HANDBOOK 2022 ISSUE 5 / 2022 MANAGEMENTSAFETYPROCESS
The drive to implement Process Safety Management (PSM) commenced back in 2001 when initial work began to meet the OSHA Inrequirements.2009,we revitalised the PSM Committee with a view to synergise the company systems and to be more compliant with the PSM GPIC’srequirement.Process Safety Management (PSM) programme is designed to integrate and align under one umbrella: our plant related engineering, safety, training, operation and maintenance activities, with a clear objective to minimise process related risks. Through this programme, we strive to ensure protecting our employees, our assets and the local community. This handbook 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 maintain GPIC to be one of the safest plants.
MessagePresident’s
Eng. Yasser Al Abbasi
We at GPIC always strive to establish new systems and strategies to improve our practices in all aspects of our business. Safety has always been at the top of our priorities and goals.
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Committee Message
HANDBOOK MANAGEMENTSAFETYPROCESS2021 4
The Process Safety Management of Highly Hazardous Chemical standard (29CFR1910.119), is intended to prevent or minimise the consequences of the catastrophic releases of toxic, reactive, flammable or explosive chemicals from the adopted processes. These releases may result in toxic, fire or explosion hazards. At GPIC, we have incorporated these requirements into the Integrated Management System in SOP-PSM-00-01. 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
Theenvironment.PSMCommittee’s role is to spearhead the establishment, maintenance, continuous evaluation and enhancement of the PSM programme. This handbook is intended to give all our employees and contractors an overall understanding of the PSM programme and how we comply with OSHA’s requirements within GPIC. All of us play an important role in the successful implementation of the PSM Programme.
TABLE OF CONTENTS PSM ELEMENTS ADMINISTRATORS 6 PSM MAIN OBJECTIVES 7 PSM DEFINITION 8 PSM ELEMENTS 9 EMPLOYEE PARTICIPATION (EP) 10 PROCESS SAFETY INFORMATION (PSI) 12 PROCESS HAZARD ANALYSIS (PHA) 14 OPERATING PROCEDURES (OP) 16 EMPLOYEE TRAINING (ET) 18 CONTRACTORS (CO) 20 PRE-STARTUP SAFETY REVIEW (PSSR) 22 MECHANICAL INTEGRITY (MI) 24 HOT WORK PERMIT (HWP) 26 MANAGEMENT OF CHANGE (MOC) 28 INCIDENT INVESTIGATION (II) 30 EMERGENCY PLANNING AND RESPONSE (EPR) 32 COMPLIANCE AUDIT (CA) 34 PSM KEY PERFORMANCE INDICATORS 36 GPIC PSM Model 37 10121142316789135 5
PSM AdministratorsElements ManufacturingManagerGeneral ChairpersonPSMC PlanningEmergency&ResponseContractorsMechanicalIntegrityOperatingProceduresHotWorkPermitProcessSafetyInformationProcessHazardAnalysisIncidentInvestigationEmployeeParticipationPre-StartupSafetyReviewManagementofChangeComplianceAuditEmployeeTrainingSafety & Workforce,SuperintendentSuperintendentSuperintendentSuperintendentSuperintendentEnvironmentPlanningUreaAmmoniaEngineeringTraining&DevelopmentSuperintendentERM&BusinessExcellenceSuperintendentInspectionSuperintendentPSMCommittee 6
PSM ObjectivesMain 7 Prevent or minimise the consequences of catastrophic release of toxic, reactive, flammable or explosive, Highly Hazardous Chemicals (HHC) from a process. To ensure safe and healthy workplaces and surrounding environment. To integrate all adopted practices, systems and procedures. To improve productivity and help minimise operational expenses.
PSM Definition 8 PROCESS SAFETY Prevention of accidental release of hazardous substances or energy which could result in safety, environmental or business impact. PROCESS MANAGEMENTSAFETY(PSM) A set of formal management practices designed to help prevent, mitigate, respond to or recover from the effects of process plant accidents. WHY DO WE NEED PROCESS SAFETY? To prevent major accidents and reduce consequences of those that do occur To improve employee’s health, safety and work environment To improve equipment and process reliability Plant and Refinery Explosions Take Deadly Toll Across Louisiana and the Rest of the United States
PSM Elements 9 GPIC Process Safety Management has 13 elements: In the following pages, the PSM standard requirements and GPIC’s compliance has been highlighted.
employee
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In order to achieve a high degree of involvement, the element directs organisations to give its employees access to Process Hazards Analysis (PHA) and all its related practices and systems. This includes all types of information concerning the safety of plants and personnel.
