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.
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.