manager
Management of Change (MOC) Plant Engineer
Emergency Response Plan PSM Coordinator
Compliance Audits PSM Coordinator
Trade Secrets PSM Coordinator

How a facility arranges the responsibilities is entirely up to them as long as they can make the case that the person assigned as a “Responsible Person” is qualified to handle the work being assigned to them.

On a practical level, your Management System should also:

  • Show what person is responsible for each PSM/RMP element / requirement
  • Ensure that only one person is responsible for each requirement
  • Make it clear that a Responsible Person can’t authorize their own work requests, such as Hot Work, MOC, PSSR, etc.
  • Be easily understood by everyone involved

Please note, that just because someone is responsible for an element, doesn’t necessarily mean they are actually doing the work. They are just responsible for ensuring the work is done. A good example outside of PSM is the facility manager of a chicken plant. That facility manager is responsible for ensuring that food safety regulations are met so the chicken is cooled in an appropriate time-frame. It is extremely unlikely that the plant manager actually handles the chicken, the cooling equipment, etc. They simply provide the resources and oversight to ensure the work is done properly.

A good PSM example might be Operating Procedures. In our case, we’ve assigned them to the Maintenance Manager. It is likely that the actual initial creation and review of the operating procedures is done entirely by the operators. Based on the results of that review, the Responsible Person would ensure that appropriate revisions are made and then certify the procedures.

Feel free to contact us If you want templates of a PSM/RMP management system.

Compliance Auditing and the Karenina Principle

August 2, 2019 /

Over the years I’ve audited well over one hundred Ammonia Refrigeration Process Safety (PSM / RMP) programs and one of the things that I always try and remember during the audit is something called the “Anna Karenina” principle. The first line in that Leo Tolstoy novel is:

“All happy families are alike; each unhappy family is unhappy in its own way.”

 

Put another way: Success requires certain key factors are addressed. Meeting those requirements means that those successful systems will be similar to other successful systems. For Process Safety programs, there are many key factors to success, but I think they all boil down to three main categories:

  • Does the facility have a written Process Safety Program that (on paper) meets the safety & compliance requirements of the law, the process, and the people, in a manner that meets the business needs of the company? If so;
  • Is the written Process Safety Program implemented as written? If so;
  • In the actual day-to-day process, does the written Process Safety Program as implemented address the safety & compliance requirements of the law, the process, and the people, in a manner that meets the business needs of the company adequately?

I often call this the “Three Levels of Compliance.” Shown in a flowchart:

While there are nearly infinite ways a Process Safety program can fail, but ALL successful programs will pass these three levels of compliance checks. Understanding this concept will help you be a better auditor, but it can also help you be a better implementer!

 

In Auditing, how does this work in practice?

Let’s look at an example of an identified deficiency of rusted pipe found during the walkthrough portion of an audit. Note, we’ve kind of started at the 3rd level of compliance here because we’ve found a problem in the field and therefore know that the plan as implemented isn’t adequate!

First-pass question concerning written plan could include:

    • Are there written instructions on their inspection frequency and acceptable conditions?
    • Is there a written plan on training to perform these inspections?
    • Does the written Mechanical Integrity Plan address these specific pipes?

The answers to these questions will help you define a finding / recommendation to improve the program.

Second-pass questions concerning implementation could include:

    • Is the written Mechanical Integrity Plan that addresses these pipes being conducted when it is scheduled to be?
    • Are the written instructions being followed?
    • Was the inspector trained in accordance with the written plan?

Again, if the answers to these questions may prompt a finding / recommendation to improve the program. If you have a written MI plan and you are implementing it, but you still have rusting pipes; then you need to fix either the plan or your implementation of it!

 

How can this concept help me be a better implementer?

Your Process Safety Program is, by its very nature, artificially bringing order to chaos. Because of Entropy, we know that all systems and processes will eventually decline into disorder and fail. This decay happens with no effort on your part but, with effort, it can be thwarted.

