When I was growing up in the profession, PSM was the king standard we lived by. Everything we did revolved around our Process Safety Management System. One thing that I continue to find is facility personnel not assigned to the process and contractors working within the covered process “battery limits” and never knowing what they were working next to or in. Almost a 100% bet I will find someone inside the battery limits that has neither been evaluated to be there or trained to be there and I am referring to BOTH in-house personnel and contractors. Now there is no requirement for what I am about to say, so don’t pull your hair out or waste your time digging through the regulations as it is not in there as a “written requirement”, but this is where a “performance-oriented standard” comes into play. We know that both OSHA and EPA require us to “control access” to our covered process(s). I know the standard(s) says “access to facility”, but let’s be real, getting on the facility carries an entirely different risk profile vs that same person(s) getting into and even adjacent to our covered process(s). We can debate the scope of this requirement in another posting, but today I want to point out the need for SIGNS and LABELS around our “covered process”.
In my early days we installed simple and fashionable chains (the Plant Manager was a neat freak! – Gosh I loved working for Claude!) and on each section of cable/chain hung a sign that read:
DANGER!
Hazardous Process Area “Unit 3 – Name of Unit”
Authorized Personnel ONLY
ALL unassigned personnel MUST obtain permission before crossing barrier
(Call #XXXXX or Channel X)
Area is a CLASS I, Div 1/2, Group D Area
FRC Required
NFPA Diamonds for our bulk HHC/EHS in the unit
Essentially, there was no way you could not know what you were getting ready to enter. This signs-controlled access and ensured those who had permission from the control room to enter knew the hazards they were facing. This was on top of their safety orientation training that covered the signs and the means to getting permission to enter.
Where these signs/barricades were located were also an “engineered decision”. We kept the barricades out at least 20′ from our process equipment, as our HAZLOC boundaries were 15′. So the barricade prevented motorized equipment (e.g. ignition sources) from entering our HAZLOCs. We had a vehicle policy in process areas as it was a “special hot work permit” method to grant vehicle access. Everyone on the plant site that needed access to a process area (even those processes that were not PSM) had to complete the “process access” training annually. Your ID badge would also show the units you had been trained to enter, as each unit may have different hazards (toxic vs. flammables). So, you may be qualified to enter unit 7 where we have Chlorine, but not qualified to enter Unit 3 as that unit uses flammable gas(s). Some people would get oriented on all the units and this would constitute the better part of a day in orientation classes. And I should mention this orientation is ON TOP of the other safety and health training they have received from their manager/employer. In fact, we took this control so serious, there were operators with 25 years experience at the plant working in Units 2, 3, 4 and were “qualified” in all those units, but they could not step foot in Unit 7 battery limits because they were only trained to the HAZCOM level for Chlorine – and that level of chemical safety training did NOT qualify them to work in a unit with a HHC/EHS.
This brings me to my last group of “controlled workers”… the emergency response team. If you were on the ERT, you had to be “qualified” on each unit to enter. This did not qualify you to do operations or maintenance in the unit, but as an ERT member, you HAD TO KNOW the hazards and the safety procedures for those units. The beauty of this level of ownership and control… the trainers for the Unit Orientations were “operators” and “engineers” from that unit with at least 3 years’ experience. They did not want safety doing the training, they wanted to own it to ensure it was “done right”!
But imagine if we did not have the written procedure to cover all of this or the chains/cables with the signs to inform personnel when they needed the training? It would be all for nothing as we would have personnel who have no idea as to the risks they are in (and the risk they present to the process) when they need to know. Ask yourself this… how will my contractors know when they are entering a HAZLOC where now they will require a special permit to perform certain tasks and specialized PPE… just an hour ago they were in a similar-looking unit but all of these permits and procedures were not in place? (e.g. they were in a caustic plant doing work using electric tools and now they are in the LPG plant wanting to run those same drills).
Provide LAYERS of PROTECTION in all your protective measures – especially when we are relying on administrative controls in a PSM/RMP covered process. And it all starts with identifying the “hazardous areas” and marking them properly and then providing the information needed to work safely in those areas.
NOTE TO SELF: Hiring a contractor to work in my LPG plant where FRC is required, I should make sure that contractor has a written PPE Procedure that includes FRC and that their employees have been trained on the care, use, inspection, and limitations of their FRC BEFORE I approve that contractor to work on my site, much less in the LPG unit. Then all I will do is orientate them on our FRC requirements, which they should have no problems complying with as their procedure and training are adequate to meet my safety needs.