Meshing process safety management with total productive maintenance
A look at how organizations have adopted total productive maintenance (TPM) and the benefits it can bring to a company
In this last section on the Process Safety Management-National Emphasis Program (PSM-NEP), we will look at how many organizations are successfully addressing it through a high-level reliability program, such as Total Productive Maintenance (TPM). Don’t be alarmed if your company has not adopted TPM; chances are that you are probably doing some of the key activities outlined by PSM. You may, however, elect to move toward a structured and purposeful process such as TPM in the future.
OSHA’s governing directive on PSM states that the standard “emphasizes the management of hazards associated with highly hazardous chemicals and establishes a comprehensive management program that integrates technologies, procedures, and management practices.” This is as clear as any statement ever made by a government official. The direction is clear; your organization will be measured on your ability to employ technology, effective and exercised procedures, and involved management practices to guarantee the safe execution of your processes regarding highly hazardous chemicals (HHCs).
This is very serious business and requires a well-thought-out and serious process to pull it all together. Regardless of the size of your organization, or your individual plants for that matter, the process steps are exactly the same, and the outcomes are essentially indistinguishable from one size plant to the other. The 14 elements that make up the PSM-NEP are required by all that handle or operate with HHCs.
Fortunately, several practices performed by higher achieving reliability programs already incorporate many of the factors necessary to build a solid PSM program, one that will successfully address the 14 elements of the NEP. One of the more fundamental processes is Total Productive Maintenance. TPM is a process employed by many companies in the United States and around the world that establishes the strategic position that we are all responsible for our equipment. It is by this founding statement that all aspects of the upkeep, maintenance, operation, and engineering of our equipment that maintenance, engineering, production, safety, purchasing, and management are tied together.
Total Productive Maintenance is a term coined by Japanese engineer Seiichi Nakajima. He was a student and follower of the American reliability pioneer George Smith. Nakajima studied and worked with Smith in the 1950s and developed this TPM philosophy in the early 1970s as an outgrowth of productive maintenance. TPM came to the United States in the mid-1980s and has since been spread around the world as one of the most effective reliability processes being practiced.
The requirement-solution give-and-take setup by PSM-NEP and TPM actually thread throughout the OSHA standard and the fundamental practices of this solid reliability program. The next few paragraphs will be dedicated to providing examples of how a TPM will address the dictates of OSHA’s Process Safety Management.
The first element of the PSM-NEP requires that employers develop a written plan to ensure employee participation. When an organization establishes the TPM process in its plants, it is first encouraged to create a steering committee and to develop a charter and a process guide, or guiding rules to “steer” it through the process. This road map of sorts always includes the process by which management brings in the employees to make them part of the solution. Remember, TPM states that we are all responsible for our equipment.
Also within this element, employers shall consult with employees when developing Process Hazard Analyses (PHAs). TPM’s structure allows this requirement to be addressed through an implementation team, supported by the steering committee mentioned above. Additionally, all aspects of a process or a piece of machinery are discussed in great detail (including PHAs) during a TPM sponsored Basic Equipment Care exercise.
Through the steering committee, another requirement of PSM is successfully addressed; employers shall provide employees access to PHAs and other information as needed to comply with this element. This steering committee sets up the ground rules for making this information common knowledge among its employees as well as establishing the metrics to measure how well this actually gets done.
Process Safety Information
The OSHA standard requires that the employer shall complete a compilation of written process safety information; this is one of the most basic tools of TPM. Much of the success of Total Productive Maintenance is that all procedures and process follow an established guide; a process guide. PSI, or Process Safety Information, under an organization that has adopted TPM, will follow the process guides to satisfy this requirement.
This standard sets in place the need for the organization to have available a tremendous amount of technical information for the process. Not only is the HHC’s Material Safety Data Sheet (MSDS) required to be available, but so is all the technical information for the components in the system, the P&IDs, the lockout/tagout procedures, and—this is a major issue—the Recognized And Generally Accepted Good Engineering Practices (RAGAGEP) direction for completing maintenance tasks. These OSHA stated necessities are gathered, screened, corrected, and used to train under the guise of TPM’s Basic Equipment Care (BEC), the Preventive Maintenance Optimization (PMO), and the Computerized Maintenance Management System (CMMS) Bill Of Material (BOM) development.
This particular element is so technically arduous that a solid reliability program such as TPM is almost required to keep the information current and accurate.
Process Hazard Analysis
The PHA element requires that companies perform an in-depth what-if analysis regarding their HHCs. This is done using tools such as Failure Modes Effects Analysis (FMEA) and facility siting. The siting request is not just a layout of the plant in relation to the surrounding area, but more of the location and operation of the HHC process and the proximity of people, and other operations in the plant (sort of a what-could-go-wrong study).
Under the guidance of TPM, the steering committee would charter and support an implementation team that performs the PHAs. The FMEA tool would be facilitated by TPM’s PMO review, where the failure mode is used to elicit root cause corrections. Facility siting is addressed as the teams march through the equipment while performing basic equipment care.
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