Employee Participation (EP)1
Controlling Documents • SOP-PSM-00-01: Process Safety Management of Hazardous Chemicals GPIC Compliance Employees are consulted and are fully involved during the development and implementation of any Process Hazard Analysis (PHA) study. Such involvement is demonstrated through the following methods: • The establishment of PHA teams and committees such as the Safety Committee and SHE Council, Management Union High Council, Management Union Committees, and through regular meetings (departmental, sectional and daily operations meetings). • Incident Reports, Suggestion Improvement Programme, Shift Talks, Knowledge Sharing Database, lessons learned, etc. MANAGEMENTSAFETYPROCESSHANDBOOK2022 11
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Process Safety Information (PSI)2
The element requires that all the Process Safety Information is made available in order to carry out a successful Process Hazard Analysis. This information will help to identify and understand the hazards posed by those processes involving highly hazardous chemicals.
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. These documents are available at six locations (i.e. controlled libraries) within the GPIC Complex. There is also an established system that ensures the control, maintenance and update of all Process Safety Information documents in those libraries. Controlling Documents • SOP-ENG-02-11: Request For Change (RFC) • SI-TEC-01: Material Safety Data Sheet Technical Data Book (TDB Volume 112)/ TDB Volume 112A • SOP-ENG-02-04: Updating Technical Documents • SOP-ENG-01-13: Process Hazard Assessment (PHA) Procedure • SOP-ENG-01-20: Process Safety Information Procedures MANAGEMENTSAFETYPROCESSHANDBOOK2022 13
Process Hazard Analysis (PHA)3 The element requires that a Process Hazard Analysis (PHA) is carried out for all processes handling highly hazardous chemicals. This helps to identify all hazards in the process. All such PHAs are revalidated at least once every five years. 14
GPIC Compliance A Process Hazard Analysis (PHA) for all plants has been completed and documented. The PHA studies were also revalidated in 2021. Furthermore, in GPIC, a PHA review is carried out on each and every change as part of the Management of Change (MOC) cycle. Controlling Documents • SOP-ENG-01-13: Process Hazard Assessment (PHA) Procedure • SOP-GEN-00-28:Management of Change (MOC) HANDBOOK MANAGEMENTSAFETYPROCESS2022 15
Operating Procedures (OP)4 The element requires that there are clear documented operating procedures to safely carry out activities concerning normal startups and shutdowns, emergency shutdowns, operations of a temporary nature, and the handling and exposure to hazardous chemicals, etc. 16
GPIC Compliance GPIC’s existing Standard Operating Procedures and Standing Instructions include: • Normal startups 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 Procedure • SHE-SAF-05: Complex Emergency Procedure • Material Safety Data Sheets (TDB Vol. 112) • Relevant P&IDs • Relevant Vendor Manuals MANAGEMENTSAFETYPROCESSHANDBOOK2022 17
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The element requires each employee operating a process, to be given appropriate training. Thus, each employee is adequately trained before being involved in operating a newly assigned process. Also, refresher training in operating such processes must be provided to the employees periodically. The training provided must also emphasise the specific safety and health hazards.
