PSM

30

Years of Excellence

PROCESS SAFETY MANAGEMENT The booklet

March 2010

General Manager's Message PSM

Safety Beyond Excellence We in GPIC always strive to establish new systems and strategies to improve our practices in all aspects of our business. Safety has always been on top of our priorities and goals. The drive to implement Process Safety Management (PSM) relates back to 2001 when the initial work began to meet the OSHA requirements.

In 2009, we revitalized the PSM Committee with a view to synergize the company systems to be more compliant with the PSM requirement.

GPIC’s Process Safety Management (PSM) program is designed to integrate and align under one umbrella, our plants related Engineering, Safety, Operation and Maintenance activities, with a clear objective to minimize process related risks.

Through this program, we intend to achieve the main goal of fulfilling

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our obligation to protect our employees, assets and the local community.

This booklet outlines the PSM requirements and describes GPIC’s approach to achieving those needs. We believe that only through the continuous support and dedication of our employees at every level we make GPIC one of the safest plants.

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Table of Contents GM MESSAGE PSM COMMITTEE MESSAGE PSM ELEMENT ADMINISTRATORS PSM MAIN OBJECTIVES DEFINITION PSM ELEMENTS EMPLOYEE PARTICIPATION (EP) PROCESS SAFETY INFORMATION (PSI) PROCESS HAZARD ANALYSIS (PHA) OPERATING PROCEDURES (OP) EMPLOYEE TRAINING (ET) CONTRACTORS (CO) PRE-STARTUP SAFETY REVIEW (PSSR) MECHANICAL INTEGRITY (MI) HOTWORK PERMIT (HWP) MANAGEMENT OF CHANGE (MOC) INCIDENT INVESTIGATION (II) EMERGENCY PLANNING AND RESPONSE (EPR) COMPLIANCE AUDITS (CA)

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PSM

Committee Message The Process Safety Management (PSM) of Highly Hazardous Chemicals, OSHA Standard 29CFR1910.119, is intended to prevent or minimize the consequences of the release of toxic, reactive, flammable or explosive chemicals from the adopted processes. At GPIC, we have incorporated these requirements into the Integrated Management System and decided to extend the scope of PSM to cover all process related hazards.

The PSM Committee’s role is to spearhead the establishment, maintenance, continuous evaluation and enhancement of the PSM program. In 2010, we will further enhance the program by introducing Risk Based Process Safety (RBPS).

The PSM system facilitates the elimination of process incidents that could potentially occur as a result of failures in systems, procedures or equipment in process plants. It is a major step forward towards a safer working environment.

All of us play an important role in the success of the PSM program implementation.

This booklet is intended to give all our employees an overall understanding of the PSM program and how we comply the OSHA’s requirements within GPIC.

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Fire & Safety Suptd.

Mechanical Suptd.

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PSM

Main Objectives Prevent or minimize the consequences of catastrophic release of toxic, reactive, flammable or explosive, Highly Hazardous Chemicals (HHC’s) from a process.

To ensure safe and Healthy workplaces and surrounding environment.  To integrate all adopted practices, system and procedures.  To improve productivity and help in minimizing operation expenses. 

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Definition – preventing of accidental releases of hazardous substances or energy which create safety, environmental or business impact.

Process Safety

Process Safety Management (PSM) –

a set of formal management practices designed to help prevent, mitigate, respond to or recover from the effects of process plants accidents.

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Why do we need Process Safety?

Prevent major accidents and reduce the consequences of those that do occur

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Improve employee’s health, safety and work environment

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Improve equipment and process reliability

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Reduce production costs

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PSM Elements Hot Work Permit

gpic Process Safety Management has 13 Elements:

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Management of Change

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Incident Investigation

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Employee Participation

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Emergency Planning and Response

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Process Safety Information

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Process Hazard Analysis

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Compliance Audits

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Operating Procedures

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In the following pages, the PSM standard requirements and the GPIC compliance are highlighted.

Employee Training

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Contractors

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Pre-Start up Safety Review

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Mechanical Integrity

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1 Employee Participation (EP) In order to achieve a high degree of “Employee� involvement, the element directs organizations to give its employees access to Process Hazards Analysis and all its related practices and systems.

This includes all types of information concerning safety of plants and personnel.

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GPIC Compliance Employees are consulted and are fully involved during the development and implementation of any Process Hazard Analysis study. Such involvement is demonstrated through the following methods: • The establishment of PHA teams, committees like the SHE committee, Management Union High Council, Management Union Committees, regular meetings (Departmental, Sectional and Daily Operations).

• Incident Reports, Suggestion Improvement Program, Shift Talks, etc.

Controlling Documents  SOP-PSM-00-01, Process Safety Management of Hazardous Chemicals  PSM Electronic Database

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2 ProcessSafety Information (PSI) The element requires that all the Process Safety Information shall be made available in order to carry out a successful Process Hazard Analysis. This information shall ď Ž help in identifying and understanding the hazards posed by those processes involving highly hazardous chemicals.

