One of the challenges to my post was “What if the flagging tape was to indicate that the valve was in an abnormal position?”
This was followed up with a challenge as to whether or not anything forbids such a method. Operating procedures should be designed to meet the requirements of IIAR Standard 7. In short, the only time valves would be manipulated to an abnormal position would likely be for “manual shutdown and isolation.” Once you change a valve position, now you have entered into a different section of the operating procedure. Now, back in 1910.119 (PSM), (f)(1) states “The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address the following…” OSHA later goes on to say “The employer shall develop and implement safe work practices to provide for the control of hazards during operations such as LOTO”… and so on, followed by “shall apply to employees and contract employees.” This means that both the operation and written mechanical integrity procedures apply to both operators as well as contractors.
Now, let’s fast forward to your PHA and assume you’re using the “what-if” combined checklist where you’ll likely find a question that says something like “What if the discharge valve is closed while starting the compressor?” You had to list safeguards that would minimize or eliminate the associated hazard identified here. Those might sound something like (well-written operating procedures, trained operators, well-qualified contractors, a pressure transducer to shut the machine down on high discharge pressure, and relief valves). But I would bet good money that at no point in the PHA did anyone say “That’ll never happen because we stick flagging tape or a red shop rag in the discharge valve so we’ll see it before we start the compressor.”
If only we had a method, or checklist to help us so that this never happens. Oh wait, we do. It’s called using the operating procedure to verify valve positions before you start the compressor, and if the compressor just underwent some form of maintenance or rebuild, you perform the Pre-Startup Safety Review. Now those are safeguards you can hang your hat on, assuming they’re not just documents in a binder on a shelf covered in dust. But doesn’t that point back to a larger, systemic problem, of not owning or following the PSM program? But hey, service techs are invincible from mistakes, so we don’t need those, right? If that’s the case, why does every company out there require a Million-dollar aggregate insurance policy before the contractor can do this work? Because they are human, and PSM still has a long way to go. Proof of that is near daily notices of ammonia releases or leaks which is what is driving me to write these articles.
We can do better.