Is there a method to OSHA’s madness in regards to the PSM required operating procedures?
A few months ago I had the pleasure of working with some great OSHA PSM professionals in a state OSHA plan and as always, every project that I do I walk away a better safety professional. This particular project was a VPP Assessment and since I had extensively helped this facility with their PSM Systems they asked if I could participate in the assessment in case they stumble on any PSM related items. (Note: There is a CSP story in this week long adventure but I will share that on another day.) All was going well on day one: they liked our PSI management system and the detailed PSI we had compiled; they loved the PHA (HAZOP) we did on the process and the tracking system the facility was using to track progress. But when it came to Operating procedures, one of the inspectors had an interesting perspective on how SOPs should flow from one to the next. Here is what their expectations were in regards to “Emergency Shutdown” SOP and the “Start-Up following an ESD”. Their position on how these two procedures should flow is that whatever valves get closed or opened in the ESD, either manually or via an interlock or DCS, those same valves should be reversed in the “Start-Up after ESD” procedure.
Basically, if your ESD calls for operators to OPEN or CLOSE valves, then why would the start-up SOP after the ESD not specifically call out these valves so that they can be returned to their normal operational position? Keeping in mind that the operators who brought the process down during the ESD procedure may very well NOT be the ones who start the process back up. One could make the argument that basic logic says to use the ESD procedure and work backwards, reversing the actions that were taken in the ESD. However, in some cases, it does not matter what order the valves were closed in the ESD, but the order in which they are opened is critical and just reversing the ESD procedure may not be appropriate.
Made perfect sense to me! I struggled when I was in the chemical industry with the level of detail that needed to be in an ESD procedure. I learned through many bad ESD events that in the “heat of the moment” when the world seems to be crashing down around us we need detailed and specific actions that were well thought out in a different state of mind. After the “dust settles” and we begin to ponder starting the process up we can often have blinders on and be rushed to get “things back to normal” (never more evident in the many start-up accidents on record). Without a procedure to guide us in the critical measures that need to be taken to ensure a safe start-up, there could be many things that go wrong.
Keep in mind that the two most dangerous states of a chemical process are shutdown and start-up; hence the regulatory emphasis on start-up and shutdown procedures. But the real test is…can you put your “Start-Up following an ESD” procedure behind your ESD procedure and they read like a book?