Meshing process safety management with total productive maintenance
A common mistake with this PSM-NEP element is to think it applies only to operators. OSHA auditors reviewing this element are looking to see if employees are performing their work as described in operating procedures. This would include operators performing production duties properly, as well as maintenance technicians going about their work properly. Also, as with most audits, an operation that appears to be neat and orderly presents the best case for success.
Under TPM, the BEC teams, as directed by the steering committee, review and establish the operating procedures as well as set up standards for 5s implementation. 5s is an organizational process that is applied to equipment, the immediate area around the equipment, and to the tools used to maintain and operate the equipment. The 5s’s are:
- Sort-organization; sorting out
- Set In Order-orderliness; a place for everything and everything in its place
- Shine-cleanliness; cleaning is inspecting
- Standardize-neatness; a routine or sequence
- Sustain-self discipline; adhering to the rules
The TPM steering committee initiates an implementation team and supports their efforts to satisfy the fundamental requirement that “employers develop a written plan to ensure employee training.”
Ironically, the actual success of a BEC exercise directly addresses this elements other key demand that “training includes demonstrated knowledge of routine tasks.”
A Process Safety Management program requires that “the employer shall obtain and evaluate information regarding the contract employer’s safety performance and programs.” The wrong way, and maybe the worst way to approach this standard mandate is to push it off onto the safety department. Under TPM guidance, an implantation team is created and chartered to address this specific subject. Remember the guiding philosophy; we are all responsible for our equipment.
Pre-startup safety review
It is reasonable to believe that any company that utilizes HHCs already has a PSSR process. As stated in earlier editions of this series, it’s not that companies don’t have these processes, it’s that they don’t follow them. Under the TPM steering committee guidance and the BEC development, this element’s first need is met: “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 second need is addressed through the process guides developed by the implementation teams: “the pre-startup safety review shall confirm that prior to the introduction of highly hazardous chemicals, confirmation is provided for a safe start.”
“The employer shall document each inspection and test that has been performed,” is clearly addressed in the process guides developed by the implementation teams. And the preventive and predictive maintenance processes and procedures are established through PMO and BEC activities. A TPM implementation also helps to establish solid metrics to measure the success of the actions in this element as well as the others.
Hot work permit
The actual application of a solid hot work permit process is complex, but the establishment of the procedure is simple. An implementation team creates and trains employees on the process guide to be applied against the requirement that “the employer shall issue a hot work permit for hot work operations conducted on or near a covered process.”
Management of change
This PSM-NEP element is perhaps the most neglected of the 14 elements. The neglect is not with malice, but most organizations build a complex flow chart of required signatures and the MOC tends to get rushed to keep a project on schedule. The standard is simple: “the employer shall establish and implement written procedures to manage changes to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.”
This process, or better to say our approach to this process, gets exacerbated as our equipment gets older and we are dealing with obsolete components. The requirement to change to a different make, model, or brand can get us into trouble if the change is not well thought out and executed.
Fortunately, the same approach to developing process guides for other element functions applies here as well. Under TPM, the steering committee forms an implementation team to create, adapt, and oversee a process guide to control the success of our MOC process.
PSM-NEP requires that “the employer shall investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemical in the workplace.” As with the MOC element, a well-thought-out, fielded, and managed process guide will address this element and keep metrics to ensure that the guide is being followed.
Emergency planning and response
A TPM steering committee, one that ensures the participation of the employees, will establish an implementation team whose process guides direct the address of this element. OSHA requires that “the employer shall establish and implement an emergency action plan for the entire plant, including the proper response for small releases.” This detail cannot fall upon the safety department; there are too many moving parts to this element and its direct ties to the PHAs.
The Compliance Audits element brings into play several TPM principal processes; not only the establishment of process guides, but planning and scheduling, BEC, and the direct oversight of the TPM steering committee.
Failure to comply with this element could bring serious consequences; try complying without a solid support structure. The element demands are very significant. First, “employers shall certify that they have evaluated compliance with the provisions of compliance audits every three years.” Second, “the employer shall promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected.”
The TPM steering committee will establish the process by which they “make all information necessary to comply with this element available, regardless of its trade secrete value”—and thus be in compliance with the final PSM-NEP element.
Fundamentally, there are two types of manufacturing companies: those that have a high-level reliability philosophy and those that don’t. TPM is “a” high level reliability approach; it isn’t the only one. TPM, and processes like it, apply to all organizations, manufacturing or otherwise.
Consider a hospital, school, movie theater, or transportation company. Certainly all of these industries would benefit from employee participation. Perhaps these industries keep trade secrets and manage contractors from time to time. It’s even possible to imagine a well-managed and supported approach to emergency planning and incident investigation could round out solid contingency plans in almost any industry.
What OSHA has done through the Process Safety Management-National Emphasis Program is put some teeth behind its mandate “to reduce or eliminate workplace hazards associated with the release of Highly Hazardous Chemicals.”
What leaders, managers, supervisors, and those in responsible positions need to recognize is that these steps, these 14 elements, aren’t just applicable to companies with HHCs. At the most basic interpretation of the requirements, all industries have the need to comply with the processes that keep their organizations running well and running safe.
See below for more articles from John Ross on plant safety.