Ultimately. I believe the only way to continuously, sustainably maintain your Process Safety Program is by forcing a feedback loop. A feedback loop is where you ensure that the output of a system is routed back to the input of the system. In our earlier worked example, we need to ensure that the output (physical condition, daily practices, etc.) of the system is routed back to the input (written plan and implementation of it) so we can know how well the system is performing and make changes as needed.

When it comes to the mechanical world, there is no better feedback loop that actual inspections and tests. If it is properly designed, your Mechanical Integrity program should be providing this information. Your team needs to understand that (no matter how small) every single deficiency you find, or breakdown that you have, is a sign that your plan can be improved.

When it comes to the operation of the system (policies, procedures, etc.) your PSM team is supposed to be providing this feedback. I say “supposed to be” because more and more I see that this important feedback loop is not being properly utilized. For more information on what the purpose of a PSM team is and what it should do see this earlier article: What is the purpose of a PSM Team?

What is the Purpose of a PSM Team?

July 30, 2019 /

The implementation of the PSM/RMP Program is a team-based effort. In my opinion, no single part of a Process Safety Program is more important than your Process Safety Team. Put another way: If you don’t have a strong Process Safety Team you won’t have a strong Process Safety Program.

 

Who should be on the Team?

At a minimum:

  • Each Responsible Person listed in the “Management System” is a member of the PSM team. Responsible Person’s are people that have responsibility for implementing individual elements of the Process Safety Program.
  • If not already included as a Responsible Person, all Process Operators are also included as PSM team members.

The team can also benefit from additional diversity such as senior members of management outside of Process Safety. Examples might include the Plant Manager or Director of Warehousing, Production Supervisors /Managers, Health, Safety & Environmental staff, etc.

 

What should the team do?

While a successful team serves many functions, it is there for two essential purposes:

  • To educate and inform
  • To provide oversight

 

Process Safety Team as an Educator

Your covered process and the safety programs that cover it are large and complex. So it the overall business that they are a part of. Our first priority in the meeting is to inform each other of what is happening in the parts of the program we deal with on a daily basis – or we are responsible for. This is often referred to as “getting everyone on the same page.”

 

Process Safety Team’s Oversight Role

The most often failed function of a Process Safety Team is to provide oversight. The Responsible Person for an element has to make day-to-day decisions to keep the process (and the business) running and we should ensure that they defend these decisions to the Process Safety Team so that the team can either validate or correct them.

For example:If the MOC Responsible Person decided that a specific change was not required to go through the MOC process, they should make that argument to the Process Safety Team which should either validate that choice or – as a group – convince the Responsible Person that their decision was in error so they can take corrective action.

Another example: The Responsible Person and two other staff members have completed an Incident Investigation on a small process leak that recently occurred. The Process Safety Team should either validate that completed Investigation or – as a group – convince the Responsible Person to investigate additional avenues, or provide addition recommendations.

This simple concept: Defend your decisions to a team of your peers so they can validate them or correct your thinking is the beating heart of any Process Safety Program. If you do it well, you provide a feedback loop, and the entire team will get better at their jobs. Whether it’s an Incident Investigation, a Management of Change, Contractor evaluations, etc., Validating your decisions with your Process Safety Team will improve the performance of the program more than nearly any other thing you can do.

 

Bonus Content: What should we discuss at our PSM meetings?

I am often dumbstruck when this question is asked of me, because I NEVER run out of things to talk about. (You can all stop laughing now)

While PSM Team Meetings should be structured to allow diverse topics and input, certain topics should be discussed at any general PSM Team Meeting:

  • Any open recommendations in the program to review status and ensure recommendations are progressing towards resolution.
  • Any upcoming, ongoing, or recently completed MOCs, PSSRs, Incident Investigations, etc. to review status and/or adequacy of documentation.
  • Any upcoming, ongoing, or recently completed work that has, or may have, safety ramifications for the covered process(es).
  • Team Validation of any decisions / work product produced by Responsible Persons

 

Note: Special thanks to end-users VD & CG who prompted me to include this information (and more) directly into my PSM Element Written Plans. We ALL improve with feedback!

