Burris Refrigerated Logistics, Chesapeake, Va. - Executive Summary |
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EMERGENCY PLANNING AND RESPONSE PURPOSE: The Plant Emergency Organization (PEO) addresses all emergency situations. Incorporated within the PEO are provisions determining who will respond to spills or planned small releases of ammonia and how they are trained, equipped to respond, and how plant personal shall be protected. Process Hazzard Analysis: To ensure a controlled and safe workplace by identifying hazards. This type of analysis applies to and is required for every hazardous (toxic & reactive) chemical listed in section 1910.119. Process Hazard Analysis (PHA) includes, but is not limited to the following items: 1. The hazards of each process; both chemical and mechanical hazards should be noted. 2. Identification/examples of previous incidents which did, or could have become, catastrophic. 3. The used or site available chemical detection methods. 4. Consequences of loss of system/process control. Factors causing loss of control include both operator and mechanical error/malfunction. REQUIREMENTS: I. Employer shall perform an initial PHA on all ammonia equipment. PHA's shall be done as soon as possible and in order of relative danger to personnel and equipment that a failure would cause. II. The employer shall use one or more generally accepted methodologies to evaluate the process hazards: What If/Checklist, Hazard and Operability Study (HAZOP), Failure Mode and Effects Analysis (FMEA), Fault Tree Analysis, or other appropriate equivalent methodology. III. The PHA shall address: A. Hazards of the process. B. Identification of any previous incident which did or had a likely potential for causing catastrophic consequences in the workplace. C. Engineering and administrative controls applicable to the process (controls, alarms, detection equipment, etc.) D. Consequences of failure. E. Facility siting. F. Human factors. G. Qualit ative evaluation of the range of safety and health effects of failure of controls. IV. PHA shall be performed by a team with expertise in engineering and process operating and the PHA methodology being used. V. The employer shall promptly address the team's findings and recommendations and document actions taken or scheduled to be completed. The employer shall communicate any changes to all affected employees and update any relevant information (operating procedures, training, etc., refer to Management of Change section). VI. Review and update PHA for the entire system on a regular basis. VII. Retain PHA information and updates along with all supporting documentation for the life of the process. PROCESS HAZARD ANALYSIS Content of Hazard Analysis A process hazard analysis comprises three parts: 1) preparation (Operating Procedures, P & ID's, PSI, etc.), 2) conducting the hazard analysis (PHA Worksheet), and 3) follow-up actions resulting from the hazard analysis (PH A Action Items). The preparatory phase for a process hazard analysis requires the gathering of date, drawings, procedures and formation of a team. Typically, each of the acceptable methods will require up-to-date process flow diagrams, piping and instrumentation drawings, and data regarding process materials and conditions. Certain hazard analysis techniques may require additional, more detailed materials. The hazard analysis is conducted with the clear goal of identifying potential hazards. Recommendations may be made with the intent of reducing or eliminating a potential hazard . Items of concern also may be identified for further, more detailed study. The follow-up phase involves evaluating the proposed recommendations to determine the appropriate course of action. the action taken may include: 17accepting and implementing the recommendations as made; 27accepting the recommendations in principle but developing an alternative approach to meet the intent; or 37accepting the current situation and not implementing the recommendation. The current situation may be the course of action taken if there appears to be no technically feasible solution for the situation identified, if any recommendation considered would pose additional, more serious hazards, or if it is determined that the reduction in risk is not significant enough to justify implementing any recommendation. Implementing engineering and/or administrative controls may be used to reduce the risk of hazard. Further study may be required to determine if certain hazards identified are indeed significant to exposed workplace employees. This further study initially may require a more detailed hazard analysis, possibly with a different technique from the group of approved methods, followed by a consequence analysis that will more precisely evaluate the consequences of the potential hazards. The type of consequence analysis required will depend upon the identified potential hazards. For example, haza rd involving fires may require evaluation of thermal radiation effects, where toxic release may require the use of vapor dispersion models along with toxicology effect models. The follow-up phase of a process hazard analysis is often an iterative process whereby the hazard analysis and/or consequence evaluations are redone as required to ensure that potential hazards are minimized. PROCESS HAZARD ANALYSIS Analysis Findings After a study has been conducted, the findings and recommendations of the study must be addressed. For this to be done systematically, a system should be established that covers the following: 17ensures that each recommendation is resolved in a timely manner and that the resolution is documented; 27documents the proposed remedial measures or actions undertaken with respect to their recommendations; 37completes actions as soon as possible; 47develops a written schedule of when these actions are to be co mpleted; and 57informs operating, maintenance and other employees who may be effected by the identified potential hazards and the recommendations and/or actions taken. Recommendations often are made in a hazard that require more detailed evaluation. Additional engineering or procedural review may determine that the recommendations are not feasible, are not desirable, or that other, more appropriate changes should be made. Such determinations do not invalidate the study, but must be weighed carefully in light of the identified potential hazard. All decisions regarding recommendation, and whether to implement them, should be fully documented. Such documentation should include the decision, reasons for the decision, planned implementation and final completion dates. Unnecessary questions of liability may arise if an incident occurs regarding a recommendation that was not implemented, without proper review and documentation to justify the decision. OSHA has said that when respondin g to the team's findings and recommendations, the employer retains the flexibility to not only reject proposals that are erroneous or infeasible, but also to modify a recommendation that may not be as protective as possible or may be no more protective than a less complex or expensive measure. OSHA's position is that an employer is required to implement the team's findings and recommendations except to the extent an employer can document that an alternative will be at least as effective or efficient in addressing the safety concerns. Once action has been taken based upon the recommendations, resulting in either process modifications, new or revised procedures, or both, employees who work in the facility should be properly informed of these changes. This communication may be handled as part of the standard's requirements for refresher training. Once proposed, evaluated and determined appropriate, recommendations should be implemented in a timely fashion. Recommendations that can be implemented without major shutdowns of the process should be done at the earliest opportunity. Recommendations that require a facility shutdown may need to wait until the next scheduled process turnaround. In establishing a schedule for implementation, consideration should be given to the likelihood and severity of the potential hazard. Recommendations associated with high likelihood and/or severity scenarios should be given a higher priority than recommendations associated with less hazardous scenarios. |