Process Safety Management Hand Book 2015

HANDBOOK 2015

President’s Message “PSM Safety Beyond Excellence”

We at GPIC always strive to establish new systems and strategies to improve our practices in all aspects of our business.

Safety has always been at the top of our priorities and goals.

The drive to implement Process Safety Management (PSM) commenced back in 2001 when initial work began to meet the OSHA requirements.

In 2009, we revitalised the PSM Committee with a view to synergise the company systems and to be more compliant with the PSM requirement.

G P I C ’s P r o c e s s S a f e t y Management (PSM) programme

is designed to integrate and align under one umbrella: our plant related engineering, safety, training, operation and maintenance activities, with a clear objective to minimise process related risks. Through this programme, we strive to ensure protecting our employees, our assets and the local community.

This handbook outlines the PSM requirements and describes GPIC’s approach to achieving those needs.

We believe that only through the continuous support and dedication of our employees at every level we maintain GPIC to be one of the safest plants.

Dr. Abdulrahman Jawahery

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HANDBOOK 2015

Committee Message The PSM of Highly Hazardous Chemicals, OSHA Standard 29CFR1910.119, is intended to prevent or minimise the consequences of the catastrophic releases of toxic, reactive, flammable or explosive chemicals from the adopted processes. These releases may result in toxic, fire or explosion hazards. At GPIC, we have incorporated these requirements into the Integrated Management System in SOP-PSM-00-01.

The PSM system facilitates the elimination of process incidents that could potentially occur as a result of failures in systems, procedures or equipment in process plants. It is a major

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step forward towards a safer working environment.

The PSM Committee’s role is to spearhead the establishment, maintenance, continuous evaluation and enhancement of the PSM programme.

This handbook is intended to give all our employees and contractors an overall understanding of the PSM programme and how we comply with OSHA’s requirements within GPIC. All of us play an important role in the successful implementation of the PSM Programme.

TABLE OF CONTENTS PSM ELEMENTS ADMINISTRATORS

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PSM MAIN OBJECTIVES

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PSM DEFINITION

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PSM ELEMENTS

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1 EMPLOYEE PARTICIPATION (EP)

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2 PROCESS SAFETY INFORMATION (PSI)

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3 PROCESS HAZARD ANALYSIS (PHA)

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4 OPERATING PROCEDURES (OP)

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5 EMPLOYEE TRAINING (ET)

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6 CONTRACTORS (CO)

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7 PRE-STARTUP SAFETY REVIEW (PSSR)

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8 MECHANICAL INTEGRITY (MI)

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9 HOT WORK PERMIT (HWP)

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10 MANAGEMENT OF CHANGE (MOC)

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11 INCIDENT INVESTIGATION (II)

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12 EMERGENCY PLANNING AND RESPONSE (EPR)

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13 COMPLIANCE AUDIT (CA)

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PSM KEY PERFORMANCE INDICATORS

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GPIC PSM Model

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PSM Elements Administrators PSM Committee Fire & Safety Superintendent Planning Superintendent

Emergency Planning & Response Incident Investigation Contractors Employee Participation

Environment Superintendent

General Manager Manufacturing

Operating Procedures Pre-Startup Safety Review Hot Work Permit

Management Systems Superintendent

Compliance Audit Process Hazard Analysis

Engineering Superintendent

Management of Change Process Safety Information

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Inspection Superintendent

Mechanical Integrity

Training & Development Superintendent

Employee Training

PSM Main Objectives

Prevent or minimise the consequences of catastrophic release of toxic, reactive, flammable or explosive, Highly Hazardous Chemicals (HHC) from a process.

To ensure safe and healthy workplaces and surrounding environment.

To integrate all adopted practices, systems and procedures.

To improve productivity and help minimise operational expenses.

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PSM Definition

PROCESS SAFETY Prevention of accidental release WHY DO WE NEED PROCESS of hazardous substances or SAFETY? energy which could result in safety, environmental or busiTo prevent major accidents ness impact. and reduce consequences of those that do occur PROCESS SAFETY MANAGEMENT (PSM) To improve employee’s health, A set of formal management safety and work environment practices designed to help prevent, mitigate, respond to or To improve equipment and recover from the effects of proprocess reliability cess plant accidents.

Waxahachie, Texas, USA

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PSM Elements

GPIC Process Safety Management has 13 elements:

In the following pages, the PSM standard requirements and GPIC’s compliance has been highlighted.