Employee Training (ET)5
GPIC Compliance A structured training programme is provided to employees (including operators, technicians, supervisors and engineers) prior to the assignment of any new responsibility. A refresher training programme is also in place and designed to update employee knowledge, skills and awareness regarding safety, environment and health hazards. Besides acquiring training on the details of plant configuration, the programme also informs employees of “lessons learned” on process incidents and accidents that have taken place in other similar plants. Furthermore, the training needs of all employees are identified and courses are organised accordingly. Controlling Documents • SOP-TRN-00-01: Training and Development Programme for Graduate Engineers • SOP-TRN-00-03: Cross-Training and Development Procedure for Plant Operators • SOP-TRN-00-11: Operator/Technician Train ing Programme • GL-TRN-00-03: New Employee(s) • SOP-TRN-00-21: Refresher Training for Staff Working in the Process Area MANAGEMENTSAFETYPROCESSHANDBOOK2022 19
process, are well trained
The element requires work work on the process to the in carrying out the known potential related to the work and/or the involved.
hazards
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processes
that contractors performing maintenance, repairs, turnaround activities, major renovation
or adjacent
Contractors (CO)6
intended work and are informed of the
or speciality
GPIC Compliance GPIC’s direct hire and/or lump sum contractors go through a selection process that starts from contractor prequalification assessment, trade testing, rental equipment physical 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 of the hazards during the safety induction training and regular Tool Box Talk. Controlling Documents • SOP-P&W-01-01: Establishing and Managing Approved Suppliers List • SOP-GEN-00-04: Contractor Services Management • FR-P&W-01-14: Contractor / Vendor Performance Evaluation Form • GL-SEC-00-04: Checking of Contractors Equipment • SOP-SEC-00-02: GPIC Complex Access & Egress (Induction to contractors by SHE Department) • FR-GEN-00-09: Checklist Prior to Placement of PO for Service Package Contractors • FR-GEN-00-10: Checklist Prior to Placement of PO for Manpower Supply Services • FR-P&W-01-06: Supplier Pre-qualification Form • FR-MNT-00-11 to FR-MNT-00-21 and FR-MNT-00-25 to FR-MNT-00-28 Typical Trade Test for Various Crafts MANAGEMENTSAFETYPROCESSHANDBOOK2022 21
The element requires that a prestartup safety review is carried out for any new facilities or modifications in the process area. The review confirms if the changes are as per the design and specifications; that the safety, operation, maintenance and emergency procedures are adequate, and that sufficient training has been given to employees with regard to operating the new process or change.
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Pre-Startup
Safety Review (PSSR)7
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 engi neering drawings • Relevant operation, safety and emergency procedures • HAZOP recommendations • Relevant training Controlling Documents • SOP-PSM-00-03: Pre-Startup Safety Review (PSSR) • PSSR Checklists (electronic database on Lotus Notes) MANAGEMENTSAFETYPROCESSHANDBOOK2022 23
Mechanical Integrity (MI)8 The element requires written procedures to be available to maintain: • Pressure vessels, storage tanks, piping systems and pumps. • Relief and venting systems, emergency shutdown systems and controls (such as alarms, trip interlocks, etc.) The standard also requires quality assurance during the fabrication and installation of plant equipment. 24
GPIC Compliance At GPIC, a comprehensive inspection schedule, in line with international standards and the pro cess licensor(s) guidelines, is being followed. A Risk Based Inspection (RBI) technique is also employed to strengthen the inspection programme. The following activities are carried out during •turnarounds:Internalexamination of major equipment. • Checking and testing of safety relief valves, emergency shutdown systems and interlocks. When new equipment is being procured it must be ascertained according to the fabrication, construction and installation specifications laid down in the technical enquiry and is checked that it adheres to the applicable codes and standards. Furthermore, a comprehensive critical equipment list exists at GPIC identifying process equipment that has an impact on safety, health and the environment. Controlling Documents • SOP-PLN-30-05: Preventive Maintenance Management • SOP-PSM-00-02: Mechanical Integrity MANAGEMENTSAFETYPROCESSHANDBOOK2022 25
Hot Work Permit (HWP)9 The element requires a Hot Work Permit to be issued for any hot work operation conducted on or near a process area. 26
GPIC Compliance GPIC’s Permit To Work (PTW) comprehensively covers the Hot Work Permit system. Authorisation to receive or issue a PTW, is only granted to those who pass both a written exam and an interview, where their full understanding of the requirement and the essence of the (PTW) is ascertained. An appraisal is completed every two years to revalidate this authorisation. In addition, GPIC’s PTW procedure is regularly audited and reviewed. Controlling Documents • SHE-SAF-00-07: Permit to Work Procedure MANAGEMENTSAFETYPROCESSHANDBOOK2022 27
Management of Change (MOC)10 The element requires that written procedures are established and implemented to manage changes to processes, chemicals, technology, equipment and procedures that are not “replacement in kind”. Employees or contract employees whose job is affected by the change, should be informed and trained on the changes prior to commissioning and startup. EngineeringPHA&ApprovalScreening Processing&ArchiveRaiseRFC Updating of PSI FAC ImplementationPSSR 28
GPIC Compliance Changes in any of GPIC’s 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 impacts, training and operating procedure changes, are considered before implementing the change. Controlling Documents • SOP-ENG-02-11: Request For Change (RFC) • SOP-GEN-00-28: Management of Change MANAGEMENTSAFETYPROCESSHANDBOOK2022 29
Incident Investigation (II)11
SSSREPORTINCIDENTTO SSSIncidentReviewsSeriousIncident IncidentMinor ReportFinal Executive ManagementPlants InvestigatingManagerOperatingTeamInterimReport 30
The standard further requires that the findings and recommendations arising from the investigation is resolved and documented.