 

IIAR 7-2019 Update

May 31, 2019 /

It’s been coming for a while now and yesterday it became official:

Introducing: ANSI/IIAR 7-2019 – Developing Operating Procedures for Closed-Circuit Ammonia Refrigeration Systems

In 2013, the first issue of IIAR 7 replaced the operations information contained in IIAR Bulletin No. 110, Guidelines for Start-Up, Inspection, and Maintenance of Ammonia Mechanical Refrigerating Systems.

This standard was first approved as an American National Standard by the American National Standards Institute (ANSI) in August 2013. ANSI requires reaffirmation or revision for periodic maintenance requirements of existing standards every five years. Work began on periodic maintenance of this standard in February 2017 and was completed in April 2019.

This standard defines the minimum requirements for developing operating procedures for closed-circuit ammonia refrigeration systems. Informative Appendix A was added to provide explanatory information related to provisions in the standard.

 

A little over two years ago, the SOP templates were updated to include all the requirements of IIAR 7 2013. That was a pretty large undertaking, but if you already made those changes, it looks like you are in good shape! I’ve reviewed the new IIAR 7 and it turns out we only need to make one substantive change to programs using the current templates.

 

What’s the requirement / change? 

The 2013 version required a visual inspection of hoses when they were used. This was a pretty minor requirement. The newer version requires that procedures include “Steps to inspect hoses and fittings visually to make sure they are suitable for ammonia refrigeration service”  whenever you Transfer (such as in pump-down) or Charge ammonia. To address this issue, I’ve modified the ROSOP-LEO and Permit form to include an explicit check and a reference to the “ITPMR-AHT-365 – Ammonia Transfer Hose Annual ITPM Record” we recently added due to IIAR 6.

So, if you’ve already updated your system for IIAR 6 compliance, then all you need to do is update your LEO procedure and Permit. If you haven’t updated your system for IIAR 6 compliance, then you need to integrate the new ITPMR as well as make plans to address the entirety of IIAR 6.

Note: Overall the 2019 IIAR 7 is much simpler than the 2013  version. It’s moved a lot of stuff to informative appendices which removes most of my complaints about it. Unfortunately they renumbered* just about every single requirement in the standard. This meant I had to completely renumber / rewrite my standalone SOP audit template. The good news is that the IIAR7-2019 version of that audit was reduced from 110 pages to 87. Of those remaining 87 pages of questions, 60 pages are due to IIAR 7.

* This was not an attempt to drive me closer to insanity, but an attempt to harmonize numbering systems between all the IIAR standards. I know this because I actually asked the IIAR about this. Thankfully, Tony Lundell has a good sense of humor.

Using the Hierarchy of Controls as a tool for Incident Investigations

May 28, 2019 /

The issue: Poor Incident Investigations and how to improve them

Often members of the Incident Investigation team miss some fairly obvious opportunities to improve their process safety. One trick is to use the Hierarchy of Controls as a brainstorming tool when coming up with causes and recommendations.

 

What is the Hierarchy of Controls and How can I use it as a tool during Incident Investigations?

The premise of the Hierarchy of Controls is that while hazards can be controlled in various ways, certain types of controls are inherently better than others. The hazard controls in the hierarchy are, in order of decreasing effectiveness:

Let’s take an example of an Incident Investigation concerning an unexpected employee NH3 exposure during an oil drain. While you will have to address any unique issues relating to the incident, here are some questions that the Hierarchy of Controls can provide for any oil drain incident:

Elimination: Physically removing the hazard. For example, when analyzing the risk of a valve packing leak in a process room, moving that valve to the roof would eliminate the hazard from the production room. Elimination is usually considered the most effective hazard control.

Substitution: Replacing the hazard with something that does not produce a hazard or something that produces a much smaller hazard. A common example of this is removing the hazard of NH3 in product chillers areas with the use of a secondary refrigerant such as CO2 or Glycol. Note that in some instances this results in simply relocating a hazard to another area with lesser consequences.

