In the chemical industry, we had things a bit easier when it came to defining our process battery limits and this made it easy for us to define who was a PSM/RMP contractor. But things are not so easy in facilities where the PSM process is a small and not core to the business. We see this in flammable liquid processes and ammonia refrigeration processes, where the Highly Hazardous Chemical that put the facility into PSM/RMP runs throughout the facility.
We have seen it many times… a contractor doing work NOT related to the covered process negatively impacts the covered process! We have seen contractors operating forklifts and man-lifts hit pipes containing the HHC and causing a serious incident, electrical workers causing an outage which leads to a serious PSM incident, etc. And none of these contractors were working in areas the facility claimed to be their covered process area. This brings to light that there are usually MANY contractors on site that should be included in the PSM/RMP Contractor Safety Program, but have fallen through the cracks.
Think about these contractors and if they should be included in your PSM/RMP Contractor Safety Program:
- You receive your HHC via rail. You have a contractor who maintains your rail spurs???
- Your PHA indicates that electricity is a critical utility (i.e. loss of electricity could impact your PSM/RMP process). Wouldn’t any contractor working on any electrical ANYWHERE on the plant site be a PSM contractor as their actions could cause a power loss. How about the contractor hired to “service” your emergency generators?!?!
- Painters who will be painting in an area where the HHC is piped through?
- Roofers who will be doing roofing work over top of your covered process or in the vicinty of the process vents?
- Concrete company who is hired to pour your secondary containments we all take credit for as “passive mitigation?
- Your process is a flammable liquid process… should your fire protection company that does your sprinkler testing/service, fire extinguisher inspections and annual servicing. I would even go as far as the fire protection contractor who services the halon system in the server room which contains the server that will be called upon for SOPs, Emergency Procedures, Checklist, etc.
- The contractor that services and calibrates your atmospheric monitors used in your hotwork and confined space programs.
- The contractor that services your EE and EX forklifts used within your HAZLOCs
- Contractor hired to change light bulbs using manlifts or ladders and to service the emergency lighting in the plant.
- The contractor who launders and repairs your flame retardant clothing?
We have to begin looking beyond “OSHA compliance” and those hands-on contractors who are actually working in, on or adjacent to our covered process in order to improve our chemical process safety efforts. I wrote earlier in the year about how we define “adjacent” and wrote about cranes set up for a non-process job, but could fall and reach a covered process and how those jobs should fall under our contractor PSM/RMP programs. I am now advocating that we need to expand our vision in who we pull into our contractor safety program. But we all have contractors on site that play a role in our “process safety” efforts that are falling through the cracks for some reason or another. Granted we need to ensure those contractors working directly in, on or adjacent to our process are evaluated and CONTROLLED when they are on site; but some of those contractors listed above can play a MAJOR ROLE in a process incident if left UNCONTROLLED.
Lastly, I am not worried about the safety record of my uniform vendor, but I am worried about what happens if they are not qualified or set up to manage a flame retardant clothing program. There are tons of uniform vendors, but you would be surprised at the very small percentage of those who have experience with flame retardant clothing. We have seen FRC’s repaired with non-compliant materials, improper laundering that made the FRC useless, etc. What am I driving to here? Their QUALIFICATIONS for the job I am hiring them for. This must be applied to all of our contractors, even if the work they are doing may not DIRECTLY cause a PSM incident, but rather it could negatively impact our safety systems we call upon when we have that PSM incident.