Most PSSR forms we encounter simply regurgitate OSHA’s 1910.119(i)(2). If the user is thoroughly knowledgeable of what each of these four (4) line items entails, we may be able to execute the PSSR appropriately. Let’s look at these four line items, especially the first line.
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1910.119(i)(2) The pre-startup safety review shall confirm that prior to the introduction of highly hazardous chemicals to a process: 1910.119(i)(2)(i) Construction and equipment is in accordance with design specifications 1910.119(i)(2)(i) Construction and equipment is in accordance with design specifications; 1910.119(i)(2)(ii) Safety, operating, maintenance, and emergency procedures are in place and are adequate; 1910.119(i)(2)(iii) For new facilities, a process hazard analysis has been performed and recommendations have been resolved or implemented before startup; and modified facilities meet the requirements contained in management of change, paragraph (l). 1910.119(i)(2)(iv) Training of each employee involved in operating a process has been completed. |
This single line item, (i)(2)(i), INCLUDES a ton of responsibility, as well as documents/data, to embrace what it is attempting to achieve fully. This line item covers EVERYTHING (physical object) the HHC/EHS touches; however, I will discuss only how it impacts PSM/RMP piping in this article.
We see a lot of PSSR in our travels, and almost all of them will have this line item signed off as completed; however, when we ask for piping installation records, we get the “deer in the headlights” look. Here is what a facility should have to sign off on this single PSSR line item properly:
1) A copy of the Welding Procedure Specification (WPS) manual from the ASME-qualified pipe installation company hired to install the piping. This tells us
- the welds used to join pipes,
- who was qualified to make those welds,
- who inspected those welds and what percentage of welds get a VT,
- the pressure testing procedures and results, and
- the leak testing procedures and results
I always suggest to my clients that they require a completed copy of the WPS at the end of the project for their PSM/RMP program. But simply checking a box that we got the WPS is NOT adequate. It is just the first layer of the proverbial onion!
Someone needs to audit the WPS records and maybe even spot-check the actual welds to ensure the field data correlates to the WPS data. For example,
- were the welds “stamped” by one of the welders in the WPS?
- was the pressure test done correctly? (e.g., was the piping pressured to the required psi and held for at least 10-minutes?)
- was the leak test done correctly? (was each weld/flange “soap tested,” or is there another specified method?)
I estimate that in the early days of our auditing, we saw maybe 25% of pressure and leak tests being done correctly. The number #1 failure would be NOT testing to either 110% of the design pressure if pneumatic testing was done or 150% of the design pressure if hydrostatic testing was done. Clean and dry gases cost $, and when a large circuit is being tested, if they run low on the volume of gas needed, this will inventively lead to lower test pressures.
The bottom line is that if we can not verify the eight (8) items listed above regarding the piping installed, we can not sign off on this line item of the PSSR!
Another article will address how this line item applies to Pressure Vessels and Relief Valves.