Note: We usually combine these two methods because if we don’t, we tend to spend more time arguing whether or not a control is an elimination or a substitution.

  • Can we avoid, or reduce the frequency of, the oil drains? Better coalescers, higher minimum head pressure to reduce oil blow-by, installation of an oil still to minimize oil draining from the system, etc.
  • Can we eliminate / reduce the NH3 involved in the oil drain? Pumpout of the oil pot and re-pressurization with shop air, conversion to a gravity drain oil pot, lower pressure suction during pumpout, etc.

 

Engineering Controls: These controls do not eliminate hazards but tend to attempt to control them or give notice when the process is approaching an unsafe state. Examples include NH3 sensors, Interlocks, High-Level Floats, Pressure and Temperature transducers, etc.

  • Is the equipment properly configured for a safe oil drain? Oil pot, “Dead-Man” valve, safe access, easy egress routes, etc.
  • Can we improve the ventilation in the area? Portable fans, local exhaust ventilation, manual use of existing Machine Room fans, etc.
  • Can we improve the hazard awareness? Local / Personal NH3 detector rather than relying on a fixed detector, pressure gauge installed during the pump-down, etc.

 

Administrative Controls: These controls are changes in the way the work is performed on or around the process. Training, Procedures, Signs and Warning labels are all administrative controls.

  • Can we improve the SOP? Better steps to address the hazards, mandating more oversight, required use of PPE, more effective use of ventilation, etc.
  • Can we improve the training? Better understanding of the hazards, procedures, PPE, tools, etc.

 

Personal Protective Equipment: PPE such as gloves, respirators, etc. is generally considered the last resort of hazard control.

  • Can we improve the PPE available? Can we make certain PPE mandatory? Improved gloves, smocks, respirators, etc.

 

Using the Hierarchy of Controls can be a great brainstorming tool to help you look at your possible causes, and your possible corrections from some new angles.

One Hazard, Multiple Attempts at Control

May 7, 2019 /

Given the catastrophic nature of the hazards associated with PSM, the interrelationship of the PSM elements work together as a safety net to help ensure that if the employer is deficient in one PSM element, the other elements if complied with would assist in preventing or mitigating a catastrophic incident. Consequently, the PSM standard requires the use of a one hazard-several abatement approach to ensure that PSM-related hazards are adequately controlled. (OSHA, CPL 2-2.45A, 1994)

 

The text above, from OSHA’s old PQV (Program Quality Verification) audit is critical to understanding a key concept of successful Process Safety: The more ways you attempt to control a hazard, the more likely you are to be successful.

Sometimes this concept is referred to as the “Swiss Cheese Model.” I’ll quote from Wikipedia:

It likens human systems to multiple slices of swiss cheese, stacked side by side, in which the risk of a threat becoming a reality is mitigated by the differing layers and types of defenses which are “layered” behind each other. Therefore, in theory, lapses and weaknesses in one defense do not allow a risk to materialize, since other defenses also exist, to prevent a single point of failure. The model was originally formally propounded by Dante Orlandella and James T. Reason of the University of Manchester, and has since gained widespread acceptance. It is sometimes called the cumulative act effect.

To understand how this works in a functioning program, I want to point out how we recently addressed a single hazard in our program to show how many different ways we attempted to control it.

 

The hazard

 In IIAR’s upcoming standard 6 “Standard for Inspection, Testing, and Maintenance of Closed-Circuit Ammonia Refrigeration Systems” a hazard is identified and a prohibition is put in place to address that hazard:

 

5.6.3.4 Hot work such as the use of matches, lighters, sulfur sticks, torches, welding equipment, and similar portable devices shall be permitted except when charging is being performed and when oil or ammonia is being removed from the system.

 

The IIAR is recognizing that there is an increased likelihood of an Ammonia / Oil fire during charging operations and when oil / ammonia is being drained from the system. They are prohibiting Hot Work operations during these operations to remove potential ignition sources.

