The 14 elements of OSHA inspections: How they affect maintenance processes
7. Pre-startup safety review
This element and the element on management of change are closely tied together as the safe and effective management of this process lies squarely with plant maintenance and engineering.
The standard requires that “The employer shall perform a pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information.” The phrase “Change in the process safety information” could literally mean a change in a single component. This is a very detailed requirement and one that cannot, and most certainly should not be taken lightly.
8. Mechanical integrity
Along with the process hazard analysis, MI, or Mechanical Integrity inspections are required on a periodic time frame and must be well documented. Systems requiring this periodic inspection are: Pressure vessels and storage tanks, piping systems, relief and vent systems and devices, pumps, controls, etc.
A very important concept comes into play in this element. Not only do the people doing the inspections have to be properly and officially trained in what to look for and how to conduct the inspections, but inspections and testing procedures need to follow “recognized and generally accepted good engineering practices,” RAGAGEP. This is a catchall phrase that is intended to tie the practices of your maintenance technicians back to some accepted OEM, trade, or company doctrine. The layperson’s question would be, “Who told your guy to do it like that?” This is a seriously simple question, but one that has to be answered in a very deliberate way.
9. Hot Work Permit
This is such a simple element, but it is so easy to violate if maintenance supervision and technicians become complacent. Aside from the inclusion of work completed by contractors that requires hot work permits, there is a great chance that the plant assigned resources could get this wrong.
“The employer shall issue a hot work permit for hot work operations conducted on or near a covered process.” Simple enough? What does “or near a covered process” mean? How “near” is near?
Also, the permit has to document that the fire prevention and protection requirements in 29 CFR 1910.252(a) have been implemented. This has to be documented, but prior to all that, we have to train our personnel on the requirement and how to verify the aspects they are responsible for, as well has how to post and file these permits.
10. Management of change
“The employer shall establish and implement written procedures to manage changes (except for “replacements in kind”) to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.” The following considerations are addressed prior to any change:
- The technical basis for the proposed change
- Impact of change on safety and health
- Modifications to operating procedures
- Necessary time period for the change
- Authorization requirements for the proposed change.
Many organizations choose to issue an MOC for every change, regardless of whether or not it is a replacement in kind, just to get around any potential errors in this element. There are many details, and questions that maintenance and engineering have to answer satisfactorily to make this a safe process.
11. Incident investigation
This is another element where the language could be a potential tripping point for maintenance as well as operators. The standard calls for an investigation into all incidents that result in, or could reasonably have resulted in, a catastrophic release of HHCs. The ambiguity of the phrasing makes it almost necessary to include all incidents around HHCs to be classified as at least meeting the lesser criteria. Maintenance and engineering leaders must shore up their what-if scenarios in the PHAs to guard against even the slightest incident.
12. Emergency planning and response
Like most emergency situations at plants all across the country, any emergency planning and response actions will include maintenance resources. This particular element requires employers to establish and implement an emergency action plan, including a plan to handle small releases.
13. Compliance audits
This element is redundant of the actions required by other elements in the PSM-NEP. Once again, the standard requires that “Employers shall certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed.”
This element continues to state the requirement that the audits will be conducted by at least one person knowledgeable in the process. Also noted in the standard is a requirement to retain the last two most recent audit reports.
Maintenance personnel will quite often be called into service to be on the audit teams.
14. Trade secrets
This element was a late add-in element published to acknowledge that until now, some companies kept process information secret from their own employees under the guise of proprietary information, in essence protecting their trade secrets.
Maintenance personnel are typically involved in all aspects of the process but might be lacking in the knowledge of the details of production. Operations and maintenance employees have the expressed right, under this element, to be made aware of those secretive processes that might affect the health and safety of the employees.
This completes a review of the 14 elements that make up the PSM-NEP line of inquiry with a brief explanation of how maintenance and others are affected by the individual elements. Of course, there is more information available on these elements and each organization has to be prepared to successfully question its own abilities and those of federal or state auditors.
The intent of this program is to ensure that we perform our processes in a manner that is consistent with safety in all operations, engineering, and maintenance tasks that are conducted involving HHCs.
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