Although the idea of this article originated from a PSSR debacle on a new process construction project, the information will apply to ALL building construction and so I have put this in the OSHA Compliance Category rather than the Chemical Process Safety category. Late last year we were finishing up a longterm project with a client who was building a new process that would eventually be a PSM/RMP covered process. SAFTENG was hired to perform an engineering review of the plans and aid in managing changes to the plans.
In the early stages of the design, it was decided that the process would be “open-air” (e.g. no walls or roof), but as the Minnesota winter set in (and it was even a mild winter in MN standards), it was decided to enclose the process so that construction work could continue and it would be more pleasant for workers in the winter months. However, this “change” is significant as we now needed ventilation, our electrical classifications/HAZLOCs will change, as will our fire ratings and egress doors. Of course, the client chose not to do a Management of Change for these changes because the process was not yet a PSM/RMP covered process (see my eyes roll). And the information I provided on the ventilation requirements, HAZLOCs concerns, and fire ratings never made it to the General Contractor.
We showed up for the Pre-Start Up Safety Review (PSSR) in February and their pile of mistakes came crumbling down. The GC was aware of the IBC requirements, but since it was not in the original scope nor budget and the client did not provide the required information, the GC was able to play dumb and say “we did what you asked”. Here is where they made their first mistake: