Posted on: November 30, 2010 Posted by: Diane Swarts Comments: 0

A process risk assessment checklist of 100 points, is promoted in the USA by ETC Compliance Solutions. Rate your site’s process safety management.

Find relevant evidence to justify ‘Yes’, ‘No’, or ‘N/A” (not applicable) to each sub-question, then tally the number of justified ‘Yes’ responses to obtain a percentage score.

Use the outcome of the checklist in health and safety meetings, to focus on the sub-headings where ‘Yes’ responses are outnumbered by ‘No’ responses.

Compare the outcome to internal and external audit outcomes, and try to explain any significant differences. Also compare the outcome to the current site risk assessment, and consider adjusting either document to closer reflect workplace health and safety conditions, systems, or procedures.

The number of questions devoted to each sub-heading or subject, should reflect the site risk assessment and risk ranking.

Repeat the checklist at intervals of three months to check whether improvements are made, or set specific evidence criteria.

The checklist may be modified to reflect relevant plant risks, or for non process sites, by replacing generic chemicals and process risks, with your relevant risks.

== Management commitment to a health and safety program; Yes No N/A

1. Is there evidence that an effective process safety management program has been set up and that explicit expectations, objectives and goals have been set with clear, desired outputs?

2. Have resources been provided in the form of personnel assigned to provide implementation and continuation of each element?

3. Have clear lines of responsibility been established and roles and responsibilities assigned?

4. Is management’s commitment to using all available resources for enhancing process safety knowledge at all levels of the organization clearly demonstrated by actions?

5. Does management encourage active participation in professional and trade associations for key PSM personnel to ensure the PSM system keeps pace with best practice?

== Employee participation; Yes No N/A

6. Does a written program exist regarding employee participation in all aspects of the facility’s PSM program?

7. Does the written program specifically include consultation with employees and their representatives on the conduct and development of process hazard analyses and on the development of other elements in the PSM rule?

8. Does the written program provide employees, including contractor employees and their representatives access to process hazard analyses and all other information developed as required by the PSM rule?

== Process Safety Information; Yes No N/A

9. Have all relevant chemicals, products, and intermediate products been identified and documented?

10. Has written PSI such as piping and instrumentation drawing, process flow drawings, operating procedures, MSDSs, equipment design specs, etc. been compiled before conducting any process hazard analysis?

11. Has responsibility for maintaining process safety documentation up to date been assigned?

12. Has a mechanism for keeping track of copies of documentation been developed and is there evidence that it works?

13. Does a review process of changes to process documentation exists?

14. Does the PSI program include the maintenance of plant experience records and for establishing ‘company memory’?

15. Is there clear documentation that indicates which codes, standards and guidelines are to be followed, and does everyone involved in design and maintenance clearly know which guidelines apply?

== Pre-startup safety reviews; Yes No N/A

16. Has a comprehensive and systematic capital project review procedure been developed and implemented for new facilities and for modifications to existing ones?

17. Is the capital projects review procedure designed to interact with a project from its inception through its completion in its five traditional phases: Conceptual Engineering, Basic Engineering, Detail Design, Equipment Procurement and Construction, and
Commissioning Prior to Startup?

18. Does the PSM program safeguard that “Fast track” projects are not allowed to short-cut pre-startup safety review procedures?

19. Does the PSM program assure that the initial scope and cost estimate of a project reflects process safety requirements?

20. Does the PSM system have a procedure to initiate pre-startup safety reviews, define responsibility for their execution, and provide a mechanism for problem resolution?

21. Are PHA reviews conducted in accordance with the process hazard analysis element of the PSM program for all new facilities or modified processes as part of the pre-startup safety review process?

22. Does the pre-startup safety review procedure establish that a running checklist of hazard review recommendations, follow-up items and a mechanism for assuring all recommendations are satisfied prior to startup is in place?

== Process Hazard Analysis; Yes No N/A

23. Does the PSM program establish a process hazard analysis procedure in accordance with the PSM rule?

24. Have personnel, who will take part in PHA’s, been provided with training in the PHA technique that will be used for their study?

25. Does the PHA procedure establish that the hazard identification team be multi-disciplined in nature, capable of covering such issues as maintenance, operations, design, inspection & testing, safety, health and environment, etc?

26. Does the PHA procedure require that the PHA team leader be specially trained in the technique that will be used?

27. Does documentation of the hazard identification process include all issues, not only those resulting in findings or recommendations?

28. Have PHA’s been conducted on all PSM-covered processes and if not, is there an established schedule for completing all PHA’s?

29. Do the PHA’s address special subjects such as “facility siting,” “human factors,” and provide qualitative consequence analysis and a risk ranking?

30. Does the PHA procedure provide a protocol for assuring that findings and recommendations are studied and satisfied on a timely basis?

31. Are PHA’s of PSM processes updated and re-validated on a five year basis and are all PHAs kept on file for the life of the process?

== Change management; Yes No N/A

32. Do Management of Change (MOC) procedures require that all changes in processes and equipment be identified and reviewed before implementation, no matter how small?

33. Are organizational or staffing changes reviewed to determine process safety implications, and prior to executing such changes, is replacement staff adequately trained?

34. Does the MOC procedure require that operating a process outside of established safe operating limits is not permitted until the proposed changes have been formally reviewed and authorized by appropriate management personnel and the safe operating limits have been updated?

35. During startup, are any changes, that may be required to process conditions or equipment, methodically and comprehensively reviewed by appropriate management levels to ensure that safety is not compromised?

36. Is a variance procedure in place to take care of unique situations that can be encountered during initial plant startup?

37. Have organizational responsibilities for approving changes to facilities been clearly defined and the procedures clearly state that changes are not approved until they have been appropriately reviewed?

38. Are minor modifications or equipment changes, not covered by capital project reviews, also controlled by the MOC procedure?

39. Is a change request form and procedure in use, specifying who should approve the change, issues to be considered, and submission of completed forms to a central individual for review and control?

40. Is a variance procedure in effect for the review of planned process deviations and the acceptance of the risks they pose?

41. Does the MOC variance procedure require a special review to use alternative approaches at least as safe as the applicable code or standard?

42. Does the MOC procedure have an initiating mechanism to ensure permanent changes are properly documented?

43. Are complex changes given a high level of review with techniques such as: “WHAT IF,” “FTA” or “HAZOP?”

44. Are changes of limited life or “temporary” modifications subject to the same process review as for permanent ones and is a time limit and additional control steps specified?

== Mechanical Integrity; Yes No N/A

45. Is there a written and implemented set of procedures available that covers the maintenance of process equipment?

46. Is information on maintenance performed on equipment recorded and organized to assist on reliability analyses and future equipment maintenance and purchase planning?

47. Is an equipment and piping material tracking system used to ensure the right materials are used?

48. Are equipment and piping fabrication requirements clearly specified in terms of codes and standards, materials, and craftsmen qualifications?

49. Are as-built drawings, fabrication test and inspection documents, materials of construction verifications, and other documents signed and dated by the person responsible for verifying the data?

50. Are control mechanisms in place to ensure that the required preventive maintenance has been performed and documented, and that data collected is reviewed, analyzed and used for program adjustments?

51. Is a field inspection part of the pre-startup safety reviews?

52. Do personnel, familiar with the design and operations, conduct field inspections?

53. Is all maintenance of process equipment initiated through a formal system?

54. Are special precautions, needed to perform maintenance work, safely identified in a work order?

55. Are such maintenance activities as process line opening, hot work, confined space entry, excavation, equipment isolation and tagging, plugging or capping open-ended valves, lifting of equipment over active process lines, etc. covered in a comprehensive Safe Work Practices procedure?

56. Are these permits issued by authorized, qualified personnel with their responsibility clearly assigned?

57. When maintenance work has been completed, do qualified operations personnel check to ensure the work requested has been satisfactorily completed, and that all equipment has been returned to an operable condition?

58. Are procedures in effect to verify the functionality of instruments and alarm systems that are not regularly activated under normal operations?

59. Are pieces of equipment that are no longer required appropriately isolated, tagged, and/or removed at the earliest opportunity?

60. Is equipment for demolition isolated, clearly marked, and decontaminated?

== Operating procedures; Yes No N/A

61. Are complete and up-to-date operating procedures readily accessible to employees who work in or maintain a process?

62. Is safety systems documentation available to operators and supervisors in each affected unit?

63. Are safe operating limits for critical operating parameters included in the operating procedures and are the consequences of deviation included?

64. Are procedures for operating upset conditions included?

65. In emergency situations, where there is no time for review and approval, is the established procedure to shut down rather than operate outside of established safe operating limits?

66. Is there evidence that operating procedures are reviewed and certified, at least on an annual basis, to ensure that they are accurate and current?

== Hot Work Permits; Yes No N/A

67. Is there an active Hot Work Permit system in use at the facility and does the procedure require that hot work permits are to be kept on file until the work is completed?

68. Does the permit document that the fire prevention and protection requirements have been implemented prior to beginning the hot work operations?

69. Does the permit document the date of the activity, a description of the activity to be done, and a place for appropriated approval signatures?

== Training; Yes No N/A

70. Is there a documented training program that includes a training history of all plant personnel and includes the name of each employee receiving the training, along with the date of the training?

71. Is there evidence that each employee has been trained on the process unit, area or department they work in?

72. Have employees been trained on the areas they are to work in, prior the actually working in the area?

73. Are training materials kept up to date and include the newest training modules for such things as the newest process units or process modification?

74. Does the facility use a documentation methodology, such as a training matrix, to indicate training requirements, including the skill and knowledge levels, needed by the plant personnel?

75. Does training include emphasis on the specific safety and health hazards, emergency response requirements and safe work practices applicable to the employee’s job tasks?

76. Do the training procedures require refresher training at least every three years and does the training documentation confirm this?

77. Do the training records indicate that each employee has received and understood the training given and the means by which this verification is done?

== Contractors; Yes No N/A

78. Is there a documented procurement procedure in place, and is there evidence, that when selecting contractors, information regarding the contractor’s safety performance and programs have been obtained and evaluated prior to hiring?

79. Does the employer inform contract employers of the known potential fire, explosion, and/or toxic hazards related to the contractor’s assigned work and the process?

80. Is there evidence that the employer has explained to the contract employees the applicable provisions of the emergency action plan?

81. Do the Safe Work Practices include provisions to control the entrance, presence, and exit of contract personnel in PSM covered process units or areas?

82. Is there evidence that the employer has performed periodic evaluations of the contractor’s safety performance, including such areas as confirming that each contract employee has received and understood the hazards training and emergency response actions required by the facility?

83. Does the employer maintain an up-to-date injury and illness log for contract employees working in PSM-covered processes?

84. Are there records of contractor performance audits that have been conducted by the employer and do the records indicate any corrective actions that may have been taken?

== Incident Investigation; Yes No N/A

85. Are all accidents, “near misses,” incidents and process upsets or deviations outside safe limits investigated according to the Incident Investigation procedure?

86. Does the procedure require that an investigation team be established for incident investigations and that at least one person on the team be knowledgeable regarding the process involved?

87. Are the lessons learned from an incident investigation documented in a report containing the facts, and analysis of the facts for revealing the underlying causes, conclusions and recommendations for corrective action?

88. Does the procedure include provisions for following up on the implementation of incident investigation?

89. Are periodic written status reports on the progress of corrective action implementation prepared and reviewed by senior management?

90. Does the procedure require that an incident investigation shall commence no later than 48 hours after the incident has occurred?

== Emergency Planning and Response; Yes No N/A

91. Is there an implemented emergency response action plan that has been developed in accordance with national health, safety and environmental legislation?

92. Does the emergency action plan include procedures for handling small releases?

93. Does the emergency plan match plant layout, modifications, and equipment?

94. Are relevant emergency response drills known to the relevant emergency services, radio stations, and public?

95. Are lessons learnt from previous incidents and emergency drills, incorporated in the emergency drill?

== Audits; Yes No N/A

96. Does the PSM Program document the requirement for PSM Program compliance audits?

97. Does Compliance Audit procedure require that the PSM Program be audited every three years and that the last two audits be retained?

98. Does the compliance audit procedure detail the planning, staffing, conducting of the audit, evaluation and corrective action, follow up and documentation?

99. Does the employer require that, when staffing the PSM compliance audit team, the team leader needs to be trained in auditing techniques?

100. Has a corrective action methodology been established that allows the audit team and management to identify deficiencies, plan for follow-up including responsibility assignments, and track progress on audit recommendations on a routine basis so that audit deficiencies do not “fall through cracks?”

* This process safety management self assessment checklist is based on a list by ETC Compliance Solutions at www.e-t-c.com

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