 

The Control(s)

You can make a (weak) case that simply referencing the RAGAGEP and inserting a single line in your Hot Work policy address the compliance requirement, but we’re going to need to do a lot more to make this prohibition a “real” thing in our actual operations.

 

Control Group #1: The Hot Work element

In the element Written Plan, we added two new “call-out’s” in the two places they are likely to be seen when planning Hot Work policies. First, in the section on Conducting Hot Work:

 

Second, in the section on Sulphur Stick use:

 

Third, in the Hot Work Permit itself, we modified the existing question on flammable atmospheres:

 

Control Group #2: The Operating & MI Procedures

All procedures that involve oil draining, ammonia charging and ammonia purging already point to the LEO (Line & Equipment Opening a.k.a. Line Break) written procedure. This makes our job a bit easier here, since we only have to modify our LEO rather than the dozens of procedures that might include this type of work.

We modified the traditional LEO “General Precautions section to place a check for Hot Work during an existing requirement to canvas the area for personnel that may be affected by the LEO:

 

In the more advanced, two-step “Pre-Plan and Permit” version of our LEO, we modified the “Pre-Plan Template” to include a warning:

 

In both versions of the LEO permit itself, we added an explicit check:

 

Closing Thoughts

This one small RAGAGEP change points to a single hazard – a hazard that we’re now trying to control in six different ways. Notice that we’ve made all these changes so they are popping up throughout the program:

  • In preparing policies for the associated work;
  • In the course of preparing for the work itself;
  • In the course of conducting the potentially hazardous operations.

This is critical because if we want to get the best “bang for our buck” in Process Safety, the safety portion has to be integrated into our actual processes on multiple levels.

Obviously, we’ll have to train on these changes to ensure that they’ll be effective. It’s quite possible that, after implementation, we’ll identify additional ways to prevent the hazard from being realized and will need to make further changes.

Responding to an OSHA NEP Inspection Document Request

April 25, 2019 /

Back in 2017 I posted on how to answer an OSHA document request from the published NEP.

OSHA’s published CPL-03-00-021 – “PSM Covered Chemical Facilities National Emphasis Program” includes an example document request list that often correlates fairly well to the one that OSHA inspectors provide during an NEP inspection.

Recently, a friend sent me the Document Request they received at the onset of the inspection which was quite a bit different from that PSM ChemNEP. Here’s what I noticed reviewing this new document:

  • It’s quite a bit longer.
  • The information – again – isn’t NH3 Refrigeration Specific. That means you have to interpret some of it.
  • In my opinion, It’s designed to be a huge fishing expedition.

I took that request and modified it to show how I would answer the 110 questions if you were using my PSM programs. You can download the 13 page, 4,500 word Microsoft Word monstrosity through the following link: 0419 OSHA Document Request.

Just a few general warnings about questions and document requests:

  • When in doubt, ask for clarification. Always get clarifications in WRITING.
  • When you are unsure of the appropriate documentation to provide, or what documentation addresses the issue, ask to get back to them and seek quality advice.
  • Always get additional documentation requests and follow-up questions in WRITING.

Previous Post on the subject.

If you need help preparing for, managing, or dealing with the aftermath of an OSHA or EPA inspection, please contact us.

Composite Fan Blades – A Replacement in Kind?

April 24, 2019 /

Imagine we’ve decided to replace the existing fans of an air unit (probably a blast cell) with composite blades. Should you consider that a Replacement in Kind?

Before we go into the change, you might be asking why people would change from a metal fan to a composite. The answer is usually three-fold:

  • Composites allow for some really elaborate / efficient shapes that are difficult to pull off with traditional metal blades. This means that the fan blades can be designed for low noise or to maximize throughput / throw. It’s not uncommon to see a composite blade manufacturer claim a 5% energy savings by using these types of fans.
  • Corrosion Resistance. The commonly used FRP (Fiber reinforced polymer) blades are more resistant to common cleaning chemicals and water than traditional metal fans.
  • Composite fans usually provide a far better weight/strength ratio than even cast aluminum. This means higher efficiency, lower motor wear, etc.

