Minnesota Brewing Company - Executive Summary |
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Purpose The purpose of this policy is to establish the procedures and methods used by Minnesota Brewing Co. (MBC) to systematically evaluate processes in order to prevent or minimize the consequences of unwanted releases of highly hazardous materials, and to comply with OSHA Standard 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals, hereafter referred to as the PSM Standard. Scope This policy covers processes at Minnesota Brewing Co. involving highly hazardous chemicals, flammable liquids, gases, or explosives in quantities at or above the amount specified in paragraph (a) of the PSM Standard. Process Ammonia refrigeration system Chemical(s) used Ammonia Max. Intended Quantity 17,000 lbs General hazards Toxic, corrosive, cryogenic (cold) This process does not involve trade secret information. Individual Process Documentation Each process covered by this policy shall have a binder or file that shall contain the following: 1. Process Safet y Information (exception: P&ID's can be substituted with a note giving their exact location) 2. List of Process Hazard Analysis Team members 3. Process Hazard Analysis 4. Current Operating and Maintenance Procedures related to the process 5. Current Mechanical Integrity Procedure 6. Copies of each Management of Change (even those not approved) 7. Copies of each Pre-Startup Safety Review 8. Copies of each Process Incident Investigation Process Safety Information Process Safety Information shall include as a minimum: 1. Material Safety Data Sheet (MSDS) for each highly hazardous chemical used or produced by the process. When an MSDS is not available, see paragraph (d) of the PSM Standard. 2. Information pertaining to the technology of the process: 7 Block Flow Diagram or Simplified Process Flow Diagram 7 Process chemistry 7 Maximum intended inventory 7 Safe upper and lower limits for such items as temperature, pressure, flow, or composition 7 Evaluation of the consequences of dev iations 3. Information pertaining to the equipment in the process: 7 Materials of construction 7 Piping and instrument diagrams (P&ID's) 7 Electrical classification 7 Relief system design and design basis 7 Ventilation system design 7 Design codes and standards employed 7 Material and energy balances (for new processes) 7 Safety systems (e.g. interlocks, detection or suppression systems) 7 Documentation that the equipment complies with recognized and generally accepted good engineering practices Process Hazard Analysis All Process Safety Information required above must be compete before a Process Hazard Analysis can begin. Process Hazard Analyses shall be conducted by a team of at least three individuals, including members with the following qualifications: 7 At least one team member shall have expertise in engineering and process operations. 7 At least one team member shall have knowledge and experience with the process being analyzed. 7 At least one member shall be knowledgeable in the specific process hazard analysis methodology being used. 7 An employee who works or will work on the process being analyzed may be a team member. Process Hazard Analyses shall be conducted using a recognized methodology in accordance with paragraph (e)(2) of the PSM Standard. Process Hazard Analyses shall address: 1. The hazards of the process; 2. The identification of any previous incident which had a likely potential for catastrophic consequences; 3. Engineering and administrative controls applicable to the hazards their interrelationships; 4. Consequences of failure of engineering and administrative controls; 5. Facility siting; 6. Offsite consequence analysis; and 7. Human factors. The Process Hazard Analysis team shall make recommendations based on the findings of the analysis. These recommendations shall be submitted on a Management of Change Form. Each Process Hazard Analysis shall be updated and revalidated by a Process Hazard Analysis Team at least every five yea rs. The initial analysis and all subsequent updates or revalidations shall be retained for the life of the process. Employee Participation Employees shall be informed of the: 1. OSHA PSM rule and its contents; 2. Processes located on the premises; 3. Identity of the hazardous chemical(s) used in the processes and their hazards; and 4. Location and availability of the individual process documentation as described above. Employees and their representatives shall have access to individual process information In accordance with Policy #3 in the MBC Safety Program, Duties and Responsibilities, employees are encouraged to bring safety concerns or suggest safety improvements to their supervisor. An employee who works or will work in the process being analyzed may be asked to be a member of the Process Hazard Analysis Team. At least one affected employee shall be consulted during the development of operating or maintenance work procedures applicable to their job duties to insure that procedures reflect what is actually done or should be done. Pre-Startup Safety Review The Pre-Startup Safety Review is a redundant follow-up that provides for an independent recheck to insure that new or modified processes and procedures are in proper condition to begin operation. The Operations Manager shall perform a Pre-Startup Safety Review: 7 for new processes; or 7 for modified existing processes whenever a Management of Change form is required. This review shall be documented on the Pre-Startup Safety Review form The Operations Manager may consult other personnel, contractors, or seek outside expertise as necessary to confidently complete the Pre-Startup Safety Review. Management of Change A Management of Change form must be completed whenever changes are made in processes covered by the PSM Standard that involves any of the following: ( Changes in process technology such as: 7 Raw materials 7 Process chemistry 7 Process control systems 7 Equipment design 7 Piping and equipment specifications ( Addition or removal of process equipment or piping ( Changes in