The element requires that each process incident which resulted in or could reasonably have resulted in a catastrophic release of highly hazardous chemicals, is investigated.
GPIC Compliance Process incidents and near misses at GPIC can be reported by any person. Details regarding the incident, the investigation findings, recommendations and subsequent actions, are recorded and saved in the company’s main database. Any “lost time” incidents are investigated by a dedicated team and the recommendations are reported to the Executive Management. Controlling Documents • SHE-SAF-00-13: Accident and Near Miss Reporting • GIMS: GPIC Incident Management System on Lotus Notes MANAGEMENTSAFETYPROCESSHANDBOOK2022 31
Emergency Planning and Response (EPR)12 The element requires that an emergency action plan for the entire complex is available. The plan must also be designed to handle small releases. 32
GPIC Compliance A comprehensive Emergency Response Plan (ERP) is established to cater for any emergencies within the complex. The plan details the emergency warning alarms, control centers, assembly points and the 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 MANAGEMENTSAFETYPROCESSHANDBOOK2022 33
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The element requires to certify that we have evaluated compliance with the provisions of this element at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed.
Compliance Audit (CA)13
The compliance audit shall be conducted by at least one person knowledgeable in the process.
A report of the findings of the audit shall be develped, determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected. The two most recent compliance audit reports shall be
GPIC Compliance There is an established procedure to carry out internal audits of the Process Safety Management System annually. The PSM external audits are carried out once every three years. Controlling Documents • SOP-IMS-00-01: Internal Audit Procedure MANAGEMENTSAFETYPROCESSHANDBOOK2022 35
PSM Key Performance Indicators PSM Elements Key Performance Indicators 1 Employee Participation A. Number of shift/safety talks completed B. Number of operators attending HAZOP studies 2 Process InformationSafety Number of outstanding documents updated (P&IDs, MSDS, ...etc.) 3 Process Hazard Analysis Number of outstanding PHA recommendations 4 Operating Procedures Number of outstanding PSM related procedures pending review 5 Employee Training Number of individuals with overdue refresher training 6 Contractors Number of outstanding “contractor on the job audit” recommendations 7 Pre-Startup Safety Review Number of outstanding PSSR 8 Mechanical Integrity A. Number of overdue inspections B. Number of challenges to automated safety devices such as number of trips 9 Hot Work Permit Number of PTW violations 10 Management of Change Number of outstanding MOCs 11 Incident Investigation Number of outstanding PSM incident recommendations closed out 12 Emergency Planning and Response Number of PSM emergency mock drills carried out 13 Compliance Audit Number of PSM audits carried out 36
GPIC PSM Model MANAGEMENTSAFETYPROCESSHANDBOOK2022 37 LeadershipGPICAchievingOperating Excellence ThroughOperationalDiscipline PersonnelFacilities Technology
MANAGEMENTSAFETYPROCESSHANDBOOK2022
P.O.Box Fax:Tel:KingdomManama26730ofBahrain(+973)17731777(+973)17731047www.gpic.comgpic@gpic.comHANDBOOK2021PROCESSSAFETYMANAGEMENT