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1

Employee Participation (EP)

In order to achieve a high degree of employee involvement, the element directs organisations to give its employees access to Process Hazards Analysis (PHA) and all its related practices and systems. This includes all types of information concerning the safety of plants and personnel.

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HANDBOOK 2015

GPIC Compliance Employees are consulted and are fully involved during the development and implementation of any Process Hazard Analysis (PHA) study. Such involvement is demonstrated through the following methods: • The establishment of PHA teams and committees such as the SHE Committee, Management Union High Council, Management Union Committees, and through regular meetings (departmental, sectional and daily operations meetings).

• Incident Reports, Suggestion Improvement Programme, Shift Talks, etc.

Controlling Documents • SOP-PSM-00-01: Process Safety Management of Hazardous Chemicals

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2

Process Safety Information (PSI)

The element requires that all the Process Safety Information is made available in order to carry out a successful Process Hazard Analysis. This information will help to identify and understand the hazards posed by those processes involving highly hazardous chemicals.

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HANDBOOK 2015

GPIC Compliance Information related to Material Safety Data Sheet (MSDS) of chemicals, codes and standards used, equipment details, Process & Instrumentation Diagrams (P&IDs) and Process Flow Diagrams (PFDs) is captured through the Technical Data Books (TDB), Maintenance Data Books (MDB), Operation Manuals and Basic Engineering Documents.

These documents are available at six locations (i.e. controlled libraries) within the GPIC Complex.

There is also an established system that ensures the control, maintenance and update of all Process Safety Information documents in those libraries.

Controlling Documents • SOP-ENG-02-11: Management of Change (MOC) • SI-TEC-01: Material Safety Data Sheet Technical Data Book (TDB Volume 112)/ TDB Volume 112A • SOP-ENG-02-04: Updating Technical Documents • SOP-ENG-01-13: Process Hazard Assessment (PHA) Procedure • SOP-ENG-01-20: Process Safety Information Procedures

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3

Process Hazard Analysis (PHA)

The element requires that a Process Hazard Analysis (PHA) is carried out for all processes handling highly hazardous chemicals. This helps to identify all hazards in the process. All such PHAs are revalidated at least once every five years.

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HANDBOOK 2015

GPIC Compliance A Process Hazard Analysis (PHA) for all plants has been completed and documented. The PHA studies were also revalidated in 2014. The next revalidation of all plants is scheduled for 2019.

Furthermore, in GPIC, a PHA review is carried out on each and every change as part of the Management of Change (MOC) cycle.

Controlling Documents • SOP-ENG-01-13: Process Hazard Assessment (PHA) Procedure • SOP-ENG-02-11: Management of Change (MOC)

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Operating Procedures (OP)

The element requires that there are clear documented operating procedures to safely carry out activities concerning normal startups and shutdowns, emergency shutdowns, operations of a temporary nature, and the handling and exposure to hazardous chemicals, etc.

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HANDBOOK 2015

GPIC Compliance GPIC’s existing Standard Operating Procedures and Standing Instructions include: • Normal startups and shutdowns • Emergency shutdowns considering various scenarios and plant upsets.

• Simplified trip logic diagrams, catalyst manual

Controlling Documents • • • • • • • •

Standard Operating Procedures (Plant SOPs) Standing Instructions (Plant SIs) Plant Trip Logic Diagrams SHE-SAF-07: Permit to Work Procedure SHE-SAF-05: Complex Emergency Procedure Material Safety Data Sheets (TDB Vol. 112) Relevant P&IDs Relevant Vendor Manuals

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5

Employee Training (ET)

The element requires each employee operating a process, to be given appropriate training. Thus, each employee is adequately trained before being involved in operating a newly assigned process. Also, refresher training in operating such processes must be provided to the employees periodically. The training provided must also emphasise the specific safety and health hazards.

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GPIC Compliance

HANDBOOK 2015

A structured training programme is provided to employees (including operators, technicians, supervisors and engineers) prior to the assignment of any new responsibility. A refresher training programme is also in place and designed to update employee knowledge, skills and awareness regarding safety, environment and health hazards.

Besides acquiring training on the details of plant configuration, the programme also informs employees of “lessons learned” on process incidents and accidents that have taken place in other similar plants. Furthermore, the training needs of all employees are identified and courses are organised accordingly.