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GPIC Compliance Information related to Material Safety Data Sheet (MSDS) of chemicals, codes and standards used, equipment details, Process & Instrumentation Diagrams (P&IDs) and Process Flow Diagrams (PFDs) is captured through the Technical Data Books (TDB), Maintenance Data Books (MDB), Operation Manuals and Basic Engineering Documents. The documents are available at six locations (i.e. controlled libraries) within GPIC Complex. There is an established system that ensures controlling, maintaining and updating of all Process Safety Information documents in those libraries.

Controlling Documents  SOP-ENG-02-11, Management of Change (MOC)  SI-TEC-01, Material Safety Data Sheet Technical Data Book (TDB Volume 112)  SOP-ENG-02-04, Updating Technical Documents  SOP-ENG-01-13 Process Hazard Assessment (PHA) Procedure

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3 ProcessHazard Analysis (PHA) The element requires that Process Hazard Analysis (PHA) should be carried out for all the processes handling Highly Hazardous Chemicals. This shall help in identifying the hazards in the process. All such PHAs should be revalidated at least once every five years.

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GPIC Compliance Process Hazard Analysis (PHA) for all the plants has been completed and documented. The PHA studies have been revalidated in year 2009. The next revalidation of all the plants is scheduled to be after 5 years.

Furthermore, in GPIC, process hazard analysis review is carried out on each and every change during the Management of Change (MOC) cycle.

Controlling Documents ď Ž SOP-ENG-01-13, Process Hazard Assessment (PHA) Procedure ď Ž SOP-ENG-02-11, Management of Change (MOC)

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4 Operating Procedures (OP) The element requires that there should be clear documented operating procedures to safely carry out activities concerning normal start-ups and shutdowns, emergency shutdowns, operations of temporary nature, handling and exposure to hazardous chemicals, etc.

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GPIC Compliance GPIC’s existing Standard Operating Procedures and Standing Instructions include: • Normal start ups and shutdowns • Emergency shutdowns considering various scenarios and plant upsets.

• Simplified trip logic diagrams, catalyst manual Controlling Documents  Standard operating procedures (Plant SOPs)  Standing Instructions (Plant SIs)  Plant Trip Logic Diagrams  SHE-SAF-07, Permit to Work System  SHE-SAF-05, Complex Emergency  Material Safety Data Sheets (TDB Vol. 112)  Relevant P&IDs  Relevant Vendor Manuals

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5 Employee Training (ET) The element requires that each employee operating a process is imparted the relevant training. Thus, each employee before being involved in operating a newly assigned process requires to be adequately trained. Also, refresher training in operating such processes needs to be provided to the employees periodically.

The training shall emphasise on the specific safety and health hazards.

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GPIC Compliance A structured training program is provided to employees (including operators, technicians, supervisors and engineers) prior to the assignment of any new responsibility. Refresher training program is also put in place and is designed to update the knowledge, skills and awareness of safety, environment and health hazards.

Besides acquiring training on the details of plant configuration, the program also aims at updating the employees with “lessons learned” on the process incidents and accidents that have taken place in other similar plants. Further, training needs of all employees are identified and courses are organized accordingly.

Controlling Documents  SOP-TRN-00-01, Training and Development Program for Graduate Supervisors & Engineers  SOP-TRN-00-03, Cross Training & Development Procedure for Plant Operators  SOP-TRN-00-11, New Operators Training Program  SI-TRN-00-08, New Employee(s)

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6 Contractors (CO) The element requires that contractors performing maintenance, repair, turnaround, major renovation work or specialty work on the process or adjacent to the process shall be well trained in carrying out the intended work and shall be informed about the known potential hazards related to the work and/or the process involved.

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GPIC Compliance GPIC's direct hire and /or lump sum contractors go through a selection process that starts from contractor prequalification assessment, trade testing, equipment verification, safety induction training, on the job assessment, weekly contractor safety meetings and post service evaluation.

Contractors performing maintenance within the process areas are apprised about the hazards during Safety induction training.

Controlling Documents  FR-PLN-70-02, Contractor Prequalification Requirements  SOP-PLN-70-01, Contracator Services Management  FR-MTR-01-09, Contractor / Vendor Performance Evaluation Form  GL-S&S-01-08, Safety Checking of Contractors Equipment  SOP-S&S-02-02, GPIC Complex Access & Egress (Induction to contractors by SHE Department)  FR-PLN-70-10, Technical Evaluation- Manpower Supply Services.  FR-PLN-70-09, Technical Evaluation- Package Contract Services.  FR-MTR-01-13, Supplier Pre-qualification Form.

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7 Pre-Startup Safety Review (PSSR) The element requires that a pre-startup safety review to be carried out for new facilities and modifications in the process area.

The review shall confirm that the changes are as per the design and specifications, that the safety, operating, maintenance and emergency procedures are adequate, and that sufficient training has been given to the employees for operating the new process or change.