Should you consider the replacement of traditional metal fans (in an air unit for example) as a Replacement in Kind? My thinking on this is the same as the answer to every other “Is it a Replacement in Kind” question: It’s a change that falls under the MOC procedure(s) until you prove that it isn’t.

To meet the lowest possible compliance threshold of OSHA and the EPA we have to know if it “satisfies the design specification.” In this case, that pretty much comes down to asking if it has the same (or better) performance characteristics as the fan it’s replacing.

Assuming you do those checks, and you find the new fan can operate at the same temperatures, static pressure, speed, etc. as the old fan, OSHA and the EPA would allow us to qualify this as a Replacement in Kind. As always, I would suggest you document that work so you can prove you’ve correctly qualified the change as a Replacement in Kind. That’s the minimal compliance answer. The process safety answer is different and it’s the answer you should care about!

For the process safety answer we also ask a few more questions. For example:

  • Does the fan have the same MI requirements?
  • Does the fan have the same failure modes?
  • Are our PHA answers concerning fans (evaporators, condensers, etc.) still the same based on these new fans?

I would like to focus on the PHA question because the others are part of our PHA answer. If you are using the IIAR’s What-If checklist (or something like it) you have a question that looks like this:

EV1.22  What If…a fan fails catastrophically? (air unit cooler only)

It’s likely you answered that for metal fans by saying there were appropriate safeguards to control this hazard such as your MI program, daily walk-through’s, 5yr independent inspections, etc. It’s also likely that if you had those safeguards in place you made “no recommendation” on that question.

Now, let me ask: What if the new fans have different failure modes / MI requirements? Wouldn’t that change your analysis?

Recently I’ve been getting reports of fan failures in the field. While not unheard of with traditional metal fans, these reports lately seem to all be about composite fan blades.

What we seem to be seeing in these composite fan failures is that they appear to be caused by:

  • Turbulent uneven air flow through the coil (usually caused by debris on the coil but could also be caused by partially blocking the airflow out of a coil)
  • The turbulent air flow causes the fan to oscillate, sometimes at a resonant frequency
  • Over time this resonant frequency causes small stress cracks to start on the fan blade at the hub
  • If the condition lasts long enough, the crack propagates, and the fan catastrophically fails

Now, that’s not a failure mode / sequence of events we are used to seeing on traditional metal fan blades. Does that mean we shouldn’t use composite blades? No, of course not – it means Identifying new hazards like this requires us to institute new / altered controls. Some good examples of appropriate changes:

  • LOWER our acceptable threshold for debris on air unit intakes. This could mean more walk-through’s or just more debris removal. We’re not talking about dust buildup here, we’re talking about the removal of large debris: cardboard chunks, labels, etc. The things that are likely to cause turbulent and uneven flow through the unit.
  • LOWER our acceptable threshold for product blocking airflow out of a coil.
  • Specifically look for signs of cracks during annual / 5yr MI inspections.

Making changes to our program like this show us that the change from a traditional fan blades to composite fan blades should not be treated as a Replacement in Kind. It is, however, a fairly simple Management of Change. I want to re-emphasize here, had we chosen to view this change as a Replacement in Kind, we would have missed these opportunities to identify and control these new hazards introduced by the change.

Properly Addressing PSM / RMP Findings & Recommendations

August 3, 2018 /

Process Safety managers are often buried under a torrent of Findings and Recommendations from PSM/RMP elements such as Employee Participation (EP), Process Hazard Analysis (PHA), Pre-Startup Safety Review (PSSR), Incident Investigations (II), and Compliance Audits (CA).

In compliance audits over the past decade the single most likely deficiency I find is failing to properly “address” these Findings / Recommendations. Note: a Finding / Recommendation is considered “addressed” when you either accept & implement it, or justifiably delay the implementation while assuring safe operation. The most common problems are:

  • Failing to respond to the Finding / Recommendation.
  • Failing to document the response to a Finding / Recommendation even if it was addressed.
  • Planning to accept a Recommendation (or proposing a solution to a Finding) in the future (usually through CapEx) while not either:
    • Assuring the situation is safe in the interim.
    • Implementing an interim solution to ensure the process is safe during the delay.