process parameters such as: 7 Temperature 7 Pressure 7 Flow 7 Composition 7 Capacity ( Changes in utilities ( Changes in facilities ( Any change significant enough to require a change in Process Safety Information This form does not need to be completed for a "replacement in kind", such as replacing a part with identical design specifications. Identical design specifications means that the replacement part has the same materials of construction, temperature and pressure ratings, diameter, capacity, maintenance requirements, and operates the same way as the original part. Replacement in kind does not apply to pressure vessels, relief systems and devices, emergency shutdown systems, sensors, alarms, interlocks, or pumps; and a Management of Change form needs to be completed each time one of these items is added, removed, or replaced. The definitive Management of Change form will be kept in the Individual Process Documentation, regardless of status. This form will be updated as progress warrants. For all changes affecting the ammonia refrigeration system, Management of Change and Evaluation of Process Safety Components to be Reviewed/Updated forms shall be approved by the Facilities Engineering Manager. For all changes affecting the ethanol process, Management of Change and Evaluation of Process Safety Components to be Reviewed/Updated forms shall be approved by the Senior Supervisor for the ethanol process. Operating, Maintenance, and Safe Work Procedures Operating procedures should be consistent with the process safety information and should address the following elements: 1. Steps for each operating phase, including: 7 Initial startup; 7 Normal operations; 7 Temporary operations; 7 Emergency shutdown, including who is responsible for emergency shutdown and the conditions under which emergency shutdown is required; 7 Emergency Operations; 7 Normal shutdown; and 7 Sta rtup following a turnaround, or after an emergency shutdown. 2. Operating limits including: 7 Consequences of deviating outside of operating limits; and 7 Steps required to correct or avoid deviation. 3. Safety and Health considerations, including: 7 Properties of and hazards presented by the chemicals used in the process; 7 Precautions necessary to prevent exposure; 7 Measures to be taken if contact or exposure occurs; 7 Quality control for raw materials and hazardous chemical inventory levels; and 7 Any special or unique hazards. 4. Safety systems and their functions. Operating procedures shall be readily accessible to employees who work in or maintain a process. Operating and maintenance procedures shall be updated as changes are implemented in the process. In addition, these procedures shall be reviewed at least annually, and certified that they are complete, current, and accurate. Safe work procedures such as Welding/Cutting/Grinding/Hot Work, Lockout/Tagout, Confined Space En try, Pipeline Breaking procedures, etc. are found in MBC's Safety & Health Program Manual. Training Each employee involved in operating a process shall receive initial training before assuming his or her job duties. Initial training shall include an overview of the process and in operating procedures as specified in the section on Operating, Maintenance, and Safe Work Procedures above. Emphasis will be given to specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks. Maintenance employees shall receive initial training to include an overview of the process and on the Operating, Maintenance, and Safe Work Procedures applicable to the employee's tasks. Refresher training shall be provided at least every three years. Additional training shall be provided whenever procedures are added, updated, or changed. Initial and refresher training shall be documented to record the identity of the employee, the training received, date of training, instructor, and {verification of understanding - quiz, test, etc.} Training records shall be maintained {location training records maintained}. Contractor Requirements Contractor requirements are found in "Safety Requirements for Contractors", Policy #12, located in MBC's Safety & Health Program Manual Incident Investigation Incidents involving equipment failure, control failure, or moderate to large ammonia leaks shall be investigated by an assembled team, as soon as possible, but not more than 48 hours after the incident. The team will include at least three persons with appropriate knowledge and expertise to thoroughly investigate and analyze the incident. At least one of the team members shall be knowledgeable in the process involved. If the incident involved work of a contractor, a contract employee shall also be included. The investigation shall be documented using the Process Incident Investigation form. Recommendations resulting from the incident investigation shall be submitted on a Management of Change form. The Process Incident Investigation form and resulting Management of Change form(s) shall be reviewed with all affected employees, including affected contract employees. Compliance Audit Procedure 1. Determine changes in the PSM Standard that have occurred since the last audit. This can be accomplished by reviewing the Federal Register excerpts on the OSHA website - http://www.osha.gov 2. Update this policy to comply with changes. 3. Perform an audit to determine MBC's compliance. An excellent way to accomplish this is to obtain a current copy of OSHA Directive Number: CPL 2-2.45A, Process Safety Management of Highly Hazardous Chemicals-Compliance Guidelines and Enforcement Procedures, also available on the OSHA website. 4. Review Incident Reports, Management of Change forms, and Pre-Startup Safety Reviews. Make sure all recommendations have been resolved. Make sure that all changes have been i ncorporated into the Process Safety Information. 5. Review Process Safety Information for each process to insure that it is complete, accurate, and up to date. In addition to the Compliance Audit, Operating and Maintenance Procedures shall be reviewed at least annually, and Process Hazard Analyses shall be revalidated at least |