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GPIC Compliance A formal Standard Operating Procedure has been put in place to ensure that any newly installed facility or modification, before being commissioned, has been executed as per: • Relevant design codes, specifications, and engineering drawings • Relevant operating, safety and emergency procedures • HAZOP recommendations • Relevant training Controlling Documents  SOP-OPR-01, Pre Startup Safety Review (PSSR) Procedure  FR-PSM-01 to 10, PSSR Checklists

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8 Mechanical Integrity (MI) The element requires that written procedures should be available to maintain: • Pressure vessels, storage tanks, piping systems, pumps. • Relief and venting systems, emergency shutdown systems, and controls (like alarms, trip interlocks, etc.)

The standard also, requires quality assurance during the fabrication and installation of plant equipment.

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GPIC Compliance At GPIC, a comprehensive inspection schedule in line with the process licensor(s) guidelines is being followed. A Risk Based Inspection technique is also employed to strengthen the inspection program.

Furthermore, the following activities are carried out during turnarounds: • Internal examination of major equipment.

• Safety Relief valves, emergency shutdown systems and interlocks are checked and tested.

When new equipment is being procured it is ascertained that the fabrication, construction and installation is as per the specifications laid down in the technical enquiry and it adheres to the applicable codes and standards.

Furthermore, a comprehensive critical equipment list has been developed at GPIC identifying process equipment which have impact on production, safety, health and environment.

Controlling Documents  SOP-PLN-30-05, Preventive Maintenance Management  SOP-MCH-01-42, Mechanical Integrity  SOP-ISP-00-14, Risk Based Inspection (RBI)  Critical Equipment List

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9 HotWork Permit (HWP) The element requires that a hot work permit is to be issued for any hot work operation conducted on or near a process area.

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GPIC Compliance GPIC Permit To Work (PTW) comprehensively covers the hot work permit system. Authorization to receive or issue permit to work is only granted to those who pass both a written exam and an interview to ensure that they fully understand the requirement and the essence of the (PTW). Appraisal is done every two years to revalidate this authorization. GPIC PTW procedure is regularly audited and reviewed.

Controlling Documents ď Ž SHE-SAF-07, Permit to Work System

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10 Management of Change (MOC) The element requires that written procedures should be established and implemented to manage changes to process, chemicals, technology, equipment and procedures that are not “Replacement in kind�.

Employees or contract employees whose job will be affected by the change should be informed and trained about the change prior to its commissioning and start-up.

PHA

Raise RFC

Archive

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Screening & Processing

Updating of PSI

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Engineering & Approval

FAC

Implementation

PSSR

GPIC Compliance Changes in any of GPIC facilities, including process related changes, are covered under the Management of Change (MOC) Procedure. The Management of Change system ensures that all requirements; such as HAZOP, environmental impact, training, and operating procedure changes are considered before implementing the change.

Controlling Documents ď Ž SOP-ENG-02-11, Management of Change (MOC)

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11 Incident Investigation (II) The element requires that each process incident which resulted in, or could reasonably have resulted in catastrophic release of highly hazardous chemicals should be investigated.

The standard further requires that the findings and recommendations arising from the investigation should be resolved and documented.

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GPIC Compliance Process Incident and near misses in GPIC can be reported by any person. The incident, investigation findings, recommendations and actions are recorded and saved in the company’s main database. The investigations of any “lost time” incidents are investigated by a dedicated team and the recommendations are reported to the Executive Management.

Controlling Documents  SHE-SAF-13, Accident and Near Miss Reporting  Lotus Notes, Plant Operations Incident Databank (derived from SHE-SAF-13)  SOP-OPR-02, GPIC Plant Operation Incident Data Bank

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12 EmergencyPlanning

and Response (EPR)

The element requires that an emergency action plan for the entire complex be available. The plan should be designed to handle small releases also.

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GPIC Compliance A comprehensive emergency response plan is established to cater to any emergencies within the Complex. The plan details the emergency warning alarms, control centers, assembly points, and job roles of the personnel during emergencies. The plan is reviewed and tested periodically.

Controlling Documents  SHE-SAF-05, Complex Emergency Procedure  SHE-SAF-06, Generic Emergency Procedure  SHE-SAF-08, GPIC Emergency Planning Guide Procedure  Mock drills procedure (part of SHE-SAF-08)

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13 Compliance Audits (CA) The element requires that the Process Safety Management (PSM) processes are evaluated through a compliance audit by at least one person knowledgeable in the process once every three years. The standard also requires that an appropriate response to each of the findings is reported and that all the deficiencies are corrected.

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GPIC Compliance There is an established procedure to carryout internal audits of Process Safety Management system as part of the internal audits of Integrated Management Systems in GPIC. External audits shall be carried out once every three years.

Controlling Documents ď Ž SOP-IMS-00-01, Internal Audit Procedure

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