Controlling Documents • SOP-TRN-00-01: Training and Development Programme for Trainee Supervisors and Engineers • SOP-TRN-00-03: Cross-Training and Development Procedure for Plant Operators • SOP-TRN-00-11: New Operators Training Programme • SI-TRN-00-08: New Employee(s) • SOP-TRN-00-21: Refresher Training for Staff Working in the Process Area

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Contractors

The element requires that contractors performing maintenance, repairs, turnaround activities, major renovation work or speciality work on the process or adjacent to the process, are well trained in carrying out the intended work and are informed of the known potential hazards related to the work and/or the processes involved.

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GPIC Compliance

HANDBOOK 2015

GPIC’s direct hire and/or lump sum contractors go through a selection process that starts from contractor pre-qualification assessment, trade testing, rental equipment physical verification, safety induction training, on the job assessment, weekly contractor safety meetings and post service evaluation.

Contractors performing maintenance within the process areas are apprised of the hazards during the safety induction training and regular Tool Box Talk.

Controlling Documents • SOP-MTR-01-07: Establishing and Managing Approval Suppliers List • FR-PLN-70-02: Contractor Prequalification Requirements • SOP-GEN-00-04: Contractor Services Management • FR-MTR-01-09: Contractor / Vendor Performance Evaluation Form • GL-S&S-01-08: Safety Checking of Contractors Equipment • SOP-S&S-02-02: GPIC Complex Access & Egress (Induction to contractors by SHE Department) • FR-GEN-00-09: Checklist Prior to Placement of PO for Service Package Contractors • FR-GEN-00-10: Checklist Prior to Placement of PO for Manpower Supply Services • FR-MTR-01-13: Supplier Pre-qualification Form • FR-MNT-00-26: Typical Trade Test for Mechanical Stationary Technician (Contractor) • FR-MNT-00-11 to FR-MNT-00-29: Typical Trade Test (Except FR-MNT-00-22 & FR-MNT-00-24)

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Pre-Startup Safety Review (PSSR)

The element requires that a pre-startup safety review is carried out for any new facilities or modifications in the process area.

The review confirms if the changes are as per the design and specifications; that the safety, operation, maintenance and emergency procedures are adequate, and that sufficient training has been given to employees with regard to operating the new process or change.

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HANDBOOK 2015

GPIC Compliance A formal Standard Operating Procedure has been put in place to ensure that any newly installed facility or modification, before being commissioned, has been executed as per: • Relevant design codes, specifications and engineering drawings • Relevant operation, safety and emergency procedures • HAZOP recommendations • Relevant training

Controlling Documents • SOP-OPR-01: Pre-Startup Safety Review (PSSR) Procedure • FR-PSM-02 to 12: PSSR Checklists

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Mechanical Integrity (MI)

The element requires written procedures to be available to maintain: • Pressure vessels, storage tanks, piping systems and pumps. • Relief and venting systems, emergency shutdown systems and controls (such as alarms, trip interlocks, etc.)

The standard also requires quality assurance during the fabrication and installation of plant equipment.

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HANDBOOK 2015

GPIC Compliance At GPIC, a comprehensive inspection schedule, in line with international standards and the process licensor(s) guidelines, is being followed. A Risk Based Inspection (RBI) technique is also employed to strengthen the inspection programme.

The following activities are carried out during turnarounds: • Internal examination of major equipment.

• Checking and testing of safety relief valves, emergency shutdown systems and interlocks.

When new equipment is being procured it must be ascertained according to the fabrication, construction and installation specifications laid down in the technical enquiry and is checked that it adheres to the applicable codes and standards.

Furthermore, a comprehensive critical equipment list exists at GPIC identifying process equipment that has an impact on safety, health and the environment.

Controlling Documents • SOP-PLN-30-05: Preventive Maintenance Management • SOP-PSM-00-02: Mechanical Integrity • Critical Equipment List in SOP-PSM-00-01

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Hot Work Permit (HWP)

The element requires a Hot Work Permit to be issued for any hot work operation conducted on or near a process area.

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HANDBOOK 2015

GPIC Compliance GPIC’s Permit To Work (PTW) comprehensively covers the Hot Work Permit system. Authorisation to receive or issue a PTW, is only granted to those who pass both a written exam and an interview, where their full understanding of the requirement and the essence of the (PTW) is ascertained. An appraisal is completed every two years to revalidate this authorisation. In addition, GPIC’s PTW procedure is regularly audited and reviewed.

