How many times have you heard, or maybe you were the one saying it, that “our initial start-up is the same as normal start-up and that is why we do not have initial start-up procedures”? If I had a $20 bill each time we heard this I would be retired!!!! Recently I was talking process safety with a client who just recently experienced a start-up problem with a new piece of equipment. Of course, this piece of equipment was covered by PSM/RMP and although the incident did NOT involve any release of the HHC/EHS or injury, it did make for a very long day AND night for this engineer. As he was telling me about what happened and how I could not help but run through the process safety failures that allowed this event to occur. But the main item that was missing from the event was an “Initial Start-Up” procedure and of course no training on any initial start-up for this piece of equipment.
The old argument that “this piece of equipment is no different than the other dozen or so just like it that we have started up up-teen billion times over the past 25 years” is NOT a legitimate argument. One fact that may make this clearer is that each of those dozen pieces of equipment was ONLY “initially started” JUST ONCE and EACH of those INITIAL start-ups were unique in their own way. Case in point…
The issue this engineer was faced with was a contractor who forgot to bleed the Nitrogen from the equipment BEFORE he opened it up to the process. This put quite a large N2 bubble into a closed loop process, which then caused a large ripple effect on the other attached pieces of equipment. Now this opens the second door, or failure, allowing a contractor to control the start-up of your PSM/RMP covered equipment. Granted this contractor is the “equipment INSTALLATION expert”; however, they were evaluated and approved as a contractor to ONLY to INSTALL the equipment and NOT operate it. If we plan to allow contractors to perform the “initial start-up” we need to ensure that contractor’s personnel involved having to be TRAINED and their knowledge VERIFIED on the “initial start-up” SOP. The argument that these contractor(s) are the “experts” does NOT eliminate the fact that on the most basic level we MUST have an SOP for the task and those executing the SOP MUST be trained on that SOP.
So back to the situation and example as to how an “initial start-up procedure” can BE ENTIRELY different than the later start-ups. Without these procedural steps to follow AND without having those in charge of the initial start-up trained in this procedure, the likelihood that errors can be made increase substantially. Thus this contractor forgot to bleed off the N2 before his attempt at start-up and thus released a large quantity of N2 into the process, creating a large bubble in the process flows. This led to an attempt by facility personnel to manually bleed off the nitrogen gas. This opens a new door to risks:
- Was there a procedure for the manual bleeding? Where was this bleeding happening? Was this location covered in PHA facility siting?
- Was there a Certified PPE hazard assessment on the tasks that defined the required PPE for the manual bleeding?
- These manual bleeds are usually done at the highest point in the process which meant the worker may have been exposed to a fall from a ladder?
- These manual bleeds usual entail opening a manual valve until the HHC/EHS started coming out and then shut the manual valve.
- MOC did on this new task (e.g. manual bleeding)?
Can we paint a worse picture for “process safety”?
An initial start-up procedure is exactly how it sounds… it is for the VERY FIRST start-up of the equipment. It applies to ALL equipment covered by our PSM/RMP battery limits. Once the initial start up is over, I would suggest that this SOP is attached to the MOC or PSSR for the new equipment for future compliance use when OSHA/EPA ask about the “initial start-up” procedure for the new equipment. This SOP does NOT have to be annually certified as once it is done, it becomes an archived document for compliance evidence only. Of course, it should go without saying that this initial start-up procedure should be CERTIFIED like all the other SOPs and personnel should be trained (and knowledge verified) just like all the other SOPs. But there is almost always a difference between the actual “initial start-up” and other start-up procedures when a major piece of equipment is installed. As in this case, the equipment was merely shipped charged with the Nitrogen to prevent moisture ingress during shipping; yet it found its way into our process! Imagine if this had been a material incompatible with our HHC/EHS; the consequences could have been far more severe. Just something to consider when we say “our initial start-up is no different than any other start-up”.