Let’s look at each of these and discuss how Process Safety manager typically fail, and what YOU can do to avoid common failures.

 

Failing to respond to a Finding / Recommendation

Failing to respond to known issues is all too common. There are many reasons this happens, but in my experience, here are the most common problems:

Not understanding the issue.

Solution: Ask questions about the reason for the Finding / Recommendation. Don’t let someone tell you that something has to be done a certain way without an adequate explanation. Many unnecessary Findings / Recommendations  can be avoided or solved simply by asking the person making it to provide their actual reasons for it. This isn’t about feelings. Ask for the specific hazard, regulation, code, standard, etc. You can’t judge a Finding / Recommendation without understanding it, and neither can management. In the case of legitimate Findings / Recommendations, understanding the issues behind the Finding / Recommendation will help you gain momentum to address the problem.

Assuming the solution won’t be approved

Solution: Don’t prejudge. That isn’t your role. Your role as the Responsible Person is to bring these issues to the people that are in charge of the process. Ask the right questions and present the necessary information to management. THEY are responsible for their decisions after that. Your role is to document their responses and remind them if you haven’t received adequate direction on the disposition of the Finding / Recommendation.

Losing Track of the Finding / Recommendation

Solution: Implement a robust tracking method. Personally, I’ve always liked tracking sheets, but electronic software can work too. Whatever your method, you need a *system* to promptly address and resolve Findings / Recommendations. Once you’ve established this system, use it to set the agenda of your regularly scheduled Process Safety meetings. A tracking system should document:

Where the Finding / Recommendation came from.

Why the recommendation was made and the the actual text of the Finding / Recommendation.

When the Finding / Recommendation was made. When the Finding / Recommendation (and any interim measures) are to be completed by. When activities on it occur and, ultimately, when it is marked as fully addressed.

Who is Responsible for it.

What has been done, is being done, and is planned to be done.

 

Failing to document the Response

If you’ve implemented a system to track Findings / Recommendations, then this shouldn’t be an issue. Where most people fail here is not documenting what they are told. An example: you bring up a recommendation during a conversation with management and they give you an answer, but you don’t document that verbal answer in your tracking system. Even better, when you are given verbal answers to a Finding / Recommendation, either document that answer in the meeting notes or in a follow-up email to the person that gave you the verbal answer.

Even when you actually addressed the Finding / Recommendation, failing to document it can come back and bite you. I’ve witnessed a situation where a recommendation to paint a valve group was implemented but not documented. A few years later, during an OSHA inspection, the facility was cited for not documenting that they did the work – even though the CSHO agreed that the valve group appeared to have been painted. Remember, there are explicit requirements in the PSM rule that you document Finding / Recommendation resolutions: PHA e(5) “the resolution is documented; document what actions are to be taken…” Incident Investigation m(5) “…Resolutions and corrective actions shall be documented.” Compliance Audit o(4) “…determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected.”

 

Assured Interim Safety or Interim Measures

When you receive a Finding / Recommendation, it’s best to work with the j(5) standard: “… correct deficiencies…before further use or in a safe and timely manner when necessary means are taken to assure safe operation.”

Put simply: Either shut it down or ensure it’s safe to operate while you are planning & implementing your response.

Let’s use the example of a valve group that has been identified as “rusty.”

First, we need to evaluate the condition of the valve station. Is it so bad that you don’t know if it’s safe? If so, shut it down until you can evaluate it further. Document this decision and the reasons for it.

Is it mild surface rust such that it just needs cleaning and a fresh coat of paint? Either clean and paint it right away or document why it’s safe to operate until when you plan on cleaning and painting it.

 

Bonus: What a flowchart of a SYSTEM for Finding / Recommendation resolution can look like:

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