Controlling Documents • SHE-SAF-07: Permit to Work Procedure

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Management of Change (MOC)

The element requires that written procedures are established and implemented to manage changes to processes, chemicals, technology, equipment and procedures that are not “replacement in kind�.

Employees or contract employees whose job is affected by the change, should be informed and trained on the changes prior to commissioning and startup.

PHA

Raise RFC

Archive

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Screening & Processing

Updating of PSI

Engineering & Approval

FAC

Implementation

PSSR

HANDBOOK 2015

GPIC Compliance Changes in any of GPIC’s facilities, including process related changes,are covered under the Management of Change (MOC) Procedure. The Management of Change system ensures that all requirements, such as, HAZOP, environmental impacts, training and operating procedure changes, are considered before implementing the change.

Controlling Documents • SOP-ENG-02-11: Management of Change (MOC)

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Incident Investigation (II)

The element requires that each process incident which resulted in or could reasonably have resulted in a catastrophic release of highly hazardous chemicals, is investigated.

The standard further requires that the findings and recommendations arising from the investigation is resolved and documented.

INCIDENT REPORT TO SSS

Minor Incident SSS Reviews Incident Serious Incident

Plants Operating Manager

Interim Report

Executive Management

Final Report

Investigating Team

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HANDBOOK 2015

GPIC Compliance Process incidents and near misses at GPIC can be reported by any person. Details regarding the incident, the investigation findings, recommendations and subsequent actions, are recorded and saved in the company’s main database. Any “lost time” incidents are investigated by a dedicated team and the recommendations are reported to the Executive Management.

Controlling Documents • SHE-SAF-13: Accident and Near Miss Reporting • Lotus Notes, Plant Operations Incident Databank (derived from SHE-SAF-13) • SOP-OPR-02: GPIC Plant Operation Incident Data Bank • SHE-SAF-10: Process Safety Incident Assessment Report Form Completion

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Emergency Planning and Response (EPR)

The element requires that an emergency action plan for the entire complex is available. The plan must also be designed to handle small releases.

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HANDBOOK 2015

GPIC Compliance A comprehensive Emergency Response Plan (ERP) is established to cater for any emergencies within the complex. The plan details the emergency warning alarms, control centers, assembly points and the job roles of the personnel during emergencies.

The plan is reviewed and tested periodically.

Controlling Documents • SHE-SAF-05: Complex Emergency Procedure • SHE-SAF-06: Generic Emergency Procedure • SHE-SAF- 22: Planning Emergency Scenario Based Training

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Compliance Audit (CA)

The element requires that the Process Safety Management (PSM) processes are evaluated once every three years through a compliance audit conducted by at least one person knowledgeable in the process. The standard also requires that an appropriate response to each of the findings is reported and that any deficiencies are corrected.

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HANDBOOK 2015

GPIC Compliance There is an established procedure to carry out internal audits of the Process Safety Management System as part of the internal audits of Integrated Management Systems in GPIC. External audits are carried out once every three years.

Controlling Documents • SOP-IMS-00-01: Internal Audit Procedure

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PSM Key Performance Indicators PSM Elements

Key Performance Indicators

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A. Number of shift/safety talks completed Employee Participation B. Number of operators attending HAZOP studies

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Process Safety Information

Number of outstanding documents updated (P&IDs, MSDS, ...etc.)

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Process Hazard Analysis

Number of outstanding PHA recommendations

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Operating Procedures

Number of outstanding PSM related procedures pending review

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Employee Training

Number of individuals with overdue refresher training

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Contractors

Number of outstanding “contractor on the job audit� recommendations

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Pre-Startup Safety Review

Number of outstanding PSSR

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Mechanical Integrity

A. Number of overdue inspections B. Number of challenges to automated safety devices such as number of trips

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Hot Work Permit

Number of PTW violations

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Management of Change

Number of outstanding MOCs

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Incident Investigation

Number of outstanding PSM incident recommendations closed out

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Emergency Planning and Response

Number of PSM emergency mock drills carried out

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Compliance Audit

Number of PSM audits carried out

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GPIC PSM Model HANDBOOK 2015

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HANDBOOK 2015

HANDBOOK 2015

P.O.Box 26730 Manama Kingdom of Bahrain Tel: (+973)17731777 Fax: (+973)17731047 www.gpic.com